IT Accessibility Policy Process Guidelines and Exceptions Process

Information Technology Accessibility Policy 04.001 Process Guidelines 

The following process describes the purchasing, assessment and exceptions process for the Information Technology Accessibility Policy 04.001.  

Step 1. Purchasing Process 

The purchasing process includes an initial risk assessment as early in the buying process as possible. The person requesting the purchase will complete a Technology Review Request to: 

• determine the risk level of the purchase
• help IT Accessibility testers gain access to the product to perform a review and
• understand how the product is intended to be used. 

Step 2.  Accessibility Assessment Process 

The Office for Information Technology (OIT) Accessibility office assesses all potential purchases first with an automated test and then, depending on the risk level, a manual test at potentially two other levels (WCAG 2.0 level A and then AA). The WCAG 2.0 AA guidelines is the internationally recognized standard for web-based accessibility and the standard OHIO requires for IT accessibility. 

LEVEL I – Automated tool Assessment* 

1. IT Accessibility office gains access to the tool 
2. Based on the provided user journey, the IT Accessibility office runs the Chrome Lighthouse extension on each page of the main tasks required to use the product by the end user 
3. The tester then records the Chrome Lighthouse score for each page in the report 
4. For each risk level:  
   • High Risk:  
     • If the score is greater than 80% then the product will be tested at LEVEL II 
     • If the high-risk score is lower than 80% the department is notified and advised it has the option to seek another purchase, work with the vendor to make the IT product accessible or request an exception using the Exception Request form. 
   • Medium Risk 
     • If the score is greater than 70%, then the purchase may continue, and the department will be responsible for providing an equitable alternative should one be requested. 
     • If not, the department is notified and advised it has the option to seek another purchase, work with the vendor to make the IT product accessible or request an exception using the Exception Request form. 
   • Low Risk 
     • If the score is greater than 50%, then the purchase may continue, and the department will be responsible for providing an equitable alternative should one be requested. 
     • If not, the department is notified and advised it has the option to seek another purchase, work with the vendor to make the IT product accessible or request an exception using the Exception Request form. 

*An automated tool assessment is very fast, but only reveals about 30% of potential accessibility issues for a given tool. It is not a replacement for a manual review of a product. 

LEVEL II – WCAG 2.0 Guidelines Level A 

• If the product scores *100% for all applicable WCAG 2.0 A Guidelines, then a LEVEL III review is done 
• If the products fails this assessment, the department is notified and advised it has the option to seek another purchase, work with the vendor to make the IT product accessible or request an exception using the Exception Request form. 

*If a product is not fully compliant at level A, it cannot be compliant at level AA. 

LEVEL III - In-depth Accessibility Assessment 

WCAG's 2.0 Guidelines Level AA 

• If the product passes WCAG’s 2.0 Guidelines Level AA at 85% or higher, the purchase will be approved and added to a list of vendors in a high level of compliance with OHIO’s IT Accessibility policy. 
• If the product fails this review the department is notified and advised it has the option to seek another purchase, work with the vendor to make the IT product accessible or request an exception using the Exception Request form. 

Results: 

When a product meets the standards, the IT Accessibility Office notifies Purchasing that the software is compliant and the department may continue with the purchasing process. 

When a product does not meet standards, the IT Accessibility Office notifies Purchasing and the department, and the department may choose to follow Step 3 and request an exception.   

Step 3. Process to Request an Exception 

If a product does not pass accessibility standards, departments seeking to make a purchase may request an exception to the policy by completing and submitting the Information Technology Accessibility Policy (OHIO Policy 04.001) Exception Form. The form requests information, including the following: 

• Description of software, hardware or third-party vendor product and intended use 
• Explanation about why accessibility compliance is not feasible 
• Vendor information about accessibility shortcomings and timeline for when vendor intends to address shortcomings 
• A plan for how alternative access will be provided, when requested, which:  
  • Outlines how the unit will make information attained through this technology available to persons living with a disability in an equally effective alternate format; and 
  • Identifies the individual responsible for providing the alternative/accommodation. 

Step 4. Exception Review Process 

The ADA/504 Coordinator, CIO and stakeholders review request for exception. Reasons that may support the granting of an exception(s) include:  

• Hardware and software for which no equivalent accessible option is available 
• Hardware and software tools specific to a limited research or development process in which no member of the research or development team requires accessibility accommodations nor likely will 
• Software that is used as a standard or common practice in a field of study, industry or profession. 
• Undue burden. An undue burden is determined on a case-by-case basis. Generally, it is an action requiring such significant difficulty or expense that it is unreasonable when considered in the context of a number of factors such as the nature of the cost, difficulty, or complexity in relation to available resources and the benefit to be achieved.  

Final determination: 

The ADA/504 Coordinator and CIO would review requested materials and make determination on the granting of exceptions. A summary of exception request, accessibility assessment report, decision, and rationale would be sent to the department requesting the Exception, OIT, and Purchasing. The decision will indicate: 

• Yes, proceed with purchase 
• Yes, proceed with conditions 
• No 
• Sent back for more information 

If the exception is granted, departments may move forward with purchasing the IT product. 

Step 4. Appeal Process 

Departments denied the ability to make a technology purchase have the opportunity to appeal this decision to the Executive Vice President and Provost (EVPP) and the Vice President for Finance and Administration (VPFA). In cases of appeal, the department will write a rationale for the appeal and forward with the Accessibility Assessment, Exception Request Form, and Exception Request response, to the EVPP and VPFA, with a copy to the ADA Coordinator. The EVPP and VPFA will render a final decision.  

The ADA/504 Coordinator will fulfill the university’s monitoring obligations under the Americans with Disabilities Act by documenting summary reports, decisions and rationale. 

* ADA/504 Coordinator Contact Information 

Kerri Griffin, JD
ADA/504 Coordinator  
Ohio University  
access@ohio.edu