Montana Accessibility Interest Group
2/7/2014
Presenter:
Cheryl Pruitt, Director
Mark Turner, Associate Director
Accessible Technology Initiative
CSU, Office of the Chancellor
Context: about the CSU
•California State University (CSU)
•Largest public baccalaureate
degree-granting institution in the
United States
•23 campuses; >400,000
students; ~80% undergraduate
•About 11,800 students with
disabilities registered with our
campus disability services offices
Poll Question
Did your campus have an accessibility effort
before the legal action at University of Montana?
a) Yes
b) No
c) Don’t know
3
Moving your institution towards
accessibility…
Cultural change
+
Institution-wide effort
=
Really BIG Job
CSU Accessibility Implementation Tools and Resources
4
CSU Strategies
Policy
Capacity/
Target High
Impact Areas
Connect
Accessible
Technology
Initiative
Procurement
Assessment
Collaborate
with vendors
5
Poll Question
• Has an accessibility awareness campaign been
started on your campus?
a) Yes
b) No
c) Don’t know
Lightning Round: Poll Question 1 of 4
1. Does your institution have standardized
contract language for purchasing accessible
information technologies?
a) Yes
b) No
c) Don’t know
Lightning Round: Poll Question 2 of 4
• Are you familiar with the Voluntary Product
Accessibility Template (VPAT)?
a) Yes
b) No
c) Don’t know
Lightning Round: Poll Question 3 of 4
• Has anyone on your campus had opportunities to
work with vendors to improve the accessibility of
their products?
a) Yes
b) No
c) Don’t know
Lightning Round: Poll Question 4 of 4
• Has anyone on your campus developed
processes for testing the accessibility of
products?
a) Yes
b) No
c) Don’t know
Accessible Procurements
1. Process that identifies when an Electronic and
Information Technology (E&IT) purchase is being made?
2. Process in place to determine level of product
accessibility
3. Process to engage vendor in accessibility conversation
4. Process to get commitment from vendor to improve the
product
5. Contract language that covers product accessibility
agreements
6. Equally Effective Access Plan in place for product
accessibility gaps
11
Recommended Roles and Responsibilities for
Accessible Procurement
• The responsibility for purchasing accessible products
should be a shared responsibility across the campus
•
•
•
•
•
•
•
•
Purchase Requester
Administrative Support Staff
Buyer (Procurement Office)
IT Staff
Disability Services Staff
E&IT Product/Service Provider
ATI Designee or Other Designee
Executive Sponsor
12
Accessible Procurement Processes
1. Process that identifies when an Electronic and
Information Technology (E&IT) purchase is being made.
• Pre-purchase/acquisition form (see similar form at CSU Channel
Islands)
• Who: Purchase Requestor
2. Process in place to determine level of product
accessibility
• Request and review product accessibility documentation
• VPAT (Voluntary Product Accessibility Template)
• Vendor test results to support claims made on the VPAT
• Requires trained personnel
• Who: ATI Designee, IT Staff
13
Accessible Procurements
3. Process to engage vendor in accessibility conversation
•
•
•
•
Following the review of the vendor supplied accessibility
documentation correspond with vendor regarding the
quality of the accessibility documentation
Request clarification or revision if warranted
Determine if product will undergo accessibility testing may
need to request access to product
Who: ATI Designee
4. Process to get commitment from vendor to improve the
product
•
•
Based on accessibility evaluation (documents or testing)
request that vendor provide an “Accessibility Roadmap”
14
Who: ATI Designee
Accessible Procurements
5. Add contract language that covers accessibility
•
•
•
Standardized language that is generic and included in the
General Provisions (see example on slide # 17)
Customized to the purchase includes language that covers
commitments made in “Accessibility Roadmap”.
Who: ATI Designee, Buyer/Procurement Officer
6. Put Equally Effective Alternate Access Plan (EEAAP) in
place for product accessibility gaps
•
•
Plan how you will accommodate students who encounter
barriers caused by product accessibility gaps.
Who: ATI Designee, Purchase Requestor, and Disability
Services
15
Question from Robert Squires:
• Our future policy will require that all content made available online be
accessible for all-users whether they have self-identified as requiring
an accommodation or not. This will mean, amongst other things, that
all video content will need to be captioned when it is uploaded or very
shortly thereafter. I wonder whether CSU has a similar policy in place
or coming into place, and how CSU provides guidance and support for
faculty. I would be particularly interested in hearing Cheryl’s thoughts
on whether this goes beyond workshops, trainings and appropriate
levels of institutional support into enforcement and personal liability.
16
Example Contract Language
Contractor hereby warrants that the products or services to be provided
under this contract comply with the accessibility requirements of section
508 of the Rehabilitation Act of 1973, as amended (29 U.S.C. 794d),
and its implementing regulations set forth at Title 36, Code of Federal
Regulations, Part 1194. Contractor agrees to promptly respond to and
resolve any complaint regarding accessibility of its products or services.
Vendor further agrees to indemnify and hold harmless the CSU using
the vendor’s products or services from any claims arising out of its
failure to comply with the aforesaid requirements. Failure to comply
with these requirements shall constitute a breach and be grounds for
termination of this Contract.
CSU General Provisions for Information Technology Acquisitions
17
Purchase Requester
• Person who requests the product/service to be purchased or
developed.
1. Selects the most accessible E&IT product/service that meets their
functional requirements
• Completes the appropriate sections of the Accessible E&IT PrePurchase document (campus-specific) including the technical
and functional requirements and market research for the
product/service
• Obtains vendor-provided accessibility conformance documents
(e.g. VPAT).
• Submits the Accessible E&IT Pre-Purchase document to
campus reviewer (e.g. ATI Designee or other designee) for
approval
2. Serve as member of EEAAP Committee
18
Administrative Support Staff
• Completes and processes all appropriate forms and documentation
for requester and coordinates with ATI Designee, Disability Service
Office, and office of Procurement to complete the accessibility review.
1. Assists purchase requestor with completing the required request
forms and processes to purchase E&IT products and services
a. Works with Purchase Requestor to complete required
accessible E&IT procurement documentation including:
• The Accessible E&IT Pre-Purchase form (campus-specific)
for review by ATI Designee (or other designee)
• Vendor-provided accessibility documentation (e.g. VPATs,
Accessibility Roadmap)
b. On behalf of Purchase Requestor, submits the documentation
listed above to campus reviewer (e.g. ATI Designee or other
designee) for approval
19
Buyer (Procurement Department)
1.
Reviews purchases of E&IT products or services to ensure all ATI
procurement requirements have been met
a.
2.
Completes all authorized purchases of E&IT products and services
a.
b.
3.
4.
Verifies that Pre-purchase form, initial EEAAP and vendor
accessibility documentation are present
Verifies that ATI Designee (or other designee) has reviewed and
approved the requested E&IT purchase
Verifies that the EEAAP Committee has drafted an EEAAP for highimpact products or services
Maintains records and documentation of procured E&IT
products/services
Upon request, in coordination with the ATI Designee and the
requesting department(s), establishes contracts with third-party
consultants to perform accessibility conformance testing
20
Information Technology Staff
• IT staff provide technical expertise and assistance with the purchase
and deployment of accessible technology.
1. Advises the ATI Designee or other designee, campus departments,
campus requester and/or campus administrative support staff on
functional and technical requirements as they relate to E&IT
purchases
a.
b.
Assists the ATI Designee with evaluating the functional and technical
requirements of a purchase request
Assists the Campus Requester with developing functional and
technical requirements
2. Advises the campus requester on evaluating vendor Section 508
documentation for completeness and possible concerns prior to
submitting it for ATI review
a.
Assists in the evaluation of market research
21
Disability Services Staff
• Disability Services staff members provide expert guidance on
accommodations and assistive technologies that provide persons
with disabilities with equal access to university programs and
services.
1. Provides expertise as a consultant in identifying potential issues
that result from the interaction between the technology and the
individual user
2. Participates in the campus ATI Steering Committee
3. Participates as a member of the EEAAP Committee in the
preparation of Equally Effective Alternate Access Plans and in the
evaluation of exemption requests
22
E&IT Product/Service Provider
• An E&IT provider of goods/services sells or develops the
product/service for a campus or campuses within the California State
University system.
1. Works with the CSU system to provide documentation regarding
product/service accessibility.
• Provides 508 conformance documentation (e.g. VPAT, testing
results and Accessibility Roadmap)
• Specifies an accessibility contact person in the 508 conformance
documentation
2. Works with the CSU system to mitigate accessibility
issues/concerns in the products/services that they are providing
• Keeps CSU apprised of work on incorporation of accessibility
standards into product or services
• Provides sample of product or services for testing or
23
demonstration of Section 508 conformance
ATI Designee or Other Designee(s)
The responsibilities may be assigned to one person (e.g. ATI
Coordinator) or shared across multiple positions on campus
1. Facilitates consistent implementation of accessible Electronic
and Information Technology (E&IT) procurement procedures
that conform with Federal and State laws as well as CSU policy
mandates
a. Consults with buyers to develop accessibility language that will be
incorporated into bids and final contracts
b. Completes appropriate campus documentation for the ATI portions of
E&IT purchases while ensuring that all ATI-related documents have the
required approvals and are readily available for campus personnel
involved in EEAAP implementations
c. Attends regularly-scheduled ATI meetings with campus stakeholders
(e.g. ATI Steering Committee, campus working groups, ATI
Procurement Community of Practice)
24
ATI Designee or Other Designee(s)
2. Oversees review of E&IT accessibility compliance
documentation for regular purchases and competitive bid
procurements (e.g. RFPs, RFIs, and RFQs)
a. Evaluates vendor-provided accessibility conformance documentation
(e.g. VPAT, Accessibility Roadmap)
b. Reviews Accessible E&IT Pre-Purchase form submitted by Purchase
Requester
3. Develops campus strategy for selecting E&IT products/services
that will be evaluated for conformance with accessibility
standards
a. Selects products/services that require accessibility conformance testing
based on impact criteria
b. As needed, arranges for accessibility conformance testing to validate
vendor accessibility claims
25
ATI Designee or Other Designee(s)
4. Coordinates with E&IT vendors to resolve issues with product
accessibility support or accessibility documentation
a. Provides feedback to E&IT vendor, as needed, regarding issues with
accessibility documentation or product accessibility support
5. Participates as a member of the EEAAP Committee in the
preparation of Equally Effective Alternate Access Plans and in
the evaluation of exemption requests
a. Coordinates the development of Equally Effective Alternative Access
Plans that will achieve accessibility for students, employees and
members of the public
6. Serves as the identified campus contact for staff, faculty,
students, and E&IT vendors regarding accessible E&IT
procurement
a. Answers questions related to purchasing accessible products
26
ATI Designee or Other Designee(s)
7. In consultation with the ATI Steering Committee, coordinates
the delivery of accessible E&IT procurement training programs
for the campus community (e.g. buyers, faculty, and staff)
a. Oversees the initial development and ongoing provision and
coordination of accessible E&IT procurement training programs for the
campus community (e.g. buyers, faculty, and staff) including participant
tracking
8. Coordinates campus communications regarding accessible
Procurement Procedures (e.g. awareness campaign)
a. Coordinates the campus roll-out of a broad-based awareness
campaign regarding accessible E&IT procurement procedures.
9. Acts as liaison with the Executive Sponsor and campus
community regarding accessible E&IT procurement issues
a. Discusses accessible E&IT procurement issues with campus Executive
Sponsor and ATI Steering Committee as needed
27
Executive Sponsor
• This ATI role oversees campus policies, projects and implementation
of the Accessible Technology Initiative.
• Works with the campus ATI Steering Committee, to review and
update the ATI Campus Plan to guide their implementation on
an annual basis
a. Conducts regular ATI Steering Committee meetings no less than twice
per year
b. Ensures that the ATI Steering Committee membership is comprised of
all key stakeholder groups and includes members with appropriate
experience and expertise to inform decision-making
28
Executive Sponsor
2. Leads the implementation effort on their campus
a. Oversees campus ATI planning and implementation process
b. Engages in a periodic administrative review process with the ATI
Steering Committee regarding challenges, milestones, resources, and
documenting ongoing progress
c. Monitors, leverages, and implements deliverables from system wide
ATI activities that will advance campus efforts
d. Ensures that ATI Steering Committee members monitor, participate in,
and contribute to Community of Practice activities
e. Channels communications from the Chancellor's Office to appropriate
parties on campus
f. Attends Executive Sponsors Steering Committee (ESSC)
29
Desire 2 Learn – Accessibility Resources
• Videos:
• Desire2Learn's Groundbreaking Work in Accessibility (award from
the NFB).
https://www.youtube.com/watch?v=mO54vAKOpzo&list=PLPXvKtUa
dRjxsdErURhYcI2YwGaf-qDvY&feature=c4-overview-vl
• Carin provides an accessibility walk-through of the D2L Learning
Environment.
• https://www.youtube.com/watch?v=-8haBSM59wE
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