Accessibility Policy at VCSU
The following policies govern digital accessibility at VCSU:
The University measures online content accessibility and functionality according to The World Wide Web Consortium’s (W3C) Web Content Accessibility Guidelines (WCAG) 2.1 Level AA.
SBHE Policy 1203.1 designates the institutional CIO as the person that may grant an exception to digital accessibility compliance. VCSU Policy V1901.3 provides details of how a request is made and processed. If an exception is granted, the requestor shall be responsible for providing some sort of equally effective alternative access, if one exists, to ensure that, to the maximum extent possible, those with disabilities receive the same benefits as their non-disabled peers.
While Universal Design and other efforts to make information and communication technology more accessible may help to reduce the number of accommodations needed, there is still a need for certain accommodations specific to a student’s disability. A student needing specific accommodations may choose to submit a Request for Services to the Disability Support Services Coordinator. The Disability Support Services Coordinator reviews the Request for Services and all supporting documentation provided by the student. The student and the Disabilities Support Services Coordinator then determine, through an interactive conversation, reasonable accommodations for that student. The Disability Support Services Coordinator notifies the student’s instructors of the student’s accommodations. Instructors who are unable to provide specific accommodations due to course or department standards of rigor may suggest alternative accommodations. Policy governing digital accessibility accommodations can be found in SBHE Policy 1203.1. Reference Accommodation Resources for more information.
Evaluation processes focus on the adherence to and conformance with the previously identified measures, primarily WCAG 2.1 Level AA. Assessment shall involve periodic reflection on the effectiveness and progress of the overall accessibility improvement program at VCSU.
Accessibility improvements in 2020-21 will rely primarily on automated evaluation tools, such as Blackboard Ally and built-in accessibility checkers available in most of the Microsoft Office productivity tools. By remediating accessibility issues that automated tools can detect and creating new content that appears compliant according to the automated tools, we will greatly reduce the number of accessibility issues remaining. As we begin more advanced testing, such as human accessibility testing, we will only need to document those things that automated tools cannot detect today. If we start with human accessibility testing immediately, people will spend hours and days documenting issues that could have been detected and documented by automated tools within seconds. If we have any spare people time in the next year or two, it will be best used for employee training and to remediate what the automated tools can detect.
A significant component for VCSU accessibility assessment will be a separate “Digital Accessibility Services Plan” within the SPOL (Strategic Planning Online) system. SPOL is a cloud-based application required by the NDUS (North Dakota University System) Office for reporting on institutional level strategic plans, e.g. VCSU Strategic Plan and Risk Management Plan. The Digital Accessibility Services Plan will include University-level objectives and tasks, as well as, Unit level objectives and tasks. Each University Unit reporting to the President will work toward and report progress on their Unit level objectives and tasks.
According to SBHE Policy 840, NDUS 840, and VCSU V840, contracts must be approved by ND AG’s Office. depending on the dollar amount of the contract, various procurement requirements apply per NDUS 803.1 and VCSU V803, NDUS 1901.3 and VCSU V1901.3 require CIO approval of certain software. SBHE 1203.1, VCSU V1912.06 and V1901.3 involve assessment of accessibility. The Compliance section of V1912.06 should be re-written to reference V1901.3, and CIO and VPAA compliance oversight roles identified in this document.
Technology Services is currently evaluating and documenting accessibility of enterprise applications and software costing $2,500 or more. Some people may not be aware of V1901.03 and others may be ignoring the policy for small acquisitions. Quite frankly, the CIO Office does not have the resources to respond in a timely manner to all the potential requests if every low-cost and free application was submitted. The proposed strategy is to create a more intuitive and efficient request process. Once this is completed, more policy awareness and training will occur. Assessment and compliance efforts will increase slowly over time.
The bottom line in procurement is we eventually need to evaluate the accessibility of all web resources and software we use. If a web resource or software is not fully compliant, we must document exemptions to compliance.
The following list of roles and responsibilities was approved by VCSU Cabinet on June 1, 2020.
- Digital accessibility is an institution-wide responsibility. Everyone that has a laptop or even replies to an email has some responsibility. Positions that create significant digital content for large audiences have greater responsibilities.
- Responsibility for accessibility related to staff positions should be reflected in position descriptions. Cabinet should establish guidelines and timelines.
- Faculty responsibility for accessibility should be reflected in academic policy. The VPAA or designee should lead a process to review academic policy to see where this will best fit.
- Executive Sponsorship
- The Office of the Chief Information Officer (CIO) shall oversee the implementation, evaluation, assessment, and compliance of the Digital Accessibility Program, with the exception of (b) below. The CIO or designee establishes procedures and coordinates procurement of all information and communications technology, as well as, requests for exemptions to accessibility compliance.
- The Office of the Vice President for Academic Affairs (VPAA) oversees the implementation, evaluation, assessment and compliance of Digital Course Content, Library Services and other academic services, excluding procurement which is a responsibility of the CIO.
- Each VCSU Cabinet member is responsible to ensure their Unit contributes to improving digital accessibility. Furthermore, each unit will develop or adopt Objectives, Tasks and Assessment Measures, along with deadlines for completion. These will be entered and tracked within the SPOL (Strategic Planning Online) system.
- Cabinet will create an administrative advisory committee or identify other institutional capacity to facilitate University-level objectives, compile annual progress assessments and recommend University-level objectives for an annual improvement plan.
- Technology Services staff, members of the current DAC, NDUS (North Dakota University System) staff and others will identify or create training materials and provide training for accessibility orientation and other basic training topics. Several materials have already been developed by DAC members.
- The Disability Services Coordinator shall work with individuals needing accommodations and shall assist faculty with making their course materials more accessible. When appropriate, the Disability Services Coordinator will 1) work with students, faculty, and staff who need accommodations, 2) work with Technology Services to make recommendations and/or implement digital accessibility tools and strategies for students, staff, and faculty who need accommodations and 3) make recommendations for departmental and/or campus-wide changes in course materials to accommodate a wider range of disabilities and reduce the need for more specific accommodations.
- The “Web Accessibility Team” shall improve the accessibility of VCSU websites and advise the CIO. The Team shall include Technology Services staff, Marketing & Communications staff and other primary content managers of the various VCSU sites.
- Accessibility support is currently available from Technology Services and Student Academic Services, through the Disability Support Services Coordinator.