Policy on Purchasing, Developing, Maintaining and Using Accessible Electronic and Information Technology (EIT)
Office of the President
Responsible University Office
Information Technology Accessibility Officer, firstname.lastname@example.org
- University EIT purchasers, developers, maintainers and users
- Procurement Services and Contract Management staff and buyers
- Division of Information Technology (DoIT) – IT Steering Committee -> End User Technologies Sub-Committee
- Colleges, departments, units, distributed IT personnel
January 18, 2018
Who is Affected
- Purchasers of EIT
- EIT vendors
- Developers and maintainers of EIT
- Students, faculty and staff with disabilities
Compliance (Rules / Regulations)
- Americans with Disabilities Act
- Rehabilitation Act Section 504
- Rehabilitation Act Section 508 Refresh
- Illinois Information Technology Accessibility Act 2.0
- NIU Accessible Technology Policy
- NIU Additional Certifications for Procurement Section 3.24 (PDF)
Roles and Responsibilities
- Procurement Services and Contract Management includes accessibility language in purchase agreements for EIT orders that it handles.
- The Division of Information Technology Steering Committee includes accessibility assessments, that are in compliance with the IITAA and its applicable regulations, in its Architecture Review of products created in-house.
- The Information Technology Accessibility Officer (ITAO) makes recommendations regarding the accessibility of EIT purchases and/or development, especially when the accessibility of a product is unknown. The ITAO assists with assessing the accessibility of EIT and creation of an equally effective alternative when necessary if an exception is made. The ITAO may be consulted when accessibility assessments are conducted.
- University purchasers of EIT must request a Voluntary Product Accessibility Template (VPAT) from the vendor of the EIT. The purchaser must request an accessibility assessment from the ITAO when the VPAT shows deficiencies in accessibility.
- The Disability Resource Center can be consulted on student needs, especially requests for reasonable accommodations in order to address a disability situation.
- Human Resource Services can be consulted on employee needs, especially requests for reasonable accommodations in order to address a disability situation.
NIU is committed to providing an accessible, usable, and integrated experience for all people. Therefore, NIU requires that all EIT procured, developed, maintained or used be accessible, as defined in applicable law, so that all members of the NIU community can make the fullest use of its EIT. NIU relies on administrators, faculty and staff to work toward providing equal access to all EIT. When NIU procures, develops, maintains, or uses EIT, it will identify the needs of users with disabilities to determine:
- How users with disabilities will perform the functions supported by the EIT; and
- How the EIT will be developed, installed, configured and maintained to support users with disabilities.
As such, purchasers, developers and maintainers of EIT at NIU are required to abide by the Illinois Information Technology Accessibility Act (IITAA), the IITAA 2.0 Standards, and the IITAA 2.0 Techniques for EIT developed, procured, or substantially modified by NIU on or after January 18, 2018.
For EIT procured and developed before January 18, 2018, and not modified after January 18, 2018, NIU is required to use the IITAA 1.0 Standards, IITAA Implementation Guidelines for Web-Based Information and Applications, and the IITAA Procurement Recommendations for compliance with the IITAA. NIU encourages university developers and purchasers of EIT to strive to meet the IITAA 2.0 Standards and Techniques even for EIT developed or purchased before January 18, 2018 where reasonable.
The IITAA defines EIT as “electronic information, software, systems, and equipment used in the creation, manipulation, storage, display, or transmission of data, including internet and intranet systems; software applications; operating systems; video and multimedia; telecommunications products; kiosks; information transaction machines; copiers; printers; and desktop and portable computers.”
In purchasing EIT, Procurement Services and Contract Management or the purchasing department will consider at minimum the following:
- Accessibility shall be a factor in scoring during Requests for Proposal or sole source decision-making.
- Sufficient degrees of accessibility must be certified by the vendor. Traditionally this is accomplished through a completed Voluntary Product Accessibility Template (VPAT) (doc). If the VPAT or other information indicates that the EIT will not be sufficiently accessible, an exception must be sought from the ITAO.
- IITAA Procurement Recommendations must be reviewed and adhered to, where applicable.
- Pursuant to NIU Procurement Certification 3.24, the vendor of EIT is required to certify that information technology, including electronic information, software, systems and equipment, developed or provided under this contract comply with the applicable requirements of the IITAA Standards 2.0.
IITAA Additional Purchasing Resources are also available for consideration.
In developing or maintaining/updating current EIT, DoIT will include accessibility in its Architectural Review. In addition, standards, implementation guidelines, techniques, and procurement recommendations under the IITAA 2.0 must be reviewed and adhered to, where applicable. Those authorities are as follows:
- IITAA 2.0
- IITAA Frequently Asked Questions (FAQs)
- IITAA 2.0 Standards (applicable to information technology purchased, developed or substantially modified after January 18, 2018)
- IITAA 2.0 Techniques (applicable to information technology purchased, developed or substantially modified after January 18, 2018)
NIU purchasers and/or purchasing departments can seek exceptions to the requirement to make EIT accessible, as defined under applicable law. Such exceptions must be submitted to the ITAO for review and consideration, and must clearly explain in detail why meeting the federal and state requirements creates an undue burden, fundamentally alters the nature of the goods, services, facilities, privileges, advantages or accommodations being offered by NIU or is otherwise excepted under applicable law.
For example, when a vendor’s VPAT is returned with indications of non-compliance or it is incomplete, then the ITAO must be contacted before purchase. Final decisions on whether EIT is appropriately accessible are made by the ITAO. The ITAO can consult with other appropriate persons or entities when making such determinations.