Below are the most frequently asked questions related to Information and Communication Technology (ICT) and CSUN's ATI Procurement Procedure:
- ICT FAQ's
- ATI Procurement FAQ's
- Accessibility Review FAQ's
- VPAT FAQ's
- Plan for Alternate Access FAQ's
ICT stands for Information and Communication Technology and it is a term used to describe technologies that provide access to information and/or serve as a mechanism of communication. This term was previously referred to as Electronic and Information Technology (E&IT) but as of March 2018, it has changed to ICT.
E&IT and ICT refer to the same thing. However, E&IT was replaced with ICT as of March 2018 following an update to Federal Laws and standards covered in Section 508 of the Rehabilitation Act and Section 255 of the Communication Act. Following the update, ICT became the globally recognized term for technologies that provide information and/or serve as a method to communicate.
ICT includes information technology and any equipment or interconnected system or subsystem of equipment that is used in the creation, conversion, or duplication of data or information. The following technologies fall into the category of ICT and any purchases of these technologies must go through the CSUN ATI procurement Procedure:
- Computer keyboard (when purchased alone)
- Computer mice
- Flash drives
- Hard drives
- Installation equipment (e.g., wall mounts, mounting brackets, cables)
- Power supplies and batteries
The Accessible Technology Initiative (ATI) requires that all CSU’s implement procedures to procure the most universally accessible ICT products and services in the market. CSUN ATI Procurement Procedure helps ensure that we are adhering to this law and the principles of accessibility for all. To read more about CSUN’s ATI Procurement Policy refer to the ICT Procurement Page.
When departments intended to purchase an ICT product, service or activity, they must start by filling out the pre-purchase accessibility form* located in the Purchasing and Contract Administration ATI Procurement page. Once the form is submitted the ATI procurement team will review the information provided and determine the impact the product will have to the University related to accessibility. Products identified as having high or medium accessibility risk will be placed in a queue to undergo a more comprehensive accessibility review by the Universal Design Center. Once the review is complete, departments and vendors will receive a report outlining areas where accessibility barriers may be a problem in these products and the steps they must take to adhere to CSUN’s ATI procurement Policy. Refer to the Accessibility Review page for more information.
*NOTE: The pre-purchase accessibility form is currently called the E&IT form. In the following months, this name will be changing to reflect current changes to the laws and standards.
Impact is defined as the overall effect an ICT purchase will have on the campus and this effect could influence users with disabilities. Impact is categorized into three levels: Low impact, medium impact, and high impact. A higher impact level increases the need to ensure that the purchased product is universally accessible.
At CSUN, we do not have any exemptions to the ATI Procurement Procedure. However, the ATI procurement group has pre-approved select ICT products and services for the CSUN community and has outline requirements departments must follow if they are purchasing these items. Refer to the Purchasing and Contract Administration ATI Procurement page for more information.
In compliance with California State University Executive Order 926 and Coded Memorandum AA-2013-03, departments at CSUN have an obligation to analyze the ICT prodcuts they purchase and ensure accessibility is addressed for these products. This means, departments should strive to procure the most accessible product of its kind in the marketplace and/or create plans of alternate access that ouline the departments steps to ensure all students, faculty, staff and the general public and access their technologies regarless of disabilites. Refer to the ATI Procurement Page: Department Responsiblities for more information.
To learn more about the accessibility review for ICT products, go to the ICT Accessiblity Review page.
Products that are placed in queue for an accessibility review are those that are considered to potentially have a significant impact to the campus community. Below are general guidelines for medium and high impact. However, please be aware that these guidelines are not all inclusive and are subject to change..
- Product will be used campus-wide
- Product will be used by a large campus audience in a college, division or department or by members of the public
- Product is a strict requirement of academic and administrative procedures
- Usage of product will directly impact a specific program and /or service on campus
- High exposure to product on campus
- Strong likelihood product will impact people with disabilities
- High risk of accessibility barriers
- Product will be used by a moderately-sized campus audience in a college, division or department or by members of the public
- Usage of product will directly impact a program and/or services within a moderately-sized division, college or department
- Exposure to product will be moderate
- There is a likelihood that this product could impact people with disabilities
- The product has potential accessibility barriers.
If a product is determined to be potentially medium or a high campus impact purchase, it will be placed in a queue for a comprehensive accessibility review by the Universal Design Center. You will receive an email from the Universal Design Center informing you that your product may be reviewed soon.
The accessibility review will typically occur within the first year of your ICT purchase or renewal. However, due to the high volume of ICT purchases at CSUN, there is extensive amount of ICT products awaiting a review and as a result, some products may not be reviewed within the first year. Those products that did not undergo a review the first year will be placed higher in the queue for future renewals.
The accessibility review can generally take within a few days to even a month. This ultimately depends on the product to be reviewed and the kind of accessibility review conducted.
If the UDC is unable to conduct an accessibility review in the first year of purchase, you can still purchase your product for the next renewal cycle. Your product will not be put on hold by the purchasing department if the accessibility review is not complete. Instead, when you renew your product, your product will re-enter the accessibility review queue and may be selected for a review in the next renewal.
Following the accessibility review, you may be required to complete a Plan for Alternate Access (PAA). The PAA is a document that must include what measures a department will take to provide alternate access solutions to users with disabilities. Additionally, some departments may be asked to sit down with the Alternate Access Working Group, a sub-group to the ATI Procurement Group, to further discuss their product and identify the most effective alternate access solutions for users.
Failure to develop an alternative plan of access could result in the denial of approval for purchase or renewal of a product/service. Purchasing and Contracts Administration Department has a list of departments with outstanding documentation and will hold the purchase until it is submitted.
It depends. While, the goal of the ATI procurement procedureis not prevent ICT purchases, if an ICT product or services is identified to have extensive accessibility barriers and poses significant risk to the campus, a replacement product may be needed instead. The ATI Procurement group and sub-groups will work with departments on a case-by-case basis.
VPAT stands for Voluntary Product Accessibility Template and it is the first step to understand the accessibility of an ICT product. This form is completed by ICT vendors and documents their products conformance to ICT accessibility standards including Section 508 (U.S.), W3C/WAI WCAG 2.0, and EN 301 549 (EU).
A completed VPAT should state which criteria the product supports, and explain what features it utilizes to support accessibility. At CSUN, a VPAT must be requested from the vendor for all ICT products being procured.
In March 2018, there was an update to Section 508 laws and standards which also resulted in an update to the VPAT. The VPAT 2.0 is the revised version of the VPAT/VPAT 1.0 and contains additional conformance requirements including requirements for Web Content Accessibility Guidelines 2.0 (WCAG 2.0).
Beginning October 2018, CSUN requires vendors to provide a VPAT 2.0. Exceptions can be granted on a case by case basis.
If you are unable to obtain a VPAT from your vendor please contact the ATI procurement group for assistance. Ultimately, a vendor’s refusal to address accessibility deficiencies/concerns could result in non-purchase or non-renewal of the product/service.
To provide your vendor a template to the latest VPAT form, refer them to the VPAT section in the Vendor Resources Page.
For more informaiton on Plan for Alternate Access, go to the Plan for Alternate Access page.
A Plan for Alternate Access or PAA is a document to be completed by departments which outlines the steps a department will take to support users with disabilities. The plan is generally completed after the accessibility review of the product and must be submitted to the alternate access working group before any further pruchases or renewals can be completed for the product.
Departments need to create a PAA for all ICT products that will be used by a large number of people and present known accessibility barriers. Departments will receive a notification from the UDC to complete a PAA following an accessibility review of their product. However, if the department is aware of the accessibility barriers in their product, they can complete the PAA before the purchase and submit it with the campus Technology Procurement Form. Submitting the PAA early in the process can streamline the purchase and future renewals of the product.
For most high impact purchases, the UDC will conduct a comprehensive accessibility review to find the accessibility barriers in the product. However, due to the high volume of ICT products in a queue, the UDC may be unable to review all ICT purchases.
As a result, departments are encouraged to conduct a preliminary, basic accessibility review to self-identify the level of accessibility and the potential accessibility gaps in the ICT product they are purchasing. UDC’s Conducting Accessibility Evaluations page will help departments conduct basic accessibility reviews by offering various testing methods they can use.
Alternate access solutions are about ensuring equitable and effective access to technology for all individuals regardless of any ability or disability. When ICT products have accessibility gaps, the gaps may prevent or make it difficult for users with disabilities to use the product or gather information. Alternate access solutions are required to allow users with disabilities the ability to perform the same tasks or gather the same information as all users.
Alternate access solutions will vary by department or by product. To come up with alternate access solutions departments can consider the following:
- How critical is the product for the department?
- Are there other processes that can be used to allow a user to achieve the same end goal?
- Are there alternative products a user can use to gather the same information?
- Is there someone in the department who can provide support when users have problems utilizing the product?
Departments will generally have 30 days to submit a completed PAA to the UDC following an email notification or following the meeting with the PAA group. If needed, departments can request extensions to the UDC.
The PAA for a product should be on file by the next renewal purchase or the department may be unable to renew the purchase.
To help guide the development of alternate access plans, the ATI Procurement group has created a sub-group called the Alternate Access Working Group. The group is comprised of members from the UDC, the Department of Equity and Diversity, Disability Resources and Educational Services (DRES), Deaf and Hard of Hearing Services (NCOD), and the Computer & Mobile Device Committee (CMDC). The members will work with departments to create alternate access solutions for the ICT products being purchased.
At this moment, the PAA group will be scheduling appointments with departments whose ICT purchases will be used by a high volume of users or whose products present significant accessibility barriers. The committee meets two times a month to review high impact purchases and will schedule a department of a high campus impact request during one of the regular meeting dates.