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Information Technology Accessibility Policy 04.001 Process Guidelines 

Information Technology Accessibility Policy 04.001 Process Guidelines

The following process describes the purchasing, assessment and exceptions process for the Information Technology Accessibility Policy 04.001. 

Step 1. Purchasing Process

The purchasing process includes an initial risk assessment at time of purchase. A 3-question risk assessment will be used to determine whether the purchase is deemed “high risk” (used by over 50 students and/or over 50 members of the public) which would trigger an accessibility review. 

“High risk” purchases go to Step 2.

During Phase I, for products that do not reach the “high risk” threshold or do not go through the Purchasing Department, the Web Accessibility Coordinator will notify the department that while their product is not deemed “high risk,” the department will have a responsibility to provide content in an accessible format should a person with a disability make a request.

Step 2.  Accessibility Assessment Process

OIT assesses the product using accessibility standards (currently WCAG 2.0). The Office for Information Technology (“OIT”) Web Accessibility Coordinator assesses “high risk” purchases at two levels and provides an accessibility report to the department. If the evaluation score is < 90% accessible at either stage, the Web Accessibility Coordinator will advise the department that it has the option to seek another purchase, work with the vendor to make the IT product accessible, or request an exception.

LEVEL I - Basic Accessibility Assessment

  1. Page Title
  2. Image Text Alt
  3. Headings
  4. Color Contrast
  5. Text Size
  6. Tab/Keyboard
  7. Form and Labels
  8. Moving, Flashing or Blinking Content
  9. Multimedia (video, audio) alternatives
  10. Links

If the IT product passes Level I at >= 90% threshold, OIT will subsequently review the product for:

LEVEL II - In-depth Accessibility Assessment

WCAG's 2.0 Guidelines Level AA

  • Perceivable
  • Operable
  • Understandable
  • Robust

Results:

When a product meets the standards, the Web Accessibility Coordinator notifies Purchasing that the software is compliant and the department may continue with the purchasing process.

When a product does not meet standards, the Web Accessibility Coordinator notifies Purchasing and the department, and the department may choose to follow Step 3 and request an exception.  

Step 3. Requesting an Exception

The department making the purchase chooses to request an exception to the policy and forwards the following to the ADA/504 Coordinator*:

  1. Description of software, hardware or third-party vendor product and intended use
  2. Web Accessibility Assessment Report conducted by web accessibility coordinator
  3. Explanation about why accessibility compliance is not feasible
  4. Vendor information about accessibility shortcomings and timeline for when vendor intends to address shortcomings
  5. A plan for how alternative access will be provided, when requested, which:
  • Outlines how the unit will make information attained through this technology available to persons living with a disability in an equally effective alternate format; 
  • Identifies the individual responsible for providing the alternative/accommodation.

Step 4. Exception Review Process

The ADA/504 Coordinator, CIO and stakeholders review request for exception. Reasons that may support the granting of an exception(s) include: 

  1. Hardware and software for which no equivalent accessible option is available
  2. Hardware and software tools specific to a limited research or development process in which no member of the research or development team requires accessibility accommodations
  3. Software that is used as a standard or common practice in a field of study, industry or profession.
  4. Undue burden. An undue burden is determined on a case-by-case basis. Generally, it is an action requiring such significant difficulty or expense that it is unreasonable when considered in the context of a number of factors such as the nature of the cost, difficulty, or complexity in relation to available resources and the benefit to be achieved. 

Final determination :

The ADA/504 Coordinator and CIO would review requested materials and make determination on the granting of exceptions. A summary of exception request, accessibility assessment report, decision, and rationale would be sent to EVPP, VP F&A, Purchasing, and the department. If the exception is granted, departments may move forward with purchasing the IT product.

Departments denied the ability to make a technology purchase have the opportunity to appeal this decision to the Executive Vice President and Provost and the Vice President for Finance & Administration.

The ADA/504 Coordinator will fulfill the university’s monitoring obligations under the Americans with Disabilities Act by documenting summary reports, decisions and rationale.

 

* ADA/504 Coordinator Contact Information

Dianne Bouvier, Ph.D.
Director for Equal Opportunity and Accessibility
ADA/504 Coordinator
Office of University Equity and Civil Rights CompliancOhio University
access@ohio.edu