The CSU Accessible Technology Initiative

1. The CSU Accessible Technology Initiative • Launched in 2004 • Systemwide collaboration to integrate accessibility into technology adoption policies/procedures in 3 Priority Areas: Web, Instructional Materials, and Procurement • Key Strategies • Establish a clear institutional commitment to AT • Build sufficient capacity to support the implementation • Measure progress over time • Target essential, high-impact areas • Drive vendor improvements to accessibility support • Leverage expertise within and outside the CSU

2. Digital Rentals Project Overview • The CSU Affordable Learning Solutions(ALS) focuses on providing faculty with a wide selection of high-quality curricular content that is more affordable for students • The ALS uses a variety of methods including: • Identify and promote the use of OER and low-cost content • Establish discounted systemwide licensing for commercial content • Share exemplary practices for authoring, selecting, and deploying content • In early 2012, the ALS planned a systemwide RFP to promote digital textbook rentals across the CSU and tasked the ATI to incorporate accessibility throughout the project lifecycle

3. Digital Rentals Project: Overall Goals/Methods • Goals • Clearly convey importance of, and expectations regarding, accessibility to prospective bidders • Determine extent of vendor accessibility support • Leverage procurement process to drive improvements to accessibility support for both products and documentation • Methods • Include accessibility requirements in RFP proposal • Review vendor accessibility documentation • Validate vendor product accessibility claims • Require vendors to document their commitments to resolve accessibility gaps

4. Digital Rentals Project: Prioritization • The CSU annually licenses tens millions of dollars in E&IT products/services yet the ATI has finite resources each year to incorporate accessibility into these contract activities • The ATI shifted from using specific dollar thresholds to implementing the CSU ATI Prioritization Framework which codifies our recommendations regarding priority-setting by • Identifying key factors (impact, probability, and capacity) • Providing key questions to assess and rate each factor • Using the aggregate priority level to select ATI projects/activities • Document their commitments in their annual plans and reports • This method better addresses no-cost but high-impact technologies that may occur without contracts (e.g. Google Apps) as well as expensive but low-impact technologies.

5. Digital Rentals Project: Prioritization (cont…) • In the context of the Digital Rentals project, The ATI also set priorities regarding • The extent of vendor accessibility submission requirements • The extent of access to the eBook platforms and content that the CSU required vendors to provide • The scope and depth of the accessibility evaluation process • The frequency with which vendors are expected to report changes in the status of accessibility remediation • These will be touched on in each of the project stages that follow

6. Digital Rentals Project: Planning Goals • When adopting any E&IT product or service, there are 4 essential questions for which we seek answers to understand the implications of adopting a technology • What accessibility features are provided? • What accessibility gaps are present? • What plans does the vendor have to address known gaps? • What workarounds/accommodations should the campus plan to provide until the accessibility gaps have been addressed? • All procurement activities and requirements are driven by the need to answer these questions

7. Digital Rentals Project: Planning Language • The ATI incorporated accessibility language into RFPs that • Specifically identified our compliance target (Section 508) • Described functional Content Accessibility Requirements tailored to eTextbooks (text access, reading order, semantic markup, etc.) • Linked to key references (e.g. the joint US Dept of Justice/Education ‘Dear Colleague’ letter and associated FAQ) • Clearly identified which accessibility documents should be submitted (VPAT, testing documentation, Accessibility Roadmap) • Provided vendor guidance/templates on preparing accessibly docs • CSU Guide to Voluntary Product Accessibility Template • CSU Accessibility Roadmap Template • CSU Product Accessibility Documentation Guidelines • Required vendors to describe their product accessibility experience and provide a dedicated accessibility point-of contact

8. Digital Rentals Project: Evaluation (Product) • It was critical that we conduct product accessibility evaluations to validate vendor accessibility claims by • Selecting a subset of essential components • Tasks to evaluate (Discovery, Acquisition, Reading, Layout Adjustment, Text Adjustment, Navigation, Annotation, and Printing) • Use cases (blindness, low-vision, keyboard-only operation) • Technical environments (OS, browsers, etc.) • Developing a standardized Digital Rental Accessibility Screening Template to • Record key data (Evaluation Overview, Executive Summary, Recommendations, Detailed Findings) • Key details (Verification Methods, Findings, Comments for each step) • Facilitate comparison across platforms • Conducting targeted conformance testing

9. Digital Rentals Project: Evaluation (Docs) • The ATI then validated vendor accessibility claims in VPAT by focusing on several key factors • Relevance (reflects current version or version to be provided) • Completeness (all relevant sections and criteria are addressed) • Specificity (criteria response clearly indicate extent of conformance) • Accuracy (responses clearly relate to associated criterion) • Correspondence (validated by product accessibility evaluation) • Each vendor received a report that • Summarized key findings from the product/documentation reviews • Listed specific performance reqs (summarized on next slide) • Provided an opportunity to discuss the findings/reqs with ATI staff

10. Digital Rentals Project: Contracting • Vendor requirements • Accessibility Documentation • Revise their VPATs to reflect findings from the evaluations • Commit to provide updated VPATs following major product updates and in advance of contract renewal • Consent for ATI to post updated VPATs and Accessibility Roadmaps to ALS Accessibility site for use by all CSU staff/faculty • Product Accessibility Remediation • Provide Accessibility Roadmaps within 60 days of contract start • Revise Accessibility Roadmaps following major product updates and in advance of contract renewal • Affirm their understanding that progress on product remediation would be a condition for CSU at time of contract renewal

11. Digital Rentals Project: Implementation Planning • ATI supports campus implementation planning by • Posting and discussing outcomes and deliverables from RFP process with CSU community • Guiding CSU campuses to develop an Equally Effective Alternate Access Plan (using ATI supplied template) • Updating website as new information is received and vetted • Maintaining ongoing communication with vendors regarding changes to their platforms • Conducting ongoing environmental scans for promising practices or tools that leverage accessibility features or facilitate workarounds/accommodationsfor accessibility gaps

12. Digital Rentals Project: Outcomes (so far…) • Benefits • Gathered authoritative accessibility information • Eliminated redundant accessibility efforts (evaluation, remediation) • Accelerate remediation of products and accessibility documentation • that resulted in significant improvements • Lessons Learned • Clearly document your accessibility requirements • Provide supportive guidance materials for vendors • Suggest remediation priorities that meet your needs • Involve vendor in workarounds/accommodations planning • Plan for inevitable accessibility gaps