ICT Use and Purchase Procedures
In accordance with the University’s Access to Programs, Services, Information, and Technology Policy Statement, the following purchase and use procedures have been implemented for Information and Communication Technologies (ICT).
With the exception of technology purchases intended for one individual’s sole use, all ICT purchases are required to be reviewed for compliance prior to procurement.
Note to purchasers: This procedure for purchasing ICT is required in order to assure that all products are accessible to individuals with disabilities. All applicable University purchasing policies must be adhered to Contracting Purchasing Services
Questions about determining the accessibility of a product should be directed to firstname.lastname@example.org.
I. Legal Requirements for Accessibility
Educational institutions receiving federal aid must provide resources for programs and services that individuals with disabilities can use to independently acquire the same information, engage in the same interactions, enjoy the same services within the same timeframe, and with substantially equivalent ease of use as individuals without disabilities.
Accessibility of programs and services to people with disabilities is considered a civil right in the United States. The Rehabilitation Act of 1973 was the first major legislation in the United States to require that the government and public support education that is accessible to people with disabilities. The Act mandates that Titles I and II of the Americans with Disabilities Act and the ADA Amendments Act reinforce that requirement for public entities including universities.
These laws do NOT require software developers, product manufacturers or vendors to make their products accessible or prevent them from attempting to sell inaccessible products to public entities. Therefore, the burden of compliance with the law is on the University to examine the products prior to purchasing and use and determine that they are indeed accessible, or that there is a plan in place to provide accommodation that will result in equally effective communication/access.
The University shall use the criteria of accessibility as part of its decision making process in purchasing web resources, software, electronic office equipment and computers. Purchasing priority is given to technologies that are accessible to all.
II. Summary of Process for Purchase and Use
- Determine if the product is accessible to individuals with disabilities, using the tools in this procedure. If a product will be used by only one person and if that person does not have a disability, you may submit the Accessibility Approval/Exceptions Request Form, identifying that the product will be used by only one person without a disability, and skip the rest of the steps.
- If it is not fully accessible, look for an accessible product that will meet your needs.
- Complete and submit an Accessibility Approval/Exceptions Request form, to the Accessible Technology Compliance Committee (“ATCC”) for permission to purchase or to obtain further instructions.
- Once you have received permission from the ATCC, you may proceed with the purchase if you have also complied with the University’s applicable Contracting and Purchasing policies (/Contracting-Purchasing-Services/).
As you are researching products, you can request accessibility information from a vendor in the following ways:
- Ask the vendor to provide you with a Voluntary Product Accessibility Template (“VPAT”) for the product/version.
- Ask the vendor to provide an accessibility statement, which should clearly indicate if the product is fully accessible, or complies with, Section 508 of the Rehabilitation Act, as amended, or, if web based content, conforms with WCAG 2.0 AA.
- Ask the vendor if they have third-party independent verification of the accessibility of their product. If one is available, ask for a copy.
If you have obtained a VPAT (Voluntary Product Accessibility Template) and it has sections that are labeled as “Supports with Exceptions” or “Not Supported,” then the product is not fully accessible and you should investigate other products which are fully accessible to meet your business needs.
If you are unable to acquire any information on the accessibility of the product, then you should look for another product which is fully accessible that meets your business needs. In the event that an accessible product is not available or the product which meets your business needs does not have a VPAT or a statement of accessibility, then an Accessibility Approval/Exceptions Request form should be fully completed, and submitted to the ATCC (read more about the exceptions request process).
If the product is fully accessible, provide the information (e.g. a URL to the accessibility statement or VPAT, or a copy of an email from the vendor stating that it is fully compliant) to email@example.com and request purchase approval.
If the product is not fully accessible, but an exception request has been approved, you should include an email from firstname.lastname@example.org with your requisition stating the approved exception.
This link provides additional guidance on working with different types of purchasing scenarios (pre-packaged products and working with or without sales representatives
This link provides additional guidance on determining accessibility, including terminology and best practices for reviewing products.
Once you have determined the best product for your business needs, complete and submit an Accessibility Approval/Exceptions Request form to email@example.com. If your product appears to be accessible, please be sure to attach all relevant documentation. If your product does not appear to be accessible, you will be required to prepare an Equally Effective Alternative Access Plan for review and approval as part of preparing the Accessibility Approval/Exceptions Request Form. All other information you need will be provided on the form and associated guidance document.
Once the form is received it will be reviewed for completeness and determined if it needs to be reviewed by the ATCC. If it needs to go to the ATCC, it will be sent to them and a final decision will be made in six business days following receipt. The requestor will be sent an email with the final decision. If the exception is granted, it is approved for two years.
You will not be allowed to complete the purchase until the Accessible Technology Compliance Committee has approved it.