Accessibility Exception Process

黑洞社区鈥檚 Accessible Content Policy (8.11) requires that all instructional content be accessible. This document details the procedure for requesting those exceptions.

The goal of an exception is to document the process by which we will ensure that the university provides effective access, with substantially equivalent ease of use, to instruction, information and services for eligible individuals in a timely manner.

This process was developed by the Accessibility Committee based on the , adapted to meet our specific needs.

Who Does this Process Help?

The university's policies create the possibility of exceptions to the accessibility standards, but not the process that will grant them. This process will make it possible to document those exceptions. In the process, it will provide important benefits to all parties.

Office of Student Accommodations and Testing: The database of resources that we develop will be create a important source of information to speed up the process of discovery in classes where students with impairments will require accommodations.
Students will, as a result of this process, get clearer and more transparent communication about accessibility challenges as they start a course, and will know they need to seek support sooner. Also, because Student Accommodations and Testing will be able to get a head start, the students should get their materials and accommodations faster.
Faculty who use this process to get an exception will be compliant with university policies.
The university will have concrete data on the work that we are all doing to move towards a more accessible future.

Getting Started: Instructor or Course Designer

The person responsible for designing a course -- whether that is the person who will be delivering the instruction or a designer who organizes a course that is delivered by others -- needs to make an evaluation of the components of the course to see if they are accessible.

For the Spring 2020 semester, we are asking instructors and designers to consider the Textbook and resources packaged with the textbook for this process. After the Spring 2020 semester, all resources (including handouts and other instructional materials) should be considered.

A brief guide has been prepared to walk instructors and staff through the initial evaluation of their resources. Follow the link below to the type of resource that you need:

The Exception Request

Exception Requests are handled with a web form:

That form will ask you to provide the following information:

Rationale

The requesting unit must document how this request fits into one or more of the following categories:

Compliance is not technically possible or feasible given current technology
The information or service is used by a specific, limited audience which has no known need for accessibility features
For third party and/or vendor delivered products, no accessible and equally effective alternative for the information or service exists
Making the information or service accessible would require extraordinary measures that constitute an undue burden to the university

Note that for the purposes of determining if an undue burden exists, 黑洞社区 is considered to be a single entity, and thus a burden would be analyzed according to the impact to the institution as a whole and not to the unit requesting the exception.

Equally Effective Access Accommodation Plan (EEAAP)

This plan should address how access barriers in the instruction, information or service will be mitigated, and any benefits or opportunities afforded by the information or service will be provided, in a timely manner for eligible individuals who are unable to effectively use or interact with the information or service.

The primary support team for accommodations is Student Accommodations and Testing, who will make arrangements with other teams if necessary. At the same time, if the instructor or course designer is making choices that are not accessible to students, they will need to be prepared to be an active part of providing accommodations to students.

For example, if the course is using publisher software that is not accessible, the instructor needs to be prepared to provide additional instructional time to students who can't use the software -- at least as much additional instructional time as typical students spend using the software to complete assignments and practice skills. This commitment to provide the accommodation should be expressed in the EEAAP.

In some cases there may be expenses due to accommodations related to an accessibility exception that has been granted. These expenses are the responsibility of the requesting department and/or college.

Depending on the nature of the information or service, examples of an accommodation might include:

Providing an alternative that effectively provides an equivalent result e.g. an alternative software that performs the same or similar function.
Providing assistance to the eligible individual either in-person or over the phone.
Providing the information in a format that meets our accessibility standards.

This plan should take into account the criticality and timeliness of the information or service and address a method to ensure that the eligible individual can access the accommodation without any adverse consequences resulting from the need for the accommodation. This means, for example, that any deadlines imposed by the information or service that are not met due to the use of an accommodation must be waved, and the requesting unit must have a plan to ensure this occurs.

Timeliness should be considered in light of the nature of the information or service but should generally not exceed 10 (ten) business days. The accommodation plan should also address the timeline for delivering the accommodation, and the process by which any benefits or opportunities afforded by the information or service will be provided to the eligible individual.

Communication Plan

The requesting unit must document a plan to ensure that eligible individuals are made aware of the availability of the EEAAP, and the steps they must take to request access, if applicable. These communications should be readily accessible in the same places that any other general communication regarding access to the information or service are present.

In the case of a course, information about the availability of the EEAAP should be included in the course syllabus. For non-academic services and content, appropriate indications that the user can request an accommodation should be provided.

Compliance Plan

Exceptions are designed to be temporary in nature and are intended only to serve as a bridge to provide effective access. Requesting units should document their plan to bring the information into compliance with our accessibility standards. These plans might include:

Contract language obligating the vendor of third-party information or services to bring their software or content into compliance within a period of time.
For internally developed information or services, a timeline for making them accessible and compliant with our accessibility standards.
Detailed collaboration with the vendor to bring their information or service into compliance.

The requesting unit must, if the information or service is not internally developed, have a compliance plan if the third party fails to make their information or service accessible. Examples include:

Contract termination
Financial penalties
Selection of an alternative product
Development of accessible front end
Replacement with internally developed alternative

Exceptions for Non-Academic Systems

This process will also be used to document exceptions, when necessary, for accessibility problems that are not related to instruction. These details will be required in addition to the rationale, accommodation plan, communication plan, and compliance plan.

Business Purpose

The requesting unit must provide the business purpose for the digital information or digital service to include:

Who 鈥� what university or external populations will use the digital information or digital service?
What 鈥� what is the function of the digital information or digital service?
How 鈥� How will the digital information or digital service be made available?

Accessible Alternative Justification

The requesting unit must document if their purchasing process evaluated other alternatives that were more accessible. If so, the requesting unit must explain what business reasons necessitate the selection of the less accessible option. If more accessible alternatives were not evaluated, or did not exist, the unit must document their plan to ensure that a search for a more accessible alternative is conducted when the contract or exception expires.

Request Evaluation Steps

The exception request form will be an online tool with a workflow that includes several steps.

Step 1. Complete the Form

Complete the form.

Step 2. Department Approval

The department will review the submissions and either approve them or return them to the requesting person for revision.

The department approval is an important stage at which assertions in the rationale should be considered. If, for example, the instructor of a course is claiming that more accessible textbooks lack other qualities that make the chosen textbook a better choice for the class despite accessibility challenges, the department chair and other department colleagues are the best subject matter experts to determine the validity of the rationale.

It is also important for the department to be aware of the number of exceptions being requested by their department or office, and to understand the challenges that those exceptions pose if an accommodation must be arranged.

Step 3. Dean/Budget Review Officer Approval

The Dean or other Budget Review Officer (for non-academic areas) will review the submissions and approve them or send them back to the Requesting Person for revision.

At this level, the approval is an opportunity for the Dean to be aware of the number and scope of exceptions being requested before they are passed along to the Provost鈥檚 office.

Step 4. Accessibility Exceptions Committee Review

The Accessibility Exceptions Committee will review the submissions as they come in and prepare recommendations for the Provost.

Step 5. Provost approval

The Provost will provide the final approval for the exceptions.

Once the exceptions have been approved, the Requesting Person will be notified.

Training and Support Resources for the Accessibility Process

A brief guide has been prepared to walk instructors and staff through some initial evaluation of their resources. Follow the link below to the type of resource that you need:

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