1. Procurement and EIT Accessibility
Best Practices in Ensuring Accessible Websites, Course Materials, and More

2. Understanding Electronic and Information Technology (EIT) “In-accessibility”

3. Challenges around Procurement
Complexity of procurement related workflows (how many different ways can something be purchased?
Magnitude of purchase requests and authorized inviduals to make purchases.
Lack of awareness about accessibility and how it plays into procurement.
Lack of resources for assessing accessibility of services and goods.

4. What We Know...
Increasing numbers of students with disabilities entering Higher Education
Greater implementation of online/e-learning technologies in higher education classrooms (online and F2F)
Growth in online education offerings by Higher Education
Growing number of legal challenges/findings against Higher Education by individuals with sensory impairments (visual and/or hearing loss)

5. Common Issues of Accessibility
Services or products are a daily use within Higher Education and thus impact various areas:
Inaccessible LMS’, University Wide Applications and teaching supplemental applications
Alternative texts (textbooks)
Document accessibility (Word, PPT, PDFs)
Captioning for videos
Inaccessible library resources (databases, search, print resources)
Additional classroom resources (e.g., iClicker, podiums)
Inaccessible university websites/web resources
ATMs
Access to auxiliary offices (financial aid, registrar)

6. Who benefits from accessibility?
Increased accessibility brings benefit to customers, colleagues and users.
All customers benefit from being able to use services and goods more effectively.
You organization benefits from reducing the need to provide alternative accommodations (sometimes costly) to users who cannot use the inaccessible product.
Vendor or supplier who incorporates accessibility increases customer base because products are more accessible for all users.

7. What exactly does EIT Accessibility ‘look’ like?

8. It looks like your every day technology
But how do you know if your everyday technology meets accessibility standards or is working towards compliance?
You don’t unless you ask!
Do they have a VPAT?
Did you search for accessibility on their website?
Do they have a roadmap showing accessibility updates?
Do they have testing documentation?

9. Assistive Technology
Definition: Disability-specific devices that allow people to use computers and other technology
Alternatives, such as foot pedals, for people who cannot use a computer mouse
Screen readers and refreshable braille devices for people who are blind or have other print disabilities
Open or closed captioning for people who are deaf

10. Anatomy of an Accessible Web Page
Document courtesy of Portland Community College:

11. Legal Requirements and useful guidelines
Section 504 and ADA
Section 508 and WCAG 2.0
ATAG 1.0

12. Applicable Laws and Standards
Section 504 of the Rehabilitation Act
The Americans with Disabilities Act
Qualified individuals with disabilities must receive equal access to all of a recipient’s programs, services, and activities.
Miami Applicable laws:
Section 508 of the Rehabilitation Act
WCAG 2.0
ATAG 1.0

13. Equal Access What is “equal access”?
OCR’s guidance on emerging technology sets the standard.
“Receive all the educational benefits provided by the technology in an equally effective and equally integrated manner”
Must be able to:
Acquire the same information,
Engage in the same interactions, and
Enjoy the same services.

14. Useful Guidelines Useful guidelines for web accessibility
Web Content Accessibility Guidelines (WCAG 2.0) from the World Wide Web Consortium (W3C)
Section 508 of the Rehabilitation Act of 1973, as amended in 1998

15. WCAG 2.0
WCAG 2.0 Guidelines
Web accessibility initiative of the World Wide Web Consortium “W3C”
Public/private consortium, world-wide, of academics, governments, technology industry, and user groups
Web Content Accessibility Guidelines
Optional for all web developers, including governmental entities
Especially: “Evaluating Accessibility”

16. Section 508
Section 508 Only Applies Directly to the Federal Government
Federal agencies must comply with the Section 508 standards
Others may use the Section 508 standards as guidance, but are not subject to Section 508 itself (except under some state laws)
Important: Section 508 does NOT “follow the money” like Section 504.
Section 508 Resources:

17. Differences Between Online vs Face-to-Face Teaching
E-Learning/Distance
Accommodations are given on individual basis
Section 504
ADA
Courses are using online components fall under Web Accessibility standards (Distance Education, hybrid, use of Learning Management Systems, etc.)
Section 508
WCAG 2.0 AA
Students must self disclose to receive academic accommodations in the classroom
Should be accessible out the box and self disclosure is needed for academic accommodations
Physical Classroom accessibility
Application accessibility is a must for class participation
WCAG 2.0

18. Similarities of Face to Face and Online Learning
Teaching to enhance the students perspective and serve them by providing the best education possible
Software, Websites and Applications
LMS and content (videos, documents, library databases)
Textbooks and Supplemental Content (3rd Party)
Students are the Focus
Similarities of Face to Face and Online Learning
Both select textbooks for students to use (some have supplemental material that should be accessible)
Both use an LMS in which should be accessible.
Both add content to the LMS to teach courses, this content should be accessible.
Both are teaching to enhance the students perspective and serve them by providing the best education possible.
Both use technologies (websites, applications, online documents, etc.)

19. Procurement Policies and Processes
Recommendations for Procurement processes and policies.
State the organization’s commitment to include accessibility in the procurement process.
Set out basic provisions, such as asking vendors for VPAT or to highlight accessibility features when reviewing possible products.
Determine where best to seek advice in relation to accessible procurement.

20. Assessing the Accessibility Issues
Include accessibility from the start.
Maintain accessibility review throughout the life of the contract (renewals, addendums, etc.)
Involve users with disabilities to test applications.
Train all those with the ability to purchase and educate vendors on the process and accessibility requirement.
Provide or create an individual or group with the responsibility to oversee purchase approvals.
Have a sound exceptions qualification (security, fundamental alteration, etc.) along with steps of how this is determined.

21. Procurement Start-Up Plans
Create an Accessibility Committee (someone to discuss accessibility and how it can be included into procurement)
Work with the Procurement Department and incorporate accessibility into the policy.
Create a Review Committee (this could be from an Architectural Standard that could include Security, Accessibility, Infrastructure Compatibility, etc.)

22. Exceptions Fundamental Alteration Defense
Covered entities do not have to do anything that would fundamentally alter the nature of the program or service they are providing.
Ex: U.S. Geological Survey’s topographic maps cannot be reduced to words to make them accessible to people who use screen readers. The very essence of their “mapness” would be destroyed in the process.

23. Remember You’re Not Alone!
Many schools and government agencies are trying to work towards building accessibility into procurement. A great resource is:
Policy Driven Adoption for Accessibility (PDAA) - The State of Minnesota is partnering with other states to pilot Policy Driven Adoption for Accessibility (PDAA), with the goal of increasing the accessibility of vendors' products and services. This page answers questions for government organizations and agencies.

24. Best Practices Here’s our roadmap DRAFT!
Establish Accessibility Policy that includes Electronic and Information Technology (EIT)
Establish/update EIT Grievance/Remediation Process
Establish/update Procedures for Procurement
Establish EIT Accessibility Training
Update AccessMU Accessibility Web Portal/Website
Hired EIT Accessibility Staff
Establish Process for Monitoring EIT Issues
Search and Complete vendor for EIT Accessibility Audit

25. The Miami Model A work in progress

26. Miami current Workflow
All requests to purchase originate in Miami Buyway as a requisition for purchase order.
A requisition is routed through work flow and approved first by funding source
Any IT related software is designated by account code and auto forwarded to IT Department staff for review prior to ordering.
Accessibility review is conducted by IT staff
Considerations; classroom, business functions for students, student organization/campus life….
In instances where a request for proposal is published the following specification is included and the vendor response will be evaluated accordingly;
For the purposes of this presentation, I have reordered the high-impact/high priority recommendations under what we specifically implemented to address communication/collaboration gaps, EIT policy updates, training resources, structural improvements, and workflow updates.

27. What can you do?
Want to get more information to help ensure a speedy purchase?
Ask vendors for a VPAT (Voluntary Product Accessibility Template).
They don’t know what one is, chances are they don’t have accessibility built into the system or have it as a priority. Don’t worry contact the Accessible Technology Staff to help.

28. Documentation to share with Vendor
Miami’s statement on accessibility:
Accessibility:  Provider warrants that it complies with federal disabilities laws and regulations.  Provider hereby warrants that the Provider Technology to be provided under this Agreement to End Users and Public Users comply with the accessibility requirements of section 508 of the Rehabilitation Act of 1973, as amended (29 U.S.C. 794d), its implementing regulations set forth at Title 36, Code of Federal Regulations, Part 1194, and Provider further warrants that its products is compliant with WCAG 2.0 AA guidelines.  Within 30 days of delivery and complete installation, and prior to payment, the Licensee reserves the right to perform acceptance testing or to have tested at Provider’s expense the Provider’s technology and services with features represented as compliant by Provider to the accessibility standards set forth in this section.  If testing discloses the products or services are not compliant, Provider will resolve the identified noncompliance at Provider’s expense based on a mutually agreed upon timeline before Licensee will approve invoices for payment.  If products or services are found not in compliance as set forth in this section during actual use of product or services by Licensee, Provider will promptly resolve the identified breach at Provider’s expense based on a mutually agreed upon timeline.  Provider further agrees to indemnify and hold harmless the Licensee from any claims arising out of its failure to comply with the aforesaid requirements. Failure to comply with these requirements shall constitute a material breach and be grounds for termination of the Agreement.

29. Want to see where you Score?
Here are some great, FREE, resources to help you determine your institutions accessibility gains and gaps.
Tech Check
Accessibility Maturity Model
NCDAE – GOALS Project

30. Updated AccessMU Website
Easier navigation
More content and user specific
Walk through of website for Policy and Procurement

31. Questions and Contact Information
Kara Zirkle
Accessible Technology Specialist
Miami University
Web: