Web Accessibility Policy Guidance: Creating Accessible Content

The World Wide Web (W3C) Consortium has established accessibility guidelines through its Web Accessibility Initiative. The Initiative's Web Content Accessibility Guidelines 2.0, or WCAG 2.0, is considered to be the international standard in ensuring accessible electronic content. These guidelines, as reiterated in UB’s Web Accessibility Policy, include the following:

• Websites must have content that is accessible with a screen reader.
• Websites must include alternative text for any non-text content when necessary to convey meaning (e.g., pictures, graphs).
• Websites must be able to be navigated through use of a keyboard, as an alternative to mouse navigation.
• Websites must not rely on color to convey meaning.
• Websites must provide captions or transcripts for all audio or video content.

The Web Accessibility Initiative - Accessible Rich Internet Applications Suite (WAI-ARIA) is a second web accessibility standard included in the Web Accessibility Policy. WAI-ARIA helps with dynamic content and advanced user interface controls developed with Ajax, HTML, JavaScript and related technologies.

Websites created in UB’s Content Management System, or UBCMS, already have some accessibility features built in. For example, the UBCMS will prompt users to add alternative text to pictures so that a brief description can be accessed with a screen reader.  The UBCMS also makes it easy to organize content with headings and bullet points, which not only benefits individuals with disabilities but makes websites easier to navigate for everyone. Still, the UBCMS does not prevent a user from inadvertently uploading an inaccessible PDF, providing a generic label for a link, or posting a video without captions. It is therefore necessary to be intentional in planning for accessibility when creating or revising web content.

Accessibility at UB was created to provide assistance in understanding and creating accessible content. You can obtain detailed information and instructions in each of the following areas:

• General guidance on website accessibility
• Ensuring that Microsoft Office documents and PDFs can be accessed with a screen reader and are easily usable
• Creating accessible audio and video material, including resources for captioning videos
• Steps to take when you are purchasing online content

Finally, it is recognized that remediating websites takes time, guidance and resources. Much of the feedback about the Web Accessibility Policy concerned how UB employees, and specifically faculty with their own lab or research webpages, will find the time and expertise to comply with the policy. Compliance with the policy will require a combination of individual effort, area-level assistance, and centralized expertise and resources. UB has expanded our resources in this area as follows:

• Acquiring a university-wide license for Siteimprove, an automated tool that will scan websites, identify accessibility issues and provide information about how to fix these issues. Siteimprove will also identify broken links and misspellings. While manual testing is also necessary to ensure website accessibility, Siteimprove can flag a number of issues automatically.
• Appointing a Web Accessibility Officer and Web Accessibility Coordinator as part of UB’s Office of Equity, Diversity and Inclusion.
• Working with UBIT, University Communications and decanal units to develop a plan to train content developers and unit web liaisons in web accessibility. This will foster unit-level expertise to remediate basic accessibility issues, while UBIT and EDI can offer centralized expertise for more complicated issues.

Course Accommodations

UB’s Office of Accessibility Resources will provide assistance with academic adjustments and auxiliary aids that are necessary for students with disabilities to have equal access to course materials. While public-facing videos, webpages and other electronic information must be accessible, information that is not public and that is provided solely to a class must be made accessible when a student with an impairment enrolls in the class and requires accessible content. Accessibility Resources can caption videos and provide other auxiliary aids to assist students and instructors in ensuring equal access to the course materials.

New and Redesigned Websites

UB’s Web Accessibility Policy applies to all university web content. It applies to websites created internally and to those designed and offered through vendors. Public-facing websites are required by law to be accessible to individuals with disabilities. Any new or redesigned web content is expected to meet accessibility requirements upon its creation or revision.

Previously Created Websites

Previously-created websites that are public-facing are also expected to meet accessibility standards, and should be remediated by November 15, 2019. It is understood that reviewing and remediating accessibility issues for each website can take time. You should therefore prioritize changes considering the following criteria:

• Is the information necessary to participate in UB programs and activities, or to obtain a benefit or service? For employees, is the information related to their job duties or conducting university business?
• How many people are expected to require access to the information? Prioritize websites and content that are expected to be accessed by the greatest number of people.
• What would be the practical and reputational impact if the material is not made accessible? Prioritize websites and other content that is most critical to facilitating and promoting inclusion. For example, if a department’s diversity plan is presented in an inaccessible PDF, this would have a clear negative reputational impact on the department.

As a checklist, review the following:

• Does your website use pictures to convey information? If so, ensure that each picture has an alt-tag so that a description can be accessed with a screen reader.
• Does your department provide forms or other documents in PDF format? If so, review the PDFs by using the Adobe Acrobat Accessibility Checker or by using the “Read Out Loud” feature under the “View” tab.
• Does your department use videos to convey information about UB? If so, provide captioning. Captioning benefits not only individuals with impairments, but also people who do not have or do not want to use speakers.
• When reviewing your website, can you tab through to access the links on the page? If so, your page will not be reliant on the use of a mouse, which promotes accessibility. Also check to see that when you tab, the order of movement of the cursor makes sense. If your cursor is jumping from one area of the page to another without a logical sequence, this will not promote usability.
• As more fully explained in the next section, any technology you purchase from vendors must also meet accessibility requirements.

UB offers many systems and programs that are purchased from vendors. Vendors do not always offer products that can be accessed with assistive technology, however. Products purchased through vendors must be accessible when they are used to access university programs, services and activities. In order to meet our obligations to provide accessible electronic information technology, it is essential to ask vendors to explain how their products are accessible and require supporting documentation whenever a purchased product will be used to access UB’s programs, services and activities.  

Question Vendors

When evaluating a product offered by a vendor, consider asking these questions:

1. Do you have clients who require accessibility? If so, would you be willing to provide reference information for clients who can speak to the accessibility of your product? 
2. What experience do developers on your team have coding for accessibility?
3. What standards are followed for coding of interfaces (if 508, what parts, if WCAG 2.0, which level)?
4. Do you do testing with users with disabilities? If so, can you explain the process and identify, roughly, the range of disabilities and access technologies used?
5. Does your company have a road map for accessibility going forward? If so, can you give us a general outline (goals, milestones)?
6. Have you tested or developed your mobile apps with accessibility in mind?
7. If we find that there are changes that need to be made to web, mobile interfaces or apps, what guarantee can we have that these will be implemented to our satisfaction prior to go-live or going forward?
8. Would your company indemnify UB against legal action related to accessibility?

Require a Voluntary Product Accessibility Template (VPAT)

One way to assess a vendor's accessibility efforts is to require a Voluntary Product Accessibility Template, or VPAT. The VPAT 2.0 is a standard form used by federal agencies to ensure that procured information technology meets accessibility requirements. Most publishers and vendors will be familiar with the VPAT requirement and will furnish a VPAT upon request. If a vendor refuses to provide a VPAT, this is a strong indication that the company has not considered accessibility in its product design, and you therefore must find a different vendor.

There may be situations where no vendor is offering an accessible product for a particular service. If this is the case, contact the Office of Equity, Diversity and Inclusion for assistance.

Controlled Web Content

The university offers web-based information for students and employees that is not public-facing. Examples of this information include online training courses for employees, course materials for students and online information systems. This information should be accessible when it is required to access university services and programs. With that said, there may be situations where creating accessible content is not feasible. For example, if a department creates video recordings of every single class that is taught and uploads them, captioning every class regardless of whether any registered students require this may be impractical and unwarranted. If a student who requires captioned videos due to an impairment enrolls in a course where lecture recordings are offered to students, or if the department chooses to make the lecture videos public, the content then must be captioned in a timely manner to provide equal access to the materials. In general, creating accessible content benefits a wide audience and is strongly encouraged regardless of whether it is legally required.

Examples:

• A course instructor provides videos of her lectures for students to review. In order to access these videos, students must be registered in the instructor’s course. There is no general requirement to caption the videos. If a student with a hearing impairment enrolls in the course and requires access to the videos, the university will be required to ensure the videos are captioned. The instructor must refer the student to Accessibility Resources. Accessibility Resources will ensure that the lecture videos are captioned because the student requires this as an auxiliary aid to participate in the course.
• An employee with a sight impairment registers for an online training course through UBEDGE. The course is offered through a vendor and is not accessible with the use of a screen reader. The department offering the training course must work with the vendor to attempt to resolve the accessibility issues. If the accessibility issues cannot be immediately resolved, the department must work with the vendor to provide a transcript of the course or other equally effective means of accessing the course content.

External Web Content

Individuals with sensory, motor and cognitive impairments must be able to access electronic materials when necessary to access university services, programs or activities. This includes content owned and controlled by UB, whether or not the content was created by UB or a third-party vendor.

In some cases, UB instructors or departments may refer students to external websites that are not part of UB’s domain for course instruction or for services. In these cases, it is important to check to determine that an external website is accessible if people will be relying on its contents to access UB programs and activities. If pre-existing programs and information cannot be made readily accessible, the university must ensure that a student or employee is provided with an alternative means to accessing the program or activity that is equally effective. A few examples follow:

• An instructor uses an external publisher’s online learning tools as part of course instruction. Students must complete homework assignments on the publisher’s website and can use the publisher’s online study guide. The instructor is informed by a student with a visual impairment that she cannot access the homework posted on the website with her screen reader. The instructor contacts the publisher, and receives confirmation that while some of the publisher’s website is accessible, the homework assignments are not. The instructor must provide the student with an equally effective means of completing homework assignments for credit, in order to give the student a comparable way of learning the material and earning credit for homework.
• A department uses an external vendor to process orders for tickets to university events. The department learns that the external vendor’s website is not accessible, but the vendor has a toll-free telephone number to call for ticket orders available during certain hours. The department must work with the external vendor to remedy the accessibility concerns. The toll-free telephone number does not provide equally effective access because unlike the website, it has limited hours of availability.

Contact the Office of Equity, Diversity and Inclusion (EDI) at ub‑webaccess@buffalo.edu or at (716) 645‑2266 if you have questions or need more information.