Procurement of Accessible ICT The Procurement Process Sharon Trerise & Kara Patten

Topics IT accessibility – The Legal Perspective IT accessibility – The User’s Perspective Evaluating your website for accessibility Intro to screen readers Mobile applications How IT Accessibility fits into the Procurement Process VPATs and other questions for vendors Accessibility evaluation of your application

Where should we engage accessibility in the procurement process? AT THE BEGINNING!

ICT Accessibility Procurement Process diagram Text version Purchaser selects a product and contacts the vendor Purchaser gathers information from the vendor: See the list of vendor pre-purchase questions Request a VPAT Fill out Part A of the ICT Accessibility Procurement Form Accessibility evaluator starts the accessibility assessment Did the vendor provide a VPAT? If so, Evaluate the VPAT (see Tips for Evaluating a VPAT) Does the VPAT provide enough information to make a judgment about accessibility? If so, does the product comply with accessibility criteria? If so, proceed with purchase If not, ask vendor for a demo version or trial account to perform an in-house accessibility evaluation Conduct a manual accessibility evaluation. Report findings using Part B of the ICT Accessibility Procurement Form Did the Manual Evaluation show that the product does comply with accessibility criteria? If so, proceed with purchase. If the VPAT shows that the product does not comply with accessibility criteria OR the manual evaluation shows that the product does not comply with accessibility criteria Evaluate the impact of the product's accessibility on the University (See the list of impact considerations) If it is determined to have a low impact on the University,  submit Parts A and B of the ICT Accessibility Procurement Form to the ICT Accessibility Compliance Committee If the ICT Accessibility Compliance Committee approves the product, proceed with purchase If the ICT Accessibility Compliance Committee does not approve the product, look at other products and follow the procurement process from the top. If it is determined that the accessibility of the product will have a high impact on the University, Request an Exception by completing Part C of the ICT Accessibility Procurement Form and submit it to the ICT Accessibility Compliance Committee If the Exception was approved by the ICT Accessibility Compliance Committee, proceed with the purchase If the Exception was not approved by the ICT Accessibility Compliance Committee, look at other products and follow the procurement process from the top.

1. Fill out Procurement Form, Part A Can be completed by purchaser Requester information Requester’s name, department & contact info Date response requested Product information Type of product Function of product Who will use product by role? Is the product required for academic or work purposes? Is the product already in use at SU?

2. Ask vendor about Accessibility Do they understand and comply with accessibility guidelines (Section 508 or WCAG 2.0 AA) Is a VPAT available? If so, ask for a copy. What is their process for testing accessibility? Do they test with actual users with different disabilities? Have they tested with any assistive technologies? Which ones? Do they have staff that specialize in accessibility? If product is not accessible, do they have a roadmap for improvement? If so, ask for a copy. Who to contact if product is found to have accessibility problems?

VPAT Voluntary Product Accessibility Template Created by the Information Technology Industry Council & General Services Administration for government procurement Version 1.0 – conformance with Section 508 accessibility standards Version 2.0 Beta – conformance with WCAG 2.0 guidelines Format Criteria Conformance Level Remarks & Explanations – known issues or workarounds

VPAT: Conformance levels Supports: The functionality of the product has at least one method that meets the criteria without known defects or meets with equivalent facilitation. Supports with Exceptions: Some functionality of the product does not meet the criteria. Does Not Support: Majority of functionality of the product does not meet the criteria. Not Applicable: The criteria are not relevant to the product. Not Evaluated (Limited to WCAG 2.0 Level AAA): The product has not been evaluated against the criteria. This can be used only with WCAG 2.0 Level AAA.

VPATs Know the difference between a truthful and fictitious VPAT “vendors tend to fall into three categories, according to Jackson: The first doesn't know much about accessibility at all; the second knows a little but tries to pull the wool over your eyes; and the third is knowledgeable and highly engaged. "It requires technical know-how to ferret out which [category] they fall into and how far you can trust the statements they are making,” he said.” from Building Accessibility into IT Procurement

3. Does the VPAT look reliable? Characteristics of a reliable VPAT The salesperson knows what a VPAT is VPAT was completed by a 3rd party rather than the product vendor Every criteria is not “Supported” It is dated within the last year or two There are Remarks and Explanations Real examples are provided Testing procedures are referenced The vendor has a reputation / history of dedicating resources to accessibility, e.g. Microsoft, Google, Blackboard

4. Ask vendor for a demo version Most vendors want to provide a canned demo – never good enough Sales staff don’t know about accessibility Hands-on testing is more informative Make sure it is the current version

5. Conduct a manual accessibility evaluation How precise do we need to be? Complete WCAG 2.0 AA testing? – probably not Enough to determine: Are there any “show stoppers” – inaccessible features that would prevent users from completing the primary functions What audiences will be effected by the accessibility issues found

Show stoppers - examples Can’t perform major functions using keyboard only Keyboard trap Can’t operate controls on critical videos Critical videos are not captioned Can’t perform major functions using screen reader E.g. items in drop-down list are not read by screen reader Form fields are not labeled Contrast between text and background is poor throughout and cannot be changed through OS

6. Gauge the potential impact of accessibility issues Will the product be used by a large number of people? Will access to a University program or service be denied? Are there workarounds to the accessibility barriers? Will a critical program or service be impacted? Will the use create significant legal exposure? Will the cost of providing accommodations (alternate access) be high?

6. Complete Procurement Form, Part B Product information Vendor & contact info Product name & version Accessibility Evaluation VPAT Results of Manual Accessibility Evaluation if done What’s next? What is the potential impact of an inaccessible product? What are the vendor’s plans for fixing accessibility issues? If moving forward with an inaccessible product, what is the justification?

7. Request an Exception to the Policy Exception Categories Commercial non-availability Required by governing body Restricted access to the technology Fundamental alteration to the nature of the product Undue burden Explain

8. Develop a Plan to provide equally effective alternate access to affected populations Who will be responsible for implementing the plan when needed? What are the details of the plan? What resources are required to implement the plan?

9. ICT Accessibility Compliance Committee reviews Exception Request Membership Co-chairs: CIO, ADA Coordinator faculty and student representation from schools and colleges Academic Affairs Division of Enrollment and Student Experience Equal Opportunity Inclusion and Resolution Services Human Resources Information Technology Services Office of Marketing and Communications Office of Disability Services Office of University Counsel Purchasing Department SU Libraries

10. Proceed with purchase or look at other products

Resources Information and Communication Technology (ICT) Accessibility Toolkit webAIM.org Tips for Getting Started with Web Accessibility, W3C