Accommodation-based Exception Requests

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Ohio State’s Digital Accessibility policy requires that all units ensure that digital information and digital services that they develop, acquire, manage, or otherwise are responsible for meet the university’s Minimum Digital Accessibility Standards (MDAS). As of August 1, 2018, All digital information and digital services acquired, developed, or delivered by any unit that do not meet our accessibility standards must have an approved exception. Digital information and digital services acquired, developed, or delivered prior to August 1, 2018 are subject to the applicable web and digital accessibility standards in effect at that time and specifically to the provisions for “legacy” content in the policy.

The goal of an exception is to document the process by which Ohio State will ensure that the university provides effective access, with substantially equivalent ease of use, to digital information and digital services for eligible individuals in a timely manner.

Exception requests must contain the following elements in order to be considered.

Requesting Unit Contacts

Contact information for the below parties:

  • The individual making the request
  • The requesting unit
  • The Accessibility Coordinator(s) responsible for the requesting unit
  • The staff responsible for oversight and administration of the Equally Effective Access Accommodation Plan (EEAP), We prefer at least two (2) regular staff members

Rationale

The requesting unit must document how this request fits into one or more of the following categories:

  • Compliance is not technically possible or feasible given current technology
  • The digital information or digital service is used by a limited audience, when the audience is known, and whose needs can be accounted for in advance
  • For third party, vendor delivered products, no accessible alternative for the digital information or digital service exists
  • The digital information or digital service is legacy under the policy (implemented prior to August 1, 2018.)
  • Making the Digital Information or Digital Service accessible would require extraordinary measures that constitute an undue burden to the university

Note that for the purposes of determining if an undue burden exists, Ohio State is considered to be a single entity, and thus a burden would be analyzed according to the impact to the institution as a whole and not to the unit requesting the exception.

Business Purpose

The requesting unit must provide the business purpose for the digital information or digital service to include:

  • Who – what university or external populations will use the digital information or digital service?
  • What – what is the function of the digital information or digital service?
  • How – How will the digital information or digital service be made available?

Accessible Alternative Justification

The requesting unit must document if their purchasing process evaluated other alternatives that were more accessible. If so, the requesting unit must explain what business reasons necessitate the selection of the less accessible option. If more accessible alternatives were not evaluated, or did not exist, the unit must document their plan to ensure that a search for a more accessible alternative is conducted when the contract or exception expires.

Equally Effective Alternate Access Plan (EEAAP)

This plan should address how access barriers in the digital information or digital service will be mitigated, and any benefits or opportunities  afforded by the digital information or digital service will be provided, in a timely manner for eligible individuals who are unable to effectively use or interact with the digital information or digital service. While the Digital Accessibility Center and the ADA Coordinator’s Office are available to consult with requesting units in forming EEAAPs, it is the requesting unit who is responsible for providing the accommodation(s).  Depending on the nature of the digital information or digital service, examples of an accommodation might include:

  • Providing an alternative that effectively provides an equivalent result e.g. an alternative software that performs the same or similar function.
  • Providing assistance to the eligible individual either in-person or over the phone.
  • Providing the digital information in a format that meets our accessibility standards.

This plan should take into account the criticality and timeliness of the digital information or digital service and address a method to ensure that the eligible individual can access the accommodation without any adverse consequences resulting from the need for the accommodation. This means, for example, that any deadlines imposed by the digital information or digital service that are not met due to the use of an accommodation must be waved, and the requesting unit must have a plan to ensure this occurs.

Timeliness should be considered in light of the nature of the digital information or digital service, but should generally not exceed 10 (ten) business days. The accommodation plan should also address the timeline for delivering the accommodation, and the process by which any benefits or opportunities afforded by the digital information or digital service will be provided to the eligible individual.

Communication Plan

The requesting unit must document a plan to ensure that eligible individuals are made aware of the availability of the EEAAP, and the steps they must take to request access, if applicable. These communications should be readily accessible in the same places that any other general communication regarding access to the digital information or digital service are present.

Compliance Plan

Exceptions are designed to be temporary in nature, and are intended only to serve as a bridge to provide effective access. Requesting units should document their plan to bring the digital information into compliance with our accessibility standards. These plans might include:

  • Contract language obligating the vendor of third party digital information or digital services to bring their software or content into compliance within a period of time.
  • For internally developed digital information or digital services, a timeline for making them accessible and compliant with our accessibility standards.
  • Detailed collaboration with the vendor to bring their digital information or digital service into compliance.

The requesting unit must, if the digital information or digital service is not internally developed, have a compliance plan if the third party fails to make their digital information or digital service accessible. Examples include:

  • Contract termination
  • Financial penalties
  • Selection of an alternative product
  • Development of accessible front end
  • Replacement with internally developed alternative

Exceptions may be requested using the online ADA Exception Tracking system. (opens in new tab)

Typical processing times for requests are 10 business days, however, incomplete or complex requests may take longer. The ADA Coordinator’s Office will contact requesting units to inform them if more time is needed. For urgent situations that require immediate consultation, the Accessibility Coordinator responsible for the requesting unit should contact Peter Bossley at (614) 688-3028 or via email at Bossley.5@osu.edu.

Representations and commitments by requesting units contained in exception requests are binding agreements between the requesting unit and the ADA Coordinator’s Office.

The ADA Coordinator’s Office may approve exceptions in consultation with the Dean or Vice President of the requesting unit, and/or the relevant academic oversight group (e.g. Unit curriculum committee, Institutional Review Board, Faculty Senate) when appropriate.

The ADA Coordinator and Section 504 Compliance Officer or their designee has final decision making authority on approval or denial of an exception request.

Requester Information

Requester Contact Information

The lastname.# (without @osu.edu) of the person making this request. The requester must be the individual to submit the request for final approval, and the requester’s unit will ultimately be responsible for honoring the commitments made in the exception request.

Additional Approvers

If necessary, add the lastname.# (without “@osu.edu”) of faculty or staff who are authorized to approve the commitments outlined in your EEAAP.

Examples:

  • If the EEAAP requires purchasing or hiring, a fiscal officer or HR professional with authority to authorize the caption should be included.
  • If the EEAAP includes individuals from another unit (The IT department plans to provide support, for example), someone from that unit should be listed as an approver.

The Digital Accessibility Coordinator for your department will be automatically added– do not include them in this field.

General Information

Name of Digital Information or Service*

The name of the software, product, or event for which you are requesting an exception. The name of the exception request should be specific, succinct, and ideally under 120 characters. Avoid using your own name.

Examples:

  • “Ohio State Admissions Office Virtual Admissions Visits”
  • “Arts and Sciences Alumni Board Meeting”
  • “Padtop Software”

Start Date and End Date

Include the dates you will need the accommodation-based exception request to cover. The exception will only be valid during this time. Date ranges for software or other purchases should be anywhere from six (6) months to three (3) years. Long-term purchases may range from one (1) to two (2) years. Additionally, date ranges for events should cover the date(s) of the actual event and should include preparation, execution, and follow-up.

What is the URL or location of the digital information or service?*

Please include any relevant URL(s) such as application URLs, event pages, registration forms, or product informational sites.

What University unit is responsible for the digital information or service?*

Include the campus, college department, etc.

What is the purpose/business need for the product or service?*

Offer some background information on the software you will be purchasing, services you will be offering, or event you will be hosting. Consider how the software will be used and the purpose of the software. Additionally, consider the date, time, style of event (lecture, town hall, discussion group, moderated Q&A), what platform will be utilized (CarmenZoom, Skype, Teams…), and the purpose of this event.

Rationale Information

Provide the circumstances as to why the requesting unit is seeking this exception (Check all that apply):

Compliance is not technically possible or feasible given current technology.

Check this box if the service you are requesting an exception for is such that it cannot be made accessible with existing technologies.

Example:

  • A piece of software designed to draw freeform shapes cannot be made accessible to people who are blind or experience low vision because this technology does not (currently) exist.
The digital information or digital service is used by a limited audience, when the audience is known, and whose needs can be accounted for in advance.

Check this box when you are offering software or an event to a known group of people. You may know the audience because this audience has previously registered for your event, signed up for a class, or belongs to a cohort. If the audience is known and can be specifically accommodated, this box is an appropriate choice.

For third party, vendor delivered products, no accessible alternative for the digital information or digital service exists.

Check this box if you have determined there are no accessible alternatives for the software you are intending to purchase after an analysis of products available in the current market.

Example:

  • Many platforms with chat bot functions exist, however there may be no accessible options created in the current market.
Making the Digital Information or Digital Service accessible would require extraordinary measures that constitute an undue burden to the university.

Check this box if making an accessible software, product, or event would be an undue budgetary or operational burden to the university. Note that this must be considered against the university as a whole not within the context of an individual department, college, or program. This option generally only applies to large, capital intensive, or enterprise-wide projects.

The Digital Information or Digital Service is legacy under the policy (Implemented prior to August 1, 2018.)

Check this box if the software, product, or services you are requesting an exception for were put in place prior to August 1st, 2018 (When the Digital Accessibility Policy was revised).

Examples:

  • You are performing a minor upgrade to a piece of software.
  • You are renewing a contract to an existing piece of software.
  • You are making enhancements to a website built in 2010.

Please note the process of making major overhauls to the user interface of a piece of software should be treated as a new purchase and would not fall under this category.

What University or external populations will be using the product or service? Please include usage patterns including service availability and frequency of use.*

Describe the audience of the product, service, or event. Consider Ohio State faculty, staff, students, alumni, prospective students, and/or the general public. Include an estimated number of attendees or users. Additionally, please include how often a user will utilize this product.

If students are a potential audience of the digital information or digital service, is their use strictly related to employment with the university? If not, does their use of this digital information or service relate to their access to educational or administrative functions that impact their full participation in a campus program, service, or activity?*

Choose between the three (3) drop-down options.

  • Students are an audience and the Digital Information or Service impacts their full participation in a service or activity of the university.
  • Students are an audience in their roles as employees only.
  • Students are not a potential audience.

Did product evaluations during the selection process explore the existence of a more accessible alternative? If so, detail the business justification for this selection over the more accessible alternative.*

If you are requesting an exception for a product or piece of software, describe the evaluation process you have completed. Include the process you used to consider a more accessible alternative. If a more accessible alternative was found, describe why it was not selected. If a more accessible alternative was not found, indicate the other products that were considered.

If you are hosting an event, please respond with “N/A”

What are the barriers to access? (Provide a summary of known accessibility issues. Reference an evaluation if appropriate.)*

Barriers are technological limitations preventing a user with a certain class of disability from fully utilizing software or participating in an event.

Specifically state the barriers that may be experienced while utilizing this product or during this event. If applicable, include summary results from an accessibility quick test or full manual test. Consider participants who are deaf, hard of hearing, utilizing a screen reader, or experience color blindness. Please be specific about accessibility issues when discussing the use of a screen reader.

EEAAP

EEAAP Contacts

Add at least one (1), preferably two (2) faculty or staff members who will be responsible for the oversight and administration of the plan outlined below. When entering EEAAP contacts, enter the OSU username (lastname.#) without “@osu.edu” in the field. Then click the “Add Contact” button. After these actions are completed, repeat the process for additional contacts.

What are the accommodations that will be in place? (Work-around, assistance, alternative products, etc.)*

Include the accommodations that will be offered to best overcome previously mentioned barriers to access. Accommodations for software or products may include providing content in alternative accessible formats, paired assistance, alternative duties for staff, or job carving.

Accommodations for events may include live captioning services, edited transcripts, captioned recordings, or personal assistance. Please describe where and when participants can expect to see an edited transcript or captioned recording after the event. Include the name of any vendor who will be providing services to satisfy the EEAAP.

What is the plan for communicating the existence of the accommodation and for relaying information between involved parties?*

Include a robust plan to communicate the existence of the EEAAP to users with disabilities who may need to make use of it. The communication plan should be accessible and should reach anyone who will use the software or participate in an event.

Examples:

  • Acknowledgement of existence of access plan during new employee onboarding.
  • Notice regarding availability of alternative formatting in footer of website.
  • An accommodation statement is offered on an event registration webpage and/or email invitations.

Please include the specific language of any accommodation statements.

Below is an example of an accommodation statement:

“If you require an accommodation such as live captioning or interpretation to participate in this event, please contact Brutus Buckeye at buckeye.1@osu.edu or 614-247-5555. Requests made 10 day prior to the event will generally allow us to provide seamless access, but the university will make every effort to meet requests made after this date.”

What is the timeline for implementing the plan? (Critical dates for announcement, hires, purchases and/or trainings, etc.)*

Include an outline of when this plan will be put into place.

Examples:

  • Before product or service launches.
  • Phased in after product or service launch.
  • It is currently in place.

Include the dates when participants will receive announcements, invitations, and follow-up communications.

Compliance Plan

What is being done to ensure that the digital information or service will become accessible? (Interactions with vendor/developers, detailed feedback from the University, etc.)

If you are requesting an exception for a piece of software or a service, outline the plan to bring it into compliance with the university’s Minimum Digital Accessibility Standards before the end of the exception period. This may include sharing evaluations conducted with vendors, efforts with vendors to remediate accessibility issues, efforts to change the way a piece of software is used to offer a more accessible option, or consideration of a separate application.

This may include conversations with vendors or information from the University.

If you are hosting an event, please respond with “N/A”

What is the timeline for remediation of the product or service? (Please provide approximate dates for accessibility improvements/upgrades/patches and goals for each date.)

If you are requesting an exception for a product or piece of software, include a remediation timeline the vendor or University has agreed to. Please include dates for these improvements. You may also include informal agreements or a vendor’s stated accessibility goals.

If you are hosting an event, please respond with “N/A”

What provisions are in place to address issues with the vendor, digital information or service if the remediation efforts do not occur in accordance with this timeline? (E.g., contract termination, system replacement, etc.)

If you are requesting an exception for a product or piece of software, include your plan to address possible failure to complete accessibility improvements. Please include any contractual terms with vendors that require accessibility standards. Describe plans to explore alternatives if the software cannot be remediated.

If you are hosting an event, please respond with “N/A”