These implementing procedures support the University of Nevada, Reno Information and Communication Technology (ICT) Accessibility Policy as published in the University Administrative Manual.
Accessibility of online content and functionality is measured according to The World Wide Web Consortium’s (W3C) Web Content Accessibility Guidelines (WCAG) 2.0 Level AA and the Web Accessibility Initiative Accessible Rich Internet Applications Suite (WAI-ARIA) 1.0 techniques for web content. Additionally, the University seeks to achieve adherence to and conformance with the following standards, where possible:
- Americans with Disabilities Act of 1990, as amended
- Section 504, Rehabilitation Act of 1973
- Section 255 of the Federal Telecommunications Act and implementing regulations
- Twenty-First Century Communications & Video Accessibility Act of 2010 and implementing regulations
- W3C's Authoring Tool Accessibility Guidelines (ATAG)
- W3C's User Agent Accessibility Guidelines (UAAG 1.0)
- Math ML, DAISY, ePub3, PDF/UA
2.2 - Timeline for Conformance of Online Content & Functionality
- New Content and Functionality. Within six months of the adoption of the University of Nevada, Reno's ("University") ICT Accessibility Policy, all new (i.e. non-existent until on or after Policy adoption), redeveloped (i.e. existing before Policy adoption but substantially changed in terms of functionality or structure) online content and functionality created by the University must be accessible to people with disabilities as measured by conformance to the Benchmarks for Measuring Accessibility, except where doing so qualifies under the Exceptions section of the ICT Accessibility Policy.
- Pre-existing Content and Functionality. Within eighteen months of the adoption of the ICT Accessibility Policy, all pre-existing (i.e. existing before Policy adoption) online content and functionality created by the University on or after January 2013, but not subject to subsection (a) above, must be accessible to people with disabilities as measured by conformance to the Benchmarks for Measuring Accessibility, except where doing so qualifies under the Exceptions section of the ICT Accessibility Policy.
- Legacy Content and Functionality. Upon request by a qualified person with a disability, any legacy (i.e. content created prior to January 2013) and archive content (content no longer in use but subject to records retention schedules) must be accessible to people with disabilities as measured by conformance to the Benchmarks for Measuring Accessibility, except where doing so qualifies under the Exceptions section of the ICT Accessibility Policy. An equally effective accessible alternative may be provided until conformance is accomplished.
- Essential Content and Functionality. Within eighteen months of the adoption of the ICT Accessibility Policy, all essential (i.e. used to conduct official University academic and business activities or to complete required training) online content and functionality created by the University, but not subject to subsections (a), (b), or (c) above, must be accessible to people with disabilities as measured by conformance to the Benchmarks for Measuring Accessibility, except where doing so qualifies under the Exceptions section of the ICT Accessibility Policy.
- Third-Party Content and Functionality. Online content and functionality created by a third-party and used for critical transactions (e.g. websites used for prospective student applications, campus housing, campus dining, registering for classes, paying bills, obtaining transcripts) or to complete required training must either:
- Be accessible to people with disabilities as measured by conformance to the Benchmarks for Measuring Accessibility, except where doing so qualifies under the Exceptions section of the ICT Accessibility Policy; or
- An equally effective accessible alternative must be provided until conformance is accomplished.
- Accessibility Audit. An accessibility audit is expected to conclude during fall 2017 that may affect the timelines above and will further articulate an ICT Accessibility Implementation Plan (Accessibility Plan) for adoption and remediation to include details of the specific content and functionality covered within and procedures, resources, and training necessary to support compliance. The Accessibility Plan will also include sufficient quality assurance procedures including setting up a system of testing and accountability to maintain the accessibility of all online content and functionality on an ongoing basis. This also applies to online content and functionality developed by, maintained by, or offered through a third-party vendor or through the use of open sources, and includes setting up systems of accountability and verifying claims of accessibility by vendors or open sources. When fundamental alteration or undue burden defenses apply, or the ICT qualifies under the Exceptions section of the ICT Accessibility Policy, the University will provide an equally effective accessible alternative. In providing an equally effective accessible alternative, the University will take any actions that do not result in a fundamental alteration or undue financial and administrative burdens, but nevertheless ensure that, to the maximum extent possible, individuals with disabilities receive the same benefits or services as their nondisabled peers.
2.3 - ICT Procurement Procedure
Adopted: October, 2015
Revised: April, 2017
Information and Communication Technology (ICT) acquisitions must follow the Purchasing Guidelines established by the Nevada System of Higher Education Business Center North (BCN) Purchasing Department. Additionally, when making ICT purchases or renewals the purchase requestor or the department buyer must ensure a compliant Voluntary Product Accessibility Template (VPAT) [VPAT definition] or an acceptable alternative must accompany the P-Card, Request for Check paperwork or Requisition before the purchase can be paid/made. The only time the BCN Purchasing Department will obtain the VPAT is when conducting a formal bid. Only vendors with a compliant VPAT or acceptable alternative will be evaluated and awarded the bid.
The vendor must ensure all ICT conforms to the Benchmarks for Measuring Accessibility. This includes any student-, faculty-, or staff-facing portions of the proposed product. Vendors must submit a completed VPAT as part of the response/proposal. Vendors must declare if any portion of the proposed product under consideration does not fully conform to the Benchmarks for Measuring Accessibility, the ways in which the proposed product is out of conformance and a remediation plan or acceptable alternative. The ICT Accessibility Committee will review and approve the remediation plan or acceptable alternative. A detailed ICT Purchasing Procedure and associated forms can be found on the Accessibility & Technology Website.
2.4 - Instructional Materials
Procedures for assessing the accessibility of instructional materials and tools and the use of University approved systems and tools can be found on the Accessibility & Technology Website.
2.5 - Classrooms, Class Labs, & Meeting Spaces
- Classroom training is provided, by the Classroom Technology division of Teaching & Learning Technologies (TLT), for any user upon request. Contact information is placed both on the podium and the desktop of the classroom computer and is available via the TLT website.
- Classroom support is provided upon request, typically, with a five minute or less response time. Contact information is placed both on the podium and the desktop of the classroom computer.
- Screen reading software is installed on the classroom computers.
- Additional assistive technology software can be installed on the classroom computer upon documented request to the space owner. Proof of purchase and license verification for the software are required. A detailed process and associated forms can be found on the UNR Accessibility & Technology Website.
- Facilities Services is responsible for ensuring furniture layouts and clearances meet ADA standards in classrooms.
For additional information about the accessibility of classrooms, class labs and meeting spaces, contact the Classroom Technology division of Teaching & Learning Technologies (TLT) or the space owner.
2.6 - Computer Labs
- All standard accessibility and screen magnification features are installed with shortcut keys enabled.
- Screen reading software is installed on computers in all general access computer labs.
- Additional assistive technology software and hardware (including, but not limited to, sound cards, appropriate amount of memory to support the use of adaptive devices and software, ergonomic and other alternative keyboards, trackballs, headphone jacks, joysticks) are made available in consult with the Disability Resource Center (DRC) upon documented request to the space owner Proof of purchase and license verification are required.
A detailed process and associated forms can be found on the Accessibility & Technology Website.
2.7 - Websites and Web Content
All colleges and divisions must designate a faculty/staff as the contact person for all web content within their division or college. The contact shall be responsible for the following:
- Maintaining a registry of all websites within the college/division that are used for official academic or business activities
- Monitoring accessibility compliance of registry websites
- Reporting the registry to the ICT Accessibility Committee
All website content creators are responsible for the following:
- Completing web accessibility training
- Monitoring accessibility conformance of content created
Web content identified as non-conformant shall be subject to any or all of the following:
- Removal from the University domain and/or network
- Removal of links from University webpages
- Escalation to the Office of the Provost for non-conformance with Benchmarks for Measuring Accessibility
All department and administrative unit websites currently hosted externally, have 120 days from the adoption of the ICT Accessibility Policy to migrate their content to a University server or ensure that content hosted off premises on non-university servers is in compliance with the ICT Accessibility Policy. Faculty may have their personal websites on University or external servers. Faculty websites must be in compliance with the ICT Accessibility Policy. If a website is found to be non-compliant, the designated contact person responsible for that website will be notified by the Office of the Provost of the website’s deficiencies or non-compliance. The person, department or administrative unit responsible for the website will have 60 days to bring their website into compliance. Failure to bring the website into compliance within that 60-day period, will result in the website being removed from University servers until such time as it can be brought into compliance. If the website is hosted externally and it is not brought into compliance after notification from the Office of the Provost, then the faculty member who is using the website for academic courses or class work may be subject to discipline under the Nevada System of Higher Education (NSHE) Code.
2.8 - Library Services & Library Website
The University's library website is accessible in accordance with Section 504 of the Rehabilitation Act of 1973 (Sec. 504), the Americans with Disabilities Act of 1990, as amended (ADA), and University Benchmarks for Measuring Accessibility. Conformance is ensured through monthly accessibility scans to ascertain whether any newly posted content is non-conformant. If corrections are needed to pages, content authors are required to make corrections in a reasonable timeline. Library Services provides assistance to users, including those with disabilities, upon request. The following categories of assistance are provided. Library Services training and operations documents will include this information and staff are made aware of these expectations. Users may ask for assistance at the Library Services Desk for the following:
- Assistance in accessing other areas of the building
- Book paging (retrieval) upon request
- Wheelchair-accessible lockers (availability varies - request before the first week of classes)
- Other related assistance as staffing allows (with copiers, printer, Wolfcard machines, etc.)
2.9 - Training
Web accessibility training is provided by Teaching & Learning Technologies (TLT). The training schedule is available at the Accessibility & Technology Website, along with other training tools and resources. The University provides training, instruction, and support to all personnel regarding the University's policy and procedures concerning accessibility. This also includes providing tools and techniques for faculty and staff to use to ensure accessibility. All faculty and staff that create web content are required to take annual training on web accessibility. This includes, but is not limited to, all faculty that use the learning management system (LMS), website Content Management Systems (CMS) or other website users (WolfWeb, etc.), Library Services faculty and staff, Office of Information Technology (OIT) staff, or any other personnel that create documents for electronic distribution. Additional web accessibility training may also be required for advanced systems such as the website Content Management System (CMS), on an annual basis. Faculty and staff with purchasing responsibilities must familiarize themselves with the ICT Accessibility Policy and the ICT Procurement Procedure.
2.10 - Audit
The University will regularly audit its ICT to examine the accessibility and usability of the ICT provided to students, prospective students, faculty, staff, and members of the public who have disabilities. The University will audit, during 2017, all content and functionality on the University website, including, but not limited to, the home page, all subordinate pages, and the University's intranet pages and sites, and identify any online content or functionality that is non-conformant, including online content and functionality developed by, maintained by, or offered through a third-party vendor or an open source. The audit will be conducted using the Benchmarks for Measuring Accessibility. During the Audit, the University will seek input regarding the accessibility of its website from persons knowledgeable about website accessibility, including employees, parents, students, and members of the public with disabilities.
- A Corrective Action Plan will be developed to address all non-conformant content and functionality identified during the Audit
- After the initial audit has been completed, subsequent periodic audits of ICT will be conducted on a regular schedule as per the Corrective Action Plan and reported to the ICT Accessibility Committee. The ICT Accessibility Committee or their designee will bring non-conformance issues and/or recommendations to the attention of the ICT responsible party.
- Tools, checklists, workshops, and other resources for self-auditing are available on the Accessibility & Technology Website
2.11 - Surveys
The University conducts a confidential survey of students who are registered with the Disability Resource Center. The survey includes questions that identify the strengths and weaknesses of the student's experiences with ICT at the University. The student survey is administered as part of the DRC Student Satisfaction Survey at the end of the fall and spring semesters and anonymous results are posted on the DRC website. The ICT Accessibility Committee may use periodic surveys to gather information to asses and improve ICT at the University. Those results are analyzed by the members of the Committee and kept with Committee or appropriate subcommittee Chairperson.
2.12 - Procedural Definitions
- Purchase requestor. The person making the request for purchase of Information and Communication Technology.
- Department buyer. The department at the University that will be making the arrangement with the vendor.
- Voluntary Product Accessibility Template (VPAT). A tool that enhances industry-customer communications on ICT product and service conformance with relevant accessibility standards and guidelines.
- Web content. Any sort of media including, but not limited to Images, text, PDF documents, Excel documents, videos, and audio to be presented via a web technology.
- Website content creators. The individual or department creating some kind of media to be presented via web technology for other people’s consumption.