The procurement of accessible Information and Communications Technology (ICT) products and services requires mindful and proactive processes that incorporate federal and state accessibility standards. The ICT Accessibility Policy (CAM HR-86) was put in place to assist our accessibility compliance efforts, and accessible procurement is one area covered under the policy.
Legal and Policy Requirements
- All ICT procured by the university must meet the technical and functional criteria of federal and state law, as outlined in the Minimum Digital Accessibility Standards (MDAS) of the ICT Accessibility Policy, or receive an approved exception for use from the Technology Accessibility Review Committee (TARC).
- All ICT must be evaluated for accessibility conformance prior to use. The level of evaluation needed will change depending on the scope of use. For example, ICT to be utilized for unit or system-wide use would require a full, formal evaluation, and ICT to be used by a small research group or a couple of university employees may only require a quick, non-technical check.
- An accessibility evaluation is also required prior to requesting an accessibility exception from the TARC.
- For web-based ICT, accessibility must be supported in all commonly used web browsers and with a variety of assistive technologies. See the MDAS for specifics.
- In the event that an ICT must be procured that would not be considered accessible under the MDAS:
- Per federal and state law, the most accessible ICT that meets business needs must be the product chosen.
- Inaccessible ICT must not be used unless it has received an approved accessibility exception.
An Important Note About Procurement Budgets
Despite our best efforts, we may receive an Office of Civil Rights (OCR) complaint regarding ICT in use on campus, especially in the realm of system-wide and classroom technologies. During an OCR investigation, our ability to procure accessible ICT is examined in light of the resources available to the entire university system. This means that project and department level budgets constraints are normally not considered a substantive barrier to procuring and utilizing accessible ICT. Be aware of this when there is a need to choose between partially accessible ICT products or services.
Five Steps to Accessible Procurement
There are five basic steps that are a part of any robust accessible procurement process on campus:
- Adopt explicit accessibility requirements
- Evaluate for accessibility before final product selection and contracting
- Include unambiguous accessibility language in vendor contracts
- Document market research and create an alternative access plan if a procured product will not be accessible
- Request a policy exception if accessibility flaws are present in the ICT