Committee for Accessible Technology (CATO) Questions and Answers

The answer to this question depends greatly on how 3rd party content is used. Here’s some language from a Department of Justice Supplemental Advance Notice of Proposed Rulemaking (SANPRM) around this very topic:

The Department is considering generally excepting Web content posted by third parties on public entities’ Web sites from compliance with WCAG 2.0 Level AA. However, the Department is considering requiring Web content posted by a third party that is essential for engaging in civic participation to comply with WCAG 2.0 Level AA. (Source)

Further, from the University of Miami Consent Decree we see that if it's content that is required to fully participate and benefit from the College's services, programs, and activities, it must be accessible or provide timely "Equally effective alternate access".

"With respect to third-party content, websites, or applications that Miami uses for completion of critical or important transactions (e.g., websites used for campus housing, campus dining, registering for classes, paying bills, obtaining transcripts) or to complete required training (e.g., AlcoholEDU), either:

1. Cause such third-party content, websites, or applications to conform with WCAG 2.0 AA and this Decree; or
2. Provide equally effective alternate access to qualified individuals with disabilities until such time that conformance can be achieved pursuant to Miami's Accessibility Audit Corrective Action."

In short, if use of third party content/applications is important or essential, then the content should be accessible or an equally effective alternative must be provided.

In terms of instructional materials, required instructional content and content that is vital for success in the course must be accessible, regardless of who develops or supplies that content. While additional/optional resources may technically be exempt, faculty should not create a situation in which optional and additional resources are only available to students without disabilities.

Posted Mar. 14, 2017

Regarding WaTech 188, see Section 1 of the policy: ..."This includes all covered technology acquired, procured, developed or substantially modified or substantially enhanced after the effective date of the policy [Aug. 11, 2016], including software available at no cost." Further, Section 6 reads: “Agencies must develop, implement and maintain an Accessibility Plan that identifies how the agency will ensure new covered technologies are accessible and the plan for making existing covered technologies accessible.” So technically, for Policy 188 you’re evaluating anything new and in use.

Regarding SBCTC policy, we have not established any timelines or the scope of work for the colleges.

However, with the new federal 508 Refresh, if your college is working with federal funds, you will have until January 18, 2018 to comply with the new 508 standards. Unless the software is already deemed compliant with existing 508 standards (in which case it does not need to comply with the 508 refresh until it is modified).

Posted Feb. 21, 2017

While the goal of the SBCTC 3.20.30B (link to word version) and WaTech’s Policy 188 overlap, they are also different. The intent of both policies is to ensure the use and adoption of accessible technology. The difference is that WaTech policy (per Policy 101) applies to business and administrative applications in higher education. However, SBCTC 3.20.30B picks up where Policy 101 drops off, including instructional technologies and content in addition to administrative and communications technologies and content. Thus, SBCTC’s policy is more comprehensive than WaTech’s policy.

Further, WaTech’s policy includes specific actions (with deadlines) that state agencies are expected to follow in order to be compliance with their policy. Per Policy 188, each agency should identify an IT Accessibility Coordinate and have policy and procedures developed by Dec 31, 2016. Each agency is also expected to post an Accessibility Plan to their website by March 31, 2017. (Please refer to Policy 188 for additional info.)

SBCTC’s policy does not currently include specific action items and deadlines for the colleges.

Posted Jan. 30, 2017

That is an excellent question, and such a thing would be an incredible resource. Currently, there is some effort being led by larger, national organizations to develop a trusted tester program so that institutions of higher ed can have uniform standards in which they evaluate technology. Agreeing to uniform standards would ease the ability for one institution’s usability results to be relevant/applicable to another institution. However, this is difficult work as it requires a certain level of technical expertise and a lot of work to keep up with continuous software updates. We’re excited to see wider reaching organizations leading this effort and look forward to being part of that conversation.

Additionally, WaTech is working on finding a way in which they can maintain a list of products and the results of their usability testing. Again, we look forward to this resource and will be happy to announce to the system when it has been developed.

If you have a question about a specific technology or are in the process of procuring new technology, we encourage you to work closely with your vendors and publishers. Ask for demonstrations that will walk you through their accessibility features. And don’t forget to invite your DSSC office to the conversations/demonstrations! For more information on procuring accessible technology check out the links provided in the Resources menu.

Posted Jan. 30, 2017

The WaTech policy only applies to business and administrative applications, not instructional technologies. However,The SBCTC policy does include instructional materials and technology. While SBCTC has not set an implementation date, to mitigate risk, we strongly encourage you to begin the work of making your content accessible.

Beginning with small steps can make this process much less overwhelming. Check out the training resources for some tips on how to make your materials accessible. This work is much easier than you think, not to mention it benefits all students, promotes good instructional strategies, and it saves you a lot of time in the long run!

Posted Jan. 30, 2017
Updated Feb. 21, 2017