Electronic and Information Technology Accessibility Policy Guidance

Individuals with visual impairments may use assistive technology such as screen readers to read the text on a webpage aloud or convert the text to Braille. It is valuable to understand how a screen reader user accesses digital content.

• Screen reader users usually navigate a page using their keyboard. A website that cannot be navigated solely with the use of a keyboard can pose a barrier to some users.
• Proper heading structure helps a screen reader user understand the page organization. They can quickly scan the headings on a page and skip to the content they want to read.
• Similarly, screen reader users may choose to listen to all of the links on a page and skip to a desired link. If a page includes generically labeled links (e.g., “click here,” “learn more” or “next”), the screen reader will read the generic labels without any context, providing no information about the link destinations.
• Screen readers cannot interpret images, so screen reader users rely on properly coded alternative text to provide the content of an image. Additionally, some incorrectly developed documents—particularly PDFs—may look like text but are actually images of text, making them inaccessible to screen reader users.

Users with cognitive and learning impairments may:

• Have difficulty processing information on a webpage,
• Become confused with complex website layouts or inconsistent navigational schemes, and
• Have difficulty focusing on lengthy sections of text

Users with hearing impairments rely on synchronized captions on videos and transcripts of audio files to understand the content on a page. 

Users may not be able to operate a mouse, making keyboard or alternative input navigation essential. They may also need more time to complete tasks on a webpage and/or larger clickable target areas.

The World Wide Web Consortium (W3C) has established accessibility guidelines through its Web Accessibility Initiative (WAI). The WAI’s Web Content Accessibility Guidelines (WCAG) are widely considered the international standard in ensuring accessible electronic content.

The university recognizes that adoption of the WCAG 2.1 AA standards is critical to increasing EIT accessibility. We are in the process of transitioning compliance to this level and expect to be completed by March 2023.

WCAG 2.1 focuses on four user-centered principles of accessibility:

• Perceivable
• Operable
• Understandable
• Robust

WCAG 2.1 includes all success criteria from 2.0, with 17 additional success criteria that address mobile accessibility, as well as practices to promote accessibility for people with low vision and people with cognitive and learning disabilities.

The guidelines include, but are not limited to, the following requirements:

• Provide alternative text for any non-text content when necessary to convey meaning (e.g., images, graphs).
• Provide captions or transcripts for all audio or video content.
• Make all functionality available through the use of a keyboard.
• Ensure color is not used to convey meaning.
• Make text readable and understandable.
• Help users avoid and correct mistakes.

For additional information about WCAG, please see the following websites:

• Web Content Accessibility Guidelines Overview
• WCAG 2.1 at a Glance for a summary of the guidelines
• How to Meet WCAG 2 (Quick Reference)
  

UB’s Content Management System (UBCMS) includes accessibility features that help authors create and maintain accessible websites. For example, the UBCMS requires authors to add alternative text to images. The UBCMS also makes it easy for authors to organize content with headings and bullet points, which not only benefits individuals with disabilities but makes websites easier to navigate for everyone. Still, the UBCMS does not prevent a user from inadvertently uploading an inaccessible document/file (PDF, Word, PPT, etc.), writing generic link text, creating unhelpful or inaccurate alternative text, or posting a video without captions. Website owners and authors must be intentional in planning for accessibility when creating or revising web content.

The Accessibility at UB website provides assistance in understanding and creating accessible content. You can obtain detailed information and instructions in each of the following areas:

• Guidance on website accessibility.
• Guidance on ensuring that Microsoft Office documents and PDFs can be accessed with a screen reader and are easily usable.
• Information about creating accessible audio and video material, including resources for captioning videos.
• Steps to take when you wish to procure EIT products/services.

Building and maintaining accessible websites takes time, guidance and resources. Compliance with the EIT Accessibility Policy requires a combination of individual effort, area-level assistance and centralized expertise and resources. UB’s resources in this area include:

• A university-wide license for Siteimprove, an automated tool that scans websites, identifies accessibility issues and provides information about how to fix these issues. Siteimprove also identifies broken links and misspellings. While manual testing is also necessary to ensure website accessibility, Siteimprove can flag many issues automatically.
• An electronic and information technology accessibility officer in the Office of Equity, Diversity and Inclusion.
• Unit web accessibility liaisons with the expertise to create accessible websites and remediate basic accessibility issues.
• A Digital Accessibility Advisory Committee that provides oversight and guidance on policy and campus-wide accessibility efforts. The committee includes representatives from high-level administrative offices and decanal units including, UB Information Technology, Office of the Vice President and Chief Information Officer, University Communications, University Libraries, Faculty Affairs, Accessibility Resources.
• A central web management website that provides resources on using the UBCMS to create and maintain accessible websites.
• Access to PDF remediation services (e.g., SUNY AbleDocs, etc.) at reasonable costs.
• Ability to use Blackboard A11y in UB Learns to enhance the usability and accessibility of course materials.

UB’s Office of Accessibility Resources will provide assistance with academic adjustments and auxiliary aids that are necessary for students with disabilities to have equal access to course materials. While public-facing videos, webpages and other electronic information must be accessible, information that is not public and that is provided solely to a class must be made accessible when a student with an impairment enrolls in the class and requires accessible content. Accessibility Resources can caption videos and provide other auxiliary aids to assist students and instructors in ensuring equal access to the course materials. Instructors are encouraged to enable auto-captioning in Panopto (although this is imperfect and requires manual review and editing).

UB’s EIT Accessibility Policy applies to all university digital content including:

• Classroom and teaching technologies
• Content and learning management systems
• Desktop, mobile and cloud-based applications created either internally or made available through third-party vendors
• Digital signs
• Electronic documents
• Email
• Instructional materials
• Library resources
• Social media
• Video and audio content
• Websites (public facing and internal)
  

When creating or editing websites, web content, applications, etc., take the time to test for accessibility during development and prior to launch. Identify the essential tasks that a user would complete on the website and perform both manual and automated testing for each one.

• Run automated tests on individual pages of websites and applications. These tools may include Siteimprove, WAVE browser extension, axe DevTools Chrome browser extension, Accessibility Insights, etc.
• Please note: Automated testing only identifies a small percentage of accessibility issues on your site.

• Confirm that all images have meaningful alternative text and that purely decorative images have null alt text.
• Use Adobe Acrobat DC’s Accessibility Checker and Read Out Loud feature to check all PDFs for accessibility. Keep in mind that using the accessibility checker and/or the read out loud feature does not mean your PDF is fully accessible. All medium- and high-impact PDFs should be remediated using services provided by AbleDocs.
• Confirm that all videos include synchronized captioning. Captioning benefits not only individuals with impairments, but also people who do not have or do not want to use speakers.
• Ensure that you can tab through the content to access the links on the page. If so, your page will not rely on using a mouse, which promotes accessibility. Also check to see that when you tab, the order of movement of the cursor makes sense. If your cursor jumps from one area of the page to another without a logical sequence, this will be confusing to visitors using assistive technology.
• Ensure that color alone is not used to convey meaning.
• Ensure color contrast is sufficient.
• Confirm that the content on a webpage can be magnified to 200% without losing content or functionality.
• Confirm that users can bypass redundant navigation links.

Any technology you procure from vendors must also meet accessibility requirements. See the Procuring Technology Requirements for detailed information.

UB has some digital content that may no longer be needed or used to access current university programs, services or activities, but may have historical impact. As stated in the EIT Accessibility Policy, archived content at least five years old is not required to meet web accessibility standards, but the university is required to provide equally effective alternative access to the content upon request. Some examples of archived content include:

• Previous Undergraduate Catalogs
• Meeting minutes

EIT accessibility requirements also apply to email content to ensure that people with disabilities have equally effective and timely access to information in email and attachments. Whether you are sending a plain text email or creating a branded email with a tool like Mailchimp, accessibility standards apply.

Be sure to:

• Utilize accessibility features available in your email tool/program.
• Use a descriptive subject line.
• Use proper heading structure.
• Correctly format lists as lists.
• Use sufficient color contrast.
• Include alternative text on images and avoiding using images of text.
• Write meaningful link text.
• Make sure all attached documents (e.g., PDF, Word, PPT, etc.) are accessible.
• Ensure that any resources you link to are accessible.

When using social media for university services, programs and activities, utilize the accessibility features available in each platform.

• Facebook accessibility features
• X accessibility support for images
• Instagram: adding alternative text to images

In addition, follow these best practices in social media content:

• Add alternative text to images and animated gifs
• Caption videos or embed captions onto video where auto-generated captions are inaccurate or not available
• Use CamelCase hashtags to improve readability (e.g., #ThisIsCamelCase)
• Limit use of emojis
• Include descriptions of gifs, memes and other visual content in alternative text, in the body of the post, in a comment directly below the post or in a link to accessible content
• Don’t use special fonts
• Don’t use special characters to create images

UB’s EIT procurement process helps ensure that products/services purchased by the university meet accessibility standards and align with our institutional values of equity and inclusion. EIT purchased through vendors must be accessible to all individuals, including individuals with disabilities, when they are used to access university programs, services and activities. In order to meet the university’s commitment and obligation to provide accessible EIT, vendors are required to explain how their products/services are accessible and provide supporting documentation.

The university’s EIT procurement process includes several levels of assessment and review.

The purpose of the intake step is to gather information about the nature and purpose of the product and determine the impact the product will have on university programs, services and activities.

Before you make any EIT purchase or renewal (regardless of cost or scope of usage), you must complete one of these two forms (along with their associated steps, including submitting a VPAT/ACR as required):

• Web-based Services and Software Under $50,000 Pre-Purchase Form
• Web-based Services and Software Over $50,000 Pre-Purchase Form

If you have a question about the impact level of your desired EIT, please contact EDI for assistance.

The purpose of the evaluation step is to assess the accessibility of the product and determine if it meets accessibility requirements. Testing proceeds as follows:

After evaluation, EDI grants decisions as follow:

• Full approval: The acquisition may proceed
• Conditional approval: Identified issues must be addressed by the vendor in the remediation period and the department must provide an Equally Effective Alternative Access Plan (EEAAP)
• Denial: The department must submit an exception request to proceed

Regardless of approval status, all medium- and high-impact EIT must have an EEAAP that includes a contact person and a description of how the department/unit will provide accommodations if someone with a disability needs access to the product. (See the complete EEAAP requirements.)

Additionally, all EIT must have a prominent, easy-to-find accessibility statement and information about how an individual can receive accommodations.

The purpose of the exception request is to determine if the product qualifies for an exception from the EIT Accessibility Policy. Limited exceptions may be granted in specific instances where compliance is not possible or would constitute undue administrative or financial burdens or where it would create a fundamental alteration. Departments requesting an exception must provide an EEAAP to ensure that, to the maximum extent possible, individuals with disabilities receive the same benefits or services as their nondisabled peers.

An Equally Effective Alternative Access Plan (EEAAP) is required for all medium- or high-impact EIT, regardless of approval status. Even with products/services that are reviewed and deemed accessible, the user experience may change based on product updates, updates to browsers or operating systems that interface with the product, or the user’s hardware, software or settings. An EEAAP details how individuals with disabilities who have difficulty using the EIT will be provided timely and effective access to the services, information and programs provided by the EIT. Please note that an EEAAP is not a substitute for accessibility and should be reviewed regularly.

The EEAAP must include the following:

• Description of any accessibility barriers in the EIT.
• Description of the person(s) or group(s) that will be affected by this issue.
• Outline of the accommodation that will be provided.
• Detail of how the alternative access will be provided.
• Description of how the available accommodation will be communicated.
• Contact information for the person(s) responsible for providing the accommodation.
• A timeframe for implementing the accessible alternative.
• Steps the vendor is taking to address accessibility issues in the product.
  

In order to begin assessing the accessibility of a product, the university requires that vendors submit a completed Voluntary Product Accessibility Template (VPAT®), also known as an Accessibility Conformance Report (ACR), or comparable documentation. The VPAT 2.x+ is a standard reporting form used to provide an analysis of a product’s conformance to accessibility standards—WCAG 2.1, Section 508 and European Standard EN 301 549.

Most vendors are familiar with the VPAT requirement and will furnish a VPAT upon request. The VPAT should be completed in its entirety and include testing procedures, conformance level and detailed comments about any partially- or non-supported level according to the WCAG 2.1 AA success criteria. In place of a VPAT, vendors may produce alternative documentation establishing the product has been reviewed for accessibility by an independent, credible and knowledgeable service using appropriate standards and testing.

If a vendor refuses to provide a VPAT or similar documentation, this is a strong indication that the company has not considered accessibility in its product design. The department should explore alternative products/services.

In some instances, no vendor offers an accessible product for a particular service. If this is the case, contact EDI for assistance.

Please note that the VPAT/ACR is just one component of the EIT accessibility review and will be retained in case of an audit or for additional review.

The university provides digital content for students and employees that is not public facing (e.g., online training courses for employees, course materials for students and online information systems). This information must be accessible when it is required to access university services, programs or activities. However, in some situations, creating accessible content is not feasible. For example, if a department creates video recordings of every single class and uploads them, captioning each one regardless of whether any registered students require this may be impractical and unwarranted. If a student who requires captioned videos due to an impairment enrolls in a course where lecture recordings are offered to students, or if the department chooses to make the lecture videos public, the content then must be captioned in a timely manner to provide equal access to the materials.

In general, creating accessible content benefits a wide audience and is strongly encouraged regardless of possible legal risk.

Examples:

• A course instructor provides videos of their lectures for students to review. In order to access these videos, students must be registered in the instructor’s course. There is no general requirement to caption the videos. However, instructors are encouraged to enable auto-captioning in Panopto (although this is imperfect and requires manual review and editing). If a student with a hearing impairment enrolls in the course and requires access to the videos, the university will be required to ensure the videos are captioned. The instructor must refer the student to Accessibility Resources. Accessibility Resources will ensure that the lecture videos are captioned because the student requires this as an auxiliary aid to participate in the course.
• An employee with a visual impairment registers for an online training course through UB EDGE. The course is offered through a vendor and is not accessible with the use of a screen reader. The department offering the training course must work with the vendor to attempt to resolve the accessibility issues. If the accessibility issues cannot be immediately resolved, the department must work with the vendor to provide a transcript of the course or provide other equally effective means of accessing the course content.

Individuals with sensory, motor, cognitive and learning impairments must be able to access electronic materials when necessary to access university services, programs or activities. This includes content owned and controlled by UB, whether or not the content was created by UB or a third-party vendor.

In some cases, UB instructors or departments may refer students to external websites for course instruction or services. It is important to verify that external websites are accessible if people must rely on its contents to access UB programs and activities. If pre-existing programs and information cannot be made readily accessible, the university must ensure that a student or employee is provided with equally effective alternative access to the program or activity.

Examples:

• An instructor uses an external publisher’s online learning tools as part of course instruction. Students must complete homework assignments on the publisher’s website and can use the publisher’s online study guide. A student with a visual impairment informs the instructor that she cannot access the homework posted on the website with her screen reader. The instructor contacts the publisher and receives confirmation that while some of the publisher’s website is accessible, the homework assignments are not. The instructor must provide the student with an equally effective means of completing homework assignments for credit in order to give the student a comparable way of learning the material and earning credit for homework.
• A department uses an external vendor to process ticket orders for university events. The department learns that the vendor’s website is not fully accessible, but the vendor has a toll-free telephone number to call for ticket orders available during certain hours. The department must work with the vendor to remedy the accessibility concerns. The toll-free telephone number does not provide equally effective access because, unlike the website, it has limited hours of availability.

Contact the Office of Equity, Diversity and Inclusion (EDI) at ub‑webaccess@buffalo.edu or at (716) 645‑2266 if you have questions or need more information.