Accessibility Procurement Policy
In accordance with the University of Cincinnati’s Electronic and Information Technology (EIT) Policy 9.2.1, electronic and information resources and content will be procured, implemented and managed in a way to be accessible to individuals with disabilities and support compliance with applicable requirements of relevant federal, state and local non-discrimination laws. In order for the university to be successful in procuring accessible EIT, purchasers must consider and inquire about accessibility as early as possible, preferably at the beginning of the purchasing process. Determining the degree of accessibility—and comparing the results with other potential options—is a key part of selecting a new EIT product.
The Accessibility Network is available to assist individuals with accessibility in the procurement process at any time and answer questions about the procedures that follow. This includes, but is not limited to, questions concerning Voluntary Product Review Template (VPAT) assessment, product testing, risk assessment, and mitigation options when gaps in accessibility may be present.
The Accessibility Procurement Process
The following section details how to incorporate accessibility into the purchasing process.
Request an Accessibility Conformance Report (ACR or VPAT)
When considering EIT products for purchase, request the vendor provide an Accessibility Conformance Report (ACR) or VPAT. The vendor will typically provide this information using a Voluntary Product Accessibility Template, or VPAT. A VPAT is a document that asserts the degree to which hardware, software, or online products and services conform to various accessibility requirements, such as the Web Content Accessibility Guidelines (WCAG) or Section 508 requirements. Most often, VPATs are completed internally by the vendor, but occasionally a third party is hired. Lack of a VPAT is likely telling with regard to a product’s potential for an accessible user experience.
Competitive Bidding & Request for Proposals (RFP)
Competitive bidding is a pricing procedure that solicits bids from potential suppliers and then selects the lowest and best proposal. An accessibility review(s) that assesses accessibility compliance will need to be included with the submitted vendor bids. For more information, refer to the UC Central Purchasing Manual.
Initiate an Accessibility Review
After receiving a completed conformance report (or VPAT) from the vendor(s), submit the information through an online service request to initiate an accessibility review process. The university’s Accessibility Review Committee will then:
- Evaluate the degree of accessibility of the potential product(s),
- Provide support in incorporating accessibility requirements into product testing,
- And assist in eventual implementation or provide suggestions for alternatives when appropriate.
Single Source Purchases
On occasion, unique requirements warrant a bid waiver request be made (sometimes referred to as a “single source purchase”), which must be submitted to Central Purchasing. Note that waiving the bidding process does not waive the requirement to conduct an accessibility review of the EIT product prior to its purchase. A single source purchase with no alternatives being considered heightens the need for an accessibility review.
Central Purchasing maintains a list of items (non-competitive list) that do not require competition or a bid waiver. Any of these items that are or include electronic or information technology will require an accessibility review be conducted.
EIT purchases that include a contract or formal agreement with a vendor will pursue inclusion of an accessibility rider. The language of this rider is currently being developed in coordination with the Office of General Counsel (OGC).
Purchase Requisitions & Purchase Cards
EIT products procured via purchase requisitions or purchase cards will need an accessibility review prior to purchase.
Inter-University Council (IUC) Purchases
Some EIT products available for purchase through the IUC may lack an acceptable level of accessibility. Until the IUC process better reflects the standards established in Section 508 of the 1973 Rehabilitation Act and WCAG 2.1, potential products available through this process will also need an accessibility review prior to purchase.
Request an updated VPAT from the vendor(s) and an Accessibility Review from the Accessibility Review Committee within 3-6 months of a product’s renewal.