D R A F T

Electronic and Information Technology Accessibility Policy

The University of Montana provides equal opportunity to its educational and administrative services, programs, and activities in accordance with federal and state law. This policy extends to the University’s electronic and information technologies and applies to their procurement, development, implementation and ongoing maintenance.

Ensuring equal and effective electronic and information technology access is the responsibility of all University administrators, faculty, and staff.

This is in accordance with federal and state laws including the Americans with Disabilities Act of 1990 (ADA) and Section 504 of the Rehabilitation Act of 1973, Section 508 of the 1973 Rehabilitation Act as amended, and Title 18, Chapter 5, Part 603, and Title 49 of the Montana Code Annotated.

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Electronic and Information Technology Accessibility Procedures

Definitions

"Accessible" and “Universal Access” means fully and equally accessible to and independently usable by individuals with disabilities so that they are able to acquire the same information, engage in the same interactions, and participate fully all of the same services as individuals without disabilities, with substantially equivalent ease of use.“Disability” means a physical or mental impairment that substantially limits one or more major life activities.

“Electronic and information technology" or "EIT" 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 term electronic and information technology includes, but is not limited to, telecommunications products (such as telephones), information kiosks, Automated Teller Machines (ATMs) and transaction machines, internet and intranet websites, electronic books and electronic book reading systems, search engines and databases, course management systems, content delivered in digital form, classroom technology and multimedia, personal response systems ("clickers"), and office equipment such as classroom podiums, copiers and fax machines"Information technology" means any equipment or interconnected system or subsystem of equipment, that is used in the automatic acquisition, storage, manipulation, management, movement, control, display, switching, interchange, transmission, or reception of data or information. The term information technology includes computers, ancillary equipment, software, firmware and similar procedures, services (including support services), and related resources.

General Guidelines

All EIT will be created accessible and according to the EITA guidelines. If non-legacy EITA is inaccessible, it will be reported via the Barrier Report.

1. Web Accessibility

1.1 Scope

This procedure applies to all University Web pages and programs used to conduct University business and activities.

Clarification: all web resources used in courses must be accessible. This is true whether they are supplemental or required. Refer to 2. Instructional Materials for additional discussion of this issue.

1.2 Standards

All web pages, websites and web-based software published, hosted or used (including remotely hosted sites and software) by the University will meet the standards and guidelines outlined in

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the Web Content Accessibility Guidelines (WCAG) 2.0 (http://www.w3.org/TR/wcag2ict/) published by the W3C as follows. All pages will meet Level AA guidelines with limited exceptions outlined at Exhibit A. All University websites, where technically feasible, will link to the University’s main Accessibility page which includes a statement of commitment to Web accessibility.

1.3 Responsibility

All Departments and programs:

• Will comply with the web accessibility standards when creating web content, sites, and programs.

• Will ensure that online activities are hosted in accessible environments and that online content follows standards outlined by this policy.

IT (central, distributed & UMOnline):

• Will provide instruction and support for campus community members creating UM websites and content so that individuals who author web content can be trained according to these standards

IT (central):

• Will ensure that any Content Management System and other web production or web object creation software proposed and supported by central IT will be accessible and will produce accessible Web pages.

IT (distributed):

• Will ensure that support is available for distributed IT staff for creating accessible UM websites and content.

EITA Coordinator and Working Group:

• Will ensure that instruction and support are available for campus community members creating UM websites and content and that individuals who author web content will do so in accordance with WCAG 2 Guidelines AA Standards.

• Will monitor and enforce these responsibilities and any related processes established during the implementation plan.

1.4 Implementation Schedule Summaryi

• “By May 16, 2014, the University shall identify a strategy to ensure that webpages that provide essential student functions are accessible” (Resolution Agreement).

• “By December 31, 2014, all University Program and Department websites, including legacy pages, unless technically impossible, shall contain a clear statement (or a link to a statement) describing the University’s commitment to web accessibility and a method to report barriers and/or to receive an alternative equally effective accessible format” (Resolution Agreement).

• “By December 31, 2014, all webpages published or hosted by the University on or after July 30, 2013, shall be accessible according to W CAG 2.0 Level AA standard” (Resolution Agreement).

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• “Upon a specific request for access by an individual with a disability, the University will update legacy pages to be in compliance with the WCAG 2.0 Level AA standard, as set forth in Appendix A to this Agreement, or the University will otherwise make the content available to the individual in a timely manner and in an equally effective accessible format” (Resolution Agreement).

2. Instructional Materials Accessibility

NOTE: Please also review requirements and timeframes for specific instructional items in other sections.

2.1 Scope

This standard applies to all electronic instructional materials (syllabi, textbooks, presentations, handouts, etc.). This includes electronic instructional materials delivered within the University’s learning management system, in face-to-face classes, or in an alternate fashion (email, blogs, etc.) and electronic instructional activities (online collaborative writing, web conferencing, etc.).

2.2 Standards

All electronic instructional materials, optional and required, will be accessible and as effective and useable for persons with disabilities as they are for persons without disabilities. Instructional materials and activities will be made available to all students at the same time.

All instructional materials must meet all applicable standards and guidelines outlined in this policy.

2.3 Responsibility

All Departments and programs:

• Will ensure that instructional materials they deliver comply with all applicable procedures outlined in this document.

• Will ensure that departmentally owned classrooms use and deliver accessible electronic and information technology.

• Will ensure that all departmental computer labs provided for student use will have assistive technologies not limited too but including accessible computer stations, screen reading software, and screen magnification.

Faculty and instructional staff:

• Will be responsible for creating and presenting accessible courses and instructional material that comply with all applicable procedures outlined in this document.

UMOnline:

• Will ensure that instruction and support are available for campus community members creating online courses and/or online instructional content.

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• Will ensure that online activities are hosted in an accessible learning management system and related hosted systems (such as web conferencing) that comply with standards outlined by this policy.

IT (central & distributed)

• Will ensure that electronic and information technology used in IT-designed and supported Technology Classrooms is accessible.

IT (Central)

• Will ensure that support exists for distributed IT and campus units needing assistance with accessibility in departmentally supported technology classrooms

Mansfield Library:

• Will work to provide universal access to library databases, collections, and services by adopting contractual accessibility language to use with vendors who provide the library with these online resources.

EITA Coordinator and Working Group:

• Will monitor and enforce these responsibilities and any related processes established during the implementation plan.

2.4 Implementation Schedule Summaryii

• “By March 14, 2014, the two accessibility issues related to the University’s learning management systems cited in the OCR Complaint (chat and forums) will be resolved. “ (Resolution Agreement)

• “By March 14, 2014, the University will identify its strategy to ensure the ongoing accessibility of its learning management systems.” (Resolution Agreement)

• “By March 14, 2014, the University’s library website shall be accessible in accordance with WCAG 2.0 Level AA standard, as set forth in Appendix A” of the Resolution Agreement. Further, “The Mansfield Library shall conduct monthly accessibility scans to ascertain whether any new posted content is inaccessible. The University shall notify content authors if corrections to pages are needed and of reasonable timelines for corrections to be made. The University shall note if corrective action has been taken during the next monthly scan.” (Resolution Agreement)

• “By May 1, 2014, the University will implement a program to provide information, education, and support for ensuring that EIT used in classrooms (including, but not limited to, clickers, podiums, blogs, and other software) is accessible.” (Resolution Agreement)

• “By July 1, 2014, the Mansfield Library shall implement a search engine that is accessible in accordance with WCAG 2.0 Level AA standard, as set forth in Appendix A to this Agreement, which can search across all library collections, including, but not limited to, e-journals, databases, and e-books.” (Resolution Agreement)

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3. Document Accessibility

3.1 Scope

This section applies to all University-produced and maintained or distributed electronic documents. Documents include, but are not limited to, word processing documents, PDFs, presentations, electronic publications and spreadsheets.

3.2 Standards:

Electronic documentation must be accessible. Interaction with University policies, procedures, notifications and other documentation should be as effective and useable for persons with disabilities as it is for persons without disabilities.

UM recommendations for preferred document types are listed on the UM Accessibility website.Electronic documents will meet the standards and guidelines outlined in the Guidance on Applying WCAG 2.0 to Non-Web Information and Communications Technologies, published by the W3C as the Working Draft 13 December 2012, (http://www.w3.org/TR/wcag2ict/).

3.3 Responsibility

All Departments and programs / University employees:

• Will create and use electronic documents, as indicated in the Implementation Plan, that meet the standards and guidelines of this policy.

IT / UMOnline/Mansfield Library:

• Will collaboratively ensure that accessible document instruction and support are available for campus community members.

EITA Coordinator and Working Group:

• Will be responsible for monitoring these responsibilities and any related processes established during the implementation plan.

• Will work with central and distributed IT, DSS, Mansfield Library and UMOnline to find and coordinate campus-wide PDF solutions.

3.4 Implementation Plan Summary1

• 12/31/2014: All straight-text documents (including PDF, Word, Excel and Powerpoint files) that do not use specialized, industry-specific notation formats (such as MathML) are accessible

• 8/25/2014: Campus conversations start around the topics of 1) accessible scientific and mathematical documents and 2) accessible documents from campus publications such as the Montanan, Montana Business Quarterly, etc.

• 12/15/2014: Strategies developed for producing accessible scientific and mathematical documents and accessible documents from publications

• 1/20/2015: Campus conversations about epub/edupub possibilities, production and purchase.

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• 5/15/2015: Strategy developed on UM’s integration of epub/edupub processes.

4. Accessible Electronic MediaAll departments will purchase and produce only accessible multimedia and update existing inaccessible media as it is put into use.

4.1 Scope

All media resources in use at the University must be accessible. For example, this includes, but is not limited to, media that is instructional, informational, marketing, and promotional.

4.2 Standards

Video media resources will be closed captioned and audio-described and audio resources will be transcribed.

4.3 Responsibility

All departments, programs, instructors and employees:• Will purchase only captioned versions of audiovisual media whenever possible. Will

ensure that all other media that will be used on the web or in instruction is captioned. • Will purchase only transcribed audio and audio-described versions of audiovisual media

whenever possible.• Will update any non-transcribed audio and any non-captioned/non-described video that

is in current use. • Will use only transcribed audio and closed-captioned media with audio-descriptions that

are made available in a timely manner to the class and will only assign such media as course material, whether optional or required.

• Will be responsible for utilizing captioned media and audio with transcriptions from their own personal or departmental collections (original or commercial productions).

Mansfield Library:

• Will maintain a library of transcribed audio and captioned video resources that are available for faculty, staff, and student use.

• Will maintain a record of commercial availability of copyrighted media resources. • Will assist faculty by identifying materials that are captioned prior to purchase.

UMOnline:

• Will ensure that captioning and media accessibility information is incorporated into training.

Central IT:

• Will ensure all classroom and presentation equipment is caption-compatible and the default on all TVs, etc.

• Will maintain and continue to provide instructions on media accessibility (such as captioning and audio-describing media and transcribing audio) as well as how to show captioned media in classrooms.

• Will ensure this information is incorporated into faculty training on AV equipment.

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University Relations:

• Will ensure all new communications and promotional materials produced under its own auspices and, on behalf of and by the University departments, will be captioned, audio-described or transcribed.

EITA Coordinator and Working Group:

• Will work with central and distributed IT, DSS, Mansfield Library and UMOnline to find and coordinate campus-wide captioning and transcribing solutions that:

o Will ensure assistance with obtaining permission to caption and audio-describe.o Will coordinate the process for transcribing, captioning and audio-describing

media resources for which permission to reproduce, caption and audio-describe has been obtained.

o Will maintain and communicate approved university protocols related to electronic media including a list of approved vendors to perform captioning.

4.4 Implementation Schedule Summary1

• 1/26/2015: All videos (professionally or internally produced) used in courses and shared on campus websites or video storage sites (such as Youtube and Vimeo, etc.) are captioned according to recommended standards.

• 1/26/2015: Students may request that recordings of course sessions and presentations created for and during a course be captioned.

• Start of Fall 2016: All videos (professionally or internally produced) used in courses and shared on campus websites or video storage sites (such as Youtube and Vimeo, etc.) are audio-described according to to-be-determined standards.

5. Software, Hardware and Systems Accessibility

5.1 Scope

All software, hardware and systems purchased must be accessible and must produce accessible products. Accessible, in this instance, means immediately available to campus assistive technology. For example, this includes, but is not limited to, learning and content management systems, library and email systems, and administrative management systems such as finance, registration and human resources, and all software, hardware and software services used for student services. Software includes freeware, shareware, desktop, enterprise, subscription and remotely-hosted options. Hardware includes …. Software that is accessed through a web-browser must also be accessible and is discussed under Section 1 of this document.

This is consistent with MCA 18-5-604 (http://leg.mt.gov/bills/mca/18/5/18-5-604.htm) and MCA 603 (http://leg.mt.gov/bills/mca/18/5/18-5-603.htm).

5.2 Standards

The University of Montana will use the following standards to determine accessibility:US Access Board’s Guide 508 Standards - Software Applications and Operating Systems (www.access-board.gov/sec508/guide/1194.21.htm)

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All Departments and programs / University employees:

• Will ensure that their software, hardware, local interfaces and modifications and electronic systems are accessible in accordance with this policy.

• Will ensure that all applications developed on campus (web, desktop, etc) are accessible according to principles of WCAG 2.0, WAI-Aria 1.0, and ATAG 2.0 standards (extrapolated as needed for non-web environments).

• All departmental computer labs provided for student use will have assistive technologies not limited too but including accessible computer stations, screen reading software, and screen magnification.

IT (central and distributed):

• Will ensure that assistive technologies are immediately available to students working in campus labs or on publically-accessed campus computers.

• Will ensure that assistive technologies are available in a timely manner for campus employees including student employees.

EITA Coordinator and Working Group:

• Will work with central and distributed IT to develop a process for determining software, hardware and software system accessibility.

o Will set testing standards and monitor their use.o Will determine a process that will lead to software being deemed accessible,

approved for provisional use or needing exception.o Will refer software reports either to:

▪ UM President for exception▪ CIO for Provision Use Agreement for Purchase

• Will be responsible for monitoring these responsibilities and any related processes established during the implementation plan.

• Will be responsible for designating a department that will take on the responsibility for coordinating and supporting assistive technology for public campus computers and campus community members.

5.4a Software Implementation Schedule Summary1

May 1, 2014: Modifications to purchasing process implemented by Procurement for purchases over $5,000.

June 27, 2014 – August 29, 2014: Existing software will be analyzed for accessibility during the self-study and implementation period as it is identified.

January 1, 2015: Plan for including process for purchases under $5,000 announced. January 2?, 2015: Implementation of plan.

5.4b Hardware Implementation Schedule Summary (Full Plan available at umt.edu/accessibility)

• 1/26/2015 The EITA Working Group considers reading systems and software that are used for textbook delivery especially critical. Systems selected should meet these guidelines: http://www.daisy.org/accessibility-screening-methodology-guidelines-and-checklist.html.

• 1/26/2015: Campus scanners should be installed with an OCR profile/option.• 1/26/2015: Accessible clickers should be selected.

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• Start of fall 2015?: Only Hardware with accessible options should be selected for use in academic courses?

6. Procurement

6.1 Scope

Buyers shall purchase only Electronic and Information Technology (E&IT) software, hardware and services that are in compliance with the E&IT accessibility requirements.

6.2 Standards

Purchase order/contract for E&IT goods and services subject to accessibility requirements and must include the following clause:

“Contractor acknowledges that no University funds may be expended for the purchase of information technology equipment and software for use by employees, program participants, or members of the public unless it provides blind or visually impaired individuals with access, including interactive use of the equipment and services, that is equivalent to that provided to individuals who are not blind or visually impaired. (18-5-603, MCA.) In addition, Contractor acknowledges that such information technology equipment and software will provide equal and effective access to all individuals in accordance with federal and state laws and regulations, including, but not limited to the Americans with Disabilities Act of 1990 (ADA), Section 504 of the Rehabilitation Act of 1973, and Section 508 of the 1973 Rehabilitation Act.” updated/amended statute citation

6.3 Responsibility

All Departments and programs / University employees:

• Will contact and work with EITA approved process/office to ensure that hardware and software they are considering to purchase are accessible.

• Will purchase only hardware that is accessible or that is part of a process that produces accessible products and will replace hardware that does not meet these standards with accessible versions. Any media produced by such hardware must be made accessible. (Photocopy machines / scanners that produce inaccessible image-based document rather than text-based documents are a prime example of this type of hardware issue.)

• Will purchase accessible software and will replace any inaccessible software with accessible versions.

Buyer:

• Will review requisition and associated documents for compliance with policies and procedures.

• Will include required terms and conditions in purchase orders/contracts.• Will include proper instructions in solicitation documents to identify accessibility and

documentations requirements.

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Requestor:

• Will coordinate with EITA approved process/office to ensure that accessibility requirements are included in the specifications.

EITA Coordinator and Working Group:

• Will monitor these responsibilities and any related processes established during the implementation plan.

• Will serve as a resource for E&IT purchases for compliance with accessibility requirements.

• Will provide written justification for all exceptions and waivers to accessibility requirements. and make these “exceptions” available to campus community/public/ADSUM?

• Will develop evaluation criteria for accessibility requirements.• Will perform evaluation of proposals for compliance with accessibility requirements

against evaluation criteria.

6.4 Implementation Schedule Summary1

• “May 1, 2014, the University shall develop and institute procedures that require the University to purchase or recommend only EITs that will provide the same programs, benefits, and services as they do to individuals without disabilities, except when it would fundamentally alter a program or when it is not technically feasible to do so, in which case the procedures will require the University to provide accessible alternate EITs.” (Resolution Agreement)

• “By May 1, 2014, the University shall implement as part of its request for proposal process a requirement that bidders meet the accessibility standards of WCAG 2.0 Level AA for web-based technology (as set forth in Appendix A to this Agreement) and Section 508 of the Rehabilitation Act and the Americans with Disabilities Act for other EITs; and requiring or encouraging, at the University’s discretion, as part of any contract with its vendors, provisions in which the vendor warrants that any technology provided complies with these standards and any applicable current federal and state disability laws.” (Resolution Agreement)

• 1/2/2015 Campus discussions started about implementation of above Procurement Standards for purchases under $5,000.

• ??/2015 Implementation of above Procurement Standards for purchases under $5,000.

7. ExceptionsIn the event that complying with this policy introduces an undue burden or would result in a fundamental program alteration, the Office of the President may grant a written exception to this policy. Because the Office for Civil Rights generally considers an institution’s entire budget when reviewing claims of undue burden, the decision to grant exceptions should be carefully weighed and sufficiently documented.

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8. Future TechnologiesAs new technology is developed, these standards and procedures will be modified to address the new technology, according to the intent of legal issues, procedures, standards and responsibilities listed herein. Attention to the following comments from the “Dear Colleague” letter is highly recommended: It is unacceptable for universities to use emerging technology without insisting that this technology be accessible to all students.

9. Procedures and Implementation Schedule ReviewUM’s EITA Procedures and Implementation Schedule will be reviewed semi-annually by the EITA Working Group and recommended changes submitted by the CIO to the President.

8/24/2014: The first review of Procedures and Implementation Schedule to be completed

8/29/2014 EIT Corrective Action Strategy disseminated.

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Appendix A: Required AA Standards

• 1.2 Time-based Media• 1.2.4 Captions are provided for all live audio content in synchronized media.• 1.2.5 Audio description is provided for all prerecorded video content in synchronized

media.• 1.4 – Distinguishable• 1.4.3 The visual presentation of text and images of text has a contrast ratio of at least

4.5:1, except for the following:▪ Large Text: Large-scale text and images of large-scale text have a

contrast ratio of at least 3:1;▪ Incidental: Text or images of text that are part of an inactive user

interface component, that are pure decoration, that are not visible to anyone, or that are part of a picture that contains significant other visual content, have no contrast requirement.

▪ Logotypes: Text that is part of a logo or brand name has no minimum contrast requirement.

• 2.4 – Navigable• 2.4.6 Headings and labels describe topic or purpose.• 2.4.7 Any keyboard operable user interface has a mode of operation where the keyboard

focus indicator is visible.• 3.2 – Predictable• 3.2.3 Navigational mechanisms that are repeated on multiple Web pages within a set of

Web pages occur in the same relative order each time they are repeated, unless a change is initiated by the user.

• 3.2.4 Components that have the same functionality within a set of Web pages are identified consistently.

• 3.3 – Input Assistance• 3.3.4 For Web pages that cause legal commitments or financial transactions for the user

to occur, that modify or delete user-controllable data in data storage systems, or that submit user test responses, at least one of the following is true:

▪ Reversible: Submissions are reversible.▪ Checked: Data entered by the user is checked for input errors and the user

is provided an opportunity to correct them.▪ Confirmed: A mechanism is available for reviewing, confirming, and

correcting information before finalizing the submission.

Appendix B:For resource allocation purposes of updating legacy non-compliant pages, priority should be given to Web pages for core institutional information such as course work, registration, advising, admission, catalogs, and student, faculty, and staff services information.

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Appendix C: Deadlines from Resolution AgreementThis section contains

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i

ii