EITA Policy and Procedures

Policy

The University of Montana provides equal opportunity to its educational and administrative services, programs, and activities in accordance with federal and state law. This policy extends to the University’s electronic and information technologies and applies to their procurement, development, implementation and ongoing maintenance.

Ensuring equal and effective electronic and information technology access is the responsibility of all University administrators, faculty, and staff.

This is in accordance with federal and state laws including the Americans with Disabilities Act of 1990 (ADA), and the Amendments Act of 2008, and Section 504 of the Rehabilitation Act of 1973, Section 508 of the 1973 Rehabilitation Act as amended, and Title 18, Chapter 5, Part 603, and Title 18-5-604 and 49 of the Montana Code Annotated.

Procedures

Purpose

The purpose of these procedures is to provide processes by which University administrators, faculty, and staff will create, obtain and maintain all electronic and information technology (EIT) in a manner that ensures that EIT is accessible to individuals with disabilities.  

These procedures apply to the following areas:

Definitions

"Accessible” means that individuals with disabilities are able to independently acquire the same information, engage in the same interactions, and enjoy the same services within the same timeframe as individuals without disabilities, with substantially equivalent ease of use.

“Disability” means a physical or mental impairment that substantially limits one or more major life activities.

“Electronic and information technology" or "EIT" includes information technology and any equipment or interconnected system or subsystem of equipment that is used in the creation, conversion, or duplication of data or information. The term electronic and information technology includes, but is not limited to, the internet and intranet websites, content delivered in digital form, electronic books and electronic book reading systems, search engines and databases, learning management systems, classroom technology and multimedia, personal response systems ("clickers"), and office equipment such as classroom podiums, copiers and fax machines.  It also includes any equipment or interconnected system or subsystem of equipment that is used in the automatic acquisition, creation, storage, manipulation, management, movement, control, display, switching, interchange, transmission, or reception of data or information.  This term includes telecommunication products (such as telephones), information kiosks, Automated Teller Machines (ATMs) transaction machines, computers, ancillary equipment, software, firmware and similar procedures, services (including support services), and related resources.

Equally effective” means that the alternative format or medium communicates the same information in as timely a fashion as does the original format or medium.

“Legacy websites” are University Program and Department websites published before July 30, 2013. 

1. Web Accessibility

1.1 Scope

These procedures apply to all University Web pages and programs used to conduct University business and activities including web resources used in courses.

1.2 Standards                                                                                                                      

All web pages, websites and web-based software published, hosted or used (including remotely hosted sites and software) by the University will meet the standards and guidelines outlined in the Web Content Accessibility Guidelines (WCAG) 2.0 (http://www.w3.org/TR/wcag2ict/) published by the W3C as follows.  All pages will meet Level AA guidelines with limited exceptions outlined at Exhibit A.  All University websites, unless technically impossible, will link to the University’s main Accessibility page which includes a statement of commitment to Web accessibility. 

1.3 Responsibility

All Departments and programs:

  • Will comply with the web accessibility standards when creating web content, sites, and programs. 
  • Will ensure that online activities are hosted in accessible environments and that online content follows standards outlined by this policy.

IT (central, distributed & UMOnline):

  • Will provide instruction and support for campus community members creating UM websites and content so that individuals who author web content can be trained according to these standards.

IT (central):

  • Will ensure that any Content Management System and other web production or web object creation software proposed and supported by central IT will be accessible and will produce accessible Web pages.

IT (distributed):

  • Will ensure that support is available for distributed IT staff for creating accessible UM websites and content.

EITA Coordinator and Working Group:

  • Will coordinate instruction and support for campus community members creating UM websites and content so that individuals who author web content will do so in accordance with WCAG 2 Guidelines AA Standards.
  • Will compile and maintain data to track compliance with the policy and procedures and make recommendations for addressing problems.

1.4 Implementation Schedule Summary[i]

  • By May 16, 2014, the University will identify a strategy to ensure that webpages that provide essential student functions are accessible.
  • By December 31, 2014, all University Program and Department websites, including legacy pages, unless technically impossible, will contain a clear statement (or a link to a statement) describing the University’s commitment to web accessibility and a method to report barriers and/or to receive an alternative equally effective accessible format.
  • By December 31, 2014, all webpages published or hosted by the University on or after July 30, 2013, will be accessible according to W CAG 2.0 Level AA standard.
  • Upon a specific request for access by an individual with a disability, the University will  update legacy pages to be in compliance with the WCAG 2.0 Level AA standard, as set forth in Appendix A to this Agreement, or the University will otherwise make the content available to the individual in a timely manner and in an equally effective accessible format.

(return to the start of Procedures)

2. Instructional Materials Accessibility

2.1 Scope

These procedures apply to all electronic instructional materials (syllabi, textbooks, presentations, handouts, etc.).  This includes electronic instructional materials delivered within the University’s learning management system, in face-to-face classes, or in an alternate fashion (email, blogs, etc.) and electronic instructional activities (online collaborative writing, web conferencing, etc.). 

2.2 Standards

All electronic instructional materials, optional and required, will be accessible and as effective and useable for persons with disabilities as they are for persons without disabilities. Instructional materials and activities will be made available to all students at the same time.

All instructional materials must meet all applicable standards and guidelines outlined in this policy.

2.3 Responsibility

All Departments and programs:

  • Will ensure that instructional materials comply with all requirements outlined in these procedures.
  • Will ensure that departmentally owned classrooms use and deliver accessible electronic and information technology.
  • Will ensure that all departmental computer labs provided for student use will have assistive technologies not limited too but including accessible computer stations, screen reading software, and screen magnification.
  • Will ensure that all applications developed on campus (web, desktop, etc.) are accessible according to principles of WCAG 2.0 AA level, WAI-Aria 1.0, and ATAG 2.0  standards (extrapolated as needed for non-web environments).

Faculty and instructional staff:

  • Will create and present accessible courses and instructional material.

UMOnline:

  • Will provide instruction and support for campus community members creating online courses and online instructional content.
  • Will facilitate hosting of online activities in an accessible learning management system and related hosted systems (such as web conferencing) that are accessible.

IT (central & distributed):

  • Will use only accessible electronic and information technology in IT-designed and supported Technology Classrooms.
  • Will monitor informational IT-web pages and implement the EITA-recommended lab software and procedures found on those pages.

IT (Central):

  • Will coordinate support for distributed IT and campus units needing assistance with accessibility in departmentally supported technology classrooms.
  • Will serve as a clearing house for information about assistive technology and modifications recommended for departmental computer labs.

Mansfield Library:

  • Will maintain an accessible website and implement an accessible search engine that can search across all library collections, including, but not limited to e-journals, databases, and e-books. .
  • Will conduct monthly accessibility scans to ascertain whether any posted content is inaccessible. The Library will notify content authors if corrections to pages are needed and of reasonable timelines for corrections to be made. The Library will note if corrective action has been taken during the next monthly scan.

EITA Coordinator and Working Group:

  • Will compile and maintain data to track compliance with the policy and procedures and make recommendations for addressing problems.

2.4 Implementation Schedule Summary[i]

  • By March 14, 2014, the two accessibility issues related to the University’s learning management systems cited in the OCR Complaint (chat and forums) will be resolved. 
  • By March 14, 2014, the University will identify its strategy to ensure the ongoing accessibility of its learning management systems.
  • By March 14, 2014, the University’s library website will be accessible in accordance with WCAG 2.0 Level AA standard, as set forth in Appendix A of the Resolution Agreement.  
  • By May 1, 2014, the University will implement a program to provide information, education, and support for ensuring that EIT used in classrooms (including, but not limited to, clickers, podiums, blogs, and other software) is accessible.
  • By July 1, 2014, the Mansfield Library will implement a search engine that is accessible in accordance with WCAG 2.0 Level AA standard, as set forth in Appendix A to this Agreement, which can search across all library collections, including, but not limited to, e-journals, databases, and e-books.
  • By January 26, 2015: Campus labs will meet EITA recommended installations and procedures listed on IT web pages.

(return to the start of Procedures)

3. Document Accessibility

3.1 Scope

These procedures apply to all University-produced and maintained or distributed electronic documents.  Electronic documents include, but are not limited to, word processing documents, PDFs, presentations, publications and spreadsheets which are scanned, uploaded, posted, or otherwise published or distributed electronically.  Legacy documents must be made accessible when used.

3.2 Standards

Electronic documents must be accessible.  Electronic interaction with University policies, procedures, notifications and other documents must be as effective and useable for persons with disabilities as it is for persons without disabilities.

Accessible electronic document types are listed on the UM Accessibility website.

Electronic documents must meet the standards and guidelines outlined in the Guidance on Applying WCAG 2.0 to Non-Web Information and Communications Technologies, published by the W3C as the Working Draft 13 December 2012.

3.3 Responsibility

All Departments and programs/University employees:

  • Will follow the accessibility requirements outlined in these procedures when creating and using electronic documents. 
  • Will provide accessible document instruction and support for campus community members.

IT/UMOnline/Mansfield Library:

The Mansfield Library will implement procedures for ensuring that materials digitized or hosted by the library for research purposes are accessible to individuals with disabilities.”

EITA Coordinator and Working Group:

  • Will compile and maintain data to track compliance with these procedures and make recommendations for addressing problems.
  • Will work with central and distributed IT, DSS, Mansfield Library and UMOnline to coordinate campus-wide PDF solutions.

3.4 Implementation Plan Summary[i]

  • By December 31, 2014: All straight-text documents (including  PDF, Word, Excel and Powerpoint files) will be accessible.
  • By August 25, 2014: Create a working group to address: 1) accessible scientific and mathematical documents and 2) accessible documents from campus publications such as the Montanan, Montana Business Quarterly, etc.
  • By December 15, 2014: Strategies developed for producing accessible scientific and mathematical documents and accessible documents from publications.
  • By January 20, 2015: Create a working group to address epub/edupub possibilities, production and purchase.
  • By May 15, 2015: Strategy developed on UM’s integration of epub/edupub processes.

(return to the start of Procedures)

4. Electronic Media Accessibility

All departments will purchase and produce only accessible multimedia and update existing inaccessible media as it is put into use.

4.1 Scope

All media resources used in University programs and activities must be accessible. For example, this includes, but is not limited to, media that is instructional, informational, marketing, and promotional.

4.2 Standards

Video media resources will be closed captioned and audio-described and audio resources will be transcribed.

4.3 Responsibility

All departments, programs, instructors and employees:

  • Will purchase only captioned versions of audiovisual media whenever possible.  Will ensure that all other media that will be used on the web or in instruction is captioned.
  • Will purchase only transcribed audio and audio-described versions of audiovisual media whenever possible.
  • Will update any non-transcribed audio and any non-captioned/non-described video that is in current use.
  • Will use only transcribed audio and closed-captioned media with audio-descriptions that are made available in a timely manner to the class and will only assign such media as course material, whether optional or required.

Mansfield Library:

  • Will maintain a library of transcribed audio and captioned video resources that are available for faculty, staff, and student use.
  • Will maintain a record of commercial availability of copyrighted media resources.
  • Will assist faculty identify materials that are captioned prior to purchase.

UMOnline:

  • Will incorporate captioning and media accessibility information into training.

Central IT:

  • Will ensure all classroom and presentation equipment is caption-compatible and the default on all TVs, etc.
  • Will maintain and continue to provide instructions on media accessibility (such as captioning and audio-describing media and transcribing audio) as well as how to show captioned media in classrooms.
  • Will incorporate into faculty training on AV equipment information about accessibility.

University Relations:

  • Will produce only new communications and promotional materials that are captioned, audio-described or transcribed.

EITA Coordinator and Working Group:

  • Will coordinate campus-wide captioning and transcribing solutions that:
    • Provide assistance with obtaining permission to caption and audio-describe.
    • Disseminate information to the University community about university protocols related to accessible electronic media including a list of approved vendors to perform captioning.

4.4 Implementation Schedule Summary[i]

  • By January 26, 2015: All videos (professionally or internally produced) used in courses and shared on campus websites or video storage sites (such as Youtube and Vimeo, etc.) will be captioned according to recommended Described and Captioned Media Program (DCMP)standards.
  • By January 26, 2015: Students may request that recordings of course sessions and presentations created for and during a course, and in use only during that course, be captioned.
  • By Fall 2016:  Assess Audio Description availability and create a plan toward audio description standards and for use on campus.   Audio Description videos will be acquired and created when technology permits.

(return to the start of Procedures)

5. Software, Hardware and Systems Accessibility

5.1 Scope

All software, hardware and systems purchased must be accessible and must produce accessible products.  Accessible, in this context, means compatible with assistive technology.   Examples of software, hardware and systems include, but are not limited to, learning and content management systems, library and email systems, and administrative management systems such as finance, registration and human resources, and all software, hardware and software services used for student services.  Software includes freeware, shareware, desktop, enterprise, subscription and remotely-hosted options.  Software that is accessed through a web-browser must also be accessible and is discussed under Section 1 of these procedures.

5.2 Standards

The University of Montana will use the following standards to determine accessibility:

US Access Board’s Guide 508 Standards - Software Applications and Operating Systems

All Departments and programs/University employees:

  • Will ensure that their software, hardware, local interfaces and modifications and electronic systems are accessible.
  • Will ensure that all applications developed on campus (web, desktop, etc.) are accessible according to principles of WCAG 2.0, WAI-Aria 1.0, and ATAG 2.0  standards (extrapolated as needed for non-web environments).

IT (central and distributed):

  • Will ensure that assistive technologies are immediately available to students working in campus labs or on publically-accessed campus computers.
  • Will ensure that assistive technologies are available in a timely manner for campus employees including student employees.

EITA Coordinator and Working Group:

  • Will coordinate campus processes for ensuring campus software, hardware and software system accessibility.

5.4a Software Implementation Schedule Summary[i]

  • By May 1, 2014:  Institute processes for purchase of only accessible EITs, except when it would fundamentally alter a program or when it is not technically feasible to do so and in such case the process will require the University to provide accessible alternate EITs.

5.4b Hardware Implementation Schedule Summary[i]

  • By January 26, 2015:  Reading systems and software that are used for textbook delivery should meet these guidelines: http://www.daisy.org/accessibility-screening-methodology-guidelines-and-checklist.html.
  • By January 26, 2015: Campus scanners will have an OCR profile/option.
  • By January 26, 2015: Accessible clickers will be selected.
  • By the start of spring 2015: Develop a strategy for review of academic and other hardware with the intent that only hardware with accessible options should be selected for use in academic courses and campus activities including such things as door swipes and educational technology.

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6. Procurement

6.1 Scope

This process applies to all University purchases of Electronic and Information Technology (EIT) software, hardware and services.

6.2 Standards

Purchase orders and contracts for EIT must include the following clause:

“Contractor acknowledges that no University funds may be expended for the purchase of information technology equipment and software for use by employees, program participants, or members of the public unless it provides blind or visually impaired individuals with access, including interactive use of the equipment and services, that is equivalent to that provided to individuals who are not blind or visually impaired. (18-5-603, MCA.) In addition, Contractor acknowledges that such information technology equipment and software will provide equal and effective access to all individuals in accordance with federal and state laws and regulations, including, but not limited to the Americans with Disabilities Act of 1990 (ADA), Section 504 of the Rehabilitation Act of 1973, and Section 508 of the 1973 Rehabilitation Act.”

6.3 Responsibility

All Departments and programs/University employees:

  • Must purchase or otherwise acquire accessible EIT, in accordance with these procedures.

EITA Coordinator and Working Group:

  • Will serve as a resource for EIT purchases and other acquisitions for compliance with accessibility requirements.
  • Will provide written justification for all provisional use waivers and post such waivers on the accessibility website.  Will provide requests for exceptions to the University ADA/504 Team for public vetting and will include the written comments from the ADA/504 Team in a written recommendation to the President for consideration on requests for exceptions.

6.4 Implementation Schedule Summary[i]

  • May 1, 2014, the University will develop and institute procedures that require the University to purchase or recommend only EITs that will provide the same programs, benefits, and services as they do to individuals without disabilities, except when it would fundamentally alter a program or when it is not technically feasible to do so, in which case the procedures will require the University to provide accessible alternate EITs.
  • By May 1, 2014, the University will implement as part of its request for proposal process a requirement that bidders meet the accessibility standards of WCAG 2.0 Level AA for web-based technology (as set forth in Appendix A to this Agreement) and Section 508 of the Rehabilitation Act and the Americans with Disabilities Act for other EITs; and requiring or encouraging, at the University’s discretion, as part of any contract with its vendors, provisions in which the vendor warrants that any technology provided complies with these standards and any applicable current federal and state disability laws.

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Appendix A: Required AA Standards

  • 2.4 – Navigable
  • 2.4.6 Headings and labels describe topic or purpose.
  • 2.4.7 Any keyboard operable user interface has a mode of operation where the keyboard focus indicator is visible.
  • 3.2 – Predictable
  • 3.2.3 Navigational mechanisms that are repeated on multiple Web pages within a set of Web pages occur in the same relative order each time they are repeated, unless a change is initiated by the user.
  • 3.2.4 Components that have the same functionality within a set of Web pages are identified consistently.
  • 3.3 – Input Assistance
  • 3.3.4 For Web pages that cause legal commitments or financial transactions for the user to occur, that modify or delete user-controllable data in data storage systems, or that submit user test responses, at least one of the following is true:
    • Reversible: Submissions are reversible.
    • Checked: Data entered by the user is checked for input errors and the user is provided an opportunity to correct them.
    • Confirmed: A mechanism is available for reviewing, confirming, and correcting information before finalizing the submission.

Appendix B:  EITA Software Accessibility & Procurement

Notes:

  • Additional information is available at umt.edu/accessibility/guides/eit/procurement
  • Submit the Accessibility Roadmap (if needed) and questions to eita@umontana.edu

Step 1: Identification

  • There will be a step in GrizMart, (that includes the sole source and bid processes) that requests a local count. 
    • All UM software purchased should be accessible. 
    • Existing software will be highlighted and researched during the self-study and continuing until we
  • Software evaluation can also be initiated by submitting the Software Evaluation Request form

Step 2: Basic Information

Requesters will be asked to provide a product VPAT[ii].  After an informational campaign on campus and sometime during the 2014-15 school year, they will also be asked to fill out the first page of the Accessible Software Request form.

Step 3: Evaluation

Qualified staff will review VPATs, check with vendors about planned accessibility fixes and indicate those fixes or possible technical adjustments for non-fully supported categories.  If neither fixes nor technical adjustments can be made, general accommodations (recommended by the DSS office) will be listed.  These will all be listed on the EITA Roadmap.

  1. If all VPAT “applicable categories” are marked “fully accessible.”
    1. The software is referred to Step 4-Determination if:
      • the use-scope of the software is 1
      • software-generated-products scope is that same individual
    2. Otherwise, EITA or ATS staff review the software.
      • If the VPAT ratings are confirmed, software (with date and version #) will be listed as recommended for UM purchase according to current standards and testing process on the Accessibility website.
      • If ratings are not confirmed, the software is processed according to Step 3B below.
  2. If all VPAT “applicable” categories are not marked fully supported:
    1. The software is referred to Step 4-Determination if:
      • the use-scope of the software is 1;
      • software-generated-products scope is that same individual; and
      • no other comparable software is accessible.
    2. Otherwise, further information is required. Please submit a UM EEAA-Accessibility Roadmap with page 1 completed.

Step 4: Determination

  1. Compiled information and report is reviewed by the EITA software/procurement subgroup for recommendations. 
  2. EITA recommendations are submitted to the CIO for final determination of “Provisional use” and/or review by UM President for “Exception.”
  • “Provisional Use” agreements are recommended for 1-3 year period, if the vendor provides evidence of genuine accessibility efforts, and periodically reviewed. 
  • “Exceptions” are infrequently, based on substantial research as indicated above and are requested from the President by the CIO.
  1. If either a provisional use or exception is granted, the requestor will be required to describe the measure(s) which will ensure that individuals with disabilities have equally effective accessible alternate (EEAA) electronic and information technology (EIT).

Step 5: Ratings & Reports

The EITA Working Group will designate software as “approved” for purchase, granted “provisional use,” granted an “exception,” or “denied.”  The name of the software, vendor, version, and date will be included in the designation.

The rating formula is described in Appendix C1.  Ratings will be displayed on UM’s Accessibility site along with:

  • Name of the department and date of the provisional use period – if appropriate
  • Name of software program, version and date reviewed
  • VPAT
  • Accessibility Roadmap document

Step 6: Review

  1. Provisional use designations are temporary.  A “provisional use” designation does not automatically roll into “approved for purchase” category.  Their status should be reviewed by the individuals or departments who requested that designation and requests for review of Provisional Use designation submitted 2 months prior to expiration.
  2. Purchasing records are reviewed quarterly supervised by EITA staff to determine:
  • Whether cumulative totals of individual departmental purchases of  software (that does not fully meet accessibility requirements specified in this policy”) are larger than expected; and
  • Whether a department has purchased additional copies beyond what was indicated on their original request.

C1: UM Ratings

UM ratings have three sections:

  • The first # is the scope of the project – approximately how many users. 
  • The second # is a 0-2 and indicates whether the program produces no products (0), produces products that “do not support” [508 standards] issues (1) or produces accessible products (2).
  • The third set of numbers 21-#:# or  21-#:#; 22-#:# or 21-#:#; 22-#:#; 31:#:# is the combined number of “not supported”, “partially supported,” and “supported with exceptions” categories as a ratio with the number of categories.  A 0 indicates that the software supports all accessibility categories. The designations will be labeled with VPAT/508 section 21 (Software applications and operating systems), section 22 (Web-based Internet Information and Applications) and occasionally section 31 (Functional Performance Criteria).
  • Examples include:
    • (3, 0, 21-8:12; 22-12:16) Security software that will be restricted in use to 3 individuals on campus, produces no products, and has multiple exceptions. 
    • (>1000, 2, 21:0:12) Software that is completely accessible, used by multiple faculty, staff, and students on campus, and that produces accessible products.

C-2: Software categories and 508 vs. WCAG standards

VPATs largely reflect Section 508 standards.  Section 508 1194.21 refers to Software Applications and Operating Systems and Section 508 1194.22 refers to Web-based Internet information and applications.  WCAG 2.0 can be mapped to Section 508 1194.22 and Section 508 1194.21 can reflect the functionality required to meet WCAG 2.0 AA.

Standards

VPATs will be required for all software purchases because they are the commonly accepted standard for assessing software accessibility and because they provide information related to both Section 508 and WCAG 2.0.

Desktop and Enterprise software

Desktop and Enterprise software that is purchased, stored and maintained on local servers is addressed by Section 508 1194.21 (and that section of the VPAT). Such software is usually licensed and locally maintained.  However, such software should match WCAG 2.0 AA functionality and should meet WCAG 2.0 AA standards (as initially analyzed through VPATs Section 508 1194.22) if:

  • its products are shared on the web
  • its functionality is provided via web browser or internet connection.

Web-based software

Software that has a web or internet component is evaluated by WCAG 2.0 AA standards (as initially reflected through VPAT’s 1194.22 section) and applies to:

  • SaaS (Software as a Service) –functions that are provided by vendors, accessed via the internet, hard to customize, often purchased through monthly and service fees.
  • Site – final product (pages) and functionality
  • SaaS (locally created) – created and maintained by UM programmers

[i] Full Plan available at umt.edu/accessibility

[ii] Voluntary Product Accessibility Template®