Accessibility Assessment for Information and Communication Technology (ICT)
Information Security Procedure

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Information Security Procedures (ISPR) provide formal methods for which Information Security Regulations, Standards, and Best Practices are conducted.

Accessibility, Section 508, and WCAG 2.0

Section 508 is a federal law that was adopted in California as California Government Code 11135 and further adopted by the California Community College System on January 1st, 2003. The law mandates that all information and communication technology developed, procured, maintained, or used by state-supported, operated, funded, or administered programs and activities be accessible to people with disabilities. The law also establishes standards for what is considered accessible for ICT (CCC Accessibility Administrator FAQs).

Furthermore, California state-funded agencies are responsible for ensuring that web content, non-web documents, and software comply with the Web Content Accessibility Guidelines (WCAG) 2.0, Level A, and Level AA (CCC Accessibility Policy, Standards, & FAQs).

As a result, the individual or business unit endorsing the ICT (Project Owner) shall attain a completed Voluntary Product Accessibility Template (VPAT) from all vendors being evaluated before ICT is purchased, procured, or otherwise adopted. VPATs must be reviewed and submitted along with their corresponding PeopleSoft Requisition before the purchase is approved and a PeopleSoft Purchase Order is created.

This standard is divided into the following sections:

Roles and Responsibilities

Addressing accessibility is a shared responsibility amongst several parties, including but not limited to, the Chancellor’s Office, California Community Colleges senior administrators, technology professionals, purchasers, human resources, and creators of ICT, including instructional materials. Each college district has the responsibility to comply with Section 508, using the guidance provided by the Chancellor’s Office (CCC Accessibility Administrator FAQs).

Each of the following parties has a specific role throughout the Accessibility Assessment Process.

Project Owner

  • Possesses an appropriate level of understanding as to how the product will be used.
  • Requests a completed VPAT from the vendor.
  • Leads the assessment process.
  • Evaluates multiple like products.
  • Selects the most accessible of those products.

Disabled Student Programs and Services (DSPS): Student-Centric Technology

  • Assists the Project Owner with identifying potential challenges to accessibility for student-centric technology.
  • Develops an Equally Effective Alternate Access Plan (EEAAP) should the product not meet 508 compliance.

Human Resources: Personnel-Centric Technology

  • The HR Compliance and ADA Analyst assists the Project Owner with identifying potential challenges to accessibility for staff and faculty-centric technology.
  • Develops an Equally Effective Alternate Access Plan (EEAAP) should the product not meet 508 compliance.

Purchasing & Contracts

  • Provides a blank VPAT to the Project Owner as needed.
  • Verifies that all necessary ICT documentation is attached to the requisition.

ITS Compliance Liaison

  • Assists with the evaluation of VPATs.
  • Provides feedback to the Project Owner.

The Accessibility Assessment Process

The Accessibility Assessment Process is one of three processes required by the ITS ICT Request Procedure.

The process is as follows:

  1. The Project Owner requests a completed VPAT from the vendor.
    1. If the vendor doesn’t have a VPAT, either the ITS Technical Liaison or Purchasing Department can supply one to the Project Owner, or the Project Owner can provide one to the vendor via the Voluntary Product Accessibility Template (VPAT) section below.
    2. If a vendor chooses not to supply the Project Owner with a VPAT, the Project Owner shall still be required to work with the appropriate accessibility specialist and attain an Attestation of Compliance (described below).
  2. The Project Owner shall attach a copy of the completed VPAT to their PSoft Requisition and forward a copy to their respective ITS Technical Liaison.
  3. The Project Owner or ITS Technical Liaison shall forward the VPAT to the ITS Compliance Liaison.
  4. Upon review, the ITS Compliance Liaison shall return comments and an overview of the evaluation process to the Project Owner.
  5. The Project Owner shall review the comments and follow the process as provided by ITS, which details the following:
    1. The Project Owner shall schedule a remote demo so that the vendor can satisfactorily demonstrate the product’s compliance with Section 508.

      If a remote demo is not possible, the Project Owner shall provide Instructional and User Support Services with an appropriate technical contact so demo software can be analyzed locally.
       
    2. The Project Owner shall work together with DSPS (if the ICT is used by students) or HR (if used solely by staff) to assist with identifying any potential issues regarding accessibility. 

      If the product does not meet Section 508 standards, an Equally Effective Alternate Access Plan (EEAAP) shall be attached to the PSoft Requisition.
  6. After testing is complete and the most accessible product is selected, the Project Owner shall attach an Attestation of Compliance to the corresponding PSoft Requisition.

    The attestation shall take the form of a simple statement confirming that the Project Owner, in concert with the appropriate accessibility specialist, has performed their due diligence and, as a result, the District adheres to 508 compliance.

Information and Communication Technology Approval

Requests for ICT shall only be approved after the Project Owner has completed:

  1. A Technical Assessment to evaluate the technology itself,
  2. The Accessibility Assessment as outlined in this document, and
  3. A Vendor Risk Assessment to evaluate security risks.

The Voluntary Product Accessibility Template (VPAT)

A VPAT is a detailed report that explains how well ICT products meet current 508 standards and is an integral part of the product research and evaluation process. If a vendor does not already have a VPAT prepared, the Project Owner can provide them with the following:

Current Version: VPAT 2.4 - Rev 508 - March 2022

Once the VPAT is returned from a vendor, it must be reviewed.

Note: Should a vendor need them, official instructions for creating a VPAT can be found on the U.S. General Services Administration’s website at https://www.section508.gov/sell/how-to-create-acr-with-vpat/.

The VPAT Assessment Process

WCAG 2.0 Level A and AA compliance reports are contained in Tables 1 and 2 (Success Criteria, Level A and Success Criteria, Level AA respectively). As the Project Owner reads these two tables, they must ask the following question for all Criteria listed:

Is the Success Criteria relevant to the functionality required of users (i.e., how they will be using it) and if so, will the answers listed in the Confirmation Level and associated Remarks/ Explanations columns hinder or prevent users from performing the expected task?

To answer that question effectively, the Project Owner must:

  1. Have an appropriate understanding of how the software will be used (i.e., what the user will be required to do), and
  2. Ensure that functionality is tested.

Otherwise, identifying areas that may present challenges, need accommodations, or require equitable alternatives is not possible.

Product Testing

Testing is essential; otherwise, identifying areas that may present challenges, need accommodations, or require equitable alternatives is not possible.

If a vendor cannot adequately demonstrate a product’s accessibility features from a remote location, then demo software should be installed to vet it.

To help determine whether accommodations or equitable alternatives are necessary, the Project Owner may ask for assistance from DSPS. If accommodations or equitable alternatives are necessary, the Project Owner shall work with DSPS to create an EEAAP.

It is important to note that if accommodations are necessary but cannot be provided, the ICT can be used but cannot be required. Instead, students, personnel (those representing or working on behalf of the District), and/or community members must be provided with an equitable alternative.

Basic Tests to Evaluate Accessibility

The following tasks should be tested first to get an idea of the general state of a product’s accessibility.

  • Can the tab-key be used to navigate to and from all interactive elements, including hyperlinks, form fields, and buttons?
  • Can hyperlinks be activated with the Enter/Return key?
  • Can buttons be activated with the Spacebar or Enter/Return key?
  • If a form field’s text label is clicked on, does the cursor move into that form field?
  • If the product contains audio or video:
    • Are there controls to pause or stop the playback?
    • Do audio files have transcripts?
    • Do videos have captions?
  • For any blinking, scrolling, or moving content, are there controls to pause, stop, or hide that content?
  • Does any content flash more than three times in a one-second period?
  • If using a website, can you zoom in 200% without loss of content or functionality?

If the software fails any of these basic tests, it is not WCAG 2.0 compliant. Conversely, there is no guarantee that the software is compliant just because it passes all of the above tests: software must be fully vetted to identify potential accessibility issues.

What if the vendor chosen is not 508 Compliant?

Products that cannot be made accessible or only meet some of the standards are eligible for consideration only if they can be accommodated in an equally effective manner. Additionally, items that are not intended for the general public, such as routers and firewalls, are exempt from these standards.

However, products that cannot be accommodated in an equally effective manner are not considered responsive, and as such, are not eligible for consideration or award of the contract or purchase order (CCC Accessibility Purchaser FAQs).

It is the District’s obligation to provide the most accessible solution. As a result, given a choice between like products, those with greater accessibility shall take precedence.

Resources

Accessibility Policy, Standards, and FAQs