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Digital Accessibility Vendor Cookbook

Table of Contents

Overview

  • There is a strong business case to make your digital products accessible to all users
  • Higher ed institutions are legally required to buy accessible products
  • Disabled and nondisabled users will benefit from accessible design throughout your products' lifecycles
  • Beware of third party "quick fixes" that may be marketed as Americans with Disabilities Act (ADA) compliance solutions but do not result in genuinely accessible products
  • The VPAT/ACR and HECVAT are two common instruments for communicating the accessibility of your products

What is the Digital Accessibility Vendor Cookbook?

Accessibility is an essential factor in the purchasing decisions of higher education (higher ed) institutions, where building inclusive educational and employment experiences is both a value and an obligation. The Digital Accessibility Vendor Cookbook is a tool to help vendors create and deliver digital products that meet the accessibility needs of colleges, universities, and other higher ed customers.

This cookbook will:

  • Present the information you need to understand digital accessibility in the context of higher ed
  • Help you make your product usable by as many people as possible
  • Explore strategies you can implement to develop accessible products
  • Promote collaborative relationships between vendors and institutions to create accessible and inclusive environments in higher education

Who this cookbook is for

If you work at the intersection of digital technology and higher ed, this cookbook is for you. This includes decisionmakers at technology vendor companies; designers, developers, and testers; legal consultants, procurement staff, and administrators.

Cookbook sections

  • The accessibility business case: Understand why accessibility makes good business sense in the higher ed marketplace.
  • Digital accessibility and the law: Know how the legal landscape of higher ed informs institutional standards and practices.
  • Disability and technology: Learn about the different ways users interact with tools and technologies, and how you can incorporate this understanding into your design process.
  • Institutional accessibility standards: Find out about the guidelines that define accessibility compliance for higher ed institutions.
  • Documenting accessibility: Understand VPAT/ACR, HECVAT, and other formats vendors can use to document accessibility of their products.
  • Avoiding accessibility pitfalls: Know how third party products that claim to improve accessibility may actually be ineffective, or even make things worse.
  • Maintaining accessibility after the sale: Learn steps to take after a purchase, including establishing accessibility contacts, planning a reporting process, and communicating accessibility-related changes.

The Accessibility Business Case

Key Points

  • The return on investment (ROI) for accessibility extends well beyond disabled users
  • Campus culture includes a demand for accessibility
  • Campuses interact to share information about accessibility of specific products
  • Accessibility implementation is much less costly and is easier than accessibility remediation
  • Campus leaders are concerned about legal ramifications of inaccessibility

Accessibility Return on Investment (ROI)

Accessible design intersects with good mobile design.

  • Example: Web pages that automatically reformat in response to magnification tools benefit both people with low vision and people using small screens. It is also important for both user categories that these reformatted pages do not require left-right scrolling.
  • Example: Buttons that can only be activated with a mouse will not be responsive to the touch screens used by most mobile users or to alternative input strategies used by many disabled individuals.

Accessible design intersects with good usability.

  • Example: Web pages often include navigation aids such as breadcrumb trails, which appear at the top of the page and look like "Home->Topic->Subtopic." These can help users with cognitive disabilities as well as anyone unfamiliar with the website.
  • Example: High color contrast between text and background benefits people with many types of disabilities, as well as individuals trying to read screens in environments with poor lighting.

Accessible design intersects with search engine optimization (SEO) to help people find your page more easily.

  • Example: Tools that accommodate disabled individuals and search engines both benefit from text that describes the content of photos and other images.
  • Example: Closed captioning on videos can also contribute to SEO.
  • Example: Unique and descriptive page titles both help users recognize what page they are on and provide useful results in online searches.

Accessible design is a product differentiator.

  • Higher ed institutions and public entities must consider accessibility as a functional requirement of product selection. Some entities must consider accessibility first as part of their product selection process.
  • Investing in accessibility is important. Higher ed institutions and other public entities discuss product accessibility early and often when considering new products or renewals.
  • Higher ed institutions and public entities have a very strong word-of-mouth network regarding accessible products and services. Sales teams with more accessible products experience broader reach and reduced effort in the sales process.

Campus Culture

Although campus cultures vary, a consistent and significant aspect involves broadening reach and impact, and being welcoming. Higher ed institutions want to ensure disabled individuals have access to class materials and academic publications, as well as programs, services, and activities. If you want to increase the impact and reach of your products, consider how to make them accessible and available to all.

Most higher ed institutions seek to provide access to research, scholarship, and engagement to the public and academics. To promote the broadest impact and ensure scholarship is disseminated effectively, they have an interest in the accessibility of tools, platforms, and content.

In order to provide a culture of accessibility, products and technologies should be usable by everyone. Institutions want to ensure disabled students have access to systems so that the impact of scholarship is broad. They also have an interest in providing accessible systems and tools that are employee facing to ensure they can attract, hire, and retain talented faculty and staff who may have a variety of disabilities. A campus culture of accessibility is part of how higher ed institutions encourage participation of people with disabilities in their programs, services and activities. This includes academic work, employment, sporting events, cultural events, and more. Vendors that sell accessible products help support this mission.

Cost-Effectiveness of Accessibility Implementation

The Americans with Disabilities Act (ADA) includes guidelines about heights for installing water fountains. It costs nothing extra to install the fountain at a compliant height. However, ripping out and reinstalling a non-compliant fountain can be costly in terms of both money and time.

Digital accessibility is similar. Planning to create accessible products up front may take some additional time and thought, but it will be much cheaper and easier than implementing accessibility as an afterthought in response to customer complaints or requests.

According to a 2022 report, 96% of audited postsecondary websites failed to meet basic accessibility standards, and 61% of these institutions face a high or very high risk of litigation (1). A landmark lawsuit in 2024 against West Virginia University determined that higher ed institutions are responsible for implementing digital accessibility even before the 2026 deadline to meet new ADA Title II regulations (2).

Legal audits include procured third-party products as well as websites developed in-house. Therefore, settlements and preventative measures include attention to accessibility in the RFP, contract, and renewal phases of procurement. Being able to prove the accessibility of your product up front will facilitate each of these phases with many institutions.

The University of Minnesota maintains a long list of postsecondary institutions that have faced lawsuits and complaints related to one or more digital accessibility violations. In most cases, this has resulted in a settlement where the institution commits to a rigorous program of ensuring digital accessibility going forward.

Summary

  • Implementation of accessible design can increase your academic customer base by demonstrating responsiveness to legal, procurement, and other concerns.
  • Implementation of accessibility design will improve your product's reputation among potential customers.
  • Implementation of accessible design will facilitate other priorities, such as mobile compatibility.
  • Implementation of accessible design up-front will enhance your cost effectiveness.

Citations

(1) Bureau of Internet Accessibility. 2022. "Why Colleges and Universities Face More Web Accessibility Lawsuits" Blog, June 27.

(2) Hill, Eve. 2025. "West Virginia University Sued Over Inaccessible Educational Technology." Law Office of Lainey Feingold blog, March 25.

Further Reading

Forbes.com. "The Power of the Purple Dollar: A Business Case for Web Accessibility."

W3C Web Accessibility Initiative. "The Business Case for Digital Accessibility."

Deque.com. "The Business Case for Accessibility."

Viget.com. "The Business Case for Accessibility."

Digital Accessibility and the Law

Key Points

  • Purchasing or using inaccessible products increases legal risk for the school
  • Specific federal legislation affects any higher ed institution that receives federal funding
  • Some institutions may be subject to additional state laws
  • Digital accessibility is consistently found to be within the scope of the Americans with Disabilities Act (ADA)

People with disabilities are legally protected from discrimination. Higher ed institutions are legally required to ensure equal access for students, faculty, and staff with disabilities. Beyond direct state and federal enforcement, most accessibility laws allow individuals, including students and employees, to sue institutions that use inaccessible products.

Some of these laws are nationwide. They affect any institution that receives federal funding; for example, financial aid or research funding. In addition, there is often relevant state legislation that higher ed institutions must adhere to when making purchases. Most institutions also have internal web or digital accessibility policies.

In this document we will only discuss federal legislation. The prominent laws are:

  • The Americans with Disabilities Act (ADA) of 1990
  • The U.S. Rehabilitation Act of 1973 (includes Sections 504 and 508)
  • Section 1557 of the Affordable Care Act (ACA)
  • Additional accessibility laws and regulations which may be more narrowly applicable depending upon industry or the purpose of the product(s) you offer.

Unlike individual vendors or publishers, higher ed institutions have specific legal obligations related to digital accessibility. There are many court cases, settlements, and resolution agreements which demonstrate regulators' view of digital accessibility as part of existing laws. This means in order to do business with higher education institutions, vendors must supply products that meet established standards for digital accessibility. Failure to provide accessible products and documentation places additional burdens on institutions, who must demonstrate compliance with various applicable laws and regulations.

The Americans with Disabilities Act of 1990 (ADA)

The Americans with Disabilities Act (ADA), sometimes also referred to as the ADA Amendments Act of 2008 (ADAAA), as amended in 2008, applies mainly to the public sector, while the Rehabilitation Act applies to federal agencies and federally funded programs.

Title II of the ADA prohibits discrimination based on disability by public entities, regardless of whether they receive federal financial assistance. In April 2024, updated regulations for Title II of the ADA were issued, requiring practically complete compliance with the Web Content Accessibility Guidelines 2.1 Level AA by 2026 for public higher ed institutions. Vendor-provided products, websites, and services are not exempted from compliance considerations that affect postsecondary institutions. To prepare for this deadline, post-secondary institutions are already contacting vendors and requiring accessibility as part of their agreements.

The Rehabilitation Act of 1973

The Rehabilitation Act applies to federal agencies and federally funded programs. It is an extension of the Civil Rights Act of 1964.

Section 504 prohibits discrimination based on disability in any program or activity operated by a federal agency or by recipients of federal funds. For higher ed institutions, this is largely tied to federal student aid. This requires that institutions provide disabled individuals an equal opportunity to participate in their programs and benefit from their services, including the provision of information to employees and members of the public.

Section 508 requires Federal agencies to ensure that persons with disabilities, both employees and members of the public, have comparable access to and use of electronic information technology. Section 508 specifies standards for whether or not a violation occurred, currently based on the Web Content Accessibility Guidelines (WCAG) version 2.0. Section 508 compliance may be required by postsecondary institutions in certain states or in cases where a postsecondary institution is receiving funding from specific grant-making agencies.

In 2024, updates to the Section 504 regulations created more specific requirements for digital accessibility in alignment with the requirements of the ADA Title II. Section 504 now requires meeting WCAG 2.1 at level AA. Postsecondary institutions and health systems that receive federal financial assistance will be expecting vendors to provide products that comply with these requirements.

Summary

  • The Rehabilitation Act and the ADA have long mandated the responsibility of postsecondary institutions to provide accessible digital products. Recent publications have clarified and strengthened these mandates.
  • Your potential customers have no choice but to be emphatic about the need for the products that they purchase to meet accessibility guidelines.
  • Vendor proactivity around accessibility will greatly facilitate your ability to respond to customer questions and RFPs with assurance that your products will meet or exceed their legal obligations.

Disability and Technology

Key Points

  • Different users interact with tools and technologies in different ways
  • Some users may use assistive technologies
  • Universal Design benefits users with and without disabilities

What is Disability?

Contemporary definitions of disability focus on addressing disparities between individual capabilities and physical, attitudinal, and social barriers. For example, the World Health Organization defines disability as resulting from "the interaction between individuals with a health condition [...], with personal and environmental factors." Under the Americans with Disabilities Act, a person with a disability is defined as "a person who has a physical or mental impairment that substantially limits one or more major life activity." Definitions of disability often include people who use other languages to describe themselves. For example, many people who are Deaf or neurodivergent may be covered by the ADA, but may not describe themselves as disabled.

Given the ubiquity of digital platforms for study and employment, digital accessibility is imperative for success in higher education. Some digital accessibility issues can even cause physical harm to users. Disabilities and identities that are more likely to impact a person's use of computers and mobile devices include those related to:

  • Vision (blind, low vision, colorblind, etc.)
  • Hearing (deaf, hard of hearing, etc.)
  • Hands and arms (carpal tunnel syndrome, arthritis, tremors, missing limbs, etc.)
  • Neurology (seizures, migraines, multiple sclerosis, etc.)
  • Balance and motion perception (vertigo, motion sickness, etc.)
  • Neurodivergence, which affects communication, learning, memory, processing, and reading (autism, ADHD, dyslexia, etc.)

Assistive Technology

Assistive technology includes software, hardware, and other tools to help disabled individuals use standard computing equipment. The Web Accessibility Initiative (W3C WAI) has a useful series of one-minute videos that demonstrate how assistive technology works and how its use is affected by digital design.

Some types of assistive technology are:

  • Audio output software typically uses synthesized speech to represent a computer's user interface and substitutes the mouse with keyboard interactions. Software designed for blind users might also provide Braille output. Examples include JAWS, VoiceOver, and NVDA for blind and some other users, and Read&Write and Kurzweil 3000 for neurodivergent users.
  • Screen magnification software allows people to enlarge the display's content, mouse and text cursors; adjust the display's contrast; apply color filters; and provide basic screen reading or text-to-speech functions.
  • Speech recognition technology helps individuals who are physically unable to type or use a mouse. It can also be beneficial to people who have difficulty with spelling or other writing skills.
  • Captioning for media content can support better access for people with a variety of disabilities. While captioning grew out of a need for better access for D/deaf and hard-of-hearing individuals, captioning is now widely used and preferred by many people.

For an IT product or service to be considered equitably accessible, users using assistive technologies must be able to access and use all the same benefits, information, functionality, and interactions as someone who does not use assistive technology.

Just as your product evolves to stay competitive in the market, assistive technologies improve to meet the demands of their customers. Keeping pace with trends in assistive technology can alert you to more accessibility potential as you improve your product. Vendors are encouraged to be aware of types of assistive technology, and to integrate testing with assistive technology into their workflows. There are many free and open-source products which may be used to assist with this type of testing. Your customers can let you know what products their students and staff are using.

Universal Design

Accessibility is about more than simply complying with standards. It is about developing solutions to meet the needs of all users. Applying universal design principles helps address and improve accessibility in areas such as digital strategy, procurement, and the design and implementation of digital products.

Through universal design, you will:

  • Save money and staff time by creating accessible products from the start
  • Leverage your accessibility efforts to create products that are attractive to all users
  • Ensure that postsecondary institutions will be able to adopt your products without violating federal, internal, and other requirements
  • Enhance the usability of your products for everyone

A good example of universal design is the steady increase in Internet usage by older adults. This is likely to escalate as a large percentage of existing Internet users age, including higher ed students, instructors, and staff. There are mild accessibility preferences that almost all older users will have, such as high color contrast and reasonably sized fonts. Since disability incidence tends to increase with age, the larger number of users with moderate to major access needs will also need to be considered.

Summary

  • Practicing digital accessibility as part of your regular work creates a more usable, inclusive digital environment.
  • If your digital technology and content are accessible, disabled people will have access to the same information, can engage in the same interactions, and can enjoy the same services and benefits as non-disabled people.

Institutional Accessibility Standards

Key Points

  • U.S. higher ed institutions are looking for conformance with digital accessibility standards
  • The usual standard is the Web Content Accessibility Guidelines 2.1 or 2.2 at level AA (WCAG; sometimes referred to as WCAG 2.x)

Institutional Requirements

An overwhelming majority of U.S. higher ed institutions require or recommend conformance with accessibility standards for digital technology. In some cases, institutions are required to maintain accessibility policy and standards as part of a mediated agreement, arbitration, or other complaint resolution.

Vendors can distinguish their product in the higher education marketplace by providing technology that meets or exceeds common, widely accepted accessibility standards, such as WCAG 2.1 AA.

Web Content Accessibility Guidelines (WCAG)

Authored and maintained by the World Wide Web Consortium (W3C), WCAG is widely recognized as the prevailing worldwide standard for digital accessibility. Most higher ed institutions are looking for conformance with WCAG version 2.1 AA, which was released in December 2022, or WCAG 2.2 AA, which was finalized in October 2023.

WCAG consists of 13 guidelines for accessibility, each of which is supported by testable success criteria. The guidelines are organized into three compliance levels: A, AA (double-A), and AAA (triple-A). Each level addresses a set of accessibility issues based on their potential impact on end users. The guidelines may be applied to a wide variety of technologies. Each guideline contains Success Criteria (SC), which are individually testable criteria that technologies should meet to be considered compliant with the WCAG standard. The most common implementation of WCAG is version 2.1 at Level AA, which includes conformance with all Level A and AA criteria. WCAG 2.2 is expected to have increased usage, as large technology companies update their protocols for accessible development.

WCAG forms the basis for other standards and regulations worldwide, including:

  • Title II of the Americans with Disabilities Act
  • Section 504 of the Rehabilitation Act
  • Section 508 of the Rehabilitation Act, which references WCAG 2.0 AA (United States)
  • Various international standards, including, but not limited to
    • The European Accessibility Act (EAA), EN 301 549, which references WCAG 2.1 AA (European Union)
    • Accessibility for Ontarians with Disabilities Act, which references WCAG 2.0 AA (Canada)

In addition to web content, WCAG is widely applied to a variety of digital technologies, including software, non-web documents, non-web applications, and mobile apps. Many content authoring platform vendors include guidelines that content creators/authors can use to create accessible documents and media using their products.

Summary

  • Vendors should ensure that their technology products meet applicable accessibility standards adopted by institutions of higher education.
  • Implementation of WCAG, Section 508, and other state and local standards can help vendors meet the accessibility requirements of their customer base.

Documenting Accessibility

Key Points

  • The Voluntary Product Accessibility Template (VPAT) and the Higher Education Community Vendor Assessment (HECVAT) Toolkit are two common documents for communicating your product's accessibility
  • Providing detailed and accurate information using these forms and supplemental documents will greatly facilitate accessibility reviews of your products.
  • Third-party vendors can help you fill out these forms; choose them wisely.

Overview

In many cases, higher ed institutions will require accessibility documentation when procuring new technologies. Vendors can distinguish their products in the higher education marketplace by providing detailed, accurate documentation of their accessibility status.

Two documents for sharing accessibility information are now widely expected by higher education institutions: the Voluntary Product Accessibility Template/Accessibility Conformance Report (VPAT/ACR) and the Higher Education Community Vendor Assessment Toolkit (HECVAT). Accessibility questions have been included in the HECVAT beginning with version 3.0. Both of these instruments allow the vendor to report on their product's accessibility. Vendors should also document accessibility information not covered in the VPAT/ACR or HECVAT.

Valid compliance documentation requires manual accessibility evaluation, since many WCAG 2.1 AA Success Criteria can only be checked manually.

Voluntary Product Accessibility Template (VPAT) / Accessibility Conformance Report (ACR)

The Voluntary Product Accessibility Template (VPAT) is an industry standard document for vendors to document the accessibility of their products. Vendors complete the document by recording their product's conformance to selected accessibility standards. When creating a report for higher ed institutions, vendors should ensure that WCAG 2.1 AA or WCAG 2.2 AA standards are used (via the WCAG or INT version of the VPAT).

Completion of the VPAT yields an Accessibility Conformance Report (ACR) that potential customers can review as part of the procurement process. Note that the acronyms VPAT and ACR are often used interchangeably, though ACR may be used to describe accessibility documentation beyond the VPAT.

The ACR is applicable to a wide variety of technologies. Vendors can generate them for:

  • Web sites, applications, and content
  • Non-web digital documents
  • Software
  • Support documentation and service
  • Streaming video and audio

Vendors are strongly encouraged to provide an ACR for all of their digital product offerings, and some schools may require them as part of their procurement process. Although anyone can create ACRs based on the VPAT, it is recommended that vendors obtain ACRs from a reputable third party to ensure detailed, accurate reports. Some vendors also maintain ACR documentation through their internal accessibility teams and update that documentation on a product by product basis at regular intervals.

To be considered valid by most higher ed institutions, ACRs must be correctly and completely filled out and must be current (e.g., created/updated within the last 18 months, for the active version of the product, and using the latest version of the VPAT).

Manual accessibility auditing or review is required in order to make a statement of compliance with VPATs or HECVATs, as manual testing is required for many WCAG 2.1 AA requirements.

Higher Education Community Vendor Assessment Toolkit (HECVAT)

The Higher Education Community Vendor Assessment Toolkit is a comprehensive questionnaire that vendors complete to provide a detailed picture of their cybersecurity, privacy, accessibility, and AI practices and processes in one place—helping higher education leaders make better technology decisions, faster. Using the HECVAT reduces the overall vendor effort needed to communicate these IT compliance areas to potential customers. Note that if you provide a HECVAT using a template version prior to v3.0 (v4.x is now preferred), you may receive a request to provide an updated HECVAT or answer an internal questionnaire.

The accessibility portion of the HECVAT includes questions to measure both the vendor's accessibility practices and the accessibility of a given product. Vendors are encouraged to complete and offer a HECVAT, including accessibility questions, with their digital products.

Note: Vendors should include complete and accurate accessibility information in their new or updated HECVAT documentation.

Learn more about the HECVAT assessment framework.

Third-Party Accessibility Reviews

You may wish to have a third-party company that specializes in accessibility reviews evaluate your products and fill out your VPATs or HECVATs. Note: the above link is not specifically endorsed by the BTAA or any member institutions, but instead is included to demonstrate the widespread availability of these services. Some higher education institutions may require a third-party review as part of their procurement process.

The following are strategies to ensure that you are selecting a good provider:

  • Ask your professional peers for recommendations
  • Ask candidate companies for sample ACRs or HECVATs that they have created. These samples should be fully filled out and include detailed information on why features are or are not in compliance with WCAG or other standards.
  • Ask candidate companies the following questions:
    • How long have you been in business?
    • Do you perform manual testing instead of or in addition to automated testing?
    • Do you have assistive technology users who perform testing with products to ensure compatibility?
    • (if appropriate) Your product has many complex features. Do you have experience reviewing similar types of products?
    • What guarantees do you provide? For example, if one or more of your findings are challenged by our customers, how will you respond?
    • Do you provide any other services, such as remediation assistance?

Common Questions Customers May Ask You

Vendors should provide any additional accessibility information in an organized and proactive manner. Consider preparing answers and documentation for the following questions:

  • What standards do you apply when considering the accessibility of your product?
  • Who is your company's accessibility contact? How can customers provide feedback on accessibility issues?
  • How does your company incorporate accessibility into its product lifecycle? Will updates or new versions impact the accessibility of your product?
  • Will you provide a functional instance of your product for accessibility testing? Can you share any results of accessibility testing? Can someone in your company demonstrate your product using assistive technology?
  • Are there known accessibility or compliance issues with your product? What remedies will your company provide for accessibility issues discovered after the procurement process is complete?
  • We received a report of X issue. Here is the documentation that demonstrates the issue. How soon will this be fixed?

Summary

  • Accurate, detailed information regarding the accessibility of your product adds value to your customers by helping them understand how your product meets their regulatory, legal, policy, or other requirements.
  • By demonstrating a commitment to accessibility, vendors can simplify and expedite accessibility reviews associated with the procurement process.

Avoiding Accessibility Pitfalls

Key Points

  • Automated tools that promise to fix accessibility issues need to be used with great care, if at all
  • Some tools can even make accessibility worse rather than better
  • Having separate main and accessible versions of a product or document can also be problematic

Vendors have an obligation to follow accessibility standards and best practices. "Solutions" such as overlays (sometimes marketed as accessibility compliance tools, shims, or widgets), alternative versions, and AI "quick fixes" are generally not viable options for meeting the needs of higher ed institutions.

Accessibility Overlays

Overlays are a broad term for technologies that claim to improve the accessibility of a website or implement WCAG compliance. They apply a script to the page that scans the code and automatically attempts to repair problems. Some overlay vendors claim to fix any problems in the website's code that are preventing assistive technology from being used easily.

Beware of companies that provide or promote overlays as an accessibility fix. These are proven to be ineffective and may cause other problems, such as security and privacy risks. These products increase institutional risk in IT compliance, such as security, privacy, and accessibility. In April 2025, the U.S. Federal Trade Commission approved a final consent order against an overlay vendor, prohibiting them from making misleading claims and requiring the company to pay a $1 million fine. The final order bars the company from representing that its automated products can make any website WCAG-compliant or can ensure continued compliance with WCAG over time, unless it has the evidence to support such claims. That company and other overlay vendors are currently the subjects of multiple class-action lawsuits. Schools including the University of Michigan, Indiana University, and the University of Iowa, provide specific guidance against overlay use.

Conforming alternate versions and work-arounds

In the past, it was sometimes permissible for vendors to provide both an inaccessible product and an alternative "accessible" product version. The latter is referred to as a "conforming alternate version." These alternate versions were often problematic, especially when they were not updated with the same regularity or completeness as the primary version.

It was also permissible for higher ed institutions to create a work-around for some inaccessible vendor products if a person with disabilities needed to use them. As an example, a publisher's PDF of a textbook might be inaccessible because text-to-speech technology (software that a blind or neurodivergent person might use to have content read to them) cannot access it. But someone at the institution might scan the PDF into a standard text form and paste it into a Word document, which could then be read.

The April 2024 ADA regulation updates significantly limit the situations in which schools can use conforming alternate versions or provide work-arounds to using vendor-provided products with accessibility issues. This means that conforming alternate versions of websites, applications, or documents often do not meet the current standard.

There are rare, specific circumstances where higher ed institutions may use conforming alternate versions of products. These conforming alternate versions may include items marketed as "accessible versions" of products. However, if there are accessible products on the market, schools cannot easily make use of conforming alternate versions if other products offer accessibility as part of their "main" product.

In instances where higher ed institutions can use conforming alternate versions, there are strict restrictions: They cannot use these versions unless the main product cannot be made accessible because of legal or technical reasons. These restrictions may make providing conforming alternate versions infeasible in many cases. Additionally, suppliers often indicate that it is resource intensive to build and maintain two separate but equal versions of their product. For these reasons, higher ed institutions typically look for products that are already demonstrably accessible and that do not rely on school or vendor remediation, retrofitting, or the maintenance of two versions of the product.

AI Quick Fixes

The use of AI tools has increased and evolved dramatically in recent years. The mediated use of AI tools can offer developers and designers opportunities to enhance their workflows in making accessibility improvements. However, using an AI solution to provide accessibility fixes or improvements without developer mediation may result in an increase in accessibility issues. Many higher education institutions are exploring the use of AI tools to assist in accessibility efforts. However, only using AI quick fixes to improve accessibility is fraught with issues, and negatively impacts end users with disabilities. For example, AI may be used to generate text descriptions of photos or other images. These need to be reviewed to ensure they are accurate and appropriate in context.

Some organizations may use automated accessibility testing tools, including those that utilize AI, in order to create compliance documentation. Manual accessibility testing is also required to accurately fill out accessibility compliance documentation.

Summary

  • Shortcuts are seldom effective in providing genuine accessibility
  • Awareness of how third-party products may promise more than they can deliver will help you act wisely to deliver accessible products that will fulfill your customers' needs

Maintaining Accessibility After the Sale

Key Points

  • Maintain products that meet accessibility standards through active and ongoing processes as updates are released, technology changes, and products evolve
  • Create and follow your accessibility roadmap
  • Track and resolve accessibility bugs in a timely manner so current users will have effective access to their education

Overview

All higher ed institutions are required to provide accessible experiences to all current users, particularly if these users have a stringent timeline related to their classes or job. The products that you sell and maintain must therefore be functionally accessible throughout the lifecycle. Customers cannot fix your product for you and relying on workarounds is not a compliant approach.

Additionally, accessibility staff often have to maintain knowledge of the accessibility of hundreds of products. It's important that vendors provide updated accessibility information and sustain accessibility initiatives for in their products.

It is common for today's contracts to contain language about remediating deficiencies, maintaining accessibility over the life of the contract, and following through on accessibility roadmaps. While there is much focus on standards, testing tools, and audits/complaints, higher ed institutions are ultimately looking for solutions that provide equitable access to education, employment, and other experiences that they offer. Demonstrated dedication, implementation, and ongoing support for accessibility will ultimately determines the real-world success of the product/service and the partnership with the school.

Start Building from the Purchasing Process

Many company employees, whether or not they are involved directly with product development, will have a role to play in ensuring product accessibility:

  • Product and development teams can demonstrate their commitment to accessibility through an integrated approach that begins with the purchasing process and continues after the sale.
  • Sales and contract teams should share accessibility issues, evaluation results, implementation plans, and customer questions gathered as part of the proposal with leadership, development, product, and support teams.
  • If an accessibility roadmap with a timeline was not already developed as part of the purchasing process, now is an excellent time to create that and get buy-in from leadership. If it is not possible to address all issues right away, being transparent and making a concrete plan available is critical for documenting your commitment to accessibility. If existing accessibility issues were identified, those should be filed as product bugs and prioritized.
  • Everyone's role should include general knowledge of and attention to accessibility. However, key accessibility team leaders can provide the necessary professional development and connections to the field to maintain accessibility knowledge and make informed decisions.

Establishing Accessibility Processes

The following best practices will help facilitate accessibility implementation:

  • Vendors should provide higher ed users and support staff with up-to-date accessibility documentation, including known issues and minimum requirements. It is best to make this documentation available on a permanent webpage so that campus knowledge bases (KBs) can link directly to this documentation instead of duplicating it. Make sure this information appears in context where users can readily find it.
  • Provide a clear, accessible, easy-to-find way for school staff and end users to report issues and barriers. Collect enough information about the user and their technology to be able to pinpoint issues. Make sure you have mechanisms to label accessibility issues in your ticketing system so that these issues can be prioritized, retrieved, and reported back to the higher ed institution.
  • Establish parameters for prioritizing reported accessibility issues and consider them bug reports rather than future functionality. The volume of accessibility issues reported is not a good indicator of priority, as one student encountering a substantial accessible barrier is one too many users who do not have effective access to their education and puts your customers in jeopardy.
  • Regularly test for accessibility, particularly in advance of major releases. Make sure new features are accessible from launch and updates to existing features do not break existing accessibility functionality.
  • If your product offers content authoring functionality, include information on how staff, faculty, or students can create accessible content.

Anticipate Evolving Technology and Accessibility Standards

Technology and accessibility standards will change over time, along with your product. This includes the development tools you use, delivery mechanisms like web browsers, and users' assistive technology. This is normal and expected; it does not move the goalposts.

Use open standards to ensure compatibility with the widest range of technology and ensure that frameworks and templates used are accessible. It is not typically appropriate to require a specific assistive technology or browser, but it is okay to set minimum supported operating systems, assistive technology versions, or browser versions. If your product development process applies standards such as the Web Content Accessibility Guidelines 2.1, then it should be widely usable by assistive technologies that are supported to use on modern operating systems.

Hold focus and user group sessions with representative campuses to keep communication channels open and to discover early what some of the changes and barriers are. Some vendors provide accessibility groups for customers to provide structured feedback to product teams. This can also be a time to vet innovative approaches that extend beyond current best practices and standards. Please recognize that customers should not need to perform your accessibility testing for you.

Provide an open communication channel with campuses and monitor listservs for issues. Higher ed institutions want to share this information but need an easy way to do so and some ensurance of results.

Remember that with the shift to vendor and hosted solutions, schools do not have access to make code changes. They are dependent on you to make timely fixes. It may also be important to advise customers when product customizations may interfere with regular updates that product teams make, including to accessibility.

Summary

It is easy to view the product sale as the final point at which you need to address accessibility. However, maintaining accessibility is an active and ongoing process that higher ed institutions need and expect from you. Vendors should:

  • Actively build accessibility into their design and testing process to provide products that are as accessible as possible when first released.
  • Create and follow accessibility roadmaps in a timely manner, which may include
  • remediating issues that were identified during the purchasing process
  • Support campuses and users by maintaining accessible products through the lifecycle, including continuing to perform user testing, implementing timely fixes for accessibility bugs, and updating documentation.
  • Using this guidance, higher ed institutions and vendors can become strong partners in delivering technology that supports accessible experiences for all users.

Credits

Authors (* indicates contributors to v. 2.1)

  • Greg Hanek, Indiana University *
  • Grey Pierce, University of Oregon *
  • Jane Berliss-Vincent, University of Michigan *
  • Kurt Murmers, University of Michigan
  • Laura Grady, University of Wisconsin
  • Leah Bowers, University of Wisconsin
  • Maria Dahman, University of Wisconsin
  • Phillip (Phil) Deaton, University of Michigan *
  • Philip Voorhees, Penn State University
  • TM Weissenberger, University of Iowa *
  • Todd Schwanke, University of Wisconsin

Thank you

  • Amy Drayer, University of Minnesota
  • Elizabeth York, Rutgers University
  • Leigh Mosley, University of Tennessee
  • Scott Spicer, University of Minnesota
  • Sunshine Carter, University of Minnesota