Montana Accessibility Interest Group 2/7/2014

1. Montana Accessibility Interest Group 2/7/2014 Presenter: Cheryl Pruitt, Director Mark Turner, Associate Director Accessible Technology Initiative CSU, Office of the Chancellor

2. Context: about the CSU California State University (CSU) Largest public baccalaureate degree-granting institution in the United States 23 campuses; >400,000 students; ~80% undergraduate About 11,800 students with disabilities registered with our campus disability services offices

3. Poll Question Did your campus have an accessibility effort before the legal action at University of Montana? • Yes • No • Don’t know

4. Moving your institution towards accessibility… Cultural change + Institution-wide effort = Really BIG Job CSU Accessibility Implementation Tools and Resources

5. CSU Strategies

6. Poll Question • Has an accessibility awareness campaign been started on your campus? • Yes • No • Don’t know

7. Lightning Round: Poll Question 1 of 4 • Does your institution have standardized contract language for purchasing accessible information technologies? • Yes • No • Don’t know

8. Lightning Round: Poll Question 2 of 4 • Are you familiar with the Voluntary Product Accessibility Template (VPAT)? • Yes • No • Don’t know

9. Lightning Round: Poll Question 3 of 4 • Has anyone on your campus had opportunities to work with vendors to improve the accessibility of their products? • Yes • No • Don’t know

10. Lightning Round: Poll Question 4 of 4 • Has anyone on your campus developed processes for testing the accessibility of products? • Yes • No • Don’t know

11. Accessible Procurements • Process that identifies when an Electronic and Information Technology (E&IT)purchase is being made? • Process in place to determine level of product accessibility • Process to engage vendor in accessibility conversation • Process to get commitment from vendor to improve the product • Contract language that covers product accessibility agreements • Equally Effective Access Plan in place for product accessibility gaps

12. Recommended Roles and Responsibilities for Accessible Procurement • The responsibility for purchasing accessible products should be a shared responsibility across the campus • Purchase Requester • Administrative Support Staff • Buyer (Procurement Office) • IT Staff • Disability Services Staff • E&IT Product/Service Provider • ATI Designee or Other Designee • Executive Sponsor

13. Accessible Procurement Processes • Process that identifies when an Electronic and Information Technology (E&IT)purchase is being made. • Pre-purchase/acquisition form (see similar form at CSU Channel Islands) • Who: Purchase Requestor • Process in place to determine level of product accessibility • Request and review product accessibility documentation • VPAT (Voluntary Product Accessibility Template) • Vendor test results to support claims made on the VPAT • Requires trained personnel • Who: ATI Designee, IT Staff

14. Accessible Procurements • Process to engage vendor in accessibility conversation • Following the review of the vendor supplied accessibility documentation correspond with vendor regarding the quality of the accessibility documentation • Request clarification or revision if warranted • Determine if product will undergo accessibility testing may need to request access to product • Who: ATI Designee • Process to get commitment from vendor to improve the product • Based on accessibility evaluation (documents or testing) request that vendor provide an “Accessibility Roadmap” • Who: ATI Designee

15. Accessible Procurements • Add contract language that covers accessibility • Standardized language that is generic and included in the General Provisions (see example on slide # 17) • Customized to the purchase includes language that covers commitments made in “Accessibility Roadmap”. • Who: ATI Designee, Buyer/Procurement Officer • Put Equally Effective Alternate Access Plan (EEAAP) in place for product accessibility gaps • Plan how you will accommodate students who encounter barriers caused by product accessibility gaps. • Who: ATI Designee, Purchase Requestor, and Disability Services

16. Question from Robert Squires: • Our future policy will require that all content made available online be accessible for all-users whether they have self-identified as requiring an accommodation or not. This will mean, amongst other things, that all video content will need to be captioned when it is uploaded or very shortly thereafter. I wonder whether CSU has a similar policy in place or coming into place, and how CSU provides guidance and support for faculty. I would be particularly interested in hearing Cheryl’s thoughts on whether this goes beyond workshops, trainings and appropriate levels of institutional support into enforcement and personal liability.

17. Example Contract Language Contractor hereby warrants that the products or services to be provided under this contract comply with the accessibility requirements of section 508 of the Rehabilitation Act of 1973, as amended (29 U.S.C. 794d), and its implementing regulations set forth at Title 36, Code of Federal Regulations, Part 1194. Contractor agrees to promptly respond to and resolve any complaint regarding accessibility of its products or services. Vendor further agrees to indemnify and hold harmless the CSU using the vendor’s products or services from any claims arising out of its failure to comply with the aforesaid requirements. Failure to comply with these requirements shall constitute a breach and be grounds for termination of this Contract. CSU General Provisions for Information Technology Acquisitions

18. Purchase Requester • Person who requests the product/service to be purchased or developed. • Selects the most accessible E&IT product/service that meets their functional requirements • Completes the appropriate sections of the Accessible E&IT Pre-Purchase document (campus-specific) including the technical and functional requirements and market research for the product/service • Obtains vendor-provided accessibility conformance documents (e.g. VPAT). • Submits the Accessible E&IT Pre-Purchase document to campus reviewer (e.g. ATI Designee or other designee) for approval • Serve as member of EEAAP Committee

19. Administrative Support Staff • Completes and processes all appropriate forms and documentation for requester and coordinates with ATI Designee, Disability Service Office, and office of Procurement to complete the accessibility review. • Assists purchase requestor with completing the required request forms and processes to purchase E&IT products and services • Works with Purchase Requestor to complete required accessible E&IT procurement documentation including: • The Accessible E&IT Pre-Purchase form (campus-specific) for review by ATI Designee (or other designee) • Vendor-provided accessibility documentation (e.g. VPATs, Accessibility Roadmap) • On behalf of Purchase Requestor, submits the documentation listed above to campus reviewer (e.g. ATI Designee or other designee) for approval

20. Buyer (Procurement Department) • Reviews purchases of E&IT products or services to ensure all ATI procurement requirements have been met • Verifies that Pre-purchase form, initial EEAAP and vendor accessibility documentation are present • Completes all authorized purchases of E&IT products and services • Verifies that ATI Designee (or other designee) has reviewed and approved the requested E&IT purchase • Verifies that the EEAAP Committee has drafted an EEAAP for high-impact products or services • Maintains records and documentation of procured E&IT products/services • Upon request, in coordination with the ATI Designee and the requesting department(s), establishes contracts with third-party consultants to perform accessibility conformance testing

21. Information Technology Staff • IT staff provide technical expertise and assistance with the purchase and deployment of accessible technology. • Advises the ATI Designee or other designee, campus departments, campus requester and/or campus administrative support staff on functional and technical requirements as they relate to E&IT purchases • Assists the ATI Designee with evaluating the functional and technical requirements of a purchase request • Assists the Campus Requester with developing functional and technical requirements • Advises the campus requester on evaluating vendor Section 508 documentation for completeness and possible concerns prior to submitting it for ATI review • Assists in the evaluation of market research

22. Disability Services Staff • Disability Services staff members provide expert guidance on accommodations and assistive technologies that provide persons with disabilities with equal access to university programs and services. • Provides expertise as a consultant in identifying potential issues that result from the interaction between the technology and the individual user • Participates in the campus ATI Steering Committee • Participates as a member of the EEAAP Committee in the preparation of Equally Effective Alternate Access Plans and in the evaluation of exemption requests

23. E&IT Product/Service Provider • An E&IT provider of goods/services sells or develops the product/service for a campus or campuses within the California State University system. • Works with the CSU system to provide documentation regarding product/service accessibility. • Provides 508 conformance documentation (e.g. VPAT, testing results and Accessibility Roadmap) • Specifies an accessibility contact person in the 508 conformance documentation • Works with the CSU system to mitigate accessibility issues/concerns in the products/services that they are providing • Keeps CSU apprised of work on incorporation of accessibility standards into product or services • Provides sample of product or services for testing or demonstration of Section 508 conformance

24. ATI Designee or Other Designee(s) The responsibilities may be assigned to one person (e.g. ATI Coordinator) or shared across multiple positions on campus • Facilitates consistent implementation of accessible Electronic and Information Technology (E&IT) procurement procedures that conform with Federal and State laws as well as CSU policy mandates • Consults with buyers to develop accessibility language that will be incorporated into bids and final contracts • Completes appropriate campus documentation for the ATI portions of E&IT purchases while ensuring that all ATI-related documents have the required approvals and are readily available for campus personnel involved in EEAAP implementations • Attends regularly-scheduled ATI meetings with campus stakeholders (e.g. ATI Steering Committee, campus working groups, ATI Procurement Community of Practice)

25. ATI Designee or Other Designee(s) • Oversees review of E&IT accessibility compliance documentation for regular purchases and competitive bid procurements (e.g. RFPs, RFIs, and RFQs) • Evaluates vendor-provided accessibility conformance documentation (e.g. VPAT, Accessibility Roadmap) • Reviews Accessible E&IT Pre-Purchase form submitted by Purchase Requester • Develops campus strategy for selecting E&IT products/services that will be evaluated for conformance with accessibility standards • Selects products/services that require accessibility conformance testing based on impact criteria • As needed, arranges for accessibility conformance testing to validate vendor accessibility claims

26. ATI Designee or Other Designee(s) • Coordinates with E&IT vendors to resolve issues with product accessibility support or accessibility documentation • Provides feedback to E&IT vendor, as needed, regarding issues with accessibility documentation or product accessibility support • Participates as a member of the EEAAP Committee in the preparation of Equally Effective Alternate Access Plans and in the evaluation of exemption requests • Coordinates the development of Equally Effective Alternative Access Plans that will achieve accessibility for students, employees and members of the public • Serves as the identified campus contact for staff, faculty, students, and E&IT vendors regarding accessible E&IT procurement • Answers questions related to purchasing accessible products

27. ATI Designee or Other Designee(s) • In consultation with the ATI Steering Committee, coordinates the delivery of accessible E&IT procurement training programs for the campus community (e.g. buyers, faculty, and staff) • Oversees the initial development and ongoing provision and coordination of accessible E&IT procurement training programs for the campus community (e.g. buyers, faculty, and staff) including participant tracking • Coordinates campus communications regarding accessible Procurement Procedures (e.g. awareness campaign) • Coordinates the campus roll-out of a broad-based awareness campaign regarding accessible E&IT procurement procedures. • Acts as liaison with the Executive Sponsor and campus community regarding accessible E&IT procurement issues • Discusses accessible E&IT procurement issues with campus Executive Sponsor and ATI Steering Committee as needed

28. Executive Sponsor • This ATI role oversees campus policies, projects and implementation of the Accessible Technology Initiative. • Works with the campus ATI Steering Committee, to review and update the ATI Campus Plan to guide their implementation on an annual basis • Conducts regular ATI Steering Committee meetings no less than twice per year • Ensures that the ATI Steering Committee membership is comprised of all key stakeholder groups and includes members with appropriate experience and expertise to inform decision-making

29. Executive Sponsor • Leads the implementation effort on their campus • Oversees campus ATI planning and implementation process • Engages in a periodic administrative review process with the ATI Steering Committee regarding challenges, milestones, resources, and documenting ongoing progress • Monitors, leverages, and implements deliverables from system wide ATI activities that will advance campus efforts • Ensures that ATI Steering Committee members monitor, participate in, and contribute to Community of Practice activities • Channels communications from the Chancellor's Office to appropriate parties on campus • Attends Executive Sponsors Steering Committee (ESSC)

30. Desire 2 Learn – Accessibility Resources • Videos: • Desire2Learn's Groundbreaking Work in Accessibility (award from the NFB). https://www.youtube.com/watch?v=mO54vAKOpzo&list=PLPXvKtUadRjxsdErURhYcI2YwGaf-qDvY&feature=c4-overview-vl • Carinprovides an accessibility walk-through of the D2L Learning Environment. • https://www.youtube.com/watch?v=-8haBSM59wE