As set forth in the University’s Electronic and Information Technology Accessibility Policy (the Policy) and Procedure (the Procedure), the University is committed to digital accessibility.
Schools and units have agency over, and responsibility for, how their units can best meet the Policy requirements.
These guidelines provide detail regarding the overall Policy and Procedure compliance and reporting program that will support those schools and units.
A. Implementation Priorities and Timelines
These guidelines provide detail regarding how the overall compliance and reporting program, including priorities and timelines, and, unit-level implementation plans, and annual reports.
The EIT Accessibility Policy establishes a priority order for accessibility compliance as follows:
- New EIT: Any EIT that is acquired, purchased, or renewed after this Policy’s effective date.
- Fundamental EIT: Any EIT that is significant and used in the normal course of operations at the University to support teaching, research, or administrative functions, as determined by the relevant Department in partnership with the Office of Diversity and Inclusion (ODI).
- Secondary EIT: Any EIT that was acquired, purchased, or renewed before this Policy’s effective date and is not Fundamental EIT.
II. Timelines for compliance
- New EIT: must be in compliance with the applicable standards and guidelines described in this Policy, as of the date this Policy is adopted, or satisfy an exception.
- Fundamental EIT: must be in compliance with the applicable standards and guidelines described in this Policy as soon as possible, but no later than two years after this Policy’s effective date, or satisfy an exception, except as noted immediately below.
- Fundamental course content that existed prior to the effective date of this Policy must be in compliance with the applicable standards and guidelines described in this Policy as soon as possible, but no later than four years after this Policy’s effective date. Until accessibility of course content is achieved, accommodations must be provided as needed per the direction of the Disability Resources and Services department.
- Secondary EIT: must be updated to be in compliance with the applicable standards and guidelines described in this Policy, or the content must otherwise be made available in an equally effective accessible format, and in a timely manner, to any individual requesting access. The unit responsible for its maintenance must make it compliant with the applicable standards or provide an equally effective accommodation.
III. Compliance plans and tracking progress
Compliance plans and tracking of progress are designed to allow the University to continuously improve and move closer to full inclusion. The key focus is on identifying areas for improvement both within units and across the University as a whole. As set forth more fully below, to best support this focus on improvement, both individual units as well as ODI will engage in continuous or regular progress monitoring and assessment through Implementation Plans and Annual Reports. In addition, an Internal Review process is included as a more robust check on institutional compliance with the policy.
I. Initial Plans
In response to COVID-19, requirements for submitting implementation plans per the University’s EIT (Electronic Information and Technology) Accessibility Procedure are being streamlined. Instead, an initial plan will be submitted by all University areas for the Fall of 2020.
II. Implementation Plans
All schools and units are required to create an initial 4-year implementation plan following adoption of the University’s EIT (Electronic Information and Technology) Accessibility Policy, which must be submitted to ODI. These plans allow schools/units to communicate individual decisions and strategies about how to best meet the requirements of the policy while providing ODI with a roadmap against which to measure annual progress.
Implementation plans ask for the following information:
- Categorization of a school/unit’s EIT as Fundamental or Secondary
- An implementation timeline with compliance targets and actions
- Unit supports and structures
- Requests for University-level support
When categorizing EIT, the following are the types of information or transactions that support normal university operations and therefore likely involve Fundamental EIT:
- Course content
- Financial Aid
- Human Resources
- Student Affairs
Plans will be reviewed by ODI to ensure they are consistent with the policy.
III. Annual Reports
All schools or units must submit an Annual EIT Accessibility Reports (EITARs) to ODI. The EITARs provide an opportunity for schools/units to internally monitor and report on the previous year’s accessibility improvements, response to complaints, and successful accessibility processes and supports. They also allow the University to assess its institutional progress year over year.
All EITARs will be reviewed by ODI to ensure each unit is making adequate progress towards accessibility and policy compliance. Additional supports and interventions may be targeted to units or provided university-wide based on EITARs. An institutional report will also be generated drawing from the trends exhibited across all schools/units.
IV. Internal Review
ODI, together with key partners as appropriate, will conduct an Internal Review for several schools/units each year. The School/Units are selected based on accessibility progress, number of accessibility complaints received, time to complaint resolution, site traffic, site size, and amount of online course content. This process will provide a more robust check on institutional compliance with the policy. If your School/Unit is chosen, you will be notified by ODI 2 months before the review begins.
The Internal Review process will utilize 3 main mechanisms:
- Automated testing deep dive - An automated accessibility testing tool has been procured for reviewing all university websites and the content contained within them. During the internal review process, scans will be run to identify areas on identified sites that do not meet accessibility standards, and historical data will be reviewed to understand growth and accessibility updates that have been made to the sites thus far.
- Manual testing sample – Automated testing is only able to identify roughly forty percent of accessibility issues. Manual testing will be conducted to reveal additional accessibility barriers on identified sites.
- Process review – Using NCDAE indicators as a guide, a review will be conducted of the processes and supports in place within the unit under review. The purpose of this process review is to identify systemic areas that could be improved to impact EIT accessibility.
The Internal Review process will conclude with a report and recommendations provided to the school/unit. Subsequent Implementation Plans should incorporate and address the Internal Review Report and Recommendation.
B. Procuring EIT that Complies with the Policy
As set forth in the EIT Accessibility Policy and Procedure, all procurement or purchasing contracts with EIT vendors must reflect the University's commitment to accessibility. As such, if more than one equivalent product/service is available, it is advisable to choose the most accessible product. However, the most accessible choice may not align with other dominant selection criteria, and the less accessible product may be chosen. If that occurs, an exception must be sought.
Any exceptions to the Policy must be formally requested through the EIT Accessibility Exception Request Form.
The form requests the following information:
- Description of software, hardware or third-party vendor product and intended use
- Completed Vendor Compliance Documentation
- Explanation about why accessibility compliance is not possible
- Timeline for when vendor intends to address shortcomings outlined in compliance documentation. Timelines should be reflective of the length of the contract and scope of the accessibility issues.
- A plan for how equivalent alternate access will be provided, when requested, which:
- Outlines how the unit will make information/services attained through this technology available to people with disabilities in an equally effective alternate format;
- Identifies the individual responsible for providing the accommodation.
- Signature of school, department, or unit head
Some complaints about inaccessible EIT can be resolved easily through internal remediation, while others will require more substantial efforts and sometimes require the coordination of outside vendors. If a complaint cannot be resolved promptly, equivalent alternate access must be provided to the information/service in a timely manner. After providing equivalent alternate access, efforts should continue to resolve the accessibility barriers for all.