Audio transcript for foreign language spelling?

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I am working with an instructor who is developing his first online Spanish class, and he recently asked this question:
"If I want students to listen to me spelling a word out in Spanish, and the purpose is for them to transcribe it, how would I make that ADA compliant?  I don't want to provide a written version of the spelling along with the audio, as that would defeat the purpose of the exercise."

The objective is for students to identify Spanish letters by sound, but if a student is hearing-impaired, they may rely on a written transcript of the audio, which in this case would include the actual letters they are to identify.

The only thing I can suggest is to spell out the letter sounds phonetically in the transcript.  Any other suggestions?  Thanks!
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Chris P.

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Posted 2 months ago

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Sheryl, Official Rep

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Hi Chris

In this case you would be exempt from the requirement to provide an alternative of the spelling due to the ‘test’ clause - something that is a test that is then invalidated by providing an alternative does not need to comply.

Kind regards
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Chris P.

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Thank you, that's helpful.  Can you refer me to any specific documentation regarding the "test clause"?  I'm unfamiliar with that aspect of accessibility guidelines.
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Sheryl, Official Rep

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Hi Chris

Yes, it is part of SC 1.1.1 (I have only copied the relevant information): 

1.1.1 Non-text Content: All non-text content that is presented to the user has a text alternative that serves the equivalent purpose, except for the situations listed below. (Level A)
  • Test: If non-text content is a test or exercise that would be invalid if presented in text, then text alternatives at least provide descriptive identification of the non-text content.
This will apply to the spelling of the foreign language words in the audio description as well. 

Kind regards