Accessibility

Electronic and information technology (EIT) includes websites, web applications, software, e-learning tools, hardware, online learning systems, electronic media and documents, multimedia or programmable interfaces. 

All EIT procured by VCU as defined by the U.S. Access Board at Title 36 Code of Federal Regulations 1194.4 is expected to comply with: 

All products and services utilized by University faculty/staff, program participants, students, or other University constituencies must be compliant with state and federal accessibility laws. Compliance means that a person with a disability can acquire the same information, engage in the same interactions, and enjoy the same services as a person without a disability, in an equally effective and integrated manner, with substantially equivalent ease of use.

Procurement and accessibility

VCU is committed to ensuring that its programs and services are accessible to everyone. Product accessibility information allows VCU to select products and or services that provide strong accessibility support and therefore reduce or eliminate the need to provide costly accommodations to work around accessibility gaps.

When procuring IT replacement technology, include the rationale for the change as well as whether or not other more accessible technologies exist. If a technology or service is not in compliance with state and federal disabilities laws, an equally and effective alternative means must be provided.

 

Procurement under $10K  - Technology Review Request

Please submit a technology acquisition review request for any technology, including any techology purchase that is not subject to approval/review by IT Governance. For questions regarding the Technology Review Request form, contact the University EIT Accessibility Coordinator by going to go.vcu.edu/eit-accessibility.

To expedite the approval process, have all documentation prepared prior to submitting the Technology Review Request form.

 
 

Evaluation process and levels of impact

In an effort to determine whether or not a technology needs to be manually reviewed for accessibility, the level of impact to the university community and the public is evaluated. The following framework are guidelines and still may be subject to a manual review evaluation.

High impact technology will need a manual accessibility review prior to approval once the VPAT has been reviewed. Medium impact technology with an adequate VPAT submitted will typically not require a manual review. Low impact technology will be approved with VPAT submission and do not require a review.

Please note, any technology that is available to the public is considered High Impact.

High Impact

For high impact technology, at least three of the following are true:

  • Collects Category I Data
  • Primary audience is persons with disabilities

  • Impacts a critical program/service (i.e. enterprise-level, student-related, mission critical)

  • Available to a large audience or is public facing (over 20% of current student population or 50% or greater of faculty/staff)

  • Creates significant legal exposure

  • Creates high accommodation costs

  • Denies access to a program/service for people with disabilities

  • Vendor VPAT indicates a substantial amount of WCAG 2.0, AA success criteria is either “not supported” or “supported with exceptions”

  • Is not in full compliance with VCU Web Standards and Guidelines


Medium Impact

For medium impact technology, at least three of the following are true:

  • Impacts an important but non-critical program/service (not enterprise-level, not mission critical)

  • Impacts a moderately-sized audience, and is not public facing (5%-10% of current student population, or less than 50% of faculty/staff)

  • Creates moderate legal exposure

  • Creates moderate accommodation costs

  • Moderate likelihood of impact for persons with disabilities

  • Vendor VPAT indicates that some of the WCAG 2.0, AA success criteria is either “not supported” or “supported with exception”

  • Is not in full compliance with VCU Web Standards and Guidelines


Low Impact

For low impact technology, at least three of the following are true:

  • Impacts an optional program/service

  • Available to a small audience, and is not public facing

  • Creates little or no legal exposure

  • Does not limit access to a program/service for people with disabilities

  • Low likelihood of impact for persons with disabilities

  • Vendor VPAT indicates all of the WCAG 2.0, AA success criteria is supported

  • Is in full compliance with VCU Web Standards and Guidelines

Steps to ensure EIT accessibility and expedite approval process 

  • Solicit accessibility information by requesting the Voluntary Product Accessibility Template (VPAT) from the vendor which is based on WCAG 2.0 Level AA. The vendor supplies the VPAT, this is not completed by the Requestor
  • All technology collecting Category I data needs to be reviewed by VCU Information Security
  • Determine the level of impact from the criteria listed above
  • If web-based, you will need to submit the requested DNS to the request form
  • If the technology requires Single Sign-On (SSO), be prepared to submit any related vendor documentation to the request form
  • If the technology is not fully WCAG 2.0, Level AA compliant, and is High Impact, complete an Equally Effective Alternate Access Plan (EEAAP) template and submit to the request form.
  • In some cases, Medium Impact technology that is not in compliance may have to submit an EEAAP
  • Validate the accessibility information provided in the VPAT by testing and evaluation
  • Review the VPAT for compliance with WCAG 2.0 Level AA conformance by noting any Success Criteria that the vendor indicates "Does Not Support" or "Supports with Exceptions"
  • Communicate with the vendor any accessibility failures in accordance with the WCAG 2.0, AA Success Criteria and request updates
  • Accessibility review requests may be submitted via Service Desk at go.vcu.edu/eit-accessibility.

Related policies and standards