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Handbook of Operating Procedures
  • Policy Process

    • Handbook of Operating Procedures
    Chapter 11 - Information Technology
    Previous Publication Date: December 5, 2023
    Publication Date: March 12, 2024
    Policy Reviewed Date: November 27, 2023
    Policy Owner: VP for Information Technology


    11.10 Web and Digital Accessibility Compliance

    I. POLICY STATEMENT

    The University of Texas at San Antonio (UTSA) must develop, procure, maintain and use websites and digital content in adherence to state and federal laws for content accessibility for persons with disabilities.

    II. RATIONALE

    The purpose of this policy is to ensure all websites and digital content are accessible by employees, students, and members of the public and provide an optimal user experience for all users without barriers for individuals with disabilities. Failure to meet modern web accessibility compliance standards could result in audits by federal and state government agencies, loss of federal funding, and/or independent lawsuits by individuals or their representatives.

    III. SCOPE

    This standard applies to all UTSA faculty, staff, and students as well as any third-party vendors contracted by UTSA to provide web and digital services.

    IV. WEBSITE ADDRESS FOR THIS POLICY

    http://www.utsa.edu/hop/chapter11/11.10.html

    V. RELATED STATUTES, POLICIES, REQUIREMENTS OR STANDARDS

    1. Section 508 of the Rehabilitation Act, as amended, 29 United States Code § 794d
    2. 36 Code of Federal Regulations Part 1194 – Electronic and Information Technology Accessibility Standards
    3. Texas Government Code, Chapter 2054, Subchapter M – Access to Electronic and Information Resources by Individuals with Disabilities
    4. Title 1, Chapter 206, Rule § 206.70 of the Texas Administrative Code
    5. Title 1, Chapter 213 of the Texas Administrative Code
    6. UTSA Handbook of Operating Procedures 4.22 University Marketing, Branding and Communications
    7. UTSA HOP Policy 9.02 Persons with Disabilities Policy 
    8. The University of Texas System (UT System) 165: Information Resources Use and Security Policy
    9. The University of Texas System (UT System) 150: UTS 150 Access by Persons with Disabilities to Electronic and Information Resources Procured or Developed by The University of Texas System Administration and The University of Texas System Institutions
      1. UT System Office of General Counsel (OGC) Bulletin 2006-1, Access by Persons with Disabilities to Electronic and Information Resources Procured by UT System Administration and UT System Institutions
      2. UT System OGC Bulletin 2009-1, Access by Persons with Disabilities to Electronic and Information Resources Developed by UT System Administration and UT System Institutions
    10. Web Content Accessibility Guidelines (WCAG)
    11. Texas Department of Information Resources Electronic Information Resources Coordinator Roles and Responsibilities

    VI. CONTACTS

    If you have any questions about HOP policy 11.10, web and digital accessibility compliance contact one of the following offices:

    1. University Marketing Web Team
      webteam@utsa.edu
    2. Academic Innovation-Digital Accessibility Team
      digitalaccessibility@utsa.edu

    VII. DEFINITIONS

    1. Accessible Rich Internet Applications
      1. Accessible Rich Internet Applications (ARIA) is a set of attributes that define ways to make web content and web applications (especially those developed with JavaScript) more accessible to people with disabilities.  
    2. Content Management System
      1. A content management system (CMS) is web-based software used to manage the creation and modification of digital content for websites. UTSA has several CMS currently being utilized. The University Marketing web team encourages the use of Cascade CMS or WordPress as supported CMS. 
    3. DIR
      1. Texas Department of Information Resources (DIR) provides resources and other guidance to government entities, including higher education institutions.
    4. EEAAP
      1. Equally Effective Alternative Access Plan (EEAAP) is an exception developed when it is not possible to make a specific technology accessible. This exception requires similar learner achievements, benefits, or results in the most integrated setting possible.
    5. Electronic and Information Resources
      1. Electronic and Information Resources (EIR) include software applications and operating systems, websites, telecommunications products, video and multimedia products, desktop and portable computers, and self-contained/closed equipment that includes EIR.
    6. Learning Management System
      1. A learning management system (LMS) is web-based software used for the administration, documentation, tracking, and reporting of educational courses.
    7. Optical Character Recognition or Optical Character Reader
      1. Optical character recognition or optical character reader (OCR) is the electronic or mechanical conversion of images of typed, handwritten, or printed text into machine-encoded text, whether from a scanned document, a photo of a document, a scene-photo or from subtitle text superimposed on an image. 
    8. Screen Reader
      1. A screen reader is a software program that allows blind and low-vision individuals to read the content on a computer screen with a voice synthesizer or braille display. The screen reader is the interface between the user and the computer operating system and its applications. 
    9. Web Accessibility
      1. Web accessibility means that websites, tools, and technologies are designed and developed so that all people can use them, including people with disabilities. More specifically, people can: perceive, understand, navigate, and interact with the Web. 
    10. Web Accessibility Evaluation Tool
      1. Web Accessibility Evaluation Tools scan web pages and identify accessibility compliance deficiencies. 
    11. Web Accessibility Scanning Software
      1. Web accessibility scanning software helps organizations optimize their websites for an inclusive user experience. It crawls websites and provides automated tests for website accessibility, broken links, misspellings, and customizable web governance rules. 
    12. Web Content Accessibility Guidelines (WCAG) Level AA
      1. The Web Content Accessibility Guidelines are part of a series of accessibility guidelines published by the Web Accessibility Initiative of the World Wide Web Consortium, the main international standards organization for the Internet. Level AA is the second-highest compliance level for the latest version of the web content accessibility guidelines.

    VIII. RESPONSIBILITIES

    1. Website Accessibility Coordinator 
      1. Serves as UTSA's primary point of contact for Web Accessibility compliance. 
      2. Manages all reports, inquiries, and complaints from the website accessibility reporting form.
      3. Serves as a liaison between federal and state government entities and the UTSA Office of Legal Affairs in the case of a formal accessibility complaint or federal audit. 
      4. Conducts manual evaluations of UTSA websites and identifies any issues that automated tools cannot identify. 
        4.1 Evaluate keyboard navigation and focus styling. 
        4.2 Ensures ARIA implementation adheres to proper coding syntax and guidelines.  
      5. Provides training, guidance, and support for use of Web Accessibility Evaluation Tools and Web Accessibility Scanning Software to web developers and content management system users. 
      6. Assists with the conversion of PDF documents to HTML webpages or revisions of PDF documents to meet accessibility compliance requirements.
    2. Web Developer 
      1. Develops website infrastructure using the latest accessibility standards. 
      2. Leverages Web Accessibility Evaluation Tools during the development of websites to identify accessibility issues. 
      3. Scans development sites with Web Accessibility Scanning Software to identify accessibility deficiencies before launch. 
      4. Requests manual evaluation of websites by the Website Accessibility Coordinator before going live. 
      5. Includes all required links currently listed in the footer of the main utsa.edu website within the website footer.  
        5.1 Includes the link titled Web Accessibility within the footer of every website. 
        5.2 Ensures the placement of the web accessibility link reflects what is currently listed on the main utsa.edu website footer.  
        5.3 Monitors the main utsa.edu website footer links for changes on a regular basis to ensure all website footers reflect current required links.  
      6. Avoids posting PDF documents to public web servers and converts PDF documents to HTML webpages whenever possible. 
    3. Content Management System User 
      1. Reviews web accessibility scanning software reports to identify accessibility issues. 
      2. Fixes misspellings. 
      3. Repairs broken links. 
      4. Ensures header tags are in hierarchical order. 
      5. Adds descriptive alt tags to all images uploaded to web servers. 
      6. Avoids using ambiguous hyperlink text like "learn more", "click here", or "read more" that lack descriptive calls-to-action that are beneficial for screen readers. 
      7. Ensures web copy adheres to lower secondary education readability within the range of 7th to 9th-grade reading levels. 
      8. Avoids reliance on PDF documents and addresses accessibility issues for existing PDF documents by revising documents or preferably migrating to HTML web content. 
    4. Academic Innovation
      1. Provides software tool evaluation before entering into vendor contracts or implementation. 
      2. Conducts screen reader website evaluation. 
      3. Assists faculty and staff with understanding how WCAG Level AA guidelines apply to digital course content development. 
      4. Provides resources for the creation of Adobe PDF documents that will pass automated accessibility checkers, when required. 
    5. Faculty and Staff
      1. Uploads class content exclusively within the LMS and/or any other UTSA-approved platform.
      2. Ensures uploaded digital content and PDF documents are accessible. 
      3. Utilizes only UTSA-approved tools that meet accessibility compliance standards. 
      4. Ensures video captioning is descriptive, accurate, synchronized, and detailed with proper punctuation. 
      5. Ensures all visual cues within videos are adequately described through the audio dialogue. 
      6. In conjunction with other departments, reviews software tools for accessibility before incorporation into the LMS or utilization by students. 
    6. Colleges and Academic Departments
      1. Ensures vendor software tools are reviewed for accessibility by University Technology Solutions, Business Contracts Office, and Academic Innovation before being approved for LMS integration or student utilization. 
    7. Graphic Designers
      1. Ensures adequate color contrast ratios within web designs. 
      2. Avoids use of excessive static text within images. 
    8. Video Producers
      1. Ensures captioning is provided for all video content. 
      2. Avoids the use of static text in videos that are not represented in captioning. 
      3. Do not auto-play video content that contains audio or captioning. 
      4. Avoids using distracting or visually overwhelming looping video content. 
      5. Ensures adequate player controls are provided and accessible to screen readers. 
    9. Library
      1. Ensures vendor and database resources adhere to accessibility compliance requirements. 
      2. Mitigates scanned PDFs and OCR issues within database documents. 
      3. Provides captioning for all video content. 
    10. Student Disability Services 
      1. Collaborates with Academic Innovation to provide support to students. 
      2. Informs faculty of resources to provide student accommodations.
      3. Provides necessary support to students for accommodation requests. 
    11. Vice President for Information Management and Technology
      1. Serves as the EIR Accessibility Coordinator and delegates accessibility compliance responsibilities to other Vice Presidents and/or their designees at UTSA to comply with the DIR accessibility rules of the state of Texas.
      2. Approves all exceptions to compliance with the DIR accessibility rules governing how UTSA develops, procures, maintains, and uses EIR.
    12. Vice President for Business Affairs and Business Contracts Office
      1. Ensures compliance with OGC Bulletin 2006-1 when UTSA procures or develops EIR.
      2. Ensures compliance with OGC Bulletin 2009-1 when UTSA procures or develops EIR.
      3. Ensures that vendors agree in writing to compliance with state EIR accessibility standards.
    13. Provost and Senior Vice President for Academic Affairs
      1. Ensures Academic Innovation provides necessary training and guidance to make content created or housed within the LMS accessible.
    14. Chief of Staff and Senior Vice President
      1. Ensures the Compliance Office works with Academic Innovation and the Website Accessibility Coordinator to develop and maintain accessibility training content for annual compliance training and onboarding training.
    15. Vice President for University Relations
      1. Ensures the Web Accessibility Coordinator provides training and support for Web Accessibility Evaluation Tools and Scanning Software.

    IX. PROCEDURES

    1. Reporting of Web Accessibility Issues 
      1. UTSA encourages any person (faculty, staff, student, applicant, or visitor) who requires additional assistance or experiences an accessibility issue on any UTSA website to report the issue to the Website Accessibility Coordinator using the Website Accessibility Reporting Form.  
      2. Submitters of the Website Accessibility Reporting Form will be contacted for more information and notified when the issue has been addressed. 
    2. Website Accessibility Compliance 
      1. Site owners and content creators (UTSA faculty, staff, or students creating UTSA websites) ensure web content meets WCAG Level AA compliance. 
      2. Site owners and content creators work with the Website Accessibility Coordinator and the University Marketing Web Team to bring UTSA websites into accessibility compliance.  
      3. Site owners and content creators leverage Web Accessibility Evaluation Tools to improve web accessibility and eliminate all critical errors and contrast errors.
      4. Site owners and content creators leverage Web Accessibility Scanning Software to improve the website accessibility dashboard score to 95% or above.
      5. Site owners shall request manual evaluations for website accessibility compliance once sites pass the web accessibility evaluation tool and web accessibility scanning software reports. Manual evaluations will be conducted by the Website Accessibility Coordinator.
      6. Site owners and content creators must actively address websites with critical errors and contrast errors, as identified by Web Accessibility Evaluation Tools, within 4 months. After 4 months from the date of notification, site owners will be subject to intervention by the Website Accessibility Coordinator and reporting to the supervisory positions overseeing the particular division and/or the respective Vice President. 
    3. Student Procedures (See UTSA HOP 9.02 )
      1. Students must inform the faculty member of the course when encountering inaccessible digital content within the LMS or during coursework to alert them of the issue.
      2. Students may also report the issue via the Digital Accessibility Reporting Form .
      3. Students may also notify Student Disability Services of inaccessible content. (as set forth in HOP 9.02).
        3.1 Only those students who have officially registered with UTSA Student Disability Services and have been awarded accommodation(s) by Student Disability Service will be eligible for that accommodation. Information regarding diagnostic criteria and policies for obtaining disability-based academic accommodation can be found at www.utsa.edu/disability.
        3.1.1 Student Disability Services notifies students of approved accommodation(s).
        3.1.2 Students may then notify their instructors of the approved accommodation(s).
    4. Faculty Procedures 
      1. Faculty will make a good faith effort to create and utilize accessible digital content. Support and training are available to assist faculty in the creation of accessible digital content.   Academic Innovation can assist in the creation of accessible digital content by routing faculty to the necessary support and training available.
      2. Faculty will make a good faith effort to remediate content to meet accessibility guidelines after being made aware of inaccessible digital content.  If an instructor is unaware of how to do so, they may contact Academic Innovation for guidance or assistance and/or refer the student to Student Disability Services. 
      3. Faculty will make a good-faith effort to ensure all course software, third-party content and applications are accessible by contacting Academic Innovation for evaluation.
        3.1 According to HOP 11.06 Application Administrator Policy , all applications must also be registered with the Office of Information Security and undergo security risk assessment and data classification before being acquired or deployed within a learning environment. 
      4. If a student with an approved accommodation encounters an accessibility barrier when accessing course software, third-party content, or applications, the Student, Faculty, Student Disability Services, and Academic Innovation will engage in a collaborative effort to ensure the student can engage with course content and meet course objectives. 
        4.1. An EEAAP shall be created in collaboration with Student, According to HOP 11.06 Application Administrator Policy , all applications must also be registered with the Office of Information Security and undergo security risk assessment and data classification before being acquired or deployed within a learning environment. 
      5. Student Disability Services may grant exceptions outlined in Section C (Students) and D (Faculty) of Procedures for the semester a student encounters and shares a barrier. After the semester, faculty shall make a good faith effort to remediate inaccessible content to prevent future barriers.
    5. Adobe PDF Documents 
      1. Site owners and content creators will convert PDF documents to accessible HTML webpages since this provides the optimal user experience for visitors without the disruption of downloading or opening the PDF document in a separate browser tab or application.  
      2. If a PDF document is utilized, creators will have to develop PDFs using the official Adobe workflow and tools for creating accessible documents. PDF documents are not inherently accessible and will fail automated checks without deliberate attempts to incorporate accessibility elements. It is the responsibility of the document creator to ensure the PDF is accessible and compliant with federal and state laws before uploading to a public webserver. Academic Innovation can provide the necessary guidance and resources so that PDF documents can be optimized for accessibility. It is not the responsibility of Academic Innovation to conduct this optimization on behalf of or for the UTSA community.
      3. Site owners and content creators will replace PDF documents that fail automated accessibility checkers during regular web accessibility scanning software crawl of UTSA websites with accessible and compliant PDFs or HTML pages.  
      4. Site owners and content creators will not upload PDFs created for print campaigns to websites since they typically contain complex visual and design elements that are inherently inaccessible and difficult to optimize for accessibility.  
      5. Site owners and content creators will not upload PDF documents that are scans of a physical document to UTSA web servers. Screen readers cannot interpret the text within these documents. Optical character recognition shall not be relied upon for accessibility since it can misinterpret or garble scanned text from the document. 
      6. Inaccessible and/or outdated (older than 5 years) PDF documents with no clear ownership or pathway to accessibility compliance are subject to removal from public web servers at the discretion of the Website Accessibility Coordinator to ensure web accessibility compliance. 
    6. Web Content Readability 
      1. Publicly available, non-academic website copy shall adhere to lower secondary education readability within the range of 7th to 9th-grade reading levels as outlined in WCAG Level AA guidelines. Web Accessibility Scanning Software crawls provide an extensive evaluation of readability as well as recommendations for copy revisions. The Website Accessibility Coordinator will monitor reading levels and ensure websites are compliant.
    7. Vendor Contracts 
      1. Vendors providing web software or EIR to UTSA must be vetted by University Technology Solutions, Business Contracts Office, and Academic Innovation to ensure they adhere to WCAG Level AA compliance prior to implementation with end-users. 
      2. Departments utilizing existing vendors known or suspected to have web accessibility compliance deficiencies must submit requests to the vendor to resolve the accessibility issues in a timely fashion and notify the Business Contracts Office and Office of Legal Affairs of the deficiencies.
      3. Vendors failing to address WCAG Level AA compliance requirements during the term of the contract will need to contact the Business Contracts Office and/or the Office of Legal Affairs to explore options and remedies under the contract or by law.
      4. The Vice President for Information Management and Technology may grant exceptions for vendor contracts in accordance with accessibility guidelines and policies. Vendors are subject to those policies and guidelines in order to renew existing contracts. 

    X. SPECIAL INSTRUCTIONS FOR IMPLEMENTATION

    None

    XI. FORMS AND TOOLS/ONLINE PROCESSES

    1. Report a Web Accessibility Issue
    2. Report a Digital Accessibility Issue

    XII. APPENDIX

    None

    XIII. Dates Approved/Amended

    03-12-2024
    12-05-2023     (SB17)
    08-02-2022