Summary
Before you buy or start using certain types of digital products or services (or renew a contract for an existing product or service), we need to make sure it can be fully used by people with disabilities. You'll need to answer basic questions about the product or service, including how it will be used, and the vendor will be required to submit information about the accessibility of the product. We may need to conduct a review of the product or service and may ask the vendor for a remediation plan if there are issues. If you're requesting a new Canvas tool/LTI integration, the Learning Management Systems (LMS) Admin team at Information Services will take care of communicating with our team and with vendors for you. If you have any questions, just email the ADA/504 Coordinator, and they'll meet with you via Zoom to explain things and provide whatever help they can!
Frequently Asked Questions
Why is accessibility part of the process?
People with disabilities have the same right as people who do not have disabilities to access university services and products. Unfortunately, many products and services are not designed with accessibility in mind and can be difficult or even impossible for people with disabilities to use. To remedy this, the University requires that accessibility considerations be included in the procurement process. This approach is consistent with the University’s obligations under Title I and II of the Americans with Disabilities Act of 1990 and Section 504 of the Rehabilitation Act of 1973.
What if no one with a disability needs to use a product or service?
We will never know whether someone with a disability uses an accessible product or service. And that is the point of ensuring that products and services are accessible: the need to disclose a disability is eliminated. Most impairments and conditions are not apparent.
Also, please do not ask anyone whether they are disabled! If you have a legitimate reason to ask about accommodation needs, just ask whether anyone needs accommodations. And never ask why an accommodation is needed.
How do I start the accessibility review process?
If you've already submitted the procurement request to PCS, someone will reach out to you to provide you with instructions on next steps.
If you have not yet submitted the procurement request to PCS (or if you don't plan to go through PCS), submit a Request for Digital Accessibility Procurement Review or email the DAA. They'll let you know if they have any questions and will send you detailed instructions on what you need to do.
What information do I need to provide for the accessibility review?
Basic Product Information
First, we collect basic information about a product or service, how it will be used, and who will use it. Answers to these questions should be provided by someone who is knowledgeable about how the product or service will be used (typically, the person who will be using or deploying it, not just an administrator who submits purchase requests).
You will be given instructions and a form to complete when you start the process. You will find an example on the Collecting and Submitting Information page.
Questions for Vendors
We also need some information from vendors. The person or department procuring the product is responsible for sending appropriate forms to the vendor, which must be filled out by the vendor, not by UO staff. If the request is for a new Canvas tool/LTI integration, the Learning Management Systems (LMS) Admin team will communicate with the vendor. Details about what the form includes are provided on the Information for Vendors page.
How do we evaluate accessibility?
Compliance Reports (ACRs/VPATs)
For any existing product or service (i.e., something that isn't being custom-made for UO), we ask vendors to provide an Accessibility Conformance Report (ACR) using the VPAT.
The VPAT (Voluntary Product Accessibility Template) is a federal standard for disclosure of digital accessibility compliance, including details of any violations. It is important that vendors fill it out using the required accessibility standard (WCAG 2.1 AA), that it be current (because products change over time), and that it be complete (they may not skip any questions and they need to provide details of any degree of non-compliance). Ideally, we want an ACR that was filled out by a third party as third-party ACRs tend to be more reliable.
Product Evaluations
When we don't have a usable ACR or when we have a product that needs additional scrutiny (for example, a product that will be used by a large number of people or for a critical purpose), we'll want to conduct our own accessibility evaluation. Generally, we'll need to ask the vendor to provide access to a test account or demo system, and may also ask them to briefly meet with an evaluator to explain how the product is used.
An accessibility expert then conducts a high-level evaluation of the product against WCAG 2.1 AA standards and documents their findings. The evaluation is manual (i.e., not reliant on automated tools), and includes testing keyboard and screen reader functionality, color contrast, and a variety of other requirements, but isn't intended to be exhaustive or comprehensive. If problems are found, we send a list to the vendor and ask them to provide a remediation plan.
Remediation/Compliance Plans
If a product is not fully accessible a remediation plan is required. A remediation or compliance plan documents a vendor's plans for bringing a product or service into compliance with accessibility requirements. These plans include timelines for fixing any issues identified, so a vendor will typically need to check with their development team and project managers before they can provide one. An "Accessibility Statement" (a broad statement from a vendor that they value accessibility and are working on improving their products, but providing no concrete details) is not sufficient.
What if the product or service I want isn't fully accessible?
If a product or service doesn't meet digital accessibility standards right now, you may request an exception from the ADA/504 Coordinator. Factors that will be considered in deciding whether to grant an exception include who will be using the product/service, for what purpose, and whether accessible alternatives are available.
If an exception is granted, that does not eliminate the university's responsibility to ensure that people with disabilities can use it in the meantime. University departments are responsible for ensuring accommodations or alternative means of access are available to all users with disabilities.
What about custom products or services, like website and software development?
If you are having a vendor create something new (for example a new website, custom software, or deliverables like reports or videos), we need to include appropriate accessibility requirements in the contract language. We also may request that the scope of work be adjusted to include digital accessibility – if the vendor determines that it will take longer or be more expensive to ensure that the final product is accessible, that needs to be accounted for. Finally, in some instances, we may ask the vendor to provide examples of prior work that meets accessibility standards, so that we can be confident that they'll be able to deliver an accessible product.
What about new Canvas tools/LTI integrations?
New Canvas tools/LTI integrations must be accessible. The Learning Management Systems (LMS) Admin team is responsible for managing the implementation of external tools in Canvas at UO. When you request a new tool integration for Canvas (also called an "LTI") to add functionality, the LMS Admin team will work with the Digital Accessibility Architect and vendor to handle the process outlined on this page. The LMS Admin team may have questions for you, but they'll be your single point of contact and will take care of most things.
What if there isn't time for an accessibility review?
If you are worried about having enough time, the best thing to do is start the process early. You can submit a Request for Digital Accessibility Procurement Review to begin the process before you go to PCS, and if you start the process early enough, it can be completed before you start working with PCS, so that the accessibility review won't introduce any delays.
If you are just starting the procurement process for a product or service and it is critical that the contract be approved or renewed within two weeks, you can apply for an Emergency Exemption Deferral. Emergency exemption deferrals allow the procurement to move forward without the full accessibility review/exemption process being completed first, but the full process still needs to be followed after the contract is signed (according to a specific timeline and process). Please note that if multiple Emergency Exemption requests are submitted at the same, it may not be possible for all to be processed within two weeks. The Emergency Exemption should be the exception, not the rule.
What if I have questions or need help?
If you have questions about the accessibility review process, the ADA/504 Coordinator and Digital Accessibility Architect are here for you! While they will not complete forms for you, they can explain the process, answer questions, read over drafts and provide feedback, etc. Just send an email to eoa@uoregon.edu and tell them you'd like to discuss the procurement process – they're happy to meet with you via Zoom or Teams!