Building Accessibility Into IT Procurement
Michigan State has developed rubrics and procedures to help its information technology procurement officers evaluate products' accessibility more effectively.
For many years, Michigan State University in East Lansing has had a clear policy about what is expected in terms of technology accessibility — whether for a faculty member teaching online or for an administrative department buying computers and software. But in 2015, MSU revamped how accessibility is integrated into information technology procurement, giving purchasing officers a risk-assessment rubric and a new accountability structure.
"I have been working on this personally for most of my career and have watched lots of approaches to this in higher education," said Brendan Guenther, director for academic technology. "This is the first time that I really feel we have something that scales and is adaptable enough to accommodate all the kinds of things a university needs to do."
"Essentially, the university purchases a lot of things, and we need to be able to provide a certain level of engagement in terms of accessibility with all those things," said James Jackson, Electronic Information Technology (EIT) accessibility coordinator for MSU IT Services. But MSU's resources are limited, especially with the central team that has the highest degree of knowledge about what constitutes an accessible product. University leaders decided to create a process in which almost every product gets assessed, with particular focus on products that are going to have the highest degree of impact.
Accessibility Throughout the Procurement Process
Jackson and his colleagues identified five places in the procurement process to engage accessibility:
- Procurement terms;
- Initial screening;
- Accessibility evaluation;
- Alternative access; and
- Accountability structures.
For instance, under procurement terms, they make sure accessibility — specifically WCAG 2.0 or Section 508 compliance — is referenced in all IT products purchased. The terms also require the vendor to provide documentation on accessibility.
Purchasing agents conduct the initial screenings. "They are provided a rubric for risk assessment created by our legal counsel, paying attention to specific language in the most recent settlement agreements," Jackson explained. "If a product falls into the medium- or high-risk range, they forward it on to my team — the digital content and accessibility team — and we take some additional steps," he added. The purchasing agents can handle the low-risk products on their own. If a product might be used by only two researchers in a lab, for example, "We know who they are. If either of them needed accommodation, we could provide it for them," Jackson said.
"Procurement and counsel have always helped us with contract language, but we used to have to market that contract language directly to the department requesting the procurement, to get them to include it in their procurement language," Guenther explained. "But some people didn't notice we asked them to include this, or they didn't ask the purchasing agent to do anything, and the purchasing agent took a passive role in this." The rubric has equipped them with a tool they find helpful, he said. "They are not accessibility experts, and they don't have to be to use this. They are able to incorporate the rubric in their standard gauntlet of things they put a vendor through." With this now part of their process, they are accruing experience with accessibility. "Most of our purchasing agents are starting to be able to distinguish between companies able to give you this information and others that are making it up and don't know what they are talking about," Guenther said. "They are beginning to differentiate and provide good advice. That is a powerful effect."
Part of the accountability structure is an EIT Accessibility Acknowledgement form. Basically the person signing the form commits to accommodating users with disabilities, and creates an "Equally Effective Alternative Access Plan." If a product is not usable by a blind student, for instance, the plan specifies how the student will be accommodated. "Then a department can pull the plan out and execute it," Jackson said. "That cuts down on the wait time to a solution. That is critical when we are talking about students who need access to do coursework. A delay of a week is a real challenge. Rapid response is critical."
The purchasing agents use the rubric to forward high-risk products to Jackson's digital content and accessibility team, which interviews the vendor, does hands-on testing and brings its findings to a monthly meeting of the Accessibility Review Committee, which was created in 2015. The committee includes people from legal counsel, the library, disability services and ADA coordinators.
Guenther noted that the committee can decide when more communication is needed with the vendor to mitigate risk. "We want to do active vendor management and cajole them to make a commitment, even up to a legally binding commitment, that software will be improved. That makes it safer to proceed with an implementation because if there is a limitation, there is probably a finite time period we have to live with it."
Talking With Vendors About Accessibility
When it comes to accessibility, vendors tend to fall into three categories, according to Jackson: The first doesn't know much about accessibility at all; the second knows a little but tries to pull the wool over your eyes; and the third is knowledgeable and highly engaged. "It requires technical know-how to ferret out which [category] they fall into and how far you can trust the statements they are making," he said.
Even if you do not have a high degree of knowledge about accessibility, tell vendors you want to do hands-on demos with the product rather than a canned demo of them running a screen reader over it, Jackson advised. "It is easy for them to go through a best-case scenario or run a mouse over words. But your user is not going to be using a mouse. Have them use a keyboard," he said.
Most important, Jackson said, is to ask vendors about their processes for addressing issues and complaints. He recalled one company that had relatively good documentation. "We did an inspection and found accessibility problems, but nothing major. Where they fell short was in process. They didn't have a roadmap for fixing things. Quality assurance didn't include accessibility."
Be sure to ask if vendors have staff trained in accessibility. What standards are they familiar with? How do they respond to complaints? "They may not have a process," Jackson said. "That gives you useful information for judging a vendor. But if they do have a clearly defined process, then if we encounter an unforeseen problem, we should get turnaround quickly. That is where accessibility is slowly becoming part of vendor processes, and asking those questions can tell you where the vendor is."
Moving Forward
MSU is constantly trying to refine its model, said Jackson. "Now that we have a year of data, we can look at how frequently products fit into our risk categories, what we did about it, and what percentage of my staff's time is necessary to maintain this level of scrutiny," he explained.
"We have eyes, ears and muscle in lots of places, which allows us to accomplish forward progress in this work," added Guenther. "That isn't possible when you have one isolated team trying to help everybody."
Both Jackson and Guenther believe smaller universities could adopt a similar approach, even though they have fewer resources. "The benefit of a prioritization-based approach is that you focus on the most crucial work first," Jackson said. "Even a small university has a procurement office that could do the triaging. Reach out and engage as many places on campus as you can. It is not necessary to be the size of MSU to do that."