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Accommodation-based Exception Requests
Ohio State’s Digital Accessibility policy requires that Campuses, Colleges, Departments, and Vice Presidential (VP) 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 campus, college, or vice presidential (VP) 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
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.
Equally Effective Access Accommodation 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.
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.
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
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.
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.firstname.lastname@example.org.
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.