This policy guidance provides information and recommendations for complying with UB’s EIT Accessibility Policy.
Recognizing that electronic and information technology (EIT) accessibility can be complicated, no single guidance document can completely address every related issue. This guidance document explains applicable standards and procedures at UB.
The State University of New York and the University at Buffalo are strongly committed to diversity and inclusion. An essential part of inclusion, EIT accessibility helps ensure that individuals with disabilities have equal access to electronic and digital resources and content. Additionally, EIT accessibility is required by law. People with sensory, motor, cognitive or learning impairments may not be able to access digital content that is created or structured in certain ways. These individuals may use assistive technology, such as captioning, screen readers or other modifications, to access digital content. While assistive technology can be very effective in conveying online content, digital content designed without accessibility in mind may form barriers to access. Understanding common issues for individuals with impairments helps authors and developers appreciate the need for ensuring accessibility in EIT.
Individuals with visual impairments may use assistive technology such as screen readers to read the text on a webpage aloud or convert the text to Braille. It is valuable to understand how a screen reader user accesses digital content.
Users with cognitive and learning impairments may:
Users with hearing impairments rely on synchronized captions on videos and transcripts of audio files to understand the content on a page.
Users may not be able to operate a mouse, making keyboard or alternative input navigation essential. They may also need more time to complete tasks on a webpage and/or larger clickable target areas.
The World Wide Web Consortium (W3C) has established accessibility guidelines through its Web Accessibility Initiative (WAI). The WAI’s Web Content Accessibility Guidelines (WCAG) are widely considered the international standard in ensuring accessible electronic content.
The university recognizes that adoption of the WCAG 2.1 AA standards is critical to increasing EIT accessibility. We are in the process of transitioning compliance to this level and expect to be completed by March 2023.
WCAG 2.1 focuses on four user-centered principles of accessibility:
WCAG 2.1 includes all success criteria from 2.0, with 17 additional success criteria that address mobile accessibility, as well as practices to promote accessibility for people with low vision and people with cognitive and learning disabilities.
The guidelines include, but are not limited to, the following requirements:
For additional information about WCAG, please see the following websites:
UB’s Content Management System (UBCMS) includes accessibility features that help authors create and maintain accessible websites. For example, the UBCMS requires authors to add alternative text to images. The UBCMS also makes it easy for authors 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 document/file (PDF, Word, PPT, etc.), writing generic link text, creating unhelpful or inaccurate alternative text, or posting a video without captions. Website owners and authors must be intentional in planning for accessibility when creating or revising web content.
The Accessibility at UB website provides assistance in understanding and creating accessible content. You can obtain detailed information and instructions in each of the following areas:
Building and maintaining accessible websites takes time, guidance and resources. Compliance with the EIT Accessibility Policy requires a combination of individual effort, area-level assistance and centralized expertise and resources. UB’s resources in this area include:
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. Instructors are encouraged to enable auto-captioning in Panopto (although this is imperfect and requires manual review and editing).
UB’s EIT Accessibility Policy applies to all university digital content including:
When creating or editing websites, web content, applications, etc., take the time to test for accessibility during development and prior to launch. Identify the essential tasks that a user would complete on the website and perform both manual and automated testing for each one.
Any technology you procure from vendors must also meet accessibility requirements. See the Procuring Technology Requirements for detailed information.
UB has some digital content that may no longer be needed or used to access current university programs, services or activities, but may have historical impact. As stated in the EIT Accessibility Policy, archived content at least five years old is not required to meet web accessibility standards, but the university is required to provide equally effective alternative access to the content upon request. Some examples of archived content include:
EIT accessibility requirements also apply to email content to ensure that people with disabilities have equally effective and timely access to information in email and attachments. Whether you are sending a plain text email or creating a branded email with a tool like Mailchimp, accessibility standards apply.
Be sure to:
When using social media for university services, programs and activities, utilize the accessibility features available in each platform.
In addition, follow these best practices in social media content:
UB’s EIT procurement process helps ensure that products/services purchased by the university meet accessibility standards and align with our institutional values of equity and inclusion. EIT purchased through vendors must be accessible to all individuals, including individuals with disabilities, when they are used to access university programs, services and activities. In order to meet the university’s commitment and obligation to provide accessible EIT, vendors are required to explain how their products/services are accessible and provide supporting documentation.
The university’s EIT procurement process includes several levels of assessment and review.
The purpose of the intake step is to gather information about the nature and purpose of the product and determine the impact the product will have on university programs, services and activities.
Before you make any EIT purchase or renewal (regardless of cost or scope of usage), you must complete one of these two forms (along with their associated steps, including submitting a VPAT/ACR as required):
|Low||EIT is not part of an essential program, service or activity||● Low number of users; small controlled group of users |
● Single instance intended for individual use
● Not public facing
|● Departmental internal project management tool|
|Medium||EIT is not essential but limits access to a program or service||● Moderate number of users |
● Used by an individual department or school, but not used across the university
|● EIT used for a single course but not required for degree completion|
|High||EIT is part of an essential program, service or activity; the product is core to the business of the university ||● High number of users |
● Enterprise-wide, mission critical, student-related
● Public facing or publicly available
|● Student information system |
● Course registration system
If you have a question about the impact level of your desired EIT, please contact EDI for assistance.
The purpose of the evaluation step is to assess the accessibility of the product and determine if it meets accessibility requirements. Testing proceeds as follows:
|Medium||EDI or the departmental web accessibility liaison reviews the vendor’s VPAT/ACR and performs basic manual and automated testing to certify the product’s accessibility. |
|High||EDI reviews the vendor’s VPAT/ACR and performs in-depth testing that includes full manual and automated testing of all key pages, user journeys and top task completion. |
After evaluation, EDI grants decisions as follow:
Regardless of approval status, all medium- and high-impact EIT must have an EEAAP that includes a contact person and a description of how the department/unit will provide accommodations if someone with a disability needs access to the product. (See the complete EEAAP requirements.)
Additionally, all EIT must have a prominent, easy-to-find accessibility statement and information about how an individual can receive accommodations.
The purpose of the exception request is to determine if the product qualifies for an exception from the EIT Accessibility Policy. Limited exceptions may be granted in specific instances where compliance is not possible or would constitute undue administrative or financial burdens or where it would create a fundamental alteration. Departments requesting an exception must provide an EEAAP to ensure that, to the maximum extent possible, individuals with disabilities receive the same benefits or services as their nondisabled peers.
An Equally Effective Alternative Access Plan (EEAAP) is required for all medium- or high-impact EIT, regardless of approval status. Even with products/services that are reviewed and deemed accessible, the user experience may change based on product updates, updates to browsers or operating systems that interface with the product, or the user’s hardware, software or settings. An EEAAP details how individuals with disabilities who have difficulty using the EIT will be provided timely and effective access to the services, information and programs provided by the EIT. Please note that an EEAAP is not a substitute for accessibility and should be reviewed regularly.
The EEAAP must include the following:
In order to begin assessing the accessibility of a product, the university requires that vendors submit a completed Voluntary Product Accessibility Template (VPAT®), also known as an Accessibility Conformance Report (ACR), or comparable documentation. The VPAT 2.x+ is a standard reporting form used to provide an analysis of a product’s conformance to accessibility standards—WCAG 2.1, Section 508 and European Standard EN 301 549.
Most vendors are familiar with the VPAT requirement and will furnish a VPAT upon request. The VPAT should be completed in its entirety and include testing procedures, conformance level and detailed comments about any partially- or non-supported level according to the WCAG 2.1 AA success criteria. In place of a VPAT, vendors may produce alternative documentation establishing the product has been reviewed for accessibility by an independent, credible and knowledgeable service using appropriate standards and testing.
If a vendor refuses to provide a VPAT or similar documentation, this is a strong indication that the company has not considered accessibility in its product design. The department should explore alternative products/services.
In some instances, no vendor offers an accessible product for a particular service. If this is the case, contact EDI for assistance.
Please note that the VPAT/ACR is just one component of the EIT accessibility review and will be retained in case of an audit or for additional review.
The university provides digital content for students and employees that is not public facing (e.g., online training courses for employees, course materials for students and online information systems). This information must be accessible when it is required to access university services, programs or activities. However, in some situations, creating accessible content is not feasible. For example, if a department creates video recordings of every single class and uploads them, captioning each one 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 possible legal risk.
Individuals with sensory, motor, cognitive and learning 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 for course instruction or services. It is important to verify that external websites are accessible if people must rely 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 equally effective alternative access to the program or activity.
Contact the Office of Equity, Diversity and Inclusion (EDI) at ub‑firstname.lastname@example.org or at (716) 645‑2266 if you have questions or need more information.