Evaluation of proposed accessible technology purchase
Translating policy into practice
PCC implemented the Accessible Technology Policy in 2018. This policy states PCC’s commitment to ensuring all technology purchased by the College meets legal requirements under Section 508 of the Rehab Act and the Americans with Disabilities Act (ADA). Failure to comply with established law exposes the College to unnecessary risk and litigation. The procedure outlined below describes how the AT Policy will be implemented through cooperation between PCC staff planning projects, the Accessible Ed & Disability Resources program, and the IT Project Management office. Questions regarding this procedure may be directed to the Manager of Accessible Technology at firstname.lastname@example.org or 971-722-4340.
Accessible technology review procedure
1: Early involvement
Please involve the Manager of Accessible Technology as early as possible when considering technology projects and potential products. This can prevent project time and resources from being spent on an inaccessible product that poses risk to the College.
Contact the vendor to obtain a Voluntary Product Accessibility Template (VPAT) report for all products being implemented in the project. A VPAT is an analysis of the product relative to accessibility benchmarks. Please submit the VPAT along with the initial submission of the project proposal to IT PMO. Please note:
- A VPAT does not ensure compliance with access benchmarks
- VPATs performed by independent third-party companies are often more accurate than those performed internally by the vendor.
- If the vendor does not have a VPAT for the product, direct them to the Federal Register Information and Communication Technology (ICT) Standards and Guidelines.
- If the vendor cannot provide a VPAT, request any documentation they have that describes how they have met Section 508 and ADA regulations.
The Accessible Technology Manager will review the VPAT and project proposal. This review will result in one of the following outcomes:
- Approval: The product is determined to meet accessibility criteria and the project may proceed.
- Further review: The Accessible Technology Manager will contact the Project Lead with the next steps in cases where the VPAT is not produced by a third-party vendor and/or information provided is insufficient to verify compliance with access criteria. This can include further discussion with the project team, discussion with the product vendor, and provision of the product by the vendor for testing with common assistive technology.
- Temporary approval: The product complies with many accessibility criteria. For access criteria that are not met, the vendor is amenable to including contract language that stipulates a timeline for future versions of the product to address remaining access concerns. Implementation of the product often requires the development of an Equally Effective Alternative Access Plan (EEAAP).
- Temporary exception: The product is provided an exception from accessible technology criteria. See below, in the section titled “Exceptions”.
- Denial: The product does not align with basic accessibility standards and there are more accessible alternatives that serve the same function.
4: Product lifecycle
- Implementation: The Manager of Accessible Technology will remain available to the project team throughout the project’s life. This is particularly important if a current student or staff member with a disability is affected by the project.
- Follow along: The Manager of Accessible Technology remains available to all PCC entities during the life cycle of the product’s use if access concerns arise.
- Renewal: Renewal of the product’s license or upgrade to a new version requires the same procedure to be followed as with a new project though this will typically proceed more quickly provided changes in the product are not significant.
Terms requiring further definition
The current implementation of Web Content Accessibility Guidelines (WCAG) Level AA as defined by the World Wide Web Consortium (W3C). Products not falling under WCAG criteria will be assessed relative to Section 508 standards.
Equally Effective Alternate Access Plan (EEAAP)
The use of accommodation is necessary when direct accessibility is not readily achievable. While the Accessible Technology Manager, ADA Coordinator, and Accessible Ed & Disability Resources team are available to consult with project leads in forming EEAAPs, it is the unit deploying the inaccessible technology or service that is responsible for providing the accommodation(s). Depending on the nature of the digital information or digital service, examples of accommodation might include:
- Providing alternative software that performs the same or similar function.
- Providing the digital information in a format that meets our accessibility standards.
- Providing assistance to the eligible individual either in-person or over the phone.
This plan should take into account the criticality and timeliness of the digital information or digital service and address a method to ensure that the eligible individual can access the accommodation without any adverse consequences resulting from the need for the accommodation. This means, for example, that any deadlines imposed by the digital information or digital service that are not met due to the use of accommodation must be waived, and the requesting unit must have a plan to ensure this occurs.
Communication regarding the availability of the EEAAP should be readily accessible in the same places that any other general communication regarding access to the digital information or digital service is present.
The Accessible Technology Manager will review requests for exceptions to the Accessible Technology Policy. Approval of an exception requires documentation of an equally effective alternate access plan, and exceptions are granted only when conformance with accessibility guidelines is not technically possible, requires extraordinary measures due to the nature of the digital information or service, or when the digital information or services will be used for a short duration by a population whose needs are already known and accounted for.
An exception is not an exemption from addressing accessibility. Instead, it is documentation of temporary acceptance of a risk until the technology or service can be brought into compliance through modification, substitution with a comparable product or service, or discontinuation.
When requesting an exception, the project lead must document if other alternatives under consideration were more accessible. If so, the project lead must explain what business reasons necessitate the selection of the less accessible option. If more accessible alternatives were not evaluated or did not exist, the unit must document their plan to ensure a search for a more accessible alternative is conducted when the contract or exception expires.
Examples of situations in which an exception may be granted could include:
- Three or fewer employees are using the product or service, and none of them experience disability-related barriers when doing so.
- Renewal of a product that is essential to the daily operation and changing products will impose an undue hardship on the College.
- No accessible alternatives that serve the same business functions are available.