Procurement & Accessibility FAQs
Electronic and Information Resources (EIR) / Information & Communication Technology (ICT) - VPAT Requirements
Audience: UT San Antonio Staff, Departments, and Vendors
This FAQ describes UT San Antonio’s procurement accessibility review process as currently implemented. The program is iterating; some elements, such as the Equally Effective Alternate Access framework, formal exception handling for non-contract purchase orders, and the accessibility validity term policy, are in development. The Office of Digital Accessibility will update this document as the process matures.
Overview
UT San Antonio is committed to ensuring digital accessibility and compliance with federal regulations. This FAQ outlines requirements for Electronic and Information Resources (EIR), including web content, software applications, mobile applications, kiosks, multimedia, electronic documents, and other Information & Communication Technology (ICT), along with the use of the Voluntary Product Accessibility Template (VPAT).
General (Requirements & Definitions)
UT San Antonio must comply with multiple overlapping accessibility authorities:
- Section 508 of the Rehabilitation Act, as implemented by the Revised 508 Standards (Title 36, Code of Federal Regulations, Part 1194)
- ADA Title II, including the U.S. Department of Justice April 2024 final rule on web and mobile application accessibility for state and local government (compliance dates April 26, 2027, and April 26, 2028)
- Texas Government Code Chapter 2054, Subchapter M (Accessibility of Information Resources Technologies)
- Title 1 of the Texas Administrative Code, Chapters 206 and 213 (which adopt the Revised 508 Standards by reference for state agencies and public institutions of higher education)
- UT System Policy UTS 150 (Access by Persons with Disabilities to EIR)
Any EIR/ICT product or service, including but not limited to:
- Web sites and web applications (public or internal)
- Software applications and operating systems (desktop, server, embedded UIs)
- Mobile applications (iOS, Android, cross-platform)
- Authoring tools, IDEs, and developer tools
- Information kiosks and self-service transaction machines (printing/copy stations, registration kiosks, payment terminals)
- Multifunction office equipment (copiers, scanners, fax, MFPs) with user interfaces
- Telecommunications products (desk phones, VoIP/softphone clients, conferencing systems, headsets)
- Hardware peripherals with user-facing controls (keypads, displays, lab/research instruments)
- Audio/video and multimedia content (lecture capture, training videos, podcasts)
- Electronic documents (PDF, Word, Excel, PowerPoint, web content)
- Cloud platforms and Software as a Service (SaaS) tool regardless of delivery channel
Note: Equipment with embedded IT whose principal function is not data processing or communication (for example, HVAC, certain medical equipment) is generally excluded; if it has an externally available web or computer interface, that interface is in scope.
Note on procurement path:
Contracts: Accessibility review occurs early in contract drafting, alongside security review, coordinated through the Business Contracts Office. Exception handling for contracts will follow the procedure described in the forthcoming Accessibility Exception and Enforcement Procedures.
Purchase orders without an associated contract: Accessibility review is conducted by the EIR Accessibility Coordinator (EIRAC) at the requisition stage and is processed in queue order. Outcomes for non-conforming requisitions will align with the forthcoming Accessibility Exception and Enforcement Procedures.
Applicable EIR/ICT must meet the Revised Section 508 Standards (Title 36, Code of Federal Regulations, Part 1194), which incorporate WCAG 2.1 Level AA for web content and electronic documents and add provisions in Chapters 4 through 7 covering hardware, software, support documentation, and support services.
The EIR Accessibility Coordinator (EIRAC) reviews each VPAT and assigns two ratings:
- A conformance letter grade based solely on accessibility criteria documented in the VPAT.
- A risk rating based on letter grade, annual cost, annual staff users, annual student users, and public availability.
The combination informs the review outcome (approval, conditional approval, deferral, or rejection) and any vendor remediation expectations.
A Voluntary Product Accessibility Template (VPAT) is a document that explains how a product complies with accessibility standards such as Section 508 and WCAG.
A VPAT must be submitted at the time of quote or solicitation response for applicable EIR/ICT. Vendors should select and submit the latest VPAT edition.
No. VPAT submission supports evaluation but does not guarantee selection.
It may:
- Delay review
- Require follow-up clarification
- Impact award eligibility
UT San Antonio End Users
If your purchase involves any EIR/ICT (for example, software, mobile applications, kiosks, multimedia, multifunction office equipment, electronic documents, or web-based products and services):
- Expect an accessibility review
- Request a VPAT from the vendor early
- Seek guidance if the vendor cannot provide a VPAT
- Submit the requisition with adequate lead time before the need-by date. Reviews are processed in queue order; last-minute submissions may be deferred or may receive a compressed review.
Provide the following details:
- UT San Antonio end username and email
- Vendor contact name and email
- Estimated annual student users
- Estimated annual staff users
- Whether the tool is public facing (Yes/No)
Contact UT San Antonio accessibility support for guidance before proceeding. Possible outcomes depend on the purchase type:
- Contracts: The Business Contracts Office facilitates a formal exception request memo with VP-level signature when accessibility gaps cannot be remediated through vendor commitments.
- Non-contract purchase orders: The EIR Accessibility Coordinator (EIRAC) may issue a Conditional Approval for low-risk requisitions meeting documented criteria, defer the review until contract renewal, or recommend rejection if accessibility risk cannot be mitigated.
In all cases the requisitioner will be notified of the outcome and any conditions or alternative options.
Most EIR/ICT purchases will undergo accessibility review, even if additional routing is required internally.
Vendors
The vendor must provide a current and accurate VPAT.
The most current and complete version, specifically to the product/service offered.
Yes, VPATs may be required for:
- New contracts
- Renewals
- Changes involving web-based functionality
The VPAT should clearly identify:
- Accessibility gaps
- Planned remediation efforts and timelines
Clearly indicate this in your response. UT San Antonio will determine whether a VPAT is required. Note that products without a web-based component (for example, installed software, hardware with on-device controls, kiosks, multifunction printers) may still be EIR/ICT and may still require a VPAT.
Failure to submit may:
- Delay the procurement process
- Negatively impact evaluation
- Affect award decisions
Vendors are expected to comply with accessibility standards and may be contractually required to address issues.
- Faster review process
- Fewer follow-ups
- Reduced delays in procurement
Key Takeaways
- Accessibility compliance is mandatory for all EIR/ICT, including software, mobile applications, hardware with user interfaces, kiosks, multimedia, electronic documents, and web content
- VPAT submission is required and vendor-owned
- Early preparation helps avoid delays
- UT San Antonio reviews all submissions for compliance and risk
