As part of the larger Technology Review Process, the accessibility review is a process for vetting all software, both web-based and non-web-based, to ensure that it meets the requirements of the Tufts Digital Accessibility Policy.  Specifically, the policy requires that all products meet WCAG 2.1 A and AA success criteria as required by Section 508 of the Rehabilitation Act of 1973.

The Digital Accessibility Procurement Protocol is as follows:

1. The requestor obtains a completed Accessibility Report on Compliance (AROC) form from the vendor.
2. The requestor submits the completed AROC form along with the supporting documentation in the form of a VPAT or HECVAT to accessibility-support@elist.tufts.edu.
3. The Digital Accessibility Specialist will review the documentation provided by the vendor and make a recommendation regarding the overall accessibility of the product or deliverable.

Upon review by the Digital Accessibility Specialist a recommendation will be made. Possible outcomes include:

1. Recommend approval if sufficient documentation is provided to confirm compliance of the product or deliverable.
2. Recommend approval if sufficient documentation is provided to confirm partial compliance AND the vendor has provided a product development roadmap with a reasonable timeframe for reaching compliance.
3. Recommend against moving forward if documentation indicates the product is not compliant or is insufficient to determine compliance of the product or deliverable.
4. Recommend seeking a policy exception in limited circumstances, as defined in the Policy Exceptions section of this document.

The Digital Accessibility Procurement Protocol applies to:

• all new purchases of software, both web-based and non-web-based
• public-facing, student-facing, and employee-only, regardless of the number of users
• renewals

The only exception is for single-instance, specialized software or software purchased for individual use that is not required for anyone other than the requestor.

VPAT

Software vendors typically document the accessibility conformance of their product using an industry-standard Vendor Product Accessibility Template, commonly referred to as a VPAT. 

A VPAT provides:

• A product description
• Methods used to evaluate the product's compliance with accessibility standards
• Specific guidelines indicating whether the 'product supports', 'partially supports', or 'does not support', etc.
• Notes field for describing instances of 'partially supports' or 'does not support.'

HECVAT

The Higher Education Community Vendor Assessment Toolkit (HECVAT) is a tool that has been used by institutions of higher education to evaluate the information security and privacy protection to assist in vendor risk management. Beginning with version 3.0 the HECVAT included a series of questions regarding accessibility conformance. 

The version 3.0 and higher HECVAT includes a section on IT Accessibility with questions including:

• Has a third party expert conducted an audit of the most recent version of your product?
• Do you have a documented an implemented process for verifying accessibility conformance?
• Have you adopted a technical or legal standard of conformance for the product in question?
• Can you provide a current, detailed accessibility roadmap with delivery timelines?
• Do you expect your staff to maintain a current skill set in IT accessibility?
• etc.

In the event that a product does not meet the requirements of the Tufts Digital Accessibility Policy, or if the vendor is unable to provide the required documentation in the form of a VPAT or HECVAT, the Policy has provisions for escalating the request to the Office of the CIO for an exception.

In order to be considered for an exception the request must meet one of the following criteria:

Not Technically Possible

When full compliance with accessibility standards is not technically possible.

Examples:

• Virtual or augmented reality media for which full compliance is not yet fully supported.
• A live media stream on a social media platform that does not yet support live captions.

Fundamental Alteration

When bringing the content, product, or service into compliance would fundamentally alter the program or service.

Example:

• A listening comprehension exam for a foreign language class does not provide closed captions because it would fundamentally alter the exam.

Not Commercially Available

• An accessible product which meets the business requirements is not commercially available.

Examples:

• While there are many 3D modeling products on the market, none are fully compliant.
• In order to maintain accreditation a professional school must prepare students to use industry standard software that is not compliant. There is no alternative that meets the curricular need.

Undue burden

When providing an accessible digital product or service would result in an undue financial or administrative burden. Requirements for demonstrating undue burden are taken within the context of the university as a whole, thus making this criterion extremely difficult to meet.