Information and Communication Technology (ICT) Procurement Procedures

Introduction

All information and communication technology (ICT) products or services acquired by the University should be accessible to individuals with disabilities. ICT products or services that have accessibility problems expose the University to risk, increase costs, and may undermine the University’s commitment to accessibility. ICT acquisitions, purchased or obtained at no cost, must be reviewed for accessibility compliance. ICT for use by one person does not need to be reviewed for accessibility.

Process

  1. Solicit accessibility information by obtaining an Accessibility Conformance Report (ACR) from the vendor using the Voluntary Product Accessibility Template® (VPAT®).
  2. Determine Impact by completing the ICT Impact Assessment
    1. Impact Priority
      1. High impact will undergo an in-depth accessibility review.
      2. Medium impact products are reviewed at the discretion of Accessibility ICT Review Committee.
      3. Low impact products are generally not reviewed in-depth.
  3. Information Technology will review the impact assessment and validate the ACR.
    1. If the acquisition requires further review:
      1. Accessibility ICT Review Committee conducts accessibility testing.
      2. Accessibility ICT Review Committee makes recommendation:
        • Yes, purchase/implement
        • Yes, purchase/implement, but only with submitting a satisfactory Equally Effective Alternate Access Plan (EEAAP) 
        • No, do not purchase/implement
  4. Upon approval, continue with the purchase following the University purchasing policy and procedures.

Related Information

Pre-approved products

A list of commonly used products and services that have been vetted for accessibility.

Documentation Language

Contracts

__________ (Vendor) warrants the products and/or services provided pursuant to this Agreement conform to the W3C Web Content Accessibility Guidelines, version 2.0 ("WCAG 2.0") at conformance levels A and AA. In the event that the products and/or services provided hereunder do not fully conform to WCAG 2.0 A and AA, __________ (Vendor) must advise Michigan Technological University in writing of such nonconformance, and should provide detailed information regarding the plans to achieve conformance, including but not limited to an intended timeline. With respect to non-web based information and communication technologies (ICT), __________ (Vendor) shall use commercially reasonable efforts to ensure that the products provided under this Agreement comply with and shall remain complaint 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 11949 (together, the "Rehabilitation Act"). __________ (Vendor) agrees to promptly respond to and resolve any complaint regarding accessibility of its products or services provided to Michigan Technological University under this Agreement. __________ (Vendor) further agrees to indemnify and hold Michigan Technological University harmless 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 Agreement.

RFx (Request for (Information, Quote, Proposal))

In the requirements section include:

Vendor warrants that (i) Web-based information and communication technologies (ICT) products provided under this Agreement conform WCAG 2.0 AA and (ii) non-web-based ICT meets or exceeds the applicable 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.

In section listing the various questions that vendors need to respond to, include:

  • Are all interfaces (both for administrators and end-users) that are part of your product compliant with Section 508 and/or WCAG 2.0 A and AA?
  • Describe your accessibility conformance testing process.
  • Do you do testing with users with disabilities? If so, can you explain the process and identify, roughly, the range of disabilities and assistive technologies used?
  • Does your product undergo accessibility testing prior to each major release? Do you use a third-party accessibility evaluation company to verify your accessibility compliance? If so, are you willing to provide a copy of your most recent evaluation report?
  • What methods do you use to inform customers of accessibility errors?
  • Who will pay to remediate any necessary fixes after purchase?
  • Do you have a designated accessibility representative to address issues or questions and provide oversight related to the accessibility of your product?
  • Provide a Voluntary Product Accessibility Template (VPAT) for your product.
  • If your product is not fully accessible, do you have a roadmap to make your product fully compliant? If so, include your roadmap.

Appendices

Impact Priority

High impact

  • Affects a critical program/service
  • Impacts a large audience/user base consisting of students
  • Creates high accommodation costs
  • Creates significant legal exposure
  • Denies access to a program/service for people with disabilities
  • Creates frequently-recurring barriers
  • Strong likelihood of impact for persons with disabilities

Medium Impact

  • Affects an important but non-critical program/service
  • Impacts a moderately-sized audience
  • Creates moderate accommodation costs
  • Creates moderate legal exposure
  • Limits access to a program/service for people with disabilities
  • Creates occasionally-recurring barriers
  • Moderate likelihood of impact for persons with disabilities

Low impact

  • Affects an optional program/service
  • Impacts a small audience
  • Creates little or no accommodation costs
  • Creates little or no legal exposure
  • Does not limit access to a program/service for people with disabilities
  • Does not create recurring barriers
  • Low likelihood of impact for persons with disabilities

Forms and Instructions

Voluntary Product Accessibility Template® (VPAT®)

ICT Procurement Impact Assessment

Equally Effective Alternate Access Plan (EEAAP)