Accessibility Coordinators are responsible for working with their units to create detailed work procedures to implement the Implement/Upgrade process and ensuring faculty and staff follow the process.
Each unit will use its Implement/Upgrade process to ensure their unit performs accessibility assessments (and/or evaluations) before implementing or upgrading new digital products. This requirement includes significant upgrades or changes in functionality, similar to the requirements of Security Assessments currently needed for new products.
Updated Definitions -- Waiver vs. Exception
During Training Session 3, many Coordinators requested clarification regarding when they should pursue a waiver of the Full Manual Testing requirement, and when they should ask for an accommodation-based exception. DAS discussed this with the ADA Coordinator's Office and we've arrived at the following definitions for waivers and exceptions:
- Waiver -- You can request a waiver when you believe a digital product is accessible and there is signficant evidence to support that belief.
- Exception -- When you know or suspect that a product is not accessible and are willing to agree to the most rigorous accommodation, you can go directly to the exception process without hiring a vendor to perform the full manual evaluation.
Proposed Process and Tools
- Identify Need
- Complete Checklist
- Accessibility Risk Definitions – We’ll be using a Risk Management Approach to prioritize our accessibility work
- Implement/Upgrade Framework – Outlines the actions and artifacts that will be required
- Accessibility Evaluation Checklist – Potential starting point for creation of Work Procedures for your area. Resources for various procedures performed throughout the Checklist are linked, below.
- VPAT Review Guidelines
- Sample VPATs
- Quick Test Guidelines
- Quick Test Evaluation Template
- Full Manual Evaluation Guidelines
- Hiring a Vendor Guidelines
- Approved Accessibility Evaluation Vendors -- Contact Information
- Ohio State Purchasing Office Website
- Accessibility Evaluation Minimum Standards
- Accessibility Evaluation Template Instructions -- Instructions to vendors regarding how to fill out the template
- Accessibility Evaluation Template -- To send to vendors for estimates and evaluations
- Sample Estimate Request -- To use as an example of how to fill out the Accessibility Evaluation Template to request an estimate from a vendor
- Accessibility Evaluation Results List -- List of new products that have been evaluated for accessibility
- OCIO ODEE ES Accessibility Evaluation Checklist -- Provided as a sample for Coordinators' reference regarding customization of work procedures for units
- Michigan State's Evaluation Protocol for WCAG 2.0 AA -- Approved testing protocol for in-house/OSU-branded builds that developers can use to test for and document accessibility instead of completing a VPAT. (To be completed before performing the Full Manual Evaluation.)
- Implement Accessible Product – or have approved exception
- Doing Business with Ohio State - Digital Accessibility -- Informational one-sheet units can provide to vendors to notify them of university's digital accessibility requirements.
- Sample Contract Language -- Sample language units can use to negotiate for accessibility-related terms in contracts for higher-risk (A3/A4) digital software and applications.
- Proposed Standard Purchase Order Terms -- Accessibility-related terms being proposed for addition tp the university's standard purchase order terms. (Still working through approval process).
- ADA Exception Tracking System -- to submit accommodation-based exception requests
- Accommodation Options for Inaccessible Products -- Potential options units can tailor to assist them in developing appropriate accommodations for users requesting access to inaccessible digital software, websites, and applications.
Accessibility Coordinators are required to include the following information related to the Implement/Upgrade process in their Annual Digital Accessibility Report and Plan:
- Work Procedures
- Include local controls to ensure process followed
- Submit to DAC for approval no later than 8/15/19
- Percent of software assessed before purchase
- Compare number of assessments to count of software purchased
- Number of exceptions granted
- Query information from Exception Tracking System
Long Term Audit Requirements
While units are not required to submit the various artifacts required for product approval as part of the university’s Implement/Upgrade process, they are required to save relevant documentation for audit purposes. Examples of documentation that should be saved as part of this process includes VPATs submitted by vendors; unit’s review of submitted VPATs; Quick Test results; Full Manual Evaluation results; etc.
Think of this process as similar to doing your taxes each year. You are only required to submit your 1040, but you have to save backup documentation for the IRS in case you are audited and need to show proof that you were authorized to take certain deductions.