Accessibility Procurement

The University procures ICT that is universal in design and accessible to all individuals, including individuals with disabilities. In the event this is technically infeasible or imposes undue burden, the University ensures an equally effective accessible alternative. All ICT must meet the applicable accessibility standards set forth in Section 508 of the Rehabilitation Act of 1973, as amended (Sec. 508), the Americans with Disabilities Act of 1990, as amended (ADA), and University of Nevada, Reno Benchmarks for Measuring Accessibility

ICT Procurement Process

STEP ONE: Research

Address Accessibility. Review accessibility needs early in your third-party product and vendor evaluations.

  1. Research which products/services are available for your needs
  2. Look to see if the product or service you selected is on the ICT Approved Product List. If so, proceed with your purchase. If not, proceed as follows.
  3. Talk with your vendor about accessibility and test the product with a keyboard
  4. Obtain compliant accessibility documentation from the vendor, using a Voluntary Product Accessibility Template (VPAT)
  5. Obtain the vendor's most recent accessibility testing results and remediation road map
    • Vendors must provide documentation of their most recent accessibility test results. If any accessibility barriers exist, the vendor must also provide documentation of their intent to remediate those barriers including a time line for expected completion of remediation.
    • If the vendor does not have a VPAT and accessibility test results, following are few resources you can recommend that offer consulting and testing services.

STEP TWO: Submit for ICT Review

Gather and Submit Accessibility Documentation. Gather and prepare your accessibility documentation. The most expedient path to a positive accessibility review is for you to provide documented evidence that a vendor is committed to providing an accessible product. Examples of that documentation may include; VPAT, evidence of accessibility review by the vendor or a third-party, an accessibility development road map, a contract clause indicating the product adheres to accessibility standards.

  1. Gather required accessibility documentation from vendor, including the following:
    • VPAT for products or a 508 Accessibility Statement for services
    • Vendor's accessibility testing results and accessibility development road map
    • Contract clause or vendor statement of commitment to accessibility
  2. Complete and submit the Information and Communication Technology (ICT) Software Accessibility Review form and attach accessibility documentation
  3. After the ICT documentation review has been completed, the requestor will receive a final determination statement by email from the Accessibility Review Committee. Expected timelines follow.
    • If you include all three required documents with the above form, the review may be complete in as little as one week
    • If the product is student- or public-facing, it also requires internal UNR ICT Software Accessibility Review Committee testing to identify any potential critical barriers to access and clarify any questions regarding the VPAT and vendor-provided testing results. You will be contacted within one week if such testing is necessary and it is advised that you begin to work with your vendor now to facilitate such access in order to keep the process moving forward. If testing is deemed necessary, access will be required to all the products and features that UNR is considering for use (student-, public-, and employee-facing) to assess how well it performs with assistive technology and to determine if it meets University Accessibility Benchmarks. Once access has been established, you can expect test results within ten working days. When the tests are complete, you will receive a written report of those findings and a recommendation of next steps.
    • The Committee has the discretion to choose not to test some student- or public-facing software. Examples of instances that may preclude testing include;
      • Software that has limited impact (relatively low number of users, 100 users is our current cut-off)
      • Committee has prior knowledge of the product accessibility (tests performed by other institutions)
      • Provided documentation clearly satisfies all Committee interests
      In these cases where the Committee has determined that additional testing is not necessary, final determination can be expected within one week from submission
    • If the product is not accessible and you request the Committee engage with you and your vendor to ensure an accessible product, this historically takes an average of eight weeks. We will gladly perform this service, currently at not cost to you or your vendor, but want to ensure you are aware of time it will take and encourage you to begin this process early.

STEP THREE: Complete Purchase

Submit NSHE Purchase Request. After receiving a determination from the ICT Software Accessibility Review Committee, complete the purchase according to NSHE BCN General Purchasing Guidelines.

What to do if your ITC request is not accessible?

If your accessibility review documentation indicates the product or service is not accessible, you can do any of the following:

  1. Develop an Equally Effective Alternative Action Plan (EEAAP). Work with your vendor to develop an Equally Effective Alternate Access Plan (EEAAP) and submit to the ICT Software Accessibility Review Committee for approval.
  2. Submit an Alternative Option. Select a more accessible solution.
  3. Submit an Exception Request. Submit an ICT Accessibility Exception Request form.

Procurement Procedures

Information and Communication Technology purchases must follow the established NSHE General Purchasing Guidelines. When making EIT purchases or renewals the Purchase Requestor or the Department Buyer, must include a compliant Voluntary Product Accessibility Template (VPAT) or acceptable alternative with 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 Software Accessibility Review Committee is available to assist with evaluating the accessibility of products.

The vendor must ensure all ICT conforms to accessibility standards as defined above. 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 accessibility standards, the ways in which the proposed product is out of compliance and a remediation plan or acceptable alternative.

VPATs will be kept on file at the University for the duration of the product's or service's life cycle. If, at any time, the product or service no longer conforms to the guidelines and laws defined above, the vendor will notify the original Purchase Requestor or the Department Buyer in writing within fourteen calendar days explaining the justification of the change which rendered the product or service noncompliant and the proposed remediation plan or acceptable alternative. If vendor is unable or unwilling to bring the product or service back into compliance with the guidelines and laws defined above without making technically unfeasible modifications, the vendor may supply the University with an accessible alternate EIT that provides an equal experience for the user at no additional expense to the University. Failure to notify the University of such a variance or failure to provide an acceptable alternative in a timely manner, not to exceed thirty calendar days, shall be considered a breach of contract.

NOTE: Portions of this procedure have been adapted from the California State University Accessible Technology Initiative.

Accessibility Procurement Definitions

Information and Communication Technology (ICT). ICT includes applies to all technology and any equipment or interconnected system or subsystem of equipment that is used in the creation, conversion, or duplication of data or information employed in support of the University's Mission and Core Themes. ICT includes, but is not limited to, the internet and intranet websites, content delivered in digital form, electronic books and electronic book reading systems, search engines and databases, learning management systems, classroom technology, instructional materials, student response systems ("clickers"), and equipment such as classroom podiums, copiers and fax machines. ICT also includes, but is not limited to, telecommunications products (such as telephones), information kiosks, Automated Teller Machines (ATMs), transaction machines (such as payment terminals), computers, ancillary equipment, software, services (including support services), equipment maintained and services operated by third-party vendors, and related resources.

Purchase Requestor.The person making the request for purchase of ICT.

Department Buyer.The department at the University that will be making the purchase with the vendor.

Vendor. The entity the University wants to purchase the ICT from.

Accessibility Review Committee. A standing committee that offers advice on the accessibility of products and services to purchasers.

Acceptable Alternative. May include plans and a time frame for achieving conformance or an alternate workaround.