Accessibility and SLS

How to Document and Establish Accommodations for Non-Compliant Resources
If a resource does not meet accessibility standards, a process should be in place to document how or why the product or resource meets the rationale for an exception and describe reasonable accommodations that could be made to provide equal and equitable access to individuals with disabilities. If the library would like to renew or subscribe to a resource that do not meet accessibility standards, the library should be prepared to work with EIT personnel on campus to create an Equally Effective Alternative Access Plan (EEAAP) or to create an EEAAP themselves.

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Any library content that does not meet accessibility standards may require an exception form, depending on the impact of the product (high, medium, low) and campus requirements. 

SUNY Procurement Accessibility Conformance Standards: Implementation Guidance (2019) document states:

There may be instances where procuring accessible products and services is extremely difficult. Therefore, a process to request and determine exceptions must be created.

In rare circumstances, the following factors may qualify as exceptions:

1. Where an accessible alternative does not exist commercially.
2. Where compliance is not technically possible or may require extraordinary measures due to the nature or intent of the information resource, application or service, a request for exception must be made. Lack of sufficient funding for any particular college, department, program, or unit of the University would not be considered for an exception.
3. Where compliance would result in a fundamental alteration of the information resource, application, or service, and not satisfy the original intent.
4. Where, in the case that information resources, applications and services that are procured through third party vendors or contractors; and that no alternative accessible products are available from other third party vendors or contractors, procurement can be made of a non-compliant product.
5. Where the product is not currently in compliance, but efforts are underway to fix the defects by a defined date.

The exception form should describe the following:

• The purpose of the product and how it meets the needs of the campus
• Other comparable products and why this product was selected over the other options. If possible, note whether or not the other products are more accessible.
• The department responsible for the product: who will host it, maintain it, etc.?
• Specific accessibility problems and what campus groups would be impacted
• Any known workarounds or alternative supports that have been identified by the vendor
• Vendor roadmap or plan to address the product's accessibility problems
• Why an exception is needed: product is vital because . . ., only for library staff use, etc.

According to SUNY Procurement Accessibility Conformance Standards: Implementation Guidance (2019):

What it Means

Equally Effective Alternate Access is an alternative mode of access or format that communicates the same information in as timely a fashion as does the original EIT. For interactive applications and hardware devices, “equally effective” means that the user action (e.g., registration) is accomplished in a comparable time and with comparable effort on the part of the requester.

An Equally Effective Alternate Access Plan is a strategy to provide EIT in an alternate mode of access or format.

Why it Matters
There may be a request for an accommodation for EIT that is not fully accessible to various individuals with disabilities. Departments should have a proactive plan in place to provide equitable access. Waiting until someone requests an accommodation may potentially exclude individuals with disabilities and delay their participation in programs, services and activities that the institution offers. 

According to UDL on Campus, the components of an EEAAP are:

1. Description of the issue
2. Persons or groups affected
3. Responsible person(s)
4. How EEAA will be provided
5. Resources required to provide EEAA
6. Vendor remediation information (including proposed completion date)
7. Timeline for unforeseen events

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