UW-Madison - Digital Accessibility Standards (DAS)

The following document contains standards in support for the UW-Madison - Digital Accessibility Policy.



Scope

The standards included here are designed for use with any UW-Madison digital resource and information technology. The conformance requirement table designates when policy compliance is required across various university scenarios. 

Background

A digital resource or information technology should be both functionally accessible (usable by a person with a disability) and technically accessible (developed according to technical standards) to ensure it is accessible to all users. The Digital Accessibility Standards (DAS) provide a set of functional requirements underpinned by technical standards for use across a variety of digital resources and information technology, including but not limited to: 
  • Websites and applications 
  • Multimedia content (including content not presented through websites) 
  • Course content and training materials 
  • Electronic publications and e-books (a.k.a. EPUBS and e-Text) 
  • Documents (including PDFs) 
  • Email (including newsletters and marketing materials) 
  • Mobile applications 
  • Software applications and systems

Functional Requirements and Technical Standards

These Digital Accessibility Standards help ensure the university is able to meet its legal obligations to the Americans with Disabilities Act (ADA) and Section 504 of the Rehabilitation Act of 1973. To comply with the Digital Accessibility Policy, a digital resource or information technology should be both functionally and technically accessible.

Evaluation of the information technology using automated and manual accessibility evaluation practices (including testing with users) determines the level of functional and technical accessibility. For more information regarding how functional and technical digital accessibility is evaluated see Addendum A: Disability Categories and Testing Methods. 

A. Functional Requirements 

Functional requirements for digital resources and services are defined by how well a person with a disability can perceive, understand, and use digital resources and information technology with their assistive technology; or, how “functionally accessible” a digital resource or information technology is. 
The determining factor of whether a digital resource or information technology is accessible is based on whether an individual with a disability can use it to achieve the same goals or outcomes, as independently (without accommodation or assistance from another individual) as someone without a disability. 
UW-Madison strives to create, procure, and deliver digital resources and information technology that are functionally accessible. To be considered functionally accessible, a digital resource or information technology must be usable by people who: 
  • Are blind or have a visual impairment 
  • Are colorblind 
  • Are deaf or hard of hearing 
  • Have motor disabilities 
  • Have cognitive or learning disabilities 
  • Have any other disabling condition 

B. Technical Standards 

A resource that meets technical standards is coded in a manner that ensures the digital resource or information technology is as accessible as possible. Both technical standards and functional requirements must be met to ensure accessibility; testing against functional requirements validates that the code is creating a usable experience for people with disabilities. 
UW–Madison strives to meet the following technical standards. These standards form the basis for the Make it Accessible guides and the Accessibility and Usability Information documentation, which the Center for User Experience provides the university for use in procuring, creating, and delivering accessible digital resources and information technology. These technical standards are in conformance with Section 508 of the Rehabilitation Act and created by the Web Accessibility Initiative (WAI) – the International Standard (ISO) for accessibility in digital environments. 

Standard Detail 
Web Content Accessibility Guidelines 2.1 Level AA  These principles, guidelines, and success criteria are our core technical standards for digital accessibility. UW-Madison additionally refers to the Guidance on Applying WCAG 2.0 to Non-Web Information and Communications Technologies (WCAG2ICT) to assist in determining and ensuring that non-web content and software meet accessibility standards. (See a comparison between WCAG 2.0 and WCAG 2.1. See more information regarding WCAG standards structure in Addendum B: Web Content Accessibility Guidelines)  
The WAI User Agent Accessibility Guidelines (UAAG)  The WAI User Agent Accessibility Guidelines (UAAG) establishes technical standards for readers and players including but not limited to browsers, media players, e-readers, and browser extensions.
  • The Authoring Tool Accessibility Guidelines (ATAG) set technical standards for authoring tools including but not limited to content and learning management systems, EPUB, and multimedia authoring tools.
  • Portable Document Format (PDF) Universal Accessibility (UA) is the international standard for PDF accessibility. 

Accessibility Approach and Impacts

Practicing digital accessibility means engaging in the following due diligence efforts: 
  1. Assess technology against the conformance requirement table to understand the level of policy compliance necessary. 
  2. Evaluate technologies to understand accessibility gaps and barriers. 
  3. Support users who may be impacted by those gaps and barriers. 
  4. Progressively remediate digital accessibility barriers and consider accessibility in new technologies built by UW-Madison and in the procurement of third-party technologies. 
The Center for User Experience will support the Digital Accessibility Liaison(s) and their units in following this process with procedures, protocols, templates, guides, and consulting. 

Digital Accessibility Due Diligence Approach 

STEP 1 - Assess which digital resource or information technologies must comply with the policy’s conformance requirements table 

The university contains a vast collection of digital resources and information technologies which need to comply with the Digital Accessibility Standards. 

Conformance Requirement Table 

This table illustrates how the institution can identify which digital resources and information technologies must comply with the policy and how these can be prioritized for resource allocation and evaluation, improvement, planning, and communication based on the following impact attributes1.

Conformance Requirement  Impact Attributes 
Conformance Required (to the fullest extent possible) Digital resources and information technology that are:
  • An enterprise or university-wide technology (e.g., Office 365, Course Search and Enroll, ShopUW+);
  • Used at or for university events (in person or virtual) with 20,000 or more attendees;
  • A public-facing website;
  • Used in undergraduate General Education Requirement courses2 ;
  • Procured via Request for Proposal or Request for Bid3 ; or,
  • Used at the following university community events: Convocation, Go Big Read, Diversity Forum, Commencement; or,
  • Reported to have a verified barrier by a user.  
Conformance Recommended   Digital resources and information technology that are:
  • Used by 1,000 or more users annually. 

Practicing Digital Accessibility with Third-Party Technologies 

These standards acknowledge that UW-Madison needs to buy and use third-party technologies and those technologies may not meet the Digital Accessibility Standards. The standards and risks for procured tools are the same as those for technology built and delivered by UW-Madison, but the processes differ. See Step 4 - Progressively remediate digital accessibility barriers and consider accessibility in new builds and procurement decisions for details on addressing digital accessibility of a resource or technology in the procurement process.

STEP 2 - Evaluate the technologies to understand accessibility gaps and barriers 

The Center for User Experience will support the Digital Accessibility Liaisons in their efforts (as much as their unit’s resources allow) to prioritize digital resources and information technologies that must comply with the policy in accordance with the conformance requirement table, evaluate them for accessibility, and understand what due diligence approach supports ongoing accessibility in the context of that technology, the needs of users, and the resources of the institution. Defined below are levels of compliance with the Digital Accessibility Policy and Standards. 

Tier Number Tier  Policy Compliance  Description 
Tier 1 Accessible Technology  Optimally compliant (no accommodation needed)  The information technology or digital resource is accessible to all users including those with disabilities. Follow the Accessible Technology Due Diligence Process for Units. 
Tier 2 Partially Accessible Technology  Minimally compliant (no accommodation needed)  The information technology or digital resource is partially accessible but includes some barriers that may decrease independent ease of use for people with disabilities. However, these barriers do not pose a direct obstacle to successful completion of user goals. Follow the Partially Accessible Technology Due Diligence Process for Units.  
Tier 3 Inaccessible Technology   Not compliant (requires accommodation planning and communication to comply)   The information technology or digital resource is not accessible and has barriers that impact the ability of a user to independently reach their goals. Follow the Inaccessible Technology Due Diligence Process for Units.  

See Addendum A: Disability Categories and Testing Methods for standards regarding the evaluation of digital resources and information technologies for accessibility. The Center for User Experience will support the university with guides and resources for accessibility evaluation. 

STEP 3 - Support users who may be impacted by those gaps and barriers 

Inaccessible digital resources and information technology create situations in which people with disabilities cannot take advantage of opportunities and benefits with equitable ease of access. If a digital resource or information technology is inaccessible, units should plan to support users who may be impacted by barriers discovered in accessibility evaluation. This mitigates a situation in which people with disabilities have no path to request accommodation or assistance, and therefore no way to participate. 

Through the processes outlined below, UW-Madison’s goal is to create a more inclusive environment that makes it easier for the university to quickly and efficiently plan for disability accommodations, communicate to users the alternative pathways for access, and productively endorse the improvement of accessibility with content creators, developers, and vendors. The processes below are executed at the unit-level, led by the Digital Accessibility Liaisons, as a unit’s resources allow, and supported by the Center for User Experience. The order in which technologies are addressed with these processes is based on where the technology fits in the conformance requirement table. 

Accessible Technology - Due Diligence Process for Units

  1. Provide users with a way to report barriers; promptly address those barriers4 directly or provide accommodations so that the user can reach their goal. 
  2. Perform accessibility evaluations with major content or version updates to ensure maintenance of accessibility. 

Partially Accessible Technology - Due Diligence Process for Units 

  1. Document existing accessibility barriers in the Accessibility and Usability Information documentation to make users aware of existing barriers and how to get help. 
  2. Provide users with a way to report barriers; promptly address those barriers4. While addressing barriers, provide an accommodation so that the user can reach their goal.
  3. Perform accessibility evaluations with major content or version updates to ensure maintenance of accessibility. 
  4. Develop an accessibility roadmap5 detailing identified barriers and target dates for resolution. 

Inaccessible Technology - Due Diligence Process for Units

  1. Document existing accessibility barriers in the Accessibility and Usability Information documentation to make users aware of existing barriers and how to get help. 
  2. Provide users with a way to report barriers; promptly address those barriers4 . While addressing barriers, provide an accommodation so that the user can reach their goal. 
  3. Perform accessibility evaluations with major content or version updates to ensure maintenance of accessibility. 
  4. Develop an accessibility roadmap5 detailing identified barriers and target dates for resolution. 
  5. Create an Equally Effective Alternative Access Plan (EEAAP)6 to document barriers, communication, and a plan for accommodations to ensure individuals with disabilities are able to use the technology or have access to the benefits provided by the technology. The EEAAP mitigates legal risks but does not contribute to compliance with the Digital Accessibility Policy. (See when an EEAAP is required in the conformance requirement table.) 

STEP 4 - Progressively remediate digital accessibility barriers and consider accessibility in new builds and procurement decisions

Digital accessibility improvements are successful through continuous processes. To that end, as a unit’s resources allow, the Digital Accessibility Liaison(s) will track the progress of accessibility improvements via each technology’s roadmap, and act as guides to digital accessibility in the build or procurement of new digital resources and information technology. The Center for User Experience will support the Digital Accessibility Liaisons in following this standard approach with procedures, protocols, templates, and consulting. 

University-created digital resources or information technology

For university-created information technology or digital resources, the Digital Accessibility Liaison(s) works with their unit to ensure newly-built technologies are tested, and to roadmap and document remediation efforts necessary to improve accessibility (as much as a unit’s resources allow). The Digital Accessibility Liaison(s) ensures the technologies are iteratively retested for accessibility based on major updates to the digital resource or information technology. 

Third-party technologies 

UW-Madison needs to buy and use third-party technologies and those technologies may not meet the Digital Accessibility Standards. The following activities, executed whenever possible and as resources allow by the Digital Accessibility Liaison(s) and their units and with the support of the Center for User Experience, will ensure (per the conformance requirement table) that third-party technologies required to comply with the policy progressively meet and maintain compliance with the Digital Accessibility Policy. 
  • In compliance required technology RFPs: Include digital accessibility under preferred requirements. 
  • During compliance required technology procurement: Digital Accessibility Liaisons should act as a digital accessibility SME (supported by the Center for User Experience) as resources allow or engage a representative from the Center for User Experience. Whenever possible, evaluate all technologies in consideration under the RFP, so the unit understands the digital accessibility barriers and risks and can make an informed decision during the procurement processes. 
  • In compliance required procurement contracts: Include digital accessibility contract language in all contracts that must comply with the policy in accordance with the conformance requirement table (as well as any other contracts to the fullest extent possible). 
  • During compliance required technology implementation: Report digital accessibility barriers to vendors, advocate for improvement, and reinforce that accessibility is a priority when deciding whether to renew a contract or authorize continuation of use. 
  • When delivering compliance required technology: Create a roadmap to document identified barriers, a timeline for remediation, and efforts towards that remediation. 
  • For ALL third-party technologies: Communicate available accessibility assistance and create an internal accommodation plan to support people with disabilities who use the technology should they need assistance.

Addendums

Addendum A: Disability Categories and Testing Methods

This matrix details disability categories, example disabilities, and testing protocols used to identify barriers in a digital resource or information technology. This list of disabling conditions is not exhaustive.

Disability Category  Example Disabilities  Accessibility Testing Protocols   
Visual Disability  e.g., blindness, low vision, color blindness 
  • Magnification testing
  • Color contrast testing
  • Screen reader testing
  • Multimedia testing (captions, transcripts, and audio descriptions)  
Auditory Disability  e.g., deafness, hard of hearing  
  • Multimedia testing  
Motor Disability  e.g., paralysis, cerebral palsy, missing/damaged limbs, facial muscular impairments 
  • Keyboard testing (Note: speech input mimics keyboard input and is included in keyboard testing.)  
Cognitive Disability  e.g., learning disabilities, traumatic brain injury, dyslexia 
  • Accessible usability review:
    • Review by usability experts based on usability heuristics
    • Usability testing performed by people with disabilities 

Accessibility Barrier Prioritization As part of an accessibility evaluation, the evaluator prioritizes accessibility barriers as high, medium, or low priority based on the Web Content Accessibility Guidelines Level AA levels of conformance and the severity of academic or administrative consequence to the user (per the conformance requirement table) posed by the particular barrier based on each disability category. 

Addendum B: Web Content Accessibility Guidelines 2.1 Level AA

Web Content Accessibility Guidelines 2.1 Level AA principles, guidelines, and success criteria are UW-Madison’s core technical standards for digital accessibility. UW-Madison additionally refers to the Guidance on Applying WCAG 2.0 to Non-Web Information and Communications Technologies (WCAG2ICT) to assist in determining and ensuring that non-web content and software meets accessibility standards. (See a comparison between WCAG 2.0 and WCAG 2.1) WCAG’s technical standards documentation consists of the following nesting structure to support design, development, and evaluating for accessibility. This nesting structure is further explained below. 
  • Principles - Perceivable, Operable, Understandable, Robust) 
    • Guidelines - To support designing for the above principles. 
      • Success Criteria - To inform evaluating for the design of above principles. 
        • Sufficient and Advisory Techniques - To inform developing for the design of above principles. 

Principles (WCAG) 

The four WCAG principles provide the foundation for accessibility: digital resources and technology should be perceivable, operable, understandable, and robust.

Guidelines (WCAG) 

The WCAG guidelines, under the WCAG principles, provide the basic goals that authors should work toward in order to make content more accessible to users with different disabilities. The guidelines provide the framework and overall objectives to help authors understand the success criteria and better implement the techniques. 

Testable Success Criteria (WCAG) 

Each WCAG guideline includes testable success criteria for use where requirements and conformance testing are necessary such as in design specification, purchasing, regulation, and contractual agreements. To meet the needs of different groups and different situations, three levels of conformance are defined: A (the lowest), AA (the standard), and AAA (the highest). Additional information on WCAG levels can be found in Understanding Levels of Conformance. 

Sufficient and Advisory Techniques (WCAG) 

Each of the WCAG guidelines and success criteria includes a wide variety of techniques that are not required but can be used to achieve accessibility. These techniques include but are not limited to the use of HTML to support accessibility with supplementary use of WAI-ARIA when HTML does not fully support accessibility standards.

Authority

The Digital Accessibility Standards are maintained by UW–Madison’s Center for User Experience under the direction of the UW-Madison ADA Coordinator and the Vice Provost of Information Technology and Chief Information Officer. Revisions of these standards are reviewed and approved by IT Governance per UW-Madison Policy 510, and must be compliant and in support of applicable federal and local mandates. The Vice Provost of Information Technology and Chief Information Officer, the ADA Coordinator, or the Center for User Experience may initiate a revision by contacting the Policy Planning and Analysis Team which engages IT Governance.

Enforcement

Updates are communicated to the university community through the university-wide Digital Accessibility Liaisons as well as through the university’s mass communication channels. Implementation of updates is supported at the local level by each unit’s Digital Accessibility Liaison(s), with oversight by the Center for User Experience. The Center for User Experience is under the direction of the Vice Provost of Information Technology and Chief Information Officer.

Contact

Please address questions or comments to itpolicy@cio.wisc.edu.

Notes

1Conformance Requirement Table
The table above is informed by analysis of recent higher education digital accessibility litigation, a Big Ten Academic Alliance Peer Review of our institution’s technological landscape, and modeled after prioritization methods used by our peers institutions in the Big Ten Academic Alliance (Penn State, Ohio State, Rutgers, University of Iowa, Illinois University, and Indiana University).

2General Education Requirement Courses 
General Education Requirement courses are those that meet the university’s General Education Requirements that undergraduate students must complete to achieve an undergraduate degree. The listing of General Education Requirement courses can be found in the Course Guide. 

3Requestfor Purchase (RFP) or Request for Bid (RFB) 
For purchases that require RFPs or RFBs under Chapter 16 of the Wisconsin State Statute, and as stated in the State Procurement Manual.

4Addressing Barriers 
Address the high-priority accessibility barriers identified during evaluation of a digital resource. Regardless of whether it is a new resource or already in use at UW-Madison, the barrier must be reported to the content creator, developer, or vendor with a request for remediation. 
  • For university-created digital resources, resolve high-priority accessibility barriers as quickly as possible through technical remediation efforts. Create an accommodation plan and communications to meet the immediate needs of users who may be impacted. 
  • For procured third-party tools, report barriers to the vendor and request remediation. Create an accommodation plan and communications to meet the immediate needs of users who may be impacted. 

5Accessibility Roadmap 
A digital accessibility roadmap documents identified barriers, chronicles target timelines for when those barriers will be remediated, and the progress toward that effort. 

6EEAAP - Equally Effective Alternative Action Plan 
The EEAAP is a formal document that identifies accessibility exception reasons, accommodation plans, and links to the digital accessibility roadmap. The EEAAP is generated by the service owner 8 of the digital resource or information technology in partnership with their unit’s Digital Accessibility Liaison and the Center for User Experience, approved by the ADA Coordinator, and retained by the Office of Compliance and the Center for User Experience. 
For broad, proactive support of people with disabilities, units should develop a general contact method (e.g. a group or service email address) through the Digital Accessibility Liaison to provide a means for users to report barriers or request assistance with any digital resource or information technology. 




Keywords:clean url name   Doc ID:116214
Owner:Khyati G.Group:IT Policy
Created:2022-01-20 15:26 CDTUpdated:2022-02-14 14:01 CDT
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