Year 2 Procurement Annual Report
California State University, Sacramento
In compliance with the Americans with Disabilities Act of 1990 (ADA), Section 508 of the 1973
Rehabilitation Act (as amended in 1998), and California State University Coded Memorandum AA-200704, annual reporting of the implementation of the Accessible Technology Initiative is required of all CSU
campuses. This report focuses on Priority Three: Accessible Electronic and Information Technology
(E&IT) Procurement, due August 15, 2008.
The topics identified in this form address your original plan from 2007 and provide a narrative
description of your progress as well as obstacles in achieving your goals. Please provide updates to
your original plan, reporting on significant tasks that were completed; what you expect to
accomplish next year; areas of difficulty and barriers to completion; and any comments on your
observations and discoveries. You may provide any attachments that you believe are relevant
to this report.
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Table of Contents for Year 2 Procurement Annual Report
1. Have you refined or changed your procedures from those you described in your 2007 plan? If
so, please explain. ..................................................................................................................................... 3
2. Please describe briefly the team involved in your 508 procurement process, and the roles and
responsibilities of team members, especially if they have changed since you submitted your plan. . ... 4
3. Please list the other significant roles of individuals involved in the 508 procurement process.
Please briefly list the 508 procurement responsibilities of each. ............................................................. 7
4. How many procurements over $50,000 were made on the campus? Were you able to
incorporate Section 508 requirements in all of them? If not, why not? ................................................. 9
5. Of the procurements that did incorporate Section 508 requirements, how many resulted in an
exception from the 508 requirements? Which exceptions have been used? Please provide an
example or two, if you have any. ............................................................................................................ 10
6. If there were exceptions, how many included a procedure to provide equally effective
alternative access? Please attach one as an example. .......................................................................... 11
7. What 508 procurement communication activities took place during the past year? Please
describe the activities and attach any relevant documents or materials............................................... 13
8. What 508 procurement training activities took place during the past year? How many people
were trained? What roles were they in? Please describe the activities and attach any relevant
documents or materials. ......................................................................................................................... 16
9. What activities took place to evaluate the implementation of 508? Please describe. What were
the results? ............................................................................................................................................. 17
10.
In what ways did implementation of your 508 Procurement Plan differ from what had been
planned? Why? ...................................................................................................................................... 19
11.
What additional resources would assist your campus in implementing 508 procurement
objectives? .............................................................................................................................................. 20
Appendix A: Milestones and Timelines for Accessible E&IT Procurement ............................................. 22
Appendix B: Survey on Accessible E&IT Procurement Pilot Process ...................................................... 28
Appendix C: PILOT PROCESS - STEPS IN ACCESSIBLE E&IT PROCUREMENT ........................................... 32
Appendix D: Communications Regarding Accessible E&IT Procurement ............................................... 35
Appendix E: Equally Effective Alternate Access Discussion .................................................................... 43
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1.
Have you refined or changed your procedures from those you described in your 2007
plan? If so, please explain.
1a. Accomplishments in 2007/2008
The general processes and procedures described in our 2007 Procurement plan have been followed.
Some procedures have been refined to include more specific steps and details. See Appendix A:
Milestones and Timelines for Accessible E&IT Procurement and Appendix C: Pilot Process.
E&IT procurements above $50,000 incorporated accessibility compliance in 2007-2008. The process for
integrating accessibility was facilitated with ample assistance from the IT Buyer and Section 508
Compliance Officer designee. The processes for determining exemptions and providing alternate access
still need to be further refined.
Accomplishments from 2007 can be found in Appendix A, and include the following:
1.
Six campus scholarships were awarded for staff to attend the Chancellor's Office ATI Section
508 Procurement Training in December 2007.
2.
The Procurement Services IT Buyer and Interim ATI Coordinator co-presented on accessible
IT procurement at the College ITC meeting in December 2007.
3.
The Provost and Faculty Senate Chair sent a memo to all faculty and staff in September 2007
regarding the ATI and technology purchases:
http://www.csus.edu/accessibility/MessageFromProvost_2007_09_24.pdf
4.
A campuswide ATI Forum was held in October 2007 to discuss the impact of the Accessible
Technology Initiative and need for Accessible EIT Procurement.
5.
A Voluntary Product Accessibility Template Webinar “Understanding the VPAT" was held on
Thursday, March 20, 2008.
6.
ATI Procurement requirements were announced at College ITC Liaisons Discussions held
monthly; meetings are well attended by campus ITCs, Information Technology and Media
Consultants
7.
The ATI "Fast Facts for Accessibility" Newsletter was distributed to all campus staff and
faculty. This newsletter included ATI contacts, ATI timelines and steps for researching
accessible E&IT procurement.
8.
The EIT Accessible Procurement process:
http://www.csus.edu/accessibility/ATI_PILOTPROCESS.doc was developed, piloted, and
evaluated. See Appendices B & C.
1b. Plans for 2008/2009
A new ATI Procurement Compliance position is currently being recruited, and is expected to start in
early fall 2008. This new position will allow significantly more consultation and technical assistance to
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the campus related to ATI Procurement. This person will further refine the processes and prepare
further action items for 2008-2009 Accessible Procurement in September.
1c. Barriers to completion
Staffing: The current 508 Compliance officer designee had limited time for management of the 508
compliance process due to other job responsibilities. This issue is being addressed by hiring an ATI
Procurement Compliance/Training specialist to lead ATI procurement efforts and assist staff and faculty
to plan, train, implement, and evaluate accessible EIT purchases. Although funding for an ATI
Procurement specialist was identified, the recruitment and hiring of the position has not been
completed yet, and there have been some unexpected delays .
Lack of dedicated administrative support for the ATI project has also caused some delays and impacted
project recordkeeping and support. In September 2007, an IRT Administrative Analyst was assigned to
assist with ATI project administrative tasks; unfortunately, this person went on leave for the majority of
the year. Other staff who were already impacted by office staff shortages have provided some back up
support.
508 Compliance Seen as Add-on: The 508 compliance review process needs to be built into the
procurement procedures in a seamless way, and not thought of as an “add on”; process itself could also
be adjusted; For example, before a requisition can be entered, a 508 compliance review must be
completed;
Manual process: The process of obtaining signatures, routing checklists and VPATs, etc. has been laborintensive; this manual approach is feasible with the $50,000 threshold, but will be difficult when the
threshold drops and many more requests need to be processed. CMS could be utilized as a tool to build
accessibility compliance into the procurement process. It was explained by our Administrative
Computing department that a change to the Procurement process in CMS might need to be proposed as
a “baseline” change to CMS systemwide. Although this system-wide approach makes sense, since it can
improve efficiency across all twenty-three campuses, the process can be cumbersome and timeconsuming. Our campus needs a business solution sooner than might be possible systemwide in order
to eliminate all of the time consuming “paper pushing”.
1d. Observations/ discoveries
The University community is slowly becoming sensitive to the need for accessible E&IT procurement.
Departments need to understand that the accessible EIT procurement process will take additional time
to do market research and gather information on 508 compliance, and the review process and
coordination, and to plan accordingly. The process of achieving cultural change in the way we do
business, including a move away from “just in time” purchase requests, will take time, communication,
and training.
2.
Please describe briefly the team involved in your 508 procurement process, and the
roles and responsibilities of team members, especially if they have changed since you
submitted your plan. If you have had trouble identifying team members, please
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explain why and include your suggestions of solutions at the campus or Chancellor’s
Office level.
2a. Accomplishments in 2007/2008
According to the 2007 plan, key team members involved in the 508 procurement process include the
following:
1. Requestors – staff, faculty, administrator initiates acquisition
This varied depending on the department making a purchase. IT staff, administrators, and
others submitted requests. At the $50,000+ level, requestors tended to be limited to either the
central IT group or large colleges.
2. 508 Compliance officer – assists with review of 508 documentation and with 508 issues
This team member was designated for 2007-2008.
3. Buyer – processes 508 documentation and purchases product
The IT Buyer performed this function.
4. Technician – helps evaluate EIT products specifications and assists with 508 issues
The 508 compliance officer also played this role. However, technicians more knowledgeable in
the EIT area being considered for purchase (e.g. PCs, data centers, printers, etc.) need to play a
role in evaluating products for compliance and to assist with more technical issues as needed.
5. E&IT Exception Review Committee (CIO, SSWD, Equal Opportunity, Buyer)– works as a team to
review requests that qualify for exemption or other issues that require expertise from multiple
sources.
It was not feasible for the EIT Exception Review Committee to review ALL requests for
exemption. Misunderstanding of the process leads many buyers to assume that an exception is
usually in order. The requests for exemption were generally reviewed by the 508 Compliance
Officer designee, and the CIO as appropriate. No EIT purchases qualified as a potential undue
burden exception. The committee could work as a team if issues arose.
2b. Plans for 2008/2009
See Appendix A for some suggested plans in the area of training key people in the process, including the
individuals listed in part 2A above; Different trainings on Section 508 are needed depending on level of
technical expertise. These plans are also to be developed in further detail by the ATI Procurement
compliance specialist position (to be hired).
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The roles of the Requestors need further definition and delineation. For instance, in some departments,
Budget Analysts and Office Managers are submitting purchase requests. In others, IT consultants are
considered the requestors. Training clearly needs to be provided to requestors regarding when
exceptions might be applicable and when they are not applicable.
A new Manager of Hardware/Software Support within IRT will provide significant additional support for
campus-wide procurement of computing items. He will identify specialists in particular areas (e.g. PC,
printers, etc.) who will provide more input in evaluating the accessibility and coming up with plans for
alternate access. Also the campus Assistive Technology Specialist may need to be consulted to provide
input on technical accessibility issues that relate to assistive technology. The Web Accessibility Specialist
may need to be consulted on web accessibility related questions.
Vendors are another key team member in the procurement process. Support and training for vendors is
also needed, especially smaller companies that may not have experience with accessibility templates
and who should still be able to compete for CSU’s business.
Since Administration & Business Affairs is the University's center for business, finance and support
operations, including Procurement and Contract Services, the Division will need to play a major role in
establishing processes which provide for a smooth flow of incoming requisitions through the
procurement cycle. In addition, the Information Resources and Technology Division will play a more key
role because it is a technology service and support organization that works with other divisions to
enhance productivity.
2c. Barriers to completion
Time needed for coordination - There has been a lot more contact and coordination required on the part
of the requestors, buyer, 508 compliance officer, and vendors. Many vendors are not experienced with
accessibility questions, and this is a new area for many companies. The accessibility requirements take
time to communicate, coordinate, and troubleshoot.
Responsibilities: Clearly delineating who does what to support accessible procurement given the new
and complicated nature of accessible procurement on campus is still needed. The responsibility for
evaluating 508 documentation has been on 508 compliance officer or the Buyer, instead of the
requestor; this is in part due to the need for further training on how to evaluate documentation, and
need for clarification of roles. This has been feasible given the small number of procurements over
$50,0000. However once the threshold drops, and the number of procurements increases, the
requestors will need to take more responsibility for ensuring that the documentation is complete. The
new Compliance specialist position will help different team members to navigate resources in order to
comply with accessibility requirements.
Perception of accessibility as an Add on: The accessible procurement process is still perceived to be
somewhat of an “add on” issue, and accessibility needs to be further embedded in the procurement
process. During the 2007-2008 year, the accessible procurement process was just being piloted. Some
individuals had already done their market research before considering accessibility. Also, including
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accessibility at the beginning of the purchase process, as well as at the beginning of planning projects,
will help. The campus is already starting to see improvements in terms of including accessibility from the
beginning of projects, as a result of communications and collaborations with the IT project manager.
2d. Observations/ discoveries
Because Procurement is a business process, team members include several members from the
Administrative Business Affairs Division. It is important that procurement be viewed as a shared campus
responsibility though. Further training and communication will hopefully help to promote this idea.
Requestors are routinely assuming that the need for sole source purchases of specific items eliminates
the need for accessibility review; training on this issue is clearly required. In addition, there is wide
confusion over what constitutes a back-office product. Many campus-wide products (e.g. network
monitoring equipment) are primarily used in central data centers (i.e., back offices), but have a small
number of users who use software interfaces to access some features of the products. Accessibility
review for such products seems unlikely to provide much benefit in terms of accessibility, yet review
takes just as long as for products that are widely used.
3. Please list the other significant roles of individuals involved in the 508 procurement
process. Please briefly list the 508 procurement responsibilities of each.
3a. Accomplishments in 2007/2008
See part 2A above for details on roles, and Appendix A Milestones for some suggested plans including
key people in the process. Other significant roles of individuals besides the roles not specifically
mentioned in part 2A above, include:

Program/department managers who must approve purchases before they are submitted to
Procurement.

Vendors are also a major part of the process, and are responsible for responding to the
requirements, and need to understand the importance that the CSU places on accessibility and how to
consistently complete an accessibility template (VPAT) .

ATI Procurement subcommittee/workgroup, which developed outputs and processes and discussed
implementation strategies for the Procurement priority of the ATI, in coordination with the ATI
Steering Committee. The Procurement workgroup included staff and administrators from Academic
Affairs, Information Resources and Technology, Library, Student Affairs, and Administrative Business
Affairs.
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3b. Plans for 2008/2009
Again, as mentioned in part 2B, we will need to clarify roles and responsibilities, and do more training
tailored for each role, including vendors. Again the new Compliance specialist position will be charged
with consulting with individuals involved in the process, including clarifying roles.
The make up of the ATI Procurement subcommittee, which is charged with outputs and timelines and
progress of ATI plan tasks in concert with the ATI Steering Committee, may change in structure in 20082009 in part because the subcommittee has completed the planning phase.
3c. Barriers to completion
Coordination with Vendors- Often, vendors’ Sales Departments are responding to requests for VPATs by
the campus, although it’s a highly technical document. This means that questions may need to be
routed through several layers. The roles of the vendors, and roles within the vendor’s companies
themselves, need to be further clarified.
Distributed nature of purchasing : Many departments have different workflow processes for handling
purchases. Depending on the departments, there may be multiple individuals involved with requisitions
and purchases. These individuals may need to work together to ensure compliance with 508
requirements.
Time for workgroup: It has been difficult to find faculty representatives to serve on the ATI Procurement
workgroup, in part due to their workload. However there are several faculty members who serve on the
ATI Steering Committee. Also, although there is a core group of staff and managers who attend the ATI
procurement workgroup meetings, some individuals do not participate fully due to time constraints.
3d. Observations/ discoveries
Not only do multiple parties need to coordinate on campus to orchestrate accessible procurement, but
we need to make sure there is inter-campus coordination too so that we are not reinventing the wheel,
and we are taking a consistent approach to evaluating accessibility. For example, some staff were able
to gather some feedback on VPATs or inquire about whether a product might qualify as an exemption
from other campuses.
The hiring of a permanent Section 508 Compliance Officer will provide a greater foundation for
compliance, training, processes and growth within the University.
Procurement processes are broadly similar across CSU campuses. It seems likely that collaborative work
across the entire CSU on procurement would be more efficient than having each campus develop its
own procedures and processes. More effort should be made to coordinate such CSU-wide work.
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4. How many procurements over $50,000 were made on the campus? Were you able to
incorporate Section 508 requirements in all of them? If not, why not?
4a. Accomplishments in 2007/2008
On campus during 2007-2008 there were 18 E&IT purchases valued over $50,000 that fell under Section
508 requirements. EIT Checklists and VPATs were secured for 10 of the orders, 8 of the orders were
back office exceptions. Details can be found in the Appendix A.
4b. Plans for 2008/2009
We need a more streamlined process for incorporating 508 requirements into the general workflow of
procurements. See Appendix A for some plans. Again, the new Compliance specialist position will help
further refine the process and ways to incorporate 508 requirements into purchases above the
threshold. We expect the number of purchases to increase (quadruple) when the threshold drops to
$15,000. Ensuring a smooth process is in place once the threshold drops to $2,500 is paramount.
4c. Barriers to completion
Paperwork: There is too much “paper pushing” – VPATs, EIT checklist, EIT exceptions documentation,
etc; Again, a technology such as CMS could be utilized as a tool to build accessibility compliance into the
procurement process without the need for separate steps. This would be best done at the system level
through creation of an electronic process for handling VPATS, exceptions, and other 508 work in a
manner that’s integrated with CMS.
Tracking: Documentation after individuals turn in their VPATs and complete their checklists is in paper
form, making it difficult to track the procurements. A log or database might help the issue with tracking
paperwork, and the new Compliance specialist could work in coordination with campus IT staff on this.
In addition, it might be worth adopting a Sharepoint site (or other similar community tool) for
requestors, Buyers, and Section 508 compliance designee to use to streamline communication between
staff and to provide an interface for documentation and tracking.
Workflow: The steps involved in researching accessibility may need to revisited for efficiency; For
example, in the pilot process VPATs should be researched as part of the overall market research.
However in reality, VPATs were requested after the requisition was entered, just prior to being
converted to a purchase order.
See evaluations in section 9, and Appendix B for more barriers perceived by requestors from
procurements above $50,000 during 2007-2008.
4d. Observations/discoveries
The campus establishes key year-end deadlines for submitting purchases above $50,000 to allow time
for corrections and processing. See http://www.csus.edu/proc/SchedofDeadliness07-08Dept.pdf
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However, according to Section 508 compliance officer designee records, more than half of all of the
purchases above $50,000 were requested after the Financial Services established deadline. With the
additional requirements of Section 508 compliance, the year-end deadlines need to be adhered to in
order to allow for enough time for reviewing accessibility. Since accessibility needs to be built into the
IT procurement business process, year-end deadlines may need to be revisited to take into account
these requirements.
CMS can and should be utilized as a platform for identifying Section 508 requirements. A specific NIGP
Code (NIGP Codes are currently utilized by the Procurement Dept to identifies goods and service
acquisitions) could be used to define requisitions that are EIT based. Those requisitions (utilizing the
defined EIT NIGP Code) could be routed in CMS to the Section 508 Compliance Officer prior to
Procurement receiving the requisition. This process improvement will greatly enhance the flow of
requirements and reduce confusion for staff and faculty. This enhancement should be done to CMS
system-wide.
5. Of the procurements that did incorporate Section 508 requirements, how many
resulted in an exception from the 508 requirements? Which exceptions have been
used? Please provide an example or two, if you have any.
5a. Accomplishments in 2007/2008
Approximately 8 purchases out of 18 of the $50,000 or above purchases (44%), resulted in an exception
to 508 requirements based on the exception of “Back Office.” Of these exceptions, 87.5% (7 out of 8)
were purchases for the Telecommunications and Networking department, which performs most of its
work in the machine room or spaces frequented by technicians and service personnel. An example of a
back office exception included Cisco routing and switching equipment from AT&T. When Sacramento
IRT staff contacted the CSU Chancellor’s Office colleagues to see if they had a VPAT at their level, they
indicated that the ATI group considered the Cisco gear “back office”, or equipment located in spaces
only visited by service personnel for maintenance, repair, or occasional monitoring of equipment.
In addition, one IT purchase which did not fall above the $50,000 threshold but which was evaluated for
Section 508 compliance for practice was considered a “Sole source” exception and included a Sole
Source Justification. The product, KBox Systems Management Appliance equipment from
MPC/Gateway, was used to ensure that all desktop security patches are up to date. Sacramento State
IRT staff completed a Justification for Sole Source document indicating that only this product provides
the level of patch management and robust asset management that meets the campus business
requirements;
If a department were to feel an exception might apply, they had to document the exception (e.g. see
www.calstate.edu/Accessibility/EIT_Procurement for sample documentation) and provide an alternative
means of access should a person with a disability require it by statutory obligations.
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The committee received no requests for undue burden exemption. If it was determined that a product
or service was an undue burden exception request, the CIO would need to forward the request along
with the EIT Exception Review Committee’s recommendation to the President.
5b. Plans for 2008/2009
More education about exceptions and need to provide alternate access is needed. Plans to identify
purchases most likely to request exceptions, as well as development of best practices for creating
alternative access, will be . Part of each exception will be to document the nature of the accessibility
issue (if possible, based on the Voluntary Product Accessibility Template), preferred format or
accommodation for accessing the IT product or service, and the address/owner of the inaccessible
product and any contact information. See Appendix A for plans, and Appendix B for the pilot EIT
Accessible Procurement process including procedure to request exceptions:
http://www.csus.edu/accessibility/ATI_PILOTPROCESS.doc .
5c. Barriers to completion
Lack of consistent training material from CSU system on exceptions and how to handle them; our
campus consulted the 508 guidelines when in question, and in some cases the Chancellor’s Office was
consulted. If campuses disagree on what is considered an exception, or what is fully compliant, that
could present a problem when trying to negotiate with vendors.
It might be helpful to keep a list of items that qualified for exceptions on campuses.
5d. Observations/ discoveries
Some departments, before they knew of the process, requested “waivers” of ATI requirements. It will
take a cultural change to shift the focus from reactive accommodations and questions like “what do I
have to do to get out of the requirements” to proactive access and commitments like “how can I better
meet the requirements to provide access for all”.
A repository for vendors and products that have already met Section 508 requirements available to
faculty and staff. The repository would help end users (faculty and staff) early in the decision making
process. This could reduce the number of requests for exceptions and waivers. Each campus currently
continues to reinvent the wheel with EIT Checklists for each acquisition and request for VPATs.
6. If there were exceptions, how many included a procedure to provide equally effective
alternative access? Please attach one as an example.
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6a. Accomplishments in 2007/2008
The procedure to provide equally effective access can be found in step 6 of the pilot EIT Accessible
Procurement process: http://www.csus.edu/accessibility/ATI_PILOTPROCESS.doc
“Plan for equally effective alternative access of E&IT- If an exception to Section 508 is
approved, the campus must determine and document how to implement alternative methods of
access to the information or technology, should individuals with disabilities need to use the
technology. The requesting department, Section 508 Compliance Officer and individual end
user, in consultation with Services to Students with Disabilities, Equal Opportunity/ Affirmative
Action/ADA Compliance and other appropriate offices, will review the exception documentation
and assess the potential impact on students, employees, and members of the public, and plan
for alternate access methods and/or reasonable accommodation for persons with disabilities.”
An example of the process can be found in Appendix E.
Out of the 9 exceptions, all of them were asked to provide alternate access should a person with a
disability require an accommodation. However, the procedures for providing alternate access are still
under development. For instance, on one fax sent to a requestor from the Telecommunications
Services department in June 2008 regarding equipment which qualified for a “back office” exception,
the Section 508 compliance designee wrote,
“… you may need to provide individuals with disabilities with reasonable accommodations
should they be required to access the inaccessible products (the accommodation will be
dependent on the extent of the accessibility problem and the users). Existing campus policies
and practices for accommodating individuals with disabilities, including procedures for handling
complaints, will be followed; however, responsibility for providing alternative access to
inaccessible E&IT products and services will rest with the individual and/or department
providing the inaccessible technology, after consultation with the E&IT Officer and the offices
responsible for accommodations.”
In a letter written to a College IT consultant in January 2008, regarding a purchase request that was not
yet subject to the Section 508 technical accessibility requirements due to the purchase amount, the
Section 508 compliance designee wrote:
“In the event that a department has been granted an exemption from Section 508 technical
accessibility compliance in the purchase of E&IT products or services, that department must still
provide individuals with disabilities with equally effective alternatives in order to access these
products or services. The alternatives will be dependent on the extent of the accessibility
problem and the users.
As a next step, I suggest that your department review the accessibility issues found in the VPATs
for the Adobe CS3 and Autodesk Design Institute products, and then continue to work together
with myself and other campus specialists to develop a concrete plan for alternate access
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methods based on the known accessibility issues, including a communications process with
contact information for the articulation of access needs and accessibility issues.”
Examples of more concrete plans need to be developed, based on campus policies for reasonable
accommodations for students, employees, and others.
6b. Plans for 2008/2009
The ATI Steering Committee and ATI Procurement workgroup, in coordination with the CSU systemwide
Communities of Practice on Procurement, and others, will need to develop best practices for providing
equally effective alternative access, tailored to the campus procedures. The web accessibility specialist
and the Compliance specialist will work in concert to develop sets of best practices for creating
alternative access. Part of each exception will include documenting the nature of the access issue,
preferred format/accommodation based on individual’s disability, a method for contacting the
department using the inaccessible technology, etc.
6c. Barriers to completion
Alternate access is challenging since there is no one formulaic way to figure out all of the issues that
might come up given the variety of functional limitations, even if the accessibility issues are known.
6d. Observations/ discoveries
Through this process, the procedures to request reasonable accommodation should become more
transparent. In addition, the 508 compliance requirements have helped to open and expand the
dialogue across campus of the importance of equal access regarding IT purchased or maintained by the
University.
7. What 508 procurement communication activities took place during the past year?
Please describe the activities and attach any relevant documents or materials.
7a. Accomplishments in 2007/2008
Communication of the policies and procedures for E&IT procurements over $50,000 really only targeted
a relatively small number of end-users, as there were specific and limited departments (e.g. IRT) that
made purchases of this size on behalf of the University and/or their organization.
For general information to the campus community regarding Section 508 procurement procedures, the
following communications methods were to be used:
Communications from 2007/2008 include the following:
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1.
The Provost and Faculty Senate Chair sent a memo to all faculty and staff in September 2007
regarding the ATI and technology purchases:
http://www.csus.edu/accessibility/MessageFromProvost_2007_09_24.pdf
2.
A campuswide ATI Forum was held in October 2007 to discuss the impact of the Accessible
Technology Initiative and need for Accessible EIT Procurement. Flyers, a web-icon on the Sac
State home page, and a staff/faculty news article were published announcing the event.
3.
An Accessibility page, including a link to Accessibility information for IT procurement, was
established at www.csus.edu/accessibility
4.
Announcements on the campus IT listserv of ATI 508 Training Scholarships for qualified staff
to attend the Chancellor's Office ATI Section 508 Procurement Training in December 2007.
5.
The Procurement Services IT Buyer and Interim ATI Coordinator co-presented on accessible
IT procurement at the College ITC meeting in December 2007
6.
Emails communicating to ITCs that the Procurement Services IT Buyer and Interim ATI
Coordinator co-presented on accessible IT procurement at the College ITC meeting in
December 2007.
7.
Consultation offered for those individuals with procurement responsibilities for a
department.
8.
Emails announcing a Voluntary Product Accessibility Template Webinar “Understanding the
VPAT" on Thursday, March 20, 2008.
9.
ATI Procurement requirements announced at College ITC Liaisons Discussions/Forums held
monthly; meetings are well attended by campus ITCs, Information Technology and Media
Consultants
10.
The ATI "Fast Facts for Accessibility" Newsletter was distributed to all campus staff and
faculty. This newsletter included ATI contacts, ATI timelines and steps for researching
accessible E&IT procurement.
11.
The Accessible EIT Procurement Process was developed, piloted, and evaluated. A link to
the EIT Checklist was posted on both the Procurement website (www.csus.edu/proc) and
the Accessibility Website (www.csus.edu/accessibility) See Appendices B & C.
12.
Information on procedures were posted on the ATI and the Procurement and Contract
Services websites. A checklist and procedures can be found at
www.csus.edu/accessibility/procure.stm
13.
Individual meetings (in person or via phone) were scheduled with each requestor involved
in the procurement of IT more than $50,000. Feedback on appropriateness of trainings can
be found in the Pilot Process Evaluation in Appendix B.
14.
Emails to Academic Affairs budget analysts/staff clarifying requirements related to
Accessible E&IT procurement.
15.
Discussions with vendors were held when needed, to explain the requirement.
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7b. Plans for 2008/2009
1. Outreach to campus departments will continue through IRT, Administrative Business
and other appropriate channels on campus.
2. ATI Project Coordinator will continue to work with the CIO and Provost to ensure that
policies are communicated regarding Accessible Procurement requirements.
Communications will take form of email, forums, articles, and other publications.
3. An ATI campus newsletter will continue to be developed and distributed, and will
feature feedback and/or comments from individuals who participated in the accessible
procurement pilot process.
4.
Information article(s) published in the Sac State staff/faculty Bulletin on the new
procurement requirements and steps is planned.
5. Presentation(s) at the Business Partners Roundtable meetings, Cabinet, Administrative
Council, and other campus affinity groups is also planned
6. The Compliance specialist (when hired) will also make direct contacts with individuals in
various departments to promote the process and encourage them to come to (or take
online) training and review requirements.
7. Using materials developed on campus and from the Chancellor’s Office, provide
awareness materials to individuals on campus related to Accessible Technology Initiative
and Accessible EIT Procurement.
8. Work with Creative Services and other units to design posters increasing awareness of
accessibility.
9. Identify other communication strategies that can be used.
7c. Barriers to completion
There is an influx of email and other communications on campus business processes, and the trick will
be to use communication channels effectively, but pursue creative means of promoting accessible EIT
procurement as well. Under consideration is an awareness campaign with posters, for example.
7d. Observations/ discoveries
Sometimes misunderstandings can lead to the best communication opportunities! For example, a
“rumor” started going around that departments were being “banned” from buying software with a
credit card, and that this had something to do with accessibility! Although this was a misunderstanding,
and quickly clarified, the colleague commented that this was a good way to get information out to staff!
ATI Procurement Report Template 2008
15
The Publications and Design department, Creative Services, IT Project Manager in Information
Resources and Technology, and other departments will be helpful in developing effective and creative
communications.
8. What 508 procurement training activities took place during the past year? How
many people were trained? What roles were they in? Please describe the activities
and attach any relevant documents or materials.
8a. Accomplishments in 2007/2008
Trainings in 2007/2008 mostly took the form of individual consultation, sharing documentation, and
group discussions on campus. See Section 7 on communications for details (communications and
trainings do overlap).
In the College ITC meeting a Skit which was adapted with permission from a skit developed by San
Francisco State, was performed to explain the process. This skit generated a lot of discussion, and the
general reception from IT staff was positive.
Some online webinars (e.g. VPAT Webinar) as well as federal government sponsored online training (e.g.
Section 508 Universe) were promoted and offered, but there is no way of tracking participation in the
off-campus trainings.
8b. Plans for 2008/2009
1. In coordination with the Chancellor’s Office Training Task Force, develop,
identify, or implement online ATI procurement training
2. Hold group trainings and forums (e.g. College ITC Liaisons forum, Business Partner
Roundtable, etc.)
3. Continue one on one consultation with departments and individuals (e.g. College ITCs)
likely to be involved with or purchase IT above $15,000
4. Refine documentation and procedures, with more details on how to complete the EIT
checklist.
5. Infuse ATI requirements into procurement 101 training
6. Include ATI procurement requirements in the Compliance seminar and the professional
development series for new managers (through HR Training & Development) are also in
the works.
ATI Procurement Report Template 2008
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7. Continue to add Information about IT Procurement on the
http://www.csus.edu/accessibility/index.stm home page to give a brief overview of the
procurement requirements, steps on how to fulfill the requirement, and links to the
associated forms.
8. Consider adding online training to LearnerWeb, and linking training to job
responsibilities (similar to the Procurement training for those involved with
procurement, or Information Security Program training for individuals with access to
information and data).
8c. Barriers to completion
Convincing individuals who are involved in the purchase process that training is worth the time
investment is challenging. ATI will need to use publicity and communications to target individuals
involved in the procurement process. Since the training is not required, perhaps it could be mandated by
HR as part of the job requirement for those employees with procurement responsibilities, similar to how
Information Security Training is mandated for those who use data and IT.
Tracking training can be an issue, especially for employees taking off-site online training, e.g. Section
508 Universe. Also, the trainings from the CSU system were helpful (we had 8 people attend the ATI
Section 508 training), but they needed to be more tailored to the CSU/campuses.
Also, the number of people to train, and the different levels of technical skills and familiarity with
assistive technology of individuals being trained, is a challenge.
Many vendors lack awareness of section 508 requirements. For example, according to a survey of
participants involved in the pilot procurement process, only 5 out of 14 participants (36%) felt that when
they requested Voluntary Product Accessibility Templates (VPAT) from vendors, the vendors were
familiar with the VPAT.
8d. Observations/ discoveries
Although vendors are not CSU employees, somehow they need further targeted training as well.
One issue that might arise by training vendors is unfair advantages - do we give vendors an advantage if
we train them how to best complete a VPAT, spend time discussing and testing accessibility issues, etc.?
9. What activities took place to evaluate the implementation of 508? Please describe.
What were the results?
9a. Accomplishments in 2007/2008
Progress in implementing 508 in IT procurements can generally be measured by percentage of IT
acquisitions that comply with Section 508 requirements. Since accessibility requirements apply for IT
purchases above $50,000, we can assess how many purchases above $50,000 included documentation
ATI Procurement Report Template 2008
17
regarding compliance. Records related to purchases are kept in Procurement and Contract Services.
Random sampling could be done to check for compliance. Documentation includes the EIT checklist
from departments indicating level of 508 compliance, Voluntary Product Accessibility Templates (VPATs)
from vendors, exceptions documentation indicating why an exception is justified, and plans for
providing alternate access should an individual with a disability require it.
An evaluation of the pilot process included an online survey distributed to individuals participating in the
process. Results can be found in Appendix B.
9b. Plans for 2008/2009
A “self check” or random sampling of IT procurements above the dollar threshold of $15,000 can be
done to check for 508 compliance in 2008/2009.
Plans to incorporate accessibility into the campus self-audits and “random sampling” that are already
done as part of Procurement and Contract Services procedures, will be explored. Random sampling of
procurement files may be helpful for assessing yearly progress; however, it will be helpful to track IT
procurements on a more regular basis to ensure that they include all required documentation and are
requirements are consistently applied when procurements are going through.
In addition, ongoing assessment of the ATI procurement related trainings and communications, to assess
staff/faculty understanding of the accessible E&IT procurement process, is also planned.
Finally, evaluation of the equally effective alternate access procedures and best practices will be a focus
area. As mentioned in Section 6, Best Practices in the area of equally effective alternate access will be
developed. The evaluation of the effectiveness of this process as part of the overall general E&IT
procurement process, may involve potential focus groups with requestors, disabled students and/or
employees.
9c. Barriers to completion
Identifying the measures for compliance with 508 is not as easy as it seems; although the 508 standards
are clearly outlined, it is difficult to assess all purchases for compliance given the same rubric since some
products are only partially compliant based on what is commercially available, and some purchases
qualify for an exception to 508 (e.g. back office).
Also, the person doing the random sampling of procurements for compliance needs to have some
familiarity with the 508 standards and with the accessible IT procurement process; however, if the
assessment involves the 508 compliance officer or IT Buyer, who helped with the process, there may be
bias.
Finding individuals to participate in the focus groups may be difficult, given workload of both employees
and students.
ATI Procurement Report Template 2008
18
9d. Observations/ discoveries
This is where use of CMS or another automated tool would be helpful. Also, exercises involving
evaluations of procurement files for 508 compliance would be helpful during the Procurement
Community of Practice.
10. In what ways did implementation of your 508 Procurement Plan differ from what
had been planned? Why?
10a. Accomplishments in 2007/2008
The implementation of the 2007/2008 plan differed in terms of the way training was delivered, and also
in terms of the exception process. Changes in procedures are referred to in Section 1, which addresses
how we refined or changed our procedures from those described in our 2007 plan.
Because the requirement only applied to purchases above the $50,000 threshold, one on one
consultation was done in lieu of group workshops for most of the training; also, because the training
wasn’t fully developed yet, the training process was iterative, and included a lot of collaboration and
discussions - it was seen as a work in progress.
The Compliance specialist position is being recruited, and is expected to begin in early fall 2008. This
position when hired, will help work on developing plans in further detail in coordination with the ATI
procurement workgroup, ATI Steering Team, and others campus stakeholders as appropriate.
10b. Plans for 2008/2009
The plan is to really get the word out more about accessible procurement procedures and requirements,
now that the process has been pilot tested for IT purchases above $50,000;
Communications will be done through a variety of mediums and channels. The ATI project coordinator,
Compliance specialist, and/or others will send an awareness alert through the campus Bulletin, and via
email through the campus IT mailing list. In addition an ATI newsletter will be published and include
more details about how to accomplish accessible IT procurement.
The Information Resources & Technology division will hold a technology fair in October 2008. This is an
opportunity to include information on CSU accessibility requirements, and an Accessible Technology
Initiative table with resources, and potential presentations, will be featured.
In November 2008, the campus will host a ATI regional meeting in coordination with the ATI Chancellor’s
Office, and this will be a good opportunity to highlight implementation of the accessible procurement
process, among other ATI related topics.
ATI Procurement Report Template 2008
19
A key plan is to hire a procurement Compliance specialist. This person will lead the efforts in the
procurement priority. Although a 508 Compliance Officer was designated for 2007/2008 and was
involved in implementing the 2007 plan, e.g. reviewing accessibility documentation and when
appropriate, approving exceptions in coordination with the CIO and the E&IT Exception Review
Committee, etc. this role was in addition to her other job responsibilities. The hiring of a Compliance
specialist, who can dedicate more ample time to the efforts and lead the accessible procurement
process and ATI training components, will be an important addition to the campus efforts to implement
accessible E&IT procurement. The specialist, along with Procurement and Contract Services,
Information Technology & Information Resources, and others will work to promote accessibility efforts
related to Procurement.
10c. Barriers to completion
Staffing: As mentioned above, staffing was a barrier, but the campus was still able to implement
accessible procurement despite limited time for management of the 508 compliance process due to
other job responsibilities. This issue is being partially addressed by hiring an ATI Procurement
Compliance/Training specialist to lead ATI procurement efforts and assist staff and faculty to plan, train,
implement, and evaluate accessible EIT purchases. This position is expected to be hired by fall 2008
Tracking: A more robust system of tracking procurement is needed. This will facilitate communication,
evaluation, and a more automated process; and utilization of tools such as CMS and Sharepoint will be
explored for incorporation into the accessible procurement process.
Alternate Access Plans: Because exceptions and planning for alternate access is the responsibility of the
departments/owners of the exempted technology, departments will need additional training and
resources to provide accessible alternatives.
10d. Observations/ discoveries
This question seems to overlap with question 1. More clarification is needed.
11. What additional resources would assist your campus in implementing 508
procurement objectives?
CSU-Wide Work ON CMS handling of Procurement: This support is essential to project success. The
process of having each campus do its own CMS modifications or requiring creation of shadow IT
systems, is horribly inefficient and counter-productive. In addition, this encourages campus-specific
behavior that runs counter to the main goal of having a “common” data management system.
Repository: A repository for vendors and products that have already met Section 508 requirements
needs to be available to faculty and staff. The repository would include VPATs and help end users
(faculty and staff) early in the decision making process. This could reduce the number of requests for
ATI Procurement Report Template 2008
20
exceptions and waivers. Each campus currently continues to reinvent the wheel with EIT Checklists for
each acquisition and request for VPATs
Training: Additional online training is needed. In the survey of the procurement process (see Appendix
B), 71% of individuals surveyed recommended online training for learning about accessible E&IT
procurement procedures. One suggestion is to explore the possibility of requiring training in accessible
procurement as a mandatory job requirement, if an individual’s job description includes procurement or
purchasing responsibilities. This may involve working with CSU Collective Bargaining Units and revisiting
which units and positions will most likely be affected, and ensure consistency systemwide. Also,
campuses could require training in accessible procurement as a mandatory job requirement, if an
individual’s job description includes procurement or purchasing responsibilities. This may involve
working with CSU Collective Bargaining Units and revisiting which units and positions will most likely be
affected, and ensure consistency systemwide.
Planning for alternate access: Best practices for alternate access, including examples of procedures and
costs involved in various workarounds, would be helpful.
Evaluating Accessibility: More assistance with evaluating accessibility is needed. Perhaps the Center for
Usability and Design Accessibility (http://www.csulb.edu/centers/cuda/) would be helpful for
developing best practices as well as for doing some actual testing of products for accessibility.
ATI Procurement Report Template 2008
21
Appendix A: Milestones and Timelines for Accessible E&IT Procurement
September 1, 2007 Milestone
Develop and Implement E&IT Procurement Procedure for acquisitions greater than $50,000.
Task
Timeline
Responsible Party
Identify Section 508
8/10/07
CIO
Compliance Officer and
Technician(s)
Submission of E&IT
8/10/07
CIO
Procurement Plan to C.O.
Complete development of
E&IT Procurement Checklist
and procedures
8/15/07
Schedule workshop for
Requesters and notify
individuals
8/15/07
Director of Procurement and
Contract Services
Progress/Comments
Completed
Completed
Completed – checklist and
procedures can be found at
www.csus.edu/accessibility/procur
e.stm
Section 508 Compliance
designee, IT Buyer
The Procurement Services IT
Buyer and Interim ATI
Coordinator co-presented on
accessible IT procurement at the
College ITC meeting in
December 2007
Individuals notified of
scholarship for ATI Section 508
training; training attended by
individuals.
A Voluntary Product
Accessibility Template Webinar
“Understanding the VPAT" was
held on Thursday, March 20,
2008.
Individual meetings with
requestors scheduled, ad hoc.
ATI Procurement Report Template 2008
22
Meeting with individuals in
key roles to review
responsibilities and process
(Compliance Officer,
Technician, Buyer, members
of E&IT Procurement Review
Team)
8/24/07
Implement E&IT Procurement
Procedure for acquisitions
greater than $50,000
9/1/07
508 Compliance Officer
Procurement Subcommittee
workgroup meetings were held
monthly or as needed during
the fall 07 and spring 08
semesters. Co-chairs included
Co-Director of
SSWD/Compliance Officer
designee & Director of
Procurement
The Provost and Faculty Senate
Chair sent a memo to all faculty
and staff in September 2007
regarding the ATI and
technology purchases:
http://www.csus.edu/accessibili
ty/MessageFromProvost_2007_
09_24.pdf
See chart $50,000 E&IT
Purchases 2007-2008 for
California State University,
Sacramento below for details on
$50,000 purchases.
September 1, 2008 Milestone
Implementation of an accessible procurement process for E&IT acquisitions greater than $15,000. All procurement card purchases are
exempt from the accessible procurement process at this point in time
Task
With input from focus groups
and operational departments,
develop pilot process and
identify pilot department(s)
ATI Procurement Report Template 2008
Timeline
2/15/08
Responsible Party
Director of Procurement and
Contracts, 508 Compliance
Officer
Progress/Comments
Procurement Subcommittee
workgroup and scholarship
recipients met in February and
March (after ATI training held
Feb. 14-15) to discuss and
23
implement pilot process. The
Accessible EIT Procurement
Process was developed, piloted,
and evaluated. See Appendices
B & C.
Create documentation, forms,
etc.
3/15/08
Director of Procurement and
Contracts, 508 Compliance
Officer
Documentation and forms found
online at www.csus.edu/accessibility/pro
cure.stm
The ATI "Fast Facts for
Accessibility" Newsletter was
distributed to all campus staff
and faculty in January 08. This
newsletter included ATI
procurement contacts, ATI
timelines and steps for
researching accessible E&IT
procurement.
Begin pilot and provide
training to pilot Requesters
4/1/08
Director of Procurement and
Contracts, 508 Compliance
Officer
Six campus scholarships were
awarded for staff to attend the
Chancellor's Office ATI Section
508 Procurement Training in
December 2007. These pilot
requestors helped test the
process, and provide feedback.
End pilot and evaluate process
6/1/08
Director of Procurement and
Contracts, 508 Compliance
Officer
Evaluations of the process can
be found in Appendix B.
ATI Procurement Report Template 2008
24
Revise process documentation
and forms as needed
7/15/08
Director of Procurement and
Contracts, 508 Compliance
Officer
A web page linked from the
accessibility page, describing
steps, and to include new
forms, is under development:
http://www.csus.edu/accessibili
ty/procure.stm
The EIT checklist on the
procurement web page will be
revised to include procedures
as well (see screenshot in
Appendix D):
www.csus.edu/proc
Send out communications per
communications plan outlined
in Component 4
7/15/08
CIO
A campuswide ATI Forum was
held in October 2007 to discuss
the impact of the Accessible
Technology Initiative and need
for Accessible EIT Procurement.
ATI Procurement requirements
were announced at College ITC
Liaisons Discussions held
monthly; meetings are well
attended by campus ITCs,
Information Technology and
Media Consultants
Development of on-line
training (?)
8/1/08
508 Compliance Officer and
Technician
Online training has not been
developed yet for the campus;
the Compliance specialist (to
be hired) will work together
with the Procurement
workgroup and Chancellor’s
Office to identify or develop
online training.
ATI Procurement Report Template 2008
25
Schedule workshops and
inform departments of dates
8/1/08
Director of Procurement and
Contracts, 508 Compliance
Officer
Training of key people in
processes
8/15/08
Director of Procurement and
Contracts, 508 Compliance
Officer
Implementation
9/1/08
Director of Procurement and
Contracts, 508 Compliance
Officer
ATI Procurement Report Template 2008
Accessible E&IT procurement
will be integrated into the
Procurement 101 workshops
starting in fall 2008. In
addition, presentations will be
planned for Business Partners
Roundtable and other forums.
These will be announced via
the campus IT listserv and the
campus staff/faculty Bulletin.
Training will be a focus in the
fall once a Compliance
specialist is in place; those
attending training will include
various individuals involved in
the IT procurement process.
This is a campus-wide
implementation;
26
$50,000 E&IT Purchases 2007-2008 for California State University, Sacramento
PO #
Date
Dept.
Product
Amount
Vendor
EIT
Except
Documentation
Chcklst
1200702780
01/17/08
1200703513
03/05/08
1200704008
04/28/08
1200703904
04/24/08
IRT-Acad
Computing
HHS
IRT-Admin
Computing
IRT-Acad
Computing
Dell LatitudeD630 laptops
$123,507.36
Dell
yes
no
VPAT For Laptops
MPC ClientPro desktops
$68,267.72
MPC
yes
no
MEA A63308
Cognos 8
$225,040.00
Cognos
yes
no
VPAT For Software Application
Epson 61101 Projector
$101,877.64
CompView
yes
no
MEA #M010173 - Epson Projector
M070038
05/13/08
IRT-Netwk
Cisco Catalyst WS-C3750
Switch
1200703937
05/19/08
IRT-Telecom
Communications Manager
1200704053
05/01/08
Drive Mgt Software
1200704275
05/19/08
IRT
IRT-Acad
Computing
Optiplex desktop
1200704418
05/23/08
IRT-Info Security
QRadar product
1200704629
05/27/08
iMac & MacBook laptops
1200704691
06/04/08
Arts & Letters
IRT-Acad
Computing
1200704854
06/05/08
IRT-Netwk
1200704782
06/05/08
IRT-Telecom
1200704913
06/04/08
IRT
1200704914
06/09/08
IRT-Telecom
1200704854
06/10/08
1200705029
06/10/08
IRT Netwk
IRT-Acad
Computing
B070019
06/11/08
Student Affairs
ATI Procurement Report Template 2008
AT&T
yes
$387,998.56
Quagga
yes
back
office
back
office
$163,176.00
ComVault
yes
backoffice
$461,178.12
Dell
yes
no
$176,454.64
Q1Labs
yes
no
$98,292.88
Bookstore
yes
no
electronic VPAT
$171,229.50
Dell
yes
Optiplex 755 VPAT
Anti-Spam mail gateway
$85,000.00
Quest
yes
G650 Gateway Hardware
Software & Support
NetApp
$218,246.26
MCC
Applied
Comp
yes
no
back
office
back
office
back
office
Optiplex desktop
Analog, T1, Media
Resource Circuit Packs
Disk expansion for
NetApp
Dell LatitudeD630 laptops
Housing/Residential Mgt
Software System
$81,471.63
$66,134.05
email
RFP B080017
Optiplex 755 VPAT
Iron Point Software Licensing
special exceptions doc.
Software to support NetApp Server
$54,000.00
Mac
Source
Quest
Media
$59,353.13
Dell
yes
no
See PO #1200702780 for VPAT
$100,000.00
RMS vs.
StarRez
no-see
RFB
no
RFP - VPAT docs received - bid not
yet awarded
$168,617.98
yes
back
office
back
office
Iron Point Software Licensing
yes
email
27
Appendix B: Survey on Accessible E&IT Procurement Pilot Process
Survey Key: ZS80209
This is an anonymous survey.
The number of people who took this survey by 7/9/2008 4:21:42 PM is: 14
Accessible E&IT Procurement Pilot Process - Feedback-1
Tell us how the Accessible E&IT Procurement Pilot Process went for you! For reference, see
www.csus.edu/accessibility/ATI_PILOTPROCESS.doc
Please take a minute to answer the following questions regarding the pilot process. If you have any
questions, please contact ati@csus.edu.
1. Did you request or consult on the purchase of E&IT over $50,000 in 2007-08?
[11] Yes
[2] No
[0] other
2. What was your role in the accessible E&IT procurement process?
[8] Requestor
[8] Technical Consultant
[0] Administrative Support
[2] Buyer
[0] Other
3. What type of training or consultation did you receive to learn about the accessible E&IT
procurement process?
[6] individual consultation
ATI Procurement Report Template 2008
28
[9] read documentation
[6] group training
[1] online training
[0] other
4. What type of accessible E&IT procurement process documentation and forms did you use?
[6] Steps in E&IT Procurement: Pilot Process
[9] E&IT Procurement Checklist
[9] CSU Guide to Completing the Voluntary Product Evaluation Template (VPAT) (for Vendors)
[1] Other
5. Where did you find the accessible E&IT procurement process documentation and forms?
[7] Accessibility web page
[6] Procurement web page
[6] they were emailed
[2] other
6. Do you understand the CSU accessible E&IT procurement requirement for providing information
on E&IT product's conformance to Section 508 (also known as Voluntary Product Accessibility
Template)?
[10] Yes
[3] Somewhat
ATI Procurement Report Template 2008
29
[0] No
7. When you requested Voluntary Product Accessibility Templates (VPAT) from vendors, were they
familiar with the VPAT?
[5] Yes
[3] No
[5] Somewhat
[1] Other
8. What training do you recommend for learning about accessible E&IT procurement procedures?
[10] online training
[7] group trainings
[4] one on one consultation
[6] documentation
9. Did you have particular questions related to Section 508 and ATI accessible E&IT procurement?
Have your questions been satisfactorily addressed?
[Yes and Yes]
[No particular questions.]
[Yes my questions have been addressed.]
[Yes & Yes]
[No]
[None.]
[No questions. I believe for completing my first purchasing following the ATI requirements that it
went fairly well.]
10. How can we make it easier for you to comply with the CSU accessibility requirements?
[Ensure that there is someone who I can contact if I have a question/issue regardinh the
requirements/process]
ATI Procurement Report Template 2008
30
[I'm not sure, but I do know the departments quick response to questions and willingness to help
and assist was a huge benifit last year.]
[The process was easy for this particular purchase, Cognos.]
[I found the documentation fine.]
[None.]
[Continuing education in the form of online training, group training and even newsletters help.]
11. Are there any other comments or recommendations you would make as the campus moves
forward in the accessible E&IT procurement process?
[Continue informing the campus about the need and process for accessible E&IT procurement.]
[As with #10, the departments quick response to questions and willingness to help made it much
easier. Thank you.]
[Additional awareness campaigns.]
[I'd like a link on the http://www.csus.edu/accessibility/index.stm home page that gives a brief
overview of the procurement requirements, steps on how to fulfill the requirement, and links to
the associated forms. The link could also include the link to the CO site because I see the CO link as
providing "too much" information.]
[Procurement might want to maintain a list of vendors through which frequent & high value
purchases are made. In that way information dissemination regarding E&IT, VPAT, etc., can be
standardized, coordinated & managed centrally.]
[no]
[None.]
ATI Procurement Report Template 2008
31
Appendix C: PILOT PROCESS - STEPS IN ACCESSIBLE E&IT PROCUREMENT
Electronic and information technology (E&IT) includes: Software applications and operating
systems; Web-based intranet and internet information and applications; Telecommunications
products; Video and multimedia products; Self contained, closed products (e.g. photocopier);
and Desktop and portable computers.
Step 1
Determine Functional Requirements - As the initiating requestor, you should figure out
as specifically as possible what you need in terms of functional requirements from the
technology product or service. Your description should be clear and concise, to include all
tangible goods associated with the purchase request. Make sure to document the needs
and business requirements and if there are specific academic considerations to be taken
into account.
Step 2
Identify Section 508 requirements that apply to the technology product - Look at the
provisions in Section 508 Technical Standards, Subpart B
(www.section508.gov/index.cfm) to determine if there are specific technical provisions
that apply to the IT product that you are looking to purchase. Include these specific
technical provisions on the requisition/support documentation or in the solicitation
document (Invitation For Bid (IFB), Request For Proposal (RFP), Request For Quote
(RFQ)), if applicable, or insert language stipulating that vendors shall provide a Voluntary
Product Accessibility Template (VPAT) to disclose product conformance with 508
standards. Suggested language:
“Any acquisition considered electronic and information technology (E&IT) as defined by
Section 508 (36 CFR Part 1194) requires the submission of a completed Voluntary
Accessibility Product Template in order for the CSU to ascertain conformance with the
applicable E&IT standards developed by the U.S. Access Board.”
Step 3
Step 4
Conduct market research and identify technology product vendors - The requestor
must perform due diligence and conduct market research on accessible electronic and
information technology products and services that meet the functional requirements of the
department. Review accessibility and product information in the Buy Accessible Wizard
www.buyaccessible.gov or look at the product vendors' websites for information on
Section 508 accessibility/ADA compliance. Vendors are required to complete a Voluntary
Product Accessibility Template (VPAT). A VPAT template can be located at
www.calstate.edu/Accessibility/EIT_Procurement/VPAT_Guide.html.
Evaluate technology products to find out if they meet the 508 accessibility
requirements - If possible, have each company demonstrate their product to verify
compliance with the accessibility standards or provide documentation from an
independent research organization such as Center for Usability in Design and
Accessibility (CUDA - www.csulb.edu/centers/cuda/). Choose the product that both
meets the functional requirements and is Section 508 conformant (i.e. accessible).
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Products being evaluated as part of a solicitation which do not fully meet 508
requirements, shall be considered based on best value methodology using relative
weighted factors. Competing products that are associated with a solicitation and are partly
compliant can be evaluated utilizing a comparison table that identifies performance
relative to Section 508 standards and other defined factors (for an example scenario, see
www.csus.edu/accessibility/samplepurchasetable.pdf).
Exception Requests:
If you feel an exception to 508 Accessibility might apply, e.g. back office equipment, net
cost increase, fundamental alteration, commercial non-availability, or undue burden, you
must document the exception and describe the alternative means of access:
www.calstate.edu/Accessibility/EIT_Procurement/APPENDIX.G.EIT_Exceptions_Do
cumentationv2.doc
The E&IT Exception Review Committee (i.e. Buyer, 508 Compliance Officer, Director of
Equal Opportunity, and CIO) will review E&IT acquisition requests for exception and
approve as appropriate. The Committee may also seek technical assistance from the
office of the Services to Students with Disabilities, Information Resources and Technology
and others. If it is determined that an E&IT product or service may qualify as a potential
undue burden exception, the CIO will then forward the Undue Burden Request, along with
the Committee’s recommendation, to the President. The President or his/her designee
has the final authority to approve or disapprove the undue burden request.
If an exception is approved, it is important to note that by statutory obligations the CSU
must still provide alternative access.
Step 5
Purchase Requisition with Supporting Documentation - The initiating requestor
should choose the product that meets the technical and functional requirements and
accessibility standards, unless an exception applies. The requestor shall then submit the
product or service purchase requisition, VPAT, and a completed E&IT Procurement
checklist www.csus.edu/accessibility/EITProcurementChecklist.xls, including the
technical and functional requirements (and exception documentation if applicable). The
508 Compliance Officer will then review the checklist and documentation and advise
Procurement of processing status, and the buyer will purchase the technology product in
accordance with campus procurement procedures. Awards shall only be made for
products and services that are approved by the 508 Compliance Officer and are in the
best interest of the University.
Step 6
Plan for equally effective alternative access of E&IT- If an exception to Section 508 is
approved, the campus must determine and document how to implement alternative
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methods of access to the information or technology, should individuals with disabilities
need to use the technology. The requesting department, Section 508 Compliance Officer
and individual end user, in consultation with Services to Students with Disabilities, Equal
Opportunity/ Affirmative Action/ADA Compliance and other appropriate offices, will review
the exception documentation and assess the potential impact on students, employees,
and members of the public, and plan for alternate access methods and/or reasonable
accommodation for persons with disabilities.
Step 7
E&IT product or service complaint process - Section 508 of the Rehabilitation Act was
enacted to eliminate barriers in electronic and information technology. The CSU has
additional obligations under Section 504 of the Rehabilitation Act including providing
"reasonable accommodations." If informal resolution is not possible, an individual with a
disability may submit a complaint to the Director of Equal Opportunity/Affirmative Action,
California State University, Sacramento, 6000 J. Street, Sacramento Hall, Room 162,
Sacramento, CA 95819-6032, tel. (916) 278-6907 using an Accessible Technology
complaint form (complaints may be filed in alternate forms):
www.calstate.edu/Accessibility/EIT_Procurement/APPENDIX.H.ComplaintFormv2.d
oc
The purpose of this process is to ensure compliance with Section 508 accessibility standards for
new E&IT purchases, with the least possible inconvenience to the requestors. For questions
and assistance with the accessible procurement process, or if you need this documentation in
alternate formats, please contact Section 508 Compliance Officer designee, 916-278-7821,
TTY: 916-278-7239, Fax 916-278-7825, or email: ati@csus.edu
For further questions about general procurement processes, please contact Procurement and
Contract Services at 916-278-7322.
This process was prepared in conjunction with the Accessible Technology Initiative E&IT
Procurement Subcommittee.
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Appendix D: Communications Regarding Accessible E&IT Procurement
1) Message from Provost Regarding Accessible Technology Initiative
http://www.csus.edu/accessibility/MessageFromProvost_2007_09_24.pdf
September 24, 2007
TO: University Faculty and Staff Members
FROM: Joseph F. Sheley, Provost, and Bruce Bikle, Chair, Faculty Senate
SUBJECT: Accessible Technology Initiative
You likely have heard reference to "ATI" recently at Sacramento State. We are writing now to give
you a sense of what "ATI" means and how it will affect us over the next few years.
We very much value educational equity and access to a high quality educational experience at
Sacramento State. We also recognize our legal responsibilities in the area of equity and educational
opportunity. Thus, the University recognizes the importance of meeting the goals of the CSU
system's Accessible Technology Initiative (ATI) to ensure that campus information technology and
resources are accessible to all individuals, regardless of disability. In launching the initiative in 2006,
the Chancellor issued Coded Memo AA 2007-04: "Access to Electronic and Information Technology
for Persons with Disabilities" defining specific, mandatory objectives to be met by all 23 campuses in
the California State University system over the next five years. They address the following three
areas:
Web Accessibility
Initial Focus: departments must ensure that new and significantly updated administrative web sites
and content incorporate accessibility standards into the website development process (Fall 2007).
Instructional Materials Accessibility
Initial Focus: faculty and departments must adopt textbooks and post syllabi, including reading lists,
early enough so that they can be provided in alternate formats (such as Braille and electronic formats
that can be read by assistive technologies) at the same time as materials are provided to all other
students (to impact Spring 2008).
Accessible Electronic & Information Technology Procurement
Initial Focus: departments must ensure that technology purchases e.g. web applications, hardware,
software, telecommunications, multimedia, etc., exceeding certain dollar thresholds conform to
accessibility standards or provide equally effective alternative forms of access (phased in through
Fall 2008).
Meeting the ambitious ATI timelines will be a challenge, and the initiative will affect us all. We must
work together to further our long-standing commitment to provide educational access to all while
complying with federal and state laws. As the Fall 2007 semester begins, we would like to apprise
you of the campus’s plans to support faculty and staff efforts in support of the ATI:
• The Office of Academic Affairs and the Faculty Senate will co-sponsor a campus-wide Forum
on October 22, 2007, from 9:00am to 10:30am in Ballroom II of the University Union, to
discuss the Accessible Technology Initiative. This is an important opportunity to brief
faculty, staff, and other members of the University community on the details and impact of
the ATI.
• Sacramento State has established an ATI Steering Committee (University Committee on
Information Technology Accessibility), led by Chief Information Officer, Larry Gilbert.
• Melissa Repa, Co-Director of the Office of Services to Students with Disabilities has been
appointed interim Accessible Technology Initiative Coordinator. She will work with Larry
Gilbert to identify resources and help guide implementation of the ATI across campus.
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• This past summer, we piloted a successful program via the Teaching using Technology (TuT)
summer institute helping 27 faculty members convert some of their course materials to
accessible formats.
• The Faculty Senate will soon consider a resolution on accessible instructional and electronic
materials that was adopted by the CSU systemwide Academic Senate.
We will provide training and support to faculty, staff, and students as we move forward to achieve
ATI objectives. In the meantime, please consider the following steps as you seek to learn more about
accessible technology:
• View the resources of the California State University Accessible Technology Initiative posted
at this website: http://www.calstate.edu/accessibility/.
• Visit the campus Accessibility website: http://www.csus.edu/accessibility/ for more information
about Sacramento State accessibility, plans, and activities.
• Watch videos of CSU students with disabilities sharing their experiences to appreciate how
accessible information technology and universal design can remove barriers for students with
disabilities and improve all students’ learning:
http://www.calstate.edu/accessibility/resources/videos.shtml.
• Attend a Faculty and Staff workshop on how to create accessible documents and how to use
WebCT: http://www.csus.edu/training/.
• Order all textbooks and other course materials by the deadline established by the Bookstore
(e.g., no later than late October for Spring 2008), to ensure that students with print-related
disabilities receive alternative instructional materials at the same time as their peers.
• Send an e-mail to ati@csus.edu if you have questions or comments about the Accessible
Technology Initiative.
We look forward to your active participation in the ATI Forum this fall and, over the next few
years, to working with the faculty and other members of the University community to ensure
that the campus provides information technology and resources in a manner that is accessible
to all.
2) Campus Bulletin Article: University levels technology access playing field article
http://www.csus.edu/bulletin/bulletin100807/bulletin100807accessible.stm
In a perfect world, everyone would have equal access to the same technology. Sacramento
State can’t make the world perfect, but it is helping provide equal access to technology for
all members of its campus community.
In 2006, the California State University developed the Accessible Technology Initiative and
directed its 23 campuses to begin ensuring information, technology and resources were
accessible to all people by 2012.
“In the past, students with disabilities had to wait to get access to technology after the
fact,” says Melissa Repa, co-director of Services to Students with Disabilities. “They deserve
to have equal access at the same time as other students.”
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The Office of Academic Affairs and the Faculty Senate will sponsor an Accessible Technology
Initiative forum 9 -10:30 a.m., Monday, Oct. 22, in the University Union Ballroom II.
Discussions will center on the impact and implementation of the initiative. The forum is
open to the campus community.
According to the Accessible Technology Initiative:



Departments must ensure new and significantly updated administrative web sites
incorporate accessibility standards into the website development process.
Faculty and departments must adopt textbooks and post syllabi and reading lists
early enough so materials can be provided in alternate formats, such as Braille and
electronic text that can be read using assistive technologies, at the same time they
are provided to other students.
Technology purchases, including web applications, hardware, software,
telecommunications and multimedia products, must conform to accessibility
standards or provide equally effective alternative forms of access.
“There is a lot of work to be done, but we are already starting to see improvements,” says
Repa. “For instance, the University webmaster has developed web page templates that
incorporate accessible technology so departments won’t have to reinvent the wheel every
time they update their sites.”
Repa says about 600 students at Sacramento State have self-identified to her office as
disabled, but said the actual number of disabled students is probably higher since students
are not required to contact her office.
“Access to technology is important not only to students with disabilities but to the entire
University,” Repa says. “It provides for a more welcoming campus and it helps us retain
students by removing barriers and increasing full participation of all students.”
To learn more about accessible technology on campus visit www.csus.edu/accessibility. For
more information on the California State University Accessible Technology Initiative, visit
www.calstate.edu/accessibility.
3) ATI Newsletter - Spring 2008 Issue 1
Excerpt:
Hints for Researching Accessible Electronic and IT Products for Purchase:
The Accessible Electronic and Information Technology (E&IT) procurement process applies to E&IT
purchases above $2,500 starting Fall 2008. Here are some tips for researching accessible IT products:
1. Identify Section 508 requirements that apply to the technology product.
Look at the provisions in Section 508 Technical Standards, Subpart B (www.section508.gov/index.cfm)
to determine if there are specific technical provisions that apply to the technology-based product that you
are looking to purchase. Include these specific technical provisions in the Request For Proposal (RFP), if
applicable. If an exception applies, e.g. back office equipment, document the exception (for sample IT
Exceptions Documentation, see www.calstate.edu/Accessibility/EIT_Procurement/.)
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2. Identify technology product vendors.
Look at the product vendor’s website for information on Section 508 accessibility or ADA compliance.
Review accessibility information about E&IT products and services in the Buy Accessible Wizard—
www.buyaccessible.gov/. Ask product vendors to complete a Voluntary Product Accessibility Template.
A VPAT template can be located at
www.calstate.edu/Accessibility/EIT_Procurement/VPAT_Guide.html
3. Evaluate technology products to find out if they meet the 508 accessibility requirements.
If possible, have each company demonstrate their product to verify compliance with the accessibility
standards. Choose the product that both meets the functional requirements and is Section 508
conformant (i.e. accessible). Products which do not fully meet 508 requirements shall be considered
based on best value methodology using relative weighted factors specified in the Request For Proposal
(RFP).
4. Purchase the technology product.
Purchase the product in accordance with applicable campus procurement policies and procedures. If a
technology product meets the criteria as an exception or is not commercially available, determine and
document how to implement an alternative method of access to the information, should individuals with
disabilities need to use the product. For further questions about researching procurement of accessible IT
products, please contact ati@csus.edu. If you have questions about general procurement processes,
please contact Procurement at 278-7322.
4) Campus Email List Announcement: CSU ATI 508 Training - Scholarships
From: Repa, Melissa J.
Sent: Friday, January 04, 2008 11:43 AM
To: Repa, Melissa J.
Subject: [CAMPUS-IT] Announcement: CSU ATI 508 Training - Scholarships available for Sac State Staff
The Accessible Technology Initiative (ATI) Project at Sacramento State is offering a scholarship to
provide financial assistance for staff planning to attend the Accessible Technology Initiative Section 508
Procurement Training on February 14-15, 2008 in San Francisco. The scholarship covers the expense of
attending the ATI training, including registration, transportation, and two nights' lodging (up to $750 total
for each recipient). For more information about the ATI Section 508 Procurement Training, see the ATI
website: www.calstate.edu/accessibility/events/S508PT.shtml
The goals of the scholarship program are to offer staff members an opportunity to learn about accessible
information technology procurement and to encourage a strong institutional commitment to accessible
technology.
Criteria:
Scholarship candidates must work in an area involved in making IT purchasing decisions and/or
evaluating the accessibility of technology products (e.g. Information Technology consultants,
Procurement IT Buyers, Academic Technology Directors, etc.). Candidates must receive their
supervisor’s approval to attend the training.
To apply for the scholarship, candidates should submit a short e-mail (approximately 2 paragraphs)
outlining why attending the ATI Section 508 Procurement Training would be beneficial. Candidates’
supervisors should submit a brief statement of support via e-mail to Melissa Repa, Interim ATI Project
Coordinator, ati@csus.edu.
Successful candidates will be asked to share their experiences from the training by 1) reporting to the ATI
Steering Committee, 2) participating in the testing of a pilot accessible E&IT procurement process in
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conjunction with the ATI Accessible E&IT Procurement Subcommittee, and 3) sharing feedback for the
next ATI “Fast Facts for Accessibility” Newsletter.
Deadline for nominations for the ATI 508 Training scholarship is January 14, 2008. Candidates will
be notified by January 17 if selected for the scholarship (deadline to sign up for the CSU ATI training is
January 21).
5) Campus IT List Announcement: Understanding VPATs Webinar
-----Original Message----From: Repa, Melissa J.
Sent: Monday, March 17, 2008 10:30 AM
To: CAMPUS-IT-L@CSUS.EDU
Subject: [Campus-IT] Accessibility Webinar: Understanding VPATs
As you may know, the CSU is required to comply with Section 508 accessibility
standards for electronic and information technology (E&IT) products and
services that it buys, creates, uses and maintains (applies to E&IT purchases
above $2,500 starting Fall 2008)?
Any E&IT vendors who wish to do business with the CSU must provide
information about their product's conformance to applicable accessibility
standards via the Section 508 Evaluation Template, also known as the
Voluntary Product Accessibility Template (VPAT).
To help you learn about the VPAT, here's an upcoming event that you might be
interested in:
Title: Webinar on Understanding Voluntary Product Accessibility Templates
(VPAT)
Date: Th. March 20, 2008
Time: 10:00 AM to 12:00 PM
Location: Mendocino 2008
Description:
This webinar will cover the history and method for utilizing the Voluntary
Product Accessibility Template (VPAT). The course is targeted at IT,
procurement, or other staff/faculty who need to evaluate the accessibility of
a proposed IT product in order to ensure compliance with CSU accessibility
requirements. At the conclusion of the course the participants will
understand how to evaluate and utilize the information that is provided by
the vendor on the VPAT.
For more information, or to RSVP, contact ati@csus.edu.
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6)
ATI PROCUREMENT PROCESS SKIT – College ITCs meeting in January 2008:
(Adapted with permission from a skit created by Director of Procurement at SFSU).
Scene 1
(A conversation between a vendor and a Sacramento State employee – the Requester tasked with purchasing software)
Vendor:
Our Cat Pro 2000 software will revolutionize your online cataloging system. It will
simultaneously apply a hundred cross indexes to fifty teraquads of data. It returns
results via 27 multi-configurable filter modes. The enhanced user interface provides an
easily assimilated target matrix of possible values within a framework of limited or
delimited alternative search modalities. And, because Cat Pro wants to build its
customer base in the university market you are eligible for our best educational
discount, pricing our premier gold level package at only $39,000 for the first year’s
subscription.
Requester:
I gotta have some of that.
Scene 2
(A conversation between the Requester and a buyer in the Purchasing Department)
Buyer:
OK we’re under $50,000 and don’t need to put this out formal competition but we still
need to evaluate whether the product is compliant with 508 standards for accessibility
to persons with disabilities. This is all part of the CSU Accessible Technology Initiative
for electronic and information technology.
Requester:
Wait, I thought those requirements only applied to high dollar purchases.
Buyer:
That’s true. Formal ATI procedures are currently mandated for purchases over $50,000.
But the requirements will apply next year if you want to renew this license, so it makes
sense to find out now if there will be any problems.
Requester:
Well OK; how do I do that?
Buyer:
As a first step you should request your vendor submit a VPAT.
Requester:
A V-What?
Buyer:
A voluntary product accessibility template. The form and instructions are on the ATI
web site. You should also contact the Accessible Technology Initiative Project
Coordinator. She can help you or put you in touch with a campus technical advisor with
some specific expertise in this area.
Requester:
Thanks
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Scene 3
(A second conversation between the Requester and the Vendor)
Vendor:
A V-What?
Requestor:
It’s a form that we require. Here’s the link where you can download the form and
instructions. http://www.calstate.edu/Accessibility/EIT_Procurement/ I also talked to a
technical specialist on our campus who suggested that once you complete the form we
set up a meeting to look at your product and go over the form.
Vendor:
Great.
Scene 4
(A meeting that includes the Requester, the Vendor, the Buyer and the Technical
Specialist)
Tech Spec.:
Notice how certain data elements are not easily discernable by the screen reader
software. And on this radio button selection list, a blind user can not determine what
functions are being selected. These elements should be redesigned to accessible
alternatives.
Buyer:
I’ve spoken with colleagues at other campuses. There is at least one other competitive
product that meets accessibility standards. We can proceed with this contract for now,
but we’ll need to consider 508 requirements and alternative products before we can
renew next year.
Requestor:
Wait a minute. I may not want to invest in implementing this system if I’m just going to
have to change it next year.
Vendor:
These don’t seem like radical programming changes. We commit to our product
satisfying all Section 508 standards before next year.
Scene 5
(A conversation one year later between the Vendor, the Requester and the Buyer)
Vendor:
It’s interesting. Making the changes to incorporate accessibility seemed to improve the
overall product. The focus groups on the new release give it the highest ratings ever on
user interface and look and feel. And you’re right, our competitor was making many
sales based on pitching their product’s 508 compliance.
Requester:
Well, we’re ready to upgrade to your new compliant release.
Buyer:
And since Sacramento State was instrumental in improving your market standing, we’ll
be seeing a deep discount on this year’s license fee, right?
Vendor:
Uh…….
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7) Screen shot of Procurement and Contract Services web page, with EIT Procurement Checklist:
8) Screen shot of Accessibility - Procurement web page, with instructions:
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Appendix E: Equally Effective Alternate Access Discussion
In February 2008, a University Committee for Persons with Disabilities (UCPD) workgroup discussed the
following issues related to alternate access.
Procedures for providing equally effective alternative access for electronic and information
technology that are approved for exceptions to ATI accessibility requirements, cannot be made
accessible, or that are not yet subject to the ATI accessibility requirements:
1. A communications process with contact information for the articulation of access needs and
accessibility issues from student, members of the public and employees with disabilities
2. Protocol around 504/ADA accommodations, including the process for providing access to E&IT
resources
3. The responsibilities of the department (that has the inaccessible technology) in providing access to
either the technology or to the information resources provided by that technology (i.e. web
application)
4. A process for filing a complaint regarding accessibility
5. A feedback mechanism to evaluate the effectiveness of the solutions
University policies:





Academic Program Access For Students With Disabilities
Computer Laboratory Access, Self Instructional, For Students With Disabilities, Policy For
Disabilities, Committee For Persons With
Disability Accommodation Policy for Public Access to Campus Events
Disability Accommodation Procedure for Current Employees
Disability Accommodation Procedure for Applicants for Employment
Complaint Form Examples:
CSU Accessible Technology Complaint Form:
http://www.calstate.edu/Accessibility/EIT_Procurement/APPENDIX.H.ComplaintFormv2.doc
Description of Problem with Access to Electronic and Information Technology
1. Please provide a detailed description of the electronic and information technology product or
service that you have found to be inaccessible (web site address; location of system or
equipment; type of system or equipment)
2. Please provide a detailed description of the inaccessible features or functions, including exactly
what happens and does not happen.
3. Please provide the date of when you encountered the problem described above and the campus
location (room number) of where the problem occurred.
4. Please identify any assistive technology you use with this product or service, such as the name
and version of your screen reading software.
5. Please provide any other relevant information (i.e. suggestions for improvement.)
Alternative Means of Filing a Complaint: The campus will provide appropriate assistance to
complainants who may need assistance in filing their complaint, and will consider complaints filed in
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alternate forms. For example, a complainant with a disability may file a complaint electronically, by
audiotape, in Braille, or in some other format. Electronic complaints should be sent to: [Insert Email
Address]. Additionally, oral complaints will be considered if the complainant is unable to write and
cannot have someone write out the complaint for him or her. To file a complaint telephonically,
complainants should call [insert phone/TTY].
A Description of a Complaint Scenario:



A Sixty Plus program student with vision loss and hand tremors
Wants to access information that is posted to a university administrative website
The website was developed by a consultant who was hired to start work December 1, 2007
(Hint: The University "purchased" the services of a consultant to develop the website after the
ATI milestone date when all new administrative web pages must be accessible per Section 508
standards)
Sample Letter of Complaint for an Inaccessible Website
To whom it may concern:
Re: Information posted to www.csus.edu/___
On several occasions over the past year, I have tried to access the information that is posted on the
www.csus.edu/___ website. Unfortunately, as a retiree who is starting to feel the effects of aging (i.e.,
some vision loss and hand tremors), I have found that your website is not very accessible to me. I am
interested in working with you to make it more accessible to individuals with disabilities such as myself,
so all people can enjoy the convenience of web-based information.
Questions about this ATI Procurement Report for Year 2 can be addressed to ati@csus.edu.
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