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All of the information below can be found on the coded memo AA 2006-41: "Access to Electronic and Information Technology for Persons with Disabilities." For a downloadable PDF copy, please visit. http://www.calstate.edu/AcadAff/CodedMemos/AA-2007-04.pdf.
Ensuring the accessibility of information technology and resources is a process for continuous improvement that will require a multi-year, phased approach. Given the iterative nature of this process, the implementation will need to occur in stages. A three-year roadmap addresses the three priorities below:
Ensuring the accessibility of information technology and resources is a shared responsibility that cuts across the campus and will require ongoing, overall institutional attention and commitment for its success. One of the common requirements in each plan described in this memo is the identification of roles and responsibilities for each aspect of accessibility. Achieving accessibility will require collaboration among faculty, disability resource centers, bookstores, academic and student services departments, academic technology and other institutional staff, and students with disabilities. Campuses are encouraged to institutionalize their accessibility compliance efforts by establishing policies that support the three ATI priorities. Additionally, systemwide support working with vendors and publishers to address the accessibility of materials will be critical.
Priority One: Web Accessibility
Access to the Internet and its resources, including websites, web applications, and digital content, is considered an area where the ADA applies. The ubiquity of the Internet in delivering information and providing services is an essential reason to make its accessibility a priority for the CSU. Creating and maintaining accessible websites will be an ongoing institutional responsibility. The dynamic nature of the web and the continuous updating of content require a process that can be facilitated by the use of an enterprise-wide web evaluation and monitoring tool along with well-defined campus policy and implementation procedures.
The plan should include, but is not limited to, the following elements, and is due with the First Year Web Report on June 15, 2007.
1. A process for auditing, monitoring and remediation of websites.
2. A process for establishing accountability and documentation procedures.
3. A strategy to ensure that new websites and web content incorporate accessibility in the design and authoring process.
4. A process for determining exceptions and for developing, documenting and communicating the equally effective alternate form of access that will be provided.
5. A process for identifying critical administrative websites that require remediation.
6. A process for providing alternative ways of delivering information during any period in which websites are undergoing retrofit.
7. A training plan for those who develop and maintain websites and who author web content.
8. A communication plan to educate the campus about web accessibility requirements.
9. An evaluation process to measure the effectiveness of the plan.
10. The identification of roles and responsibilities associated with the above processes.
11. Milestones and timelines that conform to the dates listed below.
The milestones identified take into consideration infrastructure development and represent targets for meeting accessibility requirements. To mitigate risk and cost, campuses are urged to begin implementation as soon as possible.
May 15, 2007: Completion of the First Year Web Report. This project replaces the 20-page manual evaluation previously described in the Coded Memo AA 2006-41 dated September 28, 2006. A draft process guide incorporating both an automated and manual checking process for evaluating a sample of campus websites has been developed and placed on the ATI Blackboard site at https://fullerton.blackboard.com/. This first year project will assist campuses in conducting a self-evaluation of the accessibility of their websites and in planning for remediation. (The Technology Access Transition Plan referenced in Coded Memo AA 2006-41 is no longer required.)
June 15, 2007: Submission of the Web Accessibility Implementation Plan and First Year Web Report
No later than September 1, 2007: New and updated administrative websites, web applications, and web content produced by the CSU or by third-party developers should, at a minimum, conform to baseline accessibility standards as defined in Section 508, Subpart B, and where appropriate, Subpart C (http://www.access-board.gov/sec508/standards.htm). This timeline applies only to administrative sites. The deadlines applied to instructional sites are provided in the Instructional Materials section of this memo.
May 15, 2009: All administrative sites that are critical to institutional access (as established in the Web Accessibility Implementation Plan) should, at a minimum, conform to baseline accessibility standards as defined in Section 508. If remediation or replacement of the website is not possible or would constitute an undue burden, then a plan to provide an equally effective alternate form of access must be developed, documented, and communicated.
May 15, 2012: All websites at the CSU should fully conform to Section 508. Once again, undue burden plan requirements (as described above) apply.
Priority Two: Instructional Materials Accessibility
Instructional materials and online course materials also must be accessible to persons with disabilities in order to provide them with effective communication. Communication should be, to the extent possible, as effective for persons with disabilities as it is for persons without disabilities. An essential component of effective communication is timeliness of delivery of accessible formats. To the extent possible, instructional materials, including online course materials, must be accessible to students with disabilities at the same time it is available to any other student enrolled in that program.
By June 2007, following consultation with local faculty senates as appropriate, each campus should create a plan to support faculty and staff practices that will ensure timely access to instructional materials. This plan should include, but is not limited to, the following elements:
1. A process for timely adoption of textbooks by faculty.
2. A process for identification of textbooks for late-hire faculty.
3. A process for early identification of students with disabilities who require instructional materials to be provided in an alternate format.
4. A strategy to increase faculty use of the campus learning management system (LMS) for delivering technology-enabled courses, and for posting syllabi and instructional materials online for traditional face-to-face and hybrid or blended courses.
5. A process to incorporate accessibility requirements in the purchase of digital or multimedia instructional materials (captions on videos, for example).
6. A method to incorporate accessibility as a required component in the curriculum review and approval processes.
7. A plan to support faculty in the creation of accessible course content.
8. A communication process and training plan to educate students, staff, and faculty about the campus Instructional Materials Accessibility Plan.
9. An evaluation process to measure the effectiveness of the plan.
10. The identification of roles and responsibilities associated with the above processes.
11. Milestones and timelines that conform to the dates listed below.
June 15, 2007: Submission of the campus Instructional Materials Accessibility Plan (IMAP).
July 1, 2007: Campuses will implement the IMAP provisions related to timeliness of alternate formats for print-based instructional materials such as those reflected in points #1 to #4 above. These provisions should impact the timeliness of materials for the first academic term of Calendar Year, 2008.
Fall Term, 2008: New courses and new course content, including instructional materials and instructional websites, will be designed and authored in a manner that incorporates accessibility. If incorporating accessibility is not possible or would constitute an undue burden, then a plan to provide an equally effective alternate form of access must be developed, documented, and communicated. Existing course content will be made accessible at the point of course redesign or when a student with a disability enrolls in the course.
Fall Term, 2012: Instructional materials and instructional websites for all course offerings will be accessible. Once again, undue burden plan requirements (as described above) apply.
Priority Three: Accessible Electronic and Information Technology (E&IT) Procurement
Section 508 includes a set of accessibility standards for six categories of electronic and information technology (E&IT) including web applications, hardware, software, telecommunications, multimedia, and self-contained closed products like copiers, fax machines, kiosks, etc. The CSU must incorporate Section 508 standards as it develops or acquires new E&IT resources. The CSU is required to purchase E&IT products and services that conform to the standards established for each category of covered items, if such are commercially available, and their purchase does not result in an undue burden or fundamental alteration.
By June 15, 2007, each campus must develop an implementation plan for the procurement of electronic and information technology (E&IT) covered under Section 508. The plan should include, but is not limited to, the following elements:
1.
Research, evaluation, documentation, verification where appropriate, and determination of exceptions related to E&IT procurement.
2.
A process for determining undue burden or fundamental alteration.
3.
Procedures for providing equally effective alternate access for E&IT acquisitions that are approved for exception or that are not yet subject to the E&IT accessible procurement process.
4.
A communication process and training plan to educate the campus community about Section 508 procurement requirements and the established procedures.
5.
An evaluation process to measure the effectiveness of the plan.
6.
The identification of roles and responsibilities associated with the above processes.
7.
Milestones and timelines that conform to the dates listed below.
Campuses should consider the potential impact of all E&IT acquisitions regardless of source or costs when these products or services are expected to be used by a significant portion of the campus community. This includes acquisitions that do not involve the exchange of monies (open source software) or that are below the $2,500 threshold (survey instruments that will be used by a significant percentage of students).
June 15, 2007: Submission of the Electronic and Information Technology Procurement Plan.
No later than September 1, 2007: Implementation of an accessible procurement process for E&IT formal solicitations and acquisitions greater than $50,000.
September 1, 2008: Implementation of an accessible procurement process for E&IT acquisitions greater than $2,500. All procurement card purchases are exempt from the accessible procurement process at this point in time.
September 1, 2009: Implementation of an accessible procurement process for all E&IT procurement card acquisitions greater than $2,500.
September 1, 2010: Implementation of an accessible procurement process for all E&IT acquisitions less than or equal to $2,500 to be determined by this date, following evaluation of campus progress reports.
NOTE: All of the information above can be found on the coded memo AA 2006-4: "Access to Electronic and Information Technology for Persons with Disabilities." For a downloadable PDF copy, please visit. http://www.calstate.edu/AcadAff/CodedMemos/AA-2006-4.pdf.