Equally Effective Alternate Access Planning

Formerly, Equally Effective Alternate Access Plan (EEAAP)

The enhanced Temporary Alternative Access Plan (TAAP) process introduces a more structured and systematic approach to developing alternative access solutions. Emphasizing its temporary nature, the TAAP serves as an interim measure while vendors work to remediate known accessibility barriers that impact core functionality for specific user groups.

This updated framework incorporates a built-in quality and risk assessment, ensuring that alternative solutions are evaluated and classified into one of three categories—with an Equally Effective Alternative Access Plan (EEAAP) as the ideal outcome. By doing so, campuses can better align their appropriate level of support, and clearly understand the risks associated with temporary alternatives. This structured approach helps maintain equitable access to ICT systems while remediation corrects known barriers.

Key Updates in TAAP Version 3.1

  • New Name and Framework: The plan has been renamed from EEAAP to TAAP to emphasize its temporary nature while accessibility issues are being resolved.
  • Improved Documentation Process: Updated instructions for completing the TAAP form are included in the form to provide sufficient context for authors while they complete the document.
  • Required Accessibility Statement: As part of the process, institutions must provide clear accessibility statements that outline known barriers, impacted disability groups, and available alternative solutions.
  • Quality and Risk Assessment: A detailed risk assessment framework has been introduced, categorizing solutions based on compliance with legal accessibility requirements.
  • Legal and Compliance Considerations: The TAAP aligns with recent enhancement to Title II of the ADA (effective April 24, 2026), Section 508, and California Government Codes 11135 & 7405, reinforcing the commitment to digital accessibility compliance.

Process Overview

  • Identify Known Accessibility Barriers: Determine accessibility issues that affect core product functionality.
  • Assess Impacted User Groups: Define which disability groups may be affected by the product’s accessibility limitations.
  • Develop an Alternative Access Plan: Establish an interim solution that ensures equal access while addressing barriers.
  • Communicate and Distribute the Plan: Share the TAAP with faculty, staff, disability services, IT support, and other relevant departments.
  • Review and Update Annually: Ensure the TAAP remains effective by updating it when vendors implement accessibility improvements.

While CSU remains committed to achieving 100% accessibility compliance, the TAAP provides a structured approach to mitigating accessibility challenges in the short term. The legal framework, including ADA Title II §35.205 , allows institutions to remain compliant even when ICT products are not fully accessible—provided that alternative access measures are in place and do not impose a disparate burden on users with disabilities.

A TAAP should be prepared for products and services that are not fully conformant with Section 508 accessibility standards and that specifically inhibit the core functions of a product. A TAAP is not required for minor accessibility failures. The CSU ATI Prioritization Framework (CSYou Login Required)  is a resource that provides detailed guidance about the recommended process campuses can use to determine impact. The creation of a TAAP is essential for high-impact products/services, including those that meet any of the following criteria:

  • The product/service would be used by a large number of persons
  • Access to a program/service may be denied
  • A critical program/service may be impacted
  • The cost to provide accommodations would be high
  • The product/service's use would create significant legal exposure, and/or
  • There are no known workarounds to the accessibility barriers

The best practice in creating a TAAP is to leverage a multi-disciplinary committee that clearly understands how the product/service will be used, what accessibility features and gaps are present in the product/service, and what resources and strategies should be deployed to ensure comparable access for persons with disabilities.

The following individuals should be part of the committee:

  • Purchase Requestor (or designee) – the department requesting a product/service is usually responsible for product support and is often where end users will go for assistance.
  • Disability Services Office staff – this department oversees students' accommodation plans and has specialized knowledge of disabilities and how best to assist students who experience accessibility issues.
  • Information Technology (IT) staff – provides technical expertise to the group.
  • The ATI (Procurement) Reviewer (or Designee) – this person has a broad overview of the purchase and information about accessibility barriers based on the accessibility documentation provided by the Vendor.

Also, take into consideration the following resources/representatives when their expertise is required:

  • ADA Compliance Officer – Assists in faculty and staff accommodations.
  • Dean/Manager/Supervisor – typically provides administrative approval for a TAAP and for resources available to support accessibility.
  • Procurement representative – serves as an authoritative resource for all procurement-related activities and processes.
  • Instructional Materials Specialist – provides expertise and assistance regarding the accessibility of curricular materials.
  • Web Accessibility Specialist – provides expertise in web-related accessibility issues.
  • Human Resources (HR) is an authoritative resource for faculty and staff-related processes.

After the creation of a TAAP document, campuses should ensure that key constituent groups (e.g., Disability Services Office) can quickly and easily access plans to (1) initiate accommodations and workarounds outlined in the TAAP; (2) allow updating of current TAAP based on product improvements or when a new approach is developed, and (3) streamline the authoring of future TAAPs. In addition, TAAPs should be reviewed at least once per year to coincide with the renewal of the product.

There are two methods for providing access to this documentation:

  1. Centralized
    • Establish and maintain a central document repository (e.g., SharePoint)
    • Provide access for all TAAP Committee members and key constituent groups (e.g., Disability Services Office)
  2. Distributed
    • Store the signed TAAP with the purchasing department
    • Distribute copies to the following departments:
      • Procurement Office (filed with the requisition)
      • The ATI (Procurement Reviewer) or Designee
      • Disability Services Office (responsible for accommodations for students)
      • Human Resources (accountable for accommodations for staff and faculty)