Accessibility Specs (Accessibility & Procurement)

I. Status 

Standard number: Accessibility Standard 02 (AS-02)

Date issued: June 20, 2022

Date last reviewed: June 20, 2022

Version: 1.0

Responsible office: Equity, Civil Rights, and Title IX Office (ECRT)

The Equity, Civil Rights, and Title IX office (ECRT), along with other knowledgeable and relevant stakeholders, will review and update the Accessibility Specs periodically to maintain their currency, clarity, and utility. ECRT will communicate widely about substantive revisions made to the Accessibility Specs. Units are responsible for prioritizing Information Technology and digital content to make accessible.

The University of Michigan (“university”) is committed to providing accessible electronic and information technology that can be equitably used by persons with disabilities. Consistent with this commitment and university policy, this document (“Accessibility Specs”) articulates a process to be followed when purchasing information technology that the university maintains. The university views accessibility as an inherent nonfunctional requirement of technologies, and not as a separate or additional feature or as a separate instance of a technology. The university also recognizes the benefits from universal design on the user experience for all individuals. Universal design is designing for all using empathy, research, and accepted standards that strive to meet the needs of people with disabilities.

The Accessibility Specs support and supplement the EIT Accessibility SPG. The Accessibility Specs are updated at least annually by ECRT in collaboration with Information Technology Services (ITS), Procurement Services, and relevant stakeholders.

The purchase of accessible information technology is a shared responsibility of university units, staff, and faculty. The Accessibility Specs describe how the university strives to purchase accessible technology. University units and employees have a responsibility to procure technology which is accessible for people with disabilities. The Accessibility Specs set forth a process that units and employees should follow when procuring technology. Questions about this document should be sent to the Digital Accessibility Help Form.

II. Scope

The Accessibility Specs apply to covered IT, and at contractual agreement points including upgrades, renewals, RFPs, and sole-sourced purchases. Some common, covered IT may include:

  • Website development

  • Web-based applications

  • Desktop or mobile applications

  • Document authoring applications

  • Documents, digital textbooks

This is not an exhaustive list of products or situations where compliance with SPG needs to be considered during procurement. Any time a purchase or agreement involves digital goods or information technology of any sort that have user-facing components or ramifications, compliance with the SPG is required. Please use the Digital Accessibility Help Form to discuss whether your project or purchase may benefit from accessibility considerations.

III. Standard Process

We have a suggested workflow for accessibility when units/departments are looking to procure or utilize new technology.

Departments and units seeking to procure technology should work to ensure they have accessibility information in requests for proposals or sole-sourced documentation.

Requester gauges risk and priority surrounding the accessibility of the purchase.

Accessibility is important to consider in all projects. Depending on the scope and scale of projects, certain steps may be appropriate to add in to ensure the best accessibility outcomes. Please review our Determine Risk page. Priority categories are low, medium, and high. These different priority levels will determine the level of engagement offered centrally by the university. Priority is assessed at the university level and at the unit level. High priority items for the university will receive the most central support. High priority items at the unit levels may need to address support needs for the purchase at the unit level. Priority is assessed via a variety of mechanisms and internal procedures.

Include accessibility language in RFPs or sole-source solicitation.

Work with Procurement Services to add appropriate accessibility language to your RFP or sole-source solicitation. 

The General Accessibility Statement details the university’s commitment to persons with disabilities. The Accessibility Compliance Assertion demonstrates how suppliers should meet and adhere to federal disability laws and regulations in their products when responding to university RFPs or requests for solicitation. 

Accessibility Compliance Documentation includes Supplier Accessibility Questionnaire at a minimum, but may additionally include Voluntary Product Accessibility Templates (VPATs), reviews of the technology, and other relevant information or content as requested by the university or provided by the supplier. The university may request to speak to the supplier for further clarification or to ask additional questions.

Publicly available documentation which speaks to the current state and future direction of accessibility of the product may be especially helpful. Suppliers should seek to demonstrate proactive work on accessibility issues, and show a strategy which is responsive to individual requests from people with disabilities and the university.

Supplier will provide a completed copy of the Supplier Accessibility Questionnaire. 

The supplier will return a completed copy of the Supplier Accessibility Questionnaire included in the RFP. The Supplier should fill this out to the best of their ability and knowledge, consulting with relevant individuals or groups within their organization who are most knowledgeable about the technologies used in the product and the state of accessibility in the product(s). There are many free resources available for organizations looking to learn more about Information Technology accessibility. There are also tools available online to help with semi-automated and manual accessibility checks. 

Supplier may be requested to adhere to other steps as set forth in the Accessibility Compliance Documentation Section of the General Accessibility Addendum.

The Supplier may be requested to provide additional documentation or answers to clarify or represent accessibility information presented to the University, especially when there is not an abundance of publicly available information relating to the accessibility of the product. When accessibility information is public, the supplier and university can more easily dialog about priorities related to accessibility and have open and honest discussions about roadmap, strategy, and vision for accessibility. 

Included in this step, the university may request demo access to an environment provided by the supplier which mirrors or closely mirrors an implemented product. The university may request a “user path” which demonstrates some of the common tasks a user may access with the product, and test credentials for accessing this environment. The university may provide the written review to the supplier, and in some cases, may request that high priority items be fixed through contractual addenda or through the duration of agreement.

Contact ECRT/ITS as soon as you are able in the event of high risk purchase.

Units/departments and Procurement Services should contact ECRT/ITS if they are working on projects they believe to be high risk to request assistance.

ECRT and ITS will make specific recommendations related to covered, high risk IT purchases. There are many different recommendations or determinations ECRT/ITS may make.

University units are responsible for implementing IT in a way that is mindful of accessibility.

Once a technology has been chosen and purchased, units are responsible for implementing the technology to adhere to the university’s IT accessibility policy. Units are also responsible for developing accessible content when using procured or obtained IT. Units are additionally responsible for being responsive to requests from individuals related to accessibility, and for working with the university to address issues of accessibility. Units are ultimately responsible for providing accessible activities and services, and should consider ways to provide quick, effective accommodations in the event that technologies they utilize are not fully accessible. 

ECRT and ITS take proactive measures to review the accessibility of campus technology, including procured technologies which support university and health system business. 

Units and departments are responsible for being mindful of accessibility in updates, changes, and new features.

Units and departments who procure technology are responsible for maintaining accessibility in their technology through the lifecycle of a product. Units and departments should work with suppliers to prioritize and understand any updates, changes, and features which positively or negatively affect accessibility in their products. Units and departments should seek to verify any accessibility enhancements that suppliers make to better meet the U-M accessibility standards. Units and departments should be responsive to any user feedback related to products that they own and should consult with ECRT on any digital accessibility user complaints they receive. The university or university units may conduct evaluations related to the accessibility of products that are high priority or which have received internal complaints.

The university has an oversight mechanism for reviewing IT accessibility decisions made through the procurement process. Questions about the procurement process should be addressed to the Digital Accessibility Help Form

IV. U-M Resources on Accessibility

  1. How to meet the WCAG 2.1 AA Guidelines

  2. Understanding WCAG 2.1 AA

  3. Techniques for WCAG 2.1 AA

  4. Testing for Accessibility

  5. Prioritizing IT for accessibility