UDC

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Procurement

Electronic and Information Technology

In accordance with California Government Code 11135, the California State University (CSU) system requires that all programs, services, and activities of the CSU be accessible to all students, faculty, staff, and members of the public. This includes working to ensure that all electronic and information technology (E&IT) products are also universally accessible. The CSU's policy on accessibility as articulated in Executive Order 926 (EO926) is guided by the CSU Accessible Technology Initiative (ATI) as stated in the ATI Coded Memorandum AA-2013-03.  The CSU ATI focuses on the elimination of accessibility gaps within three key areas: web, instructional materials, and procurement.  The CSU ATI Procurement Process requires that vendors who provide Electronic and Information Technology (E&IT) products to campuses within the CSU system, must also provide documentation about their products accessibility and must work with the CSU system and campuses to mitigate accessibility issues and concerns in the products they are providing.  

CSUN ATI Procurement Process

In accordance with CSU policy and the law, CSUN has put in place the ATI Procurement Process to ensure that E&IT products purchased on the CSUN campus are accessible to everyone. The ATI Procurement Process requires that vendors who provide E&IT products to campuses within the CSU must also provide documentation about their products accessibility and must work with the CSU to mitigate accessibility issues and concerns in the products they are providing.  Through the CSUN ATI Procurement Process, all E&IT products undergo an E&IT review to determine the impact the product will have on the University. Following the E&IT review, products identified as having high campus impact undergo additional evaluation and requesting departments must complete supplemental documentation about their products.

Campus Procedures:

Below you will find a step by step explanation of the ATI Procurement Process along with resources that will help you adhere to each step of the process. 

Step 1: Pre Analysis

Determining if your product must undergo the ATI Procurement Process 

ALL E&IT products identified under section 508 must undergo the ATI Procurement Process. Below are the six categories of products identified under Section 508:

  • Software applications and operating systems (including annual license renewals)
  • Web-based information and applications (including annual license renewals)
  • Telecommunication products
  • Video and multimedia products
  • Self-contained, closed products (copiers, fax machines)
  • Desktop and portable computers

An E&IT review form should NOT be completed for the following products:

  • Computer mice
  • Computer keyboard (when purchased alone)
  • Flash drives
  • Hard drives
  • Power supplies and batteries
  • Installation equipment (e.g., wall mounts, mounting brackets, cables)

Step 2: Completing The Electronic and Information Technology (E&IT) Form

The next step of the ATI Procurement Process is to complete the E&IT Procurement form. This E&IT Procurement Form is intended to provide information about the use and purpose of the product in order to determine the impact of the product on campus.  The E&IT form must be completed by the department requesting the E&IT purchase. The E&IT Procurement form can be found on the ATI Procurement Purchasing Website.

It is critical that requesting departments complete the E&IT procurement form with as much accuracy as possible. Failure to provide accurate information on the form could result in delays in the purchases of your product and could prevent your product from being purchased.

What information should be provided on the form?

Below you will find a summary of required information needed for each section of the E&IT Form.

Section 1: Requester Information/Transaction

Requesting department should provide all their contact information as well as the Requisition or PCard Case number in this section. If there is more than one requestor name, it should be included.

Section 2: Functional/Performance/Impact

The information provided in this section is critical in order to conduct an accurate E&IT review of your purchase. Providing clear and precise answers in this section will help us assess proper impact of the purchase

The following needs to be addressed in this section:

  1. What is the product to be purchased and what does it do?
  2. How will this product be utilized on the campus?
  3. Who will be the targeted users of the product?
  4. How many people will use the product?
  5. Where will this product be used?

Section 3: Product Chosen

Requestors must provide information about the product to be purchased such as the product name, version (if available), new/renewal purchase, type of the product and the product URL (if any).  

Section 4: Voluntary Product Accessibility template (VPAT)

VPAT

Along with the E&IT form, requestors must submit the Voluntary Product Accessibility Template (VPAT) of the product. The VPAT is a document that states the accessibility aspects of the product. Requestors must obtain the form from the vendor(s) of their product.  If the vendor(s) does not have an existing VPAT, the requestor must supply a blank VPAT CSU Guide to Completing the Voluntary Product Accessibility Template (VPAT) (DOCX) Microsoft Office document iconto the vendor(s) to complete and return by a specific date. It is the responsibility of the requestor to follow up on obtaining the VPAT.

If the VPAT is not available, the requestor must explain why it cannot be provided in this section (For example, the vendor has not provided a VPAT).

Section 508 Product Categories

The checklist provided in this section pertains to the six categories of E&IT products pertaining to section 508. Requestors must check all categories that apply to their product. 

Submit

When filling out the E&IT form, always make sure you have downloaded/saved the form to your computer to complete and activate the submit button. DO NOT work and submit the E&IT form through a web browser. The E&IT form should be submitted to equityanddiversity@csun.edu and purchx@csun.edu. When the submit button is activated, an email should appear with the E&IT form as an attachment.  

Submit Troubles?

If a requestor has trouble submitting the E&IT form, make sure to save the completed form on your computer and attach to an email to equityanddiversity@csun.edu and purchx@csun.edu.

Step 3: Impact Determination

Once requestors submit their E&IT Form and VPAT, their request will undergo an E&IT review. The request will be reviewed by one of the three ATI Procurement team departments (Purchasing, Equity and Diversity or Universal Design Center), to determine the impact of the product.  When the impact is established, some products may be required to undergo additional evaluation and requestors will need to provide supplemental documentation about their product.  

What is impact?

In accordance with the ATI procedures, all E&IT products  undergo an E&IT review based on their impact. Impact is defined as the overall effect an E&IT product will have on the campus, and could include a combination of the type of end user, number of users, and effect on student learning. 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. 

Identifying Impact

Impact determination is primarily centered on campus-wide involvement. The more people involved in the usage of a product, the greater the impact of the product and the higher the likelihood that further accessibility review and materials will be needed. 

Below are some of the key questions we consider when identifying impact:

  • What is the product?
  • Who are the targeted users of the product?
  • How many people will use this product?
  • How will the product be used on campus?
  • Where will the product be used?
  • What is the likelihood that this product could impact people with disabilities?
  • Could individualized accommodations be an efficient use for the product?

These key questions serve as our framework to establish the appropriate impact for the product.

Impact Levels

Below are general guidelines for impact determination. However, please be aware that these guidelines are not all inclusive and could be subject to change.

High Impact

  1. Product will be used campus-wide
  2. Product will be used by a large campus audience in a college, division or department or by members of the public
  3. Product is a strict requirement of academic and administrative procedures
  4. Usage of product will directly impact a specific program and /or service on campus
  5. High exposure to product on campus
  6. Strong likelihood product will impact people with disabilities
  7. High risk of accessibility barriers

Medium Impact

  1. Product will be used by a moderately-sized campus audience in a college, division or department or by members of the public
  2. Usage of product will directly impact a program and/or services within a moderately-sized division, college or department
  3. Exposure to product will be moderate 
  4. There is a likelihood that this product could impact people with disabilities
  5. The product has potential accessibility barriers.

Low impact

  1. Product will be used by a small campus audience and or public
  2. Usage of product will impact only optional programs and/or services within a division, college or department on campus
  3. Users will have limited exposure to product
  4. Low likelihood of impact for persons with disabilities 

Step 4: Impact Result Outcomes

Following the impact analysis, requestors will be notified via email of the outcome of their E&IT review. If the product was identified as Medium or High impact, further evaluation and documentation are required. Below is a summary of the impact analysis outcomes:

If a Product is identified as High Impact, then:

  • Accessibility review of the product will be required. UDC will conduct a compliance evaluation or a VPAT review on your product.
  • Equally Effective Alternate Access Plan is needed
    • An equally effective alternate accessibility plan must be developed by the requesting department.
    • In the EEEAAP requestors must outline key information explaining how equally effective access will be provided for individuals who may have problems using their product due to accessibility barriers.
  • Accessibility Roadmap is needed
    • An Accessibility Roadmap is a remediation commitment plan to be completed by vendors.
    • If an accessibility roadmap is needed, requestors must request vendors to complete this plan.
    • The plan should outline all known or potential accessibility barriers in the product and should establish a remediation timeline for the issues. 
    • The plan should also identify any known workarounds and any remediation obstacles present in the product.

If a product is identified a Medium Impact, then:

  • Product could be subject to a VPAT review by UDC
  • EEAAP is recommended
    • An EEAAP is not required for medium impact purchases, but it is highly recommended
  • Accessibility Roadmap will be recommended only if students are impacted by product
    • If a moderate amount of end users will be students, it is highly recommended that a remediation commitment plan is developed by the vendor

Please Note: If UDC identifies a high volume of accessibility concerns during the VPAT review, the product impact level could change resulting in an EEAAP and Accessibility Roadmap to be required

If a product is identified as Low impact, then:

  • Individualized accommodations should be considered in the event that accommodations are requested

Step 5: Completing an Equally Effective Alternate Access Plan

Once the E&IT review is completed, requestors will be informed via email if their product purchased is a medium or high impact product. Upon receiving the notification email, the first item departments should work on is the Equally Effective Alternate Access Plan (EEAAP) (DOCX) File. The EEAAP is a document used to record accessibility gaps for the product you have chosen to purchase.  The main purpose of the EEAAP is to identify known workarounds and describe how equally effective alternative access will be provided should an accommodation request arise.

The information provided in this section is designed to assist requesting departments in the completion of the EEAAP. For further assistance, please contact the Disability Resource and Educational Services (DRES) department or the Universal Design Center.

Before developing the EEAAP

Establish a Multi-Disciplinary Team

Before initiating the EEAAP, requesting departments need to establish a multidisciplinary team that will be responsible for the EEAAP.  The multi-disciplinary team should consist of individuals who have a clear understanding of how the product/service will be used on campus in order to evaluate the item for accessibility compliance.

Conduct a Preliminary Evaluation

Once the team has been established, the first step to developing an EEAAP is to conduct a basic evaluation of the product to be purchased. The intent of this evaluation is to allow requesting departments to self- identify the level of accessibility and the potential accessibility gaps in the purchase. The goal of this step is to increase campus understanding of accessibility compliance methods and standards. Please visit the Conducting Accessibility Evaluations website for information on reviewing your product.

Identifying Equally Effective Accommodation Solutions

Following the preliminary evaluation, the requesting department needs to define potential accommodations to accessibility gaps in the purchase. Departments should contact the Disability Resource and Educational Services (DRES) or the National Center on Deafness (NCOD) offices for assistance in identifying potential Equally Effective accommodation solutions that will best meet a department’s needs.

How to complete an EEAAP

Section 1: Plan Creator Information

Provide the name and contact information of the person responsible for developing the EEAAP. If there is more than one person responsible, provide the names of the other responsible individuals in Section 3.3.

Section 2: Description of Affected System, Software, Process or other E&IT Purchase

  1. Affected Product is a: Select the type of product from the list of items. If the product is “other”, explain what type of product it is.
  2. Product Name: Provide the full product name of the item to be purchased. If applicable, include a version number in this section.
  3. Product Description: Provide a brief description of what the product is and what are its key features or functions.
  4. Product Purpose: Identify what the purpose of the product will be on the campus, who will it affect, and where will it be used?

Section 3: How will “Equally Effective Alternate Access” be provided?

  1. Description of the issue:  Provide a summary or list any potential accessibility gaps or issues identified in the product through the preliminary evaluation. For assistance on conducting a preliminary evaluation, please visit the How to evaluate your product for compliance website or contact UDC.
  2. Person or groups affected: List potential individuals or groups who can be affected by the accessibility gaps in the product.
  3. Responsible person(s): Provide the names and contact information of all individuals responsible for providing accommodations for the product.
  4. How will EEAA be provided?: Provide a detailed summary of all identified equally effective alternative access solutions. For assistance in identifying alternative access solutions please contact, DRES or NCOD. If more space is needed, add an attachment document.
  5. EEAA Resources Required: list any EEAA resources to provide accommodation. Please contact DRES or NCOD for assistance.
  6. Timeline for Unforeseen Events: Develop a timeline to plan, create, implement and follow-up on alternative access plans. Please contact DRES or NCOD for assistance.

Section 4: Departmental Approvals

  • The Plan Creator and Departmental Chair/Manager should sign in the appropriate sections
  • The EEAAP should also be signed by all members of the multi-disciplinary team or all members mentioned in Question 3, Section 3 (Responsible Person(s)). If needed, provide additional space to allow more signatures.

Section 5: EEAAP Approval (Departments as appropriate)

  • If the requesting department consulted with additional departments such as DRES or NCOD, a representative from those departments (department director or consultant) must sign the EEAAP.
  • No signature from DRES or NCOD is needed if the departments were not consulted.
  • Once all appropriate departments have signed, the EEAAP should be submitted to the Universal Design Center (Room OV 5, Mail Code 8235).
  • The Universal Design Center will review the EEAAP and sign.
  • UDC will maintain the original copy of the form.
  • A copy will be sent to all responsible individuals.
  • If requesting departments need additional copies, they can be provided upon request.

Step 6: UDC Evaluation

As requesting departments develop their EEAAPs, products with the highest impact will be placed in the queue to undergo an Accessibility Compliance Evaluation by the Universal Design Center. The accessibility compliance evaluation is a targeted accessibility test to identify key gaps on a product based on Federal and State laws and standards regarding accessibility.

When UDC completes their evaluation, they will submit a report to requesting departments. Requesting departments must forward this report to vendors along with an accessibility roadmap to initiate the remediation of the product.

UDC Evaluation

The UDC evaluation will occur following the first year of the purchase of the product. All products identified as high impact will be placed in the queue to be evaluated by UDC based on priority. When time comes for your product to be evaluated, a UDC staff member will contact you to gather more information about the product to initiate the accessibility review.  

UDC evaluation vs. evaluation for EEAAP

The UDC evaluation is a technical assessment of an E&IT product to identify the underlining problems as a result of accessibility gaps.  The UDC Review is not to be confused with the preliminary evaluation for EEAAPs; the purpose of the preliminary evaluation is to identify the general accessibility problems in a product to establish departmental accommodation plans. The UDC review conducted by trained UDC staff and student employees will evaluate the deepest layers of the product to identify key technical issues in order to address accessibility barriers and to develop an Accessibility Roadmap. The review will be conducted according to accessibility standards defined by Section 508, WCAG 2.0, CSUATI Criteria, Mobile Web Best Practices (MWBP), Mobile Web Application Best Practices (MWABP), and Mobile Accessibility Guidelines.

UDC Evaluation Criteria

The UDC evaluation will consist of either a targeted compliance evaluation test or a VPAT review. The UDC targeted test is centered on evaluating the most critical accessibility criteria. UDC testers will conduct manual compliance testing on the product where testers will stimulate the experience of users with various disabilities and will conduct a review of the product code to identify accessibility gaps on a technical level. In some cases, UDC may also conduct a targeted evaluation using an automated accessibility evaluation tool, Compliance Sheriff. For Information on UDC Evaluation Criteria please visit the Web Accessibility Criteria and Compliance Sheriff  pages.  

In the VPAT Review, UDC testers will review the VPAT by analyzing the stated accessibility level of the product as defined by the vendor. For information on conducting VPAT reviews refer to the
CSU Voluntary Product Accessibility template (VPAT Review).

UDC Evaluation Report

Requesting departments should review the report to find out if the solutions/recommendations provided can be implemented and applied by the department. In addition, the report needs to be forwarded to the product vendors along with the accessibility roadmap template. Vendors should use this information initiate the roadmap. See Step 7 for more information.

Products Undergoing UDC Evaluation

Not all products will be evaluated by UDC. UDC will primarily evaluate products that are software or web application. Other products may undergo different evaluation means separate from UDC. In addition, some products are currently under a system-wide evaluation through the CSU Office of the Chancellor. Products identified in the Chancellors Office list will not be evaluated by UDC. 

Step 7: Accessibility Roadmap

Per CSU ATI Policy, vendors who provide E&IT products to all campuses within the CSU must work with the CSU and campuses to mitigate any accessibility issues or concerns in the products they are providing. As a result, once requesting departments have received the Compliance Evaluation Report by UDC, requesting departments should submit the report to vendors in order to develop a CSU Accessibility Roadmap (DOCX) File. The Accessibility Roadmap is a remediation commitment plan whose purpose is: to engage vendors in listing the accessibility gaps in their product as identified in the accessibility evaluation or VPAT review, get a commitment timeline for remediation of these gaps and to define any available workarounds for accessibility gaps.

Vendors must complete the Accessibility Roadmap in order for future purchases or renewals of their product to occur. Moreover, vendors who fail to provide a roadmap may be at risk from being unable to contract with all campuses within the CSU.

Resources