In compliance with Section 508 of the Rehabilitation Act of 1973 and the Illinois Information Technology Accessibility Act (IITAA), Information and Communications Technology (ICT) products and services that the University buys, creates, uses, and maintains must either conform to the technical and functional requirements of federal and state law, as outlined in the Minimum Digital Accessibility Standards (MDAS), or have an approved exception.
When the university must procure ICT products that cannot be considered accessible, federal and state law requires organizations to document and implement an equally effective alternative method of access that will mitigate the access barriers presented by the inaccessible digital product or service. The alternative access provided must be appropriate for the needs of those with disabilities who might use the ICT and must allow for substantially equivalent efficiency, engagement, and inclusiveness. The documentation of the alternative method of access is referred to as an Alternative Access Plan (AAP) or an Equally Effective Alternative Access Plan (EEAP).
Remember the Three E's of Accessibility
In order to be considered accessible, an ICT product or the alternative method for access must have the following three characteristics:
- Equally Integrated – Providing similarly inclusive experience and access
- Equally Effective – Providing equal opportunity or outcome
- Equivalent Ease of Use – Providing access that is not substantially more difficult for users with a disability
An alternative access plan must incorporate the Three E's in order to be considered to meet the needs of those with disabilities. Individuals must not be made to disclose their disability in order to utilize the alternative method of access. To maintain the standards of inclusiveness and timeliness, the alternative method of access should be made available in a way that individuals do not need to request the access.
Functional Accessibility Requirements
An effective alternative access plan must mitigate any access barriers in an ICT that would prevent access for or negatively impact the following interaction modalities:
- Without vision or with limited vision, where a visual mode of operation is provided
- Without perception of color, where a visual mode of operation is provided
- Without hearing or with limited hearing, where an audible mode of operation is provided
- Without speech, where speech is used for input, control, or operation
- With limited manipulation, reach, and strength, where a manual mode of operation is provided
- With limited language, cognitive, and learning abilities; making the operation of the ICT easier for individuals with limited cognitive, language, and learning abilities
For each affected modalities, consider what alternative access would be provided for someone who could not use the ICT.
Components of an Alternative Action Plan
An effective AAP will have the following components:
- The name and contact information of the plan originator and originating unit
- A brief description of the ICT product
- The scope and intended use of the ICT product, to loosely quantify the level of potential impact that the accessibility flaws in the product may have
- A brief overview of the access barriers in the product, including:
- The common disability types that will be adversely impacted
- The extent of the access barrier, i.e., users who are blind cannot utilize the product
- A description of the alternative method of access that will be provided
- How the alternative access will be systematically communicated to those who may need it
- Any notes for special consideration, such as use limitations that those who wish to utilize the ICT product should be aware of
- An alternative access plan is required documentation of the method of alternative access that will be provided. The plan itself must not be confused with actually implementing and providing the alternative access.
- In most instances, the unit that is procuring an ICT product will be responsible for maintaining the alternative access plan and reviewing it for effectiveness.
- For unit and campus wide ICT services, this duty would fall on the service management team.
- An equally effective method of alternative access will not require an individual to disclose their disability and, where possible, will not require an individual to request the alternative access.
- Remember the Three E's of accessibility!
Alternative Access Plan Template
Download the AAP template to aid you in documenting your alternative access plan.
Contact Keith Hays, the ADA IT Coordinator, if you have questions regarding alternative access and the creation of AAPs.