A.     Purpose:


1.     VCSU is committed to ensuring equal access to all programs and services for people with disabilities, prohibits disability discrimination, and assures equal opportunity to access the institution and associated information. To this end, the University will work to ensure that all constituents and members of the general public with disabilities have an opportunity equal to that of their non-disabled peers to access and utilize information and communications technologies, except where doing so would impose an undue burden on the University. 


2.    This policy fulfills a mandate for each institution to adopt policies and procedures pursuant to SBHE Policy 1203.1.


B.    Roles and Responsibilities


1.    Digital accessibility is an institution-wide responsibility. Everyone that has a laptop or even replies to an email has some responsibility. Positions that create significant digital content for large audiences have greater responsibilities.  


2.    Executive Sponsorship


a.    The Chief Information Officer (CIO) is designated as the VCSU electronic information technology (EIT) Coordinator.  The Office of the CIO shall oversee the implementation, evaluation, assessment, and compliance of the Digital Accessibility Program, with the exception of (b) below.  The CIO or designee establishes procedures and coordinates procurement of all EIT. 

b.    The Office of the Vice President for Academic Affairs (VPAA) oversees the implementation, evaluation, assessment and compliance of Digital Course Content, Library Services and other academic services, excluding procurement which is a responsibility of the CIO.  

c.    Each VCSU Cabinet member is responsible to ensure their Unit contributes to improving digital accessibility. 

d.    VCSU Cabinet will create an administrative advisory committee or identify other institutional capacity to facilitate annual accessibility audits and plans. 


3.    The Disability Services Coordinator will  1) work with students, faculty and staff who request accommodations, 2) work with Technology Services and other EIT owners to make recommendations and/or implement digital accessibility tools and strategies for students, staff, and faculty who request accommodations, 3) assist faculty with making their course materials more accessible and 4) make recommendations for departmental and/or campus-wide changes in course materials to accommodate a wider range of disabilities and reduce the need for more specific accommodations.


4.    The "Web Accessibility Team" shall improve the accessibility of VCSU web sites and advise the CIO.  The Team shall include Technology Services staff, Marketing & Communications staff and other primary content managers of the various VCSU sites appointed by the CIO.


5.    Accessibility support is available from Technology Services and Student Academic Services, through the Disability Support Services Coordinator.


C.    Procedures


1.    Please reference SBHE Policy 1203.1, which is incorporated into this policy by reference, for complete digital accessibility requirements.  

a.    All software at VCSU is considered EIT and shall comply with this policy. 

b.    Electronic course content and communications delivered via the Web is considered EIT and must comply with SBHE Policy 1203.1(1)(b).  Reference VCSU Policy V605.09.01 Expectations of Faculty Course Components for additional requirements.


2.    VCSU measures online content accessibility compliance according to The World Wide Web Consortium's (W3C) Web Content Accessibility Guidelines (WCAG) 2.1 Level AA.  WCAG 2.0 Level AA may be used to measure procured software, web sites, web services and web applications upon approval of the CIO.


3.    An audit of accessibility compliance shall be conducted on an annual basis as directed by the VCSU Cabinet.  The audit report shall include recommendations for improvement.  The report shall be provided to the VCSU Cabinet as a basis for adopting University-level objectives for an annual improvement plan.


4.    Procurement of EIT shall follow VCSU Policy V1901.03 Information Technology Approval Process.

  

5.    Exceptions to accessibility compliance per SBHE 1203.1 shall be made as follows:

a.    VCSU Policy V1901.3 provides details of how a request is made and processed for any EIT procurement, including accessibility compliance exception requests. An undue burden request must be completed prior to the issuance of an intent to award or other purchase commitment. Exceptions to accessibility compliance for all procurements must be approved by the CIO or designee.

b.    All VCSU employee-created, non-public/student facing websites, web services, and web applications, including electronic course content should meet the standards identified in 1.b. unless approved by the CIO, CIO designee, the Vice President for Academic Affairs (VPAA), or VPAA designee.

c.    All exceptions must be documented in writing explaining with specificity the reasons why compliance with SBHE 1203.1 is impossible or would impose an undue financial or administrative burden.

d.    If an exception is granted, the requestor shall bear the primary responsibility for providing some form of equally effective alternative access, if one exists, to ensure that, to the maximum extent possible, those with disabilities receive the same benefits as their non-disabled peers.


6.    An individual needing a specific accommodation may choose to submit a Request for Services to the Disability Support Services Coordinator. The Disability Support Services Coordinator reviews the Request for Services and all supporting documentation provided by the individual. The individual and the Disability Support Services Coordinator then determine, through an interactive conversation, reasonable accommodations. The Disability Support Services Coordinator notifies the individual’s instructors and/or supervisor of the individual’s accommodations. Instructors who are unable to provide specific accommodations due to course or department standards of rigor may suggest alternative accommodations .   


7.    Each VCSU website must contain an accessible link to an “Report Accessibility Issue” web form maintained by Technology Services as a point of contact if users have trouble accessing content within the site. This form shall be monitored by the EIT coordinator, the primary Technology Services staff member in charge of maintaining www.vcsu.edu and others as designated by the EIT coordinator. 


8.    Individuals wishing to file a grievance may do so by using the “accessibility-concern” web form or by contacting the EIT Coordinator directly.


D.    References

    North Dakota State Board of Higher Education Policy 1203.1 Digital Accessibility

    VCSU Policy V1901.03 Information Technology Approval Process

    VCSU Policy V605.09.01 Expectations of Faculty Course Components

    Report Accessibility Issue web form


Sponsors:  Chief Information Officer (effective October 2020) Online Standards Committee & Online Accessibility Group 

Effective: July 2014

Revised: October 2020 (formerly V1912.06)