POLICY OWNERS

This policy is jointly owned by the Vice President for Information Technologies and the Dean of Libraries.

PURPOSE OF THIS POLICY

Access to information by all members of its learning community is inherent in Colorado State University’s mission as a land grant institution of higher education. Much of the University’s instructional and business activity is conducted in whole or in part through electronic means. The University is committed to supporting an Electronic and Information Technology (EIT) environment that is accessible to all, including individuals with disabilities. To this end, the University seeks to deploy EIT designed, developed, or procured to be accessible to everyone, including those who use assistive technologies. By supporting EIT accessibility, the University helps ensure that a broad population can access, benefit from, and contribute to its programs and services. This is required by federal and state laws, including the Americans with Disabilities Act of 1990 (ADA), the ADA Amendments Act of 2008, Section 504 of the Rehabilitation Act of 1973, as amended, and C.R.S. §24-34-801, et seq.

This policy complements the Inclusive Physical and Virtual Campus Policy, which aims to state and affirm Colorado State University’s commitment to creating and sustaining a welcoming, accessible, and inclusive campus.

This policy aims to give specificity to inclusion as it pertains to EIT.

APPLICATION OF THIS POLICY

This policy applies to all University academic, administrative, business units and all University Employees.

EXEMPTIONS FROM THIS POLICY

Students, employees, and non-University organizations acting in their individual capacities, not in the scope of their University-related business, are encouraged to adopt the University's policy and standards for accessibility of electronic information and technologies (EIT), but fall outside the scope of this policy.

DEFINITIONS USED IN THIS POLICY

Academic Content means any content that is for educational use and/or content targeted to and delivered to those enrolled in courses, specific programs, majors, or classes.

Accessible refers to making EIT equally accessible to and independently usable by individuals with disabilities so that they can acquire the same information, engage in the same interactions, and enjoy the same services as individuals without disabilities, with substantially equivalent ease of use, using reasonable accommodations when necessary. It does not mean that the means of access must be identical, but that an Equally Effective means of access is afforded in a  time frame as determined case by case by the Student Disability Center or the Office of Equal Opportunity.

Archived means a web page or electronic resource that is no longer available online but is still subject to the applicable records retention requirement under university policy.

Assistive Technology is any item, piece of equipment, or product system, whether acquired commercially or off the shelf, modified or customized, that is used to increase, maintain, or improve the functional capabilities of individuals with disabilities  as defined by the federal Technology Related Assistance to Individuals with Disabilities Act of 1988, as amended (29 U.S. Code § 3002(4)) Examples include special input hardware  (e.g., head or foot mouse, sip and puff switches, speech recognition), and software such as screen readers, screen magnifiers, and literacy software with features  such as text-to-speech.

ADA/Section 504 Coordinator means the Director of the Office of Equal Opportunity, who is the person designated to coordinate the University’s compliance with Section 504 of the Rehabilitation Act of 1973 (“Section 504”) and Title II of the Americans with Disabilities Act of 1990 (“Title II”), or the director’s designee. To contact the Director, contact the Office of Equal Opportunity and Title IX , located at 101 Student Services Building, Colorado State University, Fort Collins, CO 80523-0160, phone (970) 491-5836; fax: (970) 491-2690; email oeo@colostate.edu.

Electronic Information and Technologies (EIT) includes any equipment or interconnected system or subsystem of equipment that is used in the creation, conversion, or duplication of electronic or digital data or information, such as: web sites, emails, marketing materials, course, instructional and communication materials (Word documents, PDF documents, PowerPoint presentations, videos, podcasts, online textbooks, adaptive courseware, exams, flyers, brochures, etc.), courseware, software, other classroom technologies, content management systems, search engines and databases, registration and grades, online proctoring tools, financial and human resource management systems, telecommunications, official CSU social media sites, and emerging technologies.

Employee means any person in the service of the University, including (but not limited to) faculty, administrative professionals, state classified, student employees, hourly, and temporary employees.

Equally Effective means that the alternative format or medium communicates the same information in as timely a fashion as does the original format or medium. For interactive or service pages, Equally Effective means that the result (e.g., registration) is accomplished in a comparable amount of time and with comparable effort on the part of the requestor.

Individual With a Disability is a person who has a physical, mental, sensory or cognitive impairment that substantially limits one or more major life activities, a person who has a history or record of such an impairment, or a person who is regarded by others as having such an impairment. To be certified as an Individual With a Disability receiving reasonable accommodations, a student must be certified by the Student Disability Center and an Employee must be certified by the Office of Equal Opportunity.

University Application means an electronic software and/or hardware solution that is used to conduct University business, for teaching or for work tasks (e.g., Canvas, RamWeb, Kuali).

University Website means a website created and published by the University for official business. It does not include web pages published by Employees for personal purposes. A university legacy web page means a university web page created and published by Colorado State University prior to May 24, 2016.

POLICY STATEMENT

The University’s commitment to accessibility of Electronic Information and Technology (EIT) contributes to a rich and effective learning and working environments for all members of our community. Access to information by members of the university community is critical to their success as students, instructors, employees, and contributors. Accessibility of information transmitted through EIT assists a broad population that includes individuals with disabilities and those with diverse learning needs.

The application of the principles of inclusive and accessible design to the delivery of information and resources through EIT is consistent with legal and ethical requirements placed on the University, as well as contributing to an inclusive environment that assists the University to recruit and retain the best students, faculty, and employees. It is the express policy of the University to proactively support EIT accessibility and universal design, as well as be responsive to requests for accommodations. The Assistive Technology Resource Center is the primary resource for initial requests for accessible content and consultations.

Ensuring Equally Effective access as required is the responsibility of those university Employees responsible for creating and publishing the content. By law, the University must make reasonable accommodations as appropriate to remove any barriers that may exist for an Individual With a Disability. Students requiring reasonable accommodations should contact the Student Disability Center, and employees and others requiring reasonable accommodations should contact the Office of Equal Opportunity. Once students have identified with the Student Disability Center and employees with the Office of Equal Opportunity, they may seek Assistive Technology accommodations, training and support from the Assistive Technology Resource Center. Once the individual has been certified to be an Individual With a Disability and has requested an accommodation, it becomes the University’s responsibility to engage in a good-faith, diligent and timely effort to provide a reasonable accommodation that will allow the individual and others similarly situated to access and use the desired content in an Equally Effective manner.

POLICY PROVISIONS

The University is committed to consistently improving accessibility through implementation of accessibility standards.

Under this policy, the University will: (a) establish standards and guidelines for making EIT accessible; (b) implement procurement requirements for EIT products and services; (c) provide training, as needed, to departments, faculty and staff to enable them to utilize available software and tools to make EIT accessible; (d) promote awareness of this policy to all members of the University community, particularly those in roles that are responsible for creating, selecting, or maintaining EITAD; and (e) assign responsibility for accessible design of EIT to the appropriate departments and personnel.

Responsibility for Accessibility of Electronic Information and Technologies

Those responsible for the creation of information shared through EIT will be responsible for making its content accessible. Where accessibility is not reasonably practicable or when it would fundamentally alter a program to make EIT accessible, please request an exemption from the Office of Equal Opportunity. Units or individuals needing assistance with creating , accessible content can submit a request for assistance using the contact form on the Accessibility by Design website which is managed by the Assistive Technology Resource Center.  In general, these factors pertain to issues other than cost alone, although cost may be a factor. Examples may include content that is innovative, experimental technologies or new technologies that have not achieved a maturity to the degree that they can be practicably deployed in an accessible manner. In such cases, the responsible department or Employee may be required to provide timely, accessible, Equally Effective alternate materials or means of access.

Upon specific request to make content accessible to individuals with disabilities, the content must be made accessible, or an Equally Effective alternative provided, within the time period after receiving the request that is determined by SDC or OEO to be reasonable . Any such request that cannot be accommodated within three business days must be referred to the ADA/Section 504 Coordinator for review.

Accessibility Resources

Many software programs and electronic systems have tools and features already built in that can be easily utilized with no or a minimal amount of training, either self-guided or through training resources offered by the Assistive Technology Resource Center, to create accessible content. All faculty and staff are encouraged to take the time to investigate and utilize such resources. Resource references are provided online through the Accessibility by Design website or are available in the links below.

Procurement Requirements

Accessibility will be included as a factor in the procurement process for EIT, including software, externally developed websites, electronic systems, and hardware. Prospective vendors will be required to demonstrate their knowledge of and commitment to accessibility as part of the RFP or other EIT evaluation process.

Departments and individuals associated with CSU must also consider accessibility when adopting technology tools which students or employees will be required to use, whether purchased or free, even if a formal procurement process is not required.

Vendor requirements for RFPs and other purchasing procedures will, when available, include providing a Voluntary Product Accessibility Template (VPAT), information about the vendor’s accessibility practices and roadmap, and access to manual testing of the product, or certification of a third party accessibility consultant.

When choosing between equivalent products, the purchaser should choose the more accessible product when possible. New EIT should be accessible upon acquisition or implementation to the extent practicable. All new university contracts for EIT will contain appropriate provisions concerning accessibility, as prescribed by the Office of General Counsel.

Promoting Awareness of Accessibility

The ADA/Section 504 Coordinator in the Office of Equal Opportunity, Student Disability Center, Division of University Communications, Division of Information Technology, Assistive Technology Resource Center, The Office of Inclusive Excellence, The Institute for Learning and Teaching, CSU Online, and other departments and offices as appropriate will collaborate to promote awareness of accessibility of EIT.

COMPLIANCE WITH THIS POLICY

Compliance with this policy is required. Assistance with accessibility issues and compliance with this policy may be obtained by using the contact form on the Accessibility by Design website.

Students and prospective students encountering barriers may seek assistance by reporting an accessibility concern or contacting the Student Disability Center.

Employees, prospective employees, and others encountering barriers may seek assistance by reporting an accessibility concern or contacting the Office of Equal Opportunity.

REFERENCES

• Accessibility of Electronic Information Technology Standards
• Accessibility by Design website
• Assistive Technology Resource Center
• ADA/Section 504 Coordinator (Office of Equal Opportunity)
• Student Disability Center
• Office of Inclusive Excellence
• CSU Policy: Inclusive Physical and Virtual Campus
• CSU Policy: Accommodating Individuals with Disabilities
• CSU Policy: Protection of Minors
• CSU Policy: Central Administrative Data Governance

APPROVALS

Approved by Anthony A. Frank, President, June 28, 2016 (effective May 14, 2016)

Revision approved by Brendan J. Hanlon, Vice President for University Operations, on November 11, 2022