Equally Effective Alternate Access Planning
In compliance with California Government Code Section 11135 and Section 508 of the Rehabilitation Act of 1973, the University must apply accessibility standards to Information and Communication Technology (ICT) products and services that it buys, develops, uses or maintains. When ICT products/services do not fully conform to Section 508 accessibility standards, an Equally Effective Alternative Access Plan (EEAAP) is developed to address known accessibility barriers.
The CSU EEAAP template is used to develop, document, and obtain approvals for each Equally Effective Alternative Access Plan. Approval of an EEAAP, by campus-designated approvers, is required before a procurement can proceed for a partially-conformant product or service.
An EEAAP should be prepared for products and services that are not fully conformant with Section 508 accessibility standards. The CSU ATI Prioritization Framework (*) is a resource that provides detailed guidance about the recommended process campuses can use to determine impact. The creation of an EEAAP is especially important 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
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An EEAAP should be created by a multi-disciplinary committee that has a clear understanding of 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.
The committee should also take into consideration the following resources/representatives:
- ADA Compliance Officer – Assists in faculty and staff accommodations.
- Dean/Manager/Supervisor – typically provides administrative approval for an EEAAP, has knowledge of 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) – serves as authoritative resource for faculty and staff related processes.
As EEAAP documentation is created, campuses should ensure that key constituent groups (e.g. Disability Services Office) are able to quickly and easily access plans in order to (1) initiate accommodations and workarounds outlined in the EEAAPs; (2) allow updating of current EEAAPs based on product improvements or when a new approach is developed; and (3) streamline the authoring of future EEAAPs. In addition, EEAAPs should be reviewed at least once per year, often coinciding with the renewal of the product.
There are two methods for providing access to this documentation:
- Establish and maintain a central document repository (e.g. SharePoint)
- Provide access for all EEAAP Committee members and key constituent groups (e.g. Disability Services Office)
- Store the signed EEAAP 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 (responsible for accommodations for staff and faculty)