In general, our goal is to procure hardware and software that meets digital accessibility compliance standards. The first step to determining compliance is through a completed voluntary product accessibility template (VPAT) called an Accessibility Compliance Report (ACR). These reports are often gathered when hardware or software vendors are being considered for a contract or at a contract renewal period.
What type of situation would require an exception request?
In cases where the Digital Accessibility Officer evaluates situations of egregious Section 508 non-compliance as documented in the ACR, there is a process to follow to file an Accessibility Exception Request (TAC 213.37) that includes:
- Evaluating the situation to determine the impact on staff or students.
- Determining whether compliance with a provision of Electronic and Information Resource (EIR) accessibility law or administrative rules imposes a significant difficulty or expense to the institution.
- Routing the documentation to leadership if compliance imposes a significant difficulty or expense.
- Providing an alternate method of access when required if an exception is approved.
Does having an approved accessibility exception mean we have reduced our risk?
Even when an exception is approved, it does NOT:
- Eliminate risks associated with non-accessible IT, as we would still be open to complaints and lawsuits
- Eliminate the responsibility to provide an accessible solution or an alternative means of access
The goal of documenting accessibility exceptions is not to eliminate risk, but instead to document the situation and provide insights to leadership for strategic software and hardware decisions.
What's included with the exception request?
An exception request would be filed for situations where a product or digital interface poses considerable risk or is egregiously non-compliant, meaning major barriers or inability to access. For each exception request, the requestor includes information outlining the situation with documentation of:
- Solid justification for non-accessible IT
- Non-availability of accessible products (sole solution)
- Fundamental alteration required to make accessible (integrated into systems)
- Cost prohibitive to make Information and Communication Technology accessible (provide a cost analysis)
- A plan for future compliance (limited duration for the exception including product or deliverables roadmap
An exception request is prepared by the Texas A&M Engineering Experiment Station (TEES) Digital Accessibility Officer in association with the owner or requestor. Once prepared, the documentation is routed for review and approval by the TEES IT Director and/or Chief Information Officer and then to the associated Vice Chancellor and Chancellor. If you feel you might have a situation that needs an accessibility exception, please email tees-a11y@tamu.edu.
What happens after an accessibility exception has been signed?
The TEES Digital Accessibility Officer maintains documentation for TEES approved exceptions. Texas A&M Engineering maintains a Laserfiche repository that contains vendor submitted Accessibility Compliance Reports (completed VPATs).
If the procurement has a mixed funding stream, the University Division of IT maintains lists of Texas A&M University approved Exceptions and Supplementary Exceptions for the College of Engineering. Email itaccessibility@tamu.edu for specific details.