Compliance Documentation

Suppliers are expected to maintain and provide up-to-date, accurate documentation about the accessibility of their products and services.

What to Collect

U-M uses Web Content Accessibility Guidelines 2.1 Level AA as its digital accessibility standard and accepts industry standard documentation, VPAT and HECVAT:

• Voluntary Product Accessibility Template (VPAT)
  • VPATs should be current, and ideally no more than 12 months old  
  • VPAT-WCAG or VPAT-INT templates are preferred
  • VPAT version 2.5 is preferred, 2.4 and 2.3 are acceptable
  • Refer to IT Industry Council for latest VPAT templates
• Higher Education Community Vendor Assessment Toolkit (HECVAT)
  • HECVATs should be current, and ideally no more than 12 months old
  • HECVAT v4 is preferred, refer to EDUCAUSE for the latest HECVAT templates
  • Alternative: U-M Supplier Accessibility Questionnaire (all sourcing events will automatically require suppliers to complete the U-M Supplier Accessibility Questionnaire, which is modelled on questions in the HECVAT).

Other documentation sources may include:

• Contractual statements (preferred),   
• Roadmaps (less preferred), or   
• Email assertions/written statements (least preferred)

Suppliers that are performing professional services for U-M, such as designing websites or editing video media may not be able to provide a VPAT or HECVAT for those services to unit requestors. However, the product that they create for U-M must meet the same standards. Suppliers should still fill out the U-M Supplier Accessibility Questionnaire.

Where to Find It

• Review responses to the supplier accessibility questionnaire
  • Procurement Services staff will export responses from their system (Jaggaer) for selection teams to review, during RFP or bid activities
• Check supplier websites
  • Documentation may be publicly available on webpages about "accessibility", "compliance", "section 508" or similar keywords
  • If documentation is stored in areas that require a login, such as a Trust Center, request access from the supplier
• Reach out to the supplier directly
  • Notify the supplier of U-M’s digital accessibility requirements
  • Request accessibility compliance documentation as described above (VPAT and HECVAT)

If no digital accessibility documentation is made available, exercise a high degree of caution and evaluate alternative products or services. Suppliers who do not demonstrate awareness of or interest in digital accessibility are unlikely to be able to meet U-M’s digital accessibility requirements.

How to Evaluate It

Check the following:

1. Date of publication: Should be dated within the past 12 months. Anything older than this is unlikely to be an accurate representation of the current state of the product.
2. Template version (for VPATs and HECVATs): Out-of-date templates may not reflect current accessibility criteria or may provide less information than is ideal for assessing digital accessibility.
3. Assessment methods and tools: The documentation should clearly reflect how the accessibility of the product or service was determined. Ideally, products and services will be assessed using a combination of automated scanning tools and manual testing with assistive technology (e.g., screen readers like NVDA, VoiceOver, or JAWs, keyboard testing, magnification tools).
4. Applicable, supported accessibility criteria: The accessibility criteria that apply will vary depending on the type of product or service and the included features. The supplier should indicate which criteria apply and which are supported (have been met). The supplier should also include notes about how the criteria are supported, especially if using a VPAT or HECVAT with fields for this information. Vague or non-existent notes often amount to inadequate documentation.
5. Applicable, unsupported accessibility criteria: The supplier should indicate which criteria are applicable to the product or service and not currently supported (have not been met). The supplier should also provide a reasonable timeline for addressing inaccessible features. Considerations when determining timeline reasonableness include: whether the most serious issues will be addressed first, the resources the supplier can devote to fixes, how often the supplier releases improvements, how widespread the issues are, and how difficult the issues are to fix.
6. AI, Overlays, & “Toggle On” accessibility features: If the documentation indicates that accessibility criteria are met through use of AI tools, accessibility overlays, or settings that need to be toggled on by the user, proceed with caution. These tools are typically supplemental aids rather than a substitute for embedded accessible design. Evidence of manual testing with assistive technology becomes much more important in cases where these tools are being utilized.

Inadequate Documentation: Next Steps

If supplier documentation is out-of-date or incomplete, follow up with the supplier to request the information needed to understand the current digital accessibility of their product or service. 

If the supplier is unresponsive or does not provide requested information, exercise a high degree of caution and evaluate alternative products or services. Suppliers who do not demonstrate responsiveness to digital accessibility inquiries are unlikely to be able to meet U-M’s digital accessibility requirements. 

If digital accessibility issues are noted in supplier documentation, work with your Procurement Services Buyer to reflect improvement commitments in the contract terms. Also prepare for ongoing supplier management to show a good faith effort to get the product or service to conform to digital accessibility requirements.