1. Creating a Culture of Access at Your Institution
Kirsten Behling, MA
Tufts University

2. The landscape right now
By in large most EIT in higher education is not accessible.
Students and lay people are taking note.
Students are threatening to go to the press if the issues are not resolved.
Lay people are filing civil rights suits with the Office of Civil Rights.
100+ suits just this year alone around web site accessibility
Focus on Admissions, Athletics, DS offices, Financial Aid

3. Advice from the Office of Civil Rights
Existing Content or Purchases  Pay immediate attention to front facing websites and EIT tools used
Institutions have between 18 months and 2 years to bring everything up to compliance
Institutions should put together a task force to determine high touch points to focus on
Some information can be “archived”
New Content or Purchases  Create a policy for any new content being posted or new EIT being purchased
The policy should be written, shared and used within 60 to 90 days of settlement
This policy must apply to all content developers and purchases
Notice of Content  Prioritize content as it is requested by people with disabilities.
Training around access needs: Online developers
Faculty
Students
Purchasing office

4. Proactive Steps Forward
Create a Taskforce
Create a Web Accessibility Policy
Create Procurement Policy
Begin looking at both in regards to what you currently have
Roll out your policies
Revisit and up-date your policies annually

5. Create a Taskforce OCR suggests….
Disability support personal (including Assistive Technologist if you have one)
General Counsel
Marketing/ Web Designers
Instructional/ Informational Technology
Influential Faculty Members
Online Learning Office
Take a minute and note who should be on your task force.

6. Create a Web Accessibility Policy
Use the WCAG 2.0 AA standards
Perceivable – Information and user interface components must be presentable to users in ways they can perceive.
Operable – User interface components and navigation must be operable.
Understandable – Information and the operation of user interface must be understandable.
Robust – Content must be robust enough that it can be interpreted reliably by a wide variety of user agents, including assistive technologies.
State what the policy encompasses (all websites, all websites purchased by the university, all websites that contain pertinent information to the university)
Address how archived content will be handled
Make sure it is publically available on your website

7. Example: Ohio State Website Accessibility Policy
“The creation and dissemination of knowledge is a defining characteristic of universities and is fundamental to The Ohio State University's mission. Ohio State is committed to ensuring equal access to information for all its constituencies. This policy establishes minimum standards for the accessibility of web based information and services considered necessary to meet this goal and ensure compliance with applicable state and federal regulations.”
Highlight the focus on the university’s mission.

8. Example: Ohio State Website Accessibility Policy
Ohio State’s Policy Details Requirements:
All new and redesigned web pages published by any college, department, program, or unit must be in compliance with the university Minimum Web Accessibility Standards (MWAS).
Legacy pages are subject to the standards in place at the time of their development and to the legacy page guidelines provided for in this policy.
Each university web site, including legacy pages, must indicate, in plain text, a method of contact for users having trouble accessing content within the site.
Upon a specific request for access by an individual with a disability, legacy pages must be updated to be in compliance with the MWAS or the content must otherwise be made available to any individual requesting access in a timely manner. Timeliness should be considered in the context of the type of information or service a page provides and generally within 10 business days.
Upon specific request for access, web sites and pages in archive status containing core administrative or academic information, official records, and similar information be must be made available/accessible to any individual eligible for and needing access to such web content, by revision or otherwise.”
Highlight the focus on the university’s mission.

9. Example: The University of Texas at Austin’s Website Accessibility Policy
1. Purpose
All Web applications and sites at The University of Texas at Austin must meet the statutory requirements in Texas Administrative Code Accessibility Standards (TAC ), which references the U.S. Section 508 standards.
2. Required Link
Each Web application or site must contain a link for "Web Accessibility Policy" that links to this policy.
3. Accessibility Coordinator
The university has a designated Accessibility Coordinator whose role is to monitor the university's compliance with accessibility policies and to facilitate training of Web publishers and developers to ensure all Web applications and sites are accessible.
The Accessibility Coordinator may grant written requests for exceptions to accessibility policies under appropriate circumstances.
Highlight governance with state laws
Highlight designated person to take this on
March 23, 2015

10. Take a moment to note the key factors in your web accessibility policy (whether it exists, is in draft form or needs to be written)

11. Create a Procurement Policy
Key components:
Language in the RFP process
Solicit accessibility information from the vendor
Validate that information
Make a determination of how to proceed 
Include accessibility assurances in contracts

12. Example: Tufts University RFP Language
“If the Services or Deliverables are for electronic and information technology, Supplier shall comply with the ADA by designing its Deliverables in a manner that supports assistive software or devices such as large print interfaces, text-to-speech output, voice activated input, refreshable braille displays, alternate keyboard or pointer interfaces, and by other means to ensure that end users with disability-related impairments have an equal opportunity to the use and enjoy the Deliverables in a manner consistent with the W3C Web Content Accessibility Guidelines. Supplier shall provide to Tufts a current completed Voluntary Product Accessibility Template (VPAT) to demonstrate compliance with the WCAG 2.0 level AA standards. If the Deliverables do not comply with the WCAG 2.0 level AA standards, Tufts reserves the right to terminate this Agreement, seek redress for harm incurred by end users and to adapt the Deliverables in order to comply with federal and state accessibility laws.”
Language in the RFP puts your intent for accessible materials out there from the beginning:

13. Solicit accessibility information from the vendor
VPATs
Voluntary!
Accessibility contact information
Vendor should fill out self-review form
Click on self-review form

14. Validate information provided
Secure a testing space within the software
Test the software using keyboard short cuts and screen reading software (Andrew shared these earlier)
Summarize the findings
Click on image to review

15. Determine how to proceed
Possible Outcomes:
Product is accessible and therefore compliant
Exception status
Exemption status

16. Products that meet compliance
Purchasing should be encouraged.
The product should be reevaluated annually, or anytime a new version is released or the contract is up for renewal.
Begin keeping a list of accessible products.

17. Exception Status
If the product is found to be inaccessible (in all or some areas), an exception may be granted.
If the university can ensure that SWD have access to the product through another means, or the university only uses the accessible areas of the product then a limited exception may be granted. The vendor must:
Develops a roadmap to compliance
Works with the university to identify an interim workaround solution
And demonstrates a good faith effort to address the identified standards barriers
Do all of this by a specified timeline
At the end of the time period, the University may terminate the contract if the product is still not accessible.

18. Exemption Status Exemptions are possible if:
The university made a good faith effort to find an accessible product
Any accessible products fundamentally alter the program or program standards
Any accessible products create an undue burden

19. University of Montana
2012 OCR complaint that EIT was not accessible. In response:
UM formed the EITA Task Force to draft a UM policy and coordinate necessary support activities.
Developed a policy about Electronic and Information Technology
Provided accessibility training for faculty and staff
Created a process of self-study and implementation

20. Example: Oregon State University Policy
Part I. Introduction – why this is important (aligns with mission), policy will be phased in
Part II. Policy statement – what it is, who it applies to, possible exemptions, date it goes into effect
Part III. Parties responsible for implementing the policy
Part IV. Compliance
Part V. Definitions
Part VI. Additional contacts

21. Example: University of Washington
Procuring Accessible IT Steps:
Solicit accessibility information.
Have a third part evaluate the product
Ask the vendor to complete U. Washington’s checklist
Ask for a VPAT
Validate accessibility information received.
Check the vendor’s self-report
Include accessibility assurances in contracts.
Include language that assures continued accessibility as the product is updated.

22. Roll-Out Plan How do you get it adopted?
Gather critical people, come with a drafted proposed process.
Know your school demographics
Know the law, just in case
Who needs to know?
Those who purchase, the purchasing office, vendors
How do you make it known?
Presentations to department heads (faculty and staff)
Notice on your website (DS, IT, Purchasing)
Workshops on how to test – Train-the-trainer model
Embedded in all purchasing contract checks, like security
Writing a process is one thing, but getting it adopted and used is another.

23. What is your roll out plan?
Take a minute and jot down some ideas