Six Questions Colleges Should Ask Themselves regarding Accessibility and Procurement
By Haylee R. Dass, Director of Online Programs, Butler Community College
“Procure that which is accessible, or spend precious resources making it so.”
- Cyndi Rowland, Ph.D.
Due to renewed focus on accessibility in higher education, institutions are working on redesigning their procurement process to incorporate the latest accessibility standards. This can be a complex task involving many offices across campus. Although one size does not fit all institutions, there are some key items that all institutions will need to consider; end-user, financial responsibility, stakeholders and the regulating authority. There are often more questions than answers when initially considering accessibility, especially when considering the procurement process (Hermann, 2018).
First, it is important to remember one main point – the law does not require the vendor to make an accessible product. Based on what we have learned from recent court rulings, when it comes to accessibility in higher education, the institution itself carries ultimate responsibility for the accessibility of what is procured and used (Rowland, 2018). As part of accepting responsibility, institutions are considering what it looks like to incorporate accessibility as a major component to the procurement process.
Figure 1. A Visual Depicting Structural Accessibility Challenges (free from Pixabay)
1. What is the Standard?
Before weaving accessibility into the process, it is imperative to know the institutional standard when it comes to accessibility. You can typically find this information in your institution's accessibility statement (which should be located on the institutions website). If your institution does not have an accessibility statement, I recommend backtracking and creating an accessibility committee to create a statement and strategic plan regarding accessibility.
If you search various institutional websites for examples of accessibility statements, you will find a variety of approaches in depth and verbiage. At minimum, the institutional standard(s) should be present as well as what the standard(s) applies to. Contact information for campus representatives should also be included in the same area. One trend I am pleased to see at many institutions is the inclusion of an accessibility concern form on the website, allowing someone to alert the college of a concern without necessarily self-identifying.
2. What Does the Standard Apply To?
Identifying what the standard applies to will help stakeholders understand the level and scope of commitment by the institution. Do your institutional standards apply to facilities, your website, your content delivered in your classrooms, software/hardware, etc.? This statement should mirror the overall strategic plan put together by the accessibility committee.
3. What Should be Incorporated in the RFP (Request For Proposal) / Contract?
Once you identify the standard and how it is applied, you are ready to interweave accessibility with the procurement process. Typically, the procurement or IT team on your campus would develop the process and approval would come from various stakeholders, committees, and other decision makers.
As earlier stated, the institutions themselves carry the burden of making procured material accessible (Rowland, 2018). The procurement process is where some of the burden of responsibility can begin to shift back to the vendor. Consider requiring bids to include demonstration on how the product or service meets the institutions accessibility requirements or third-party testing (provided by the vendor).
The University of California’s procurement website has resources available that may help guide other institutions as they outline their process. They have a comprehensive RFP outline and checklist that clearly states what standards the institution is looking for when evaluating products or services. At their institution (which is the same for many of us) the bar is set to meet WCAG 2.0 AA standards (“Electronic accessibility”, n.d.). This is helpful to have on the front end, especially if your institution decides to do some form of testing. The contract should also include verbiage to identify the responsible party when it comes to financial obligation, who will test the product, upgrades, remediation and the plan of action if the institutions standards change or the product/service does not meet the standard.
4. Who Will Test?
The institution should decide if in-house testing or third-party testing requirements need to be woven in to the process and at what level. After all, someone needs to verify the VPAT (Voluntary Product Accessibility Template) and/or the completed checklist submitted with the RFP. Institutions with limited funding or ability to test products may require the vendor to provide a third-party evaluation at their expense. This is becoming more popular as the complexities of testing can be overwhelming. With regular maintenance and consistent upgrades, internal testing can quickly become more than any one position or team can handle. In situations where third-party testing may not be warranted a vendor demonstration may be required in order to address each of the standards required by the institution.
Figure 2. An Image Depicting Accessible Hearing (free image by Pixabay)
5. What about Ongoing Compliance?
As mentioned above, the ever-changing technological environment we have all grown to embrace requires institutions to think through the process for periodic verification of procured items. Some institutions may elect to verify products annually as part of an accessibility maintenance plan while others may opt for verification if an upgrade is released or the institutions standards change. Institutional resources and workload may be guiding factors when considering this portion of the process. Ultimately, these items should be outlined in the contract between the vendor and the institution.
6. What Happens if the Product is Not Accessible?
Lastly, consider how the institution should approach remediation. For example, if a vendor does not meet one standard, yet meets all other requirements, does this call for a timeline of compliance for that one standard? Does this mean the institution will pass on that product or service until the vendor meets all necessary requirements? Should there be a rubric identifying burden of risk or a roadmap to remediation and what accommodation could be provided in the meantime? These are all questions that should be answered and highlighted in the institution's procurement process documentation.
Considering accessibility during the procurement process can help protect the institution from costly remediation. It is also considered the most proactive approach to creating a campus focused on accessibility. Best practices for this process are still being developed. Although we will always look at ways to improve and/or streamline, a good foundation and healthy understanding of accessibility standards is critical.
For more information regarding the content of this article, please contact Dr. Haylee R. Dass at email@example.com.
“Electronic accessibility.” (n.d.). Retrieved from https://www.ucop.edu/electronic-accessibility/standards-and-best-practices/procurement/index.html
Hermann, K. (2018, Nov. 14). Accessibility & procurement: What do we need to know? Retrieved from https://onlinelearningconsortium.org/accessibility-procurement-what-do-
Rowland, C., Ph.D. (2018, Oct.22). The role of procurement in digital accessibility. Retrieved from https://onlinelearningconsortium.org/procurement-digital-accessibility/
About the Author
Haylee R. Dass is currently the Director of Online Programs at Butler Community College. She joined the Butler family in 2016 and has enjoyed the dynamic, fast-paced environment. Dr. Dass has worked in various leadership roles at CNM, Central Michigan University, Mayville State University, and Auburn University in Montgomery, Alabama.
Her approach to leadership is to “create a team so strong you don’t immediately recognize the leader”. Dr. Dass has also taught for Butler Community College, Mayville State University, Auburn University in Montgomery, and the University of Mary. She is dedicated to the creation of flexible and innovative educational programs that match industry and student needs. Her motto, “A challenge is an opportunity to make something better”.
Dr. Dass may be reached at firstname.lastname@example.org.
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