Purchasing hardware or software (including hosted services) for the Texas A&M Engineering Experiment Station (TEES) requires documenting the digital accessibility compliance of the product as required by the Texas Administrative Code (TAC), Part 10, Chapter 213.
The Digital Accessibility Officer reviews the completed documents and determines if additional action is required.
What documentation is gathered from vendors during procurement/renewal?
For procurement of hardware and software, the vendor must provide a completed Volunteer Product Accessibility Template (VPAT). Once completed, the document is referred to as an Accessibility Compliance Report (ACR) but it’s very common to hear it referred to as a completed VPAT.
For development services that will be delivered as part of the contact (for example, websites development, custom applications, native apps, etc.), the vendor must provide a completed Vendor Accessibility Development Services Information Request (VADSIR) or equivalent. This provides a clear picture of what policies and processes are in place to ensure accessible products.
In some situations vendors may be required to provide Policy Driven Adoption for Accessibility (PDAA) documentation which offers a holistic self-report of the organization’s inner accessibility governance. The expectation is that organizations with a mature approach to digital accessibility will greatly improve the levels of accessibility conformance in their products.
When is accessibility compliance documentation not required?
Here are some examples to help you determine when accessibility conformance reports are required:
Examples of direct and significant types of use where documentation is required:
- Software used by Texas A&M/TEES, public facing
- Software used by Texas A&M/TEES, employees and contractors
- Externally hosted digital content
Examples of direct and insignificant type of use where documentation would mostly not be required:
- Software purchased one license at a time with a specific user in mind
- Software with no direct user interface (i.e., back-end system)
Examples of indirect and significant types of use where documentation is required:
- Procedures, training, announcements, and other resources - internal or external
- Online payment systems
- Health and retirement benefits services
Examples of indirect and insignificant types of use where documentation is not required:
- Software used exclusively by the vendor
- Vendor-hosted time and leave system
Note: All graphic information systems (GIS) products fall into a statewide exemption.
Back-end systems with no administrative or public user interface in most cases will NOT require compliance documentation. Other examples that would mostly not require documentation include operational technology, high voltage systems, servers, networking equipment, and equipment behind locked doors.
What does a VPAT measure?
A VPAT is formal statements documenting digital accessibility compliance of the product.
- Vendor provides documentation as part of the procurement lifecycle
- Completed using accessibility test results (requires skill/knowledge
- Each version of a product/software needs a new VPAT
A completed VPAT measures the accessibility of an asset against the conformance criteria aligned to Web Content Accessibility Guidelines (WCAG) success criteria. Each criterion can be categorized as supports, partially supports, does not support or not applicable.
What if a vendor is not experienced with filling out a VPAT?
To start, a vendor can review training provided by itic.org that covers how to complete a VPAT.
In some cases, especially for small companies, vendors might not have the expertise on hand to complete a VPAT. It is recommended that VPATs be filled out by digital accessibility specialist that understand the tools and techniques used to determine the levels of conformance.
There are accessibility professionals (not endorsing, just providing a list) that will conduct a review and complete a VPAT for a vendor (costs and turnaround times vary):
- userway.org
- accessibe.com
- levelaccess.com
- deque.com
- tpgi.com
The Texas Department of Information Resources (DIR) is now offering free digital accessibility training for IT vendors serving state and local entities. The training will educate vendors on Texas’ digital accessibility requirements for state websites and electronic and required documentation when responding to DIR’s Cooperative Contracts solicitations. To learn more, visit the DIR website or email them at statewideaccessibility@dir.texas.gov.
How often should a completed VPAT be updated?
Each new version of the hardware or software needs a new completed VPAT. It is recommended that Accessibility Compliance Reports are updated at least every two years, or the vendor can provide a statement that no updates to the software have occurred since the last report was produced.
New templates are available with each update to the accessible conformance standards (i.e., WCAG). Vendors are encouraged to stay informed as new templates are available and update as appropriate.
Is a completed VPAT the only accessibility documentation required to determine digital accessibility conformance?
No, other documentation may be required during the product's lifecycle. VPATs are product-specific documentation. Additional documentation may be required for any custom developed applications or software.
For all developed services, all custom development should be tested for compliance prior to launch. A report is generated with the following information for each WCAG success criteria:
- Audience and scope of use (internal/external, number of users)
- Type of compliance issues (WCAG SC, A, AA, etc.)
- Link to page and number of issues
- Test conditions (versions, platforms, tools used)
- Explanation of the issue (expected result)
- Resolution or Suggested Fix
- Impact (global issue, etc.)
- Severity level or priority
For all electronic content deliverables (training, documents, reports, manual, etc.), the vendor must ensure the materials have passed all accessibility checkers available through each originated platform and/or completed the Electronic and Information Resource (EIR) accessibility checklist prior to delivery. TEES verifies if all deliverables meet digital accessibility compliance standards.