Below are the most frequently asked questions related to Information and Communication Technology (ICT) and CSUN's ATI Procurement Procedure:
- ICT FAQs
- ATI Procurement FAQs
- Accessibility Review FAQs
- Accessibility Conformance Report (ACR) FAQs
- Plan for Alternate Access FAQs
ICT FAQs
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ICT stands for Information and Communication Technology and it is a term used to describe technologies that provide access to information and/or serve as a mechanism of communication. This term was previously referred to as Electronic and Information Technology (E&IT) but as of March 2018, it has changed to ICT.
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E&IT and ICT refer to the same thing. However, E&IT was replaced with ICT as of March 2018 following an update to Federal Laws and standards covered in Section 508 of the Rehabilitation Act and Section 255 of the Communication Act. Following the update, ICT became the globally recognized term for technologies that provide information and/or serve as a method to communicate.
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ICT includes information technology and any equipment or interconnected system or subsystem of equipment that is used in the creation, conversion, or duplication of data or information. The following technologies fall into the category of ICT and any purchases of these technologies must go through the CSUN ATI procurement procedure:
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For the most current list of items that are not ICT or otherwise do not need a review, please see the pre-reviewed ICTs page.
ATI Procurement FAQs
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The Accessible Technology Initiative (ATI) requires that all CSUs implement procedures to procure the most universally accessible ICT products and services in the market. CSUN ATI procurement procedure helps ensure that we are adhering to this law and the principles of accessibility for all. To read more about CSUN’s ATI procurement policy refer to the ICT Procurement page.
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When departments intend to purchase an ICT product, service or activity, they must start by filling out the pre-purchase accessibility form* located in the ICT Procurement Form page. Once the form is submitted the ATI procurement team will review the information provided and determine the risk the product poses to the University related to accessibility. Products identified as having high or medium accessibility risk will undergo an accessibility review by the Universal Design Center. Once the review is complete, departments and vendors will receive a report outlining areas where accessibility barriers may be a problem in these products and the steps they must take to adhere to CSUN’s ATI procurement policy. Refer to the Accessibility Review for ICT page for more information.
Risk is defined as the overall effect an ICT purchase could have on the campus and how the usability of this ICT could affect users with disabilities. Risk is categorized into five levels: minimal, low, medium, high, and critical. While all campus ICT should be accessible, a higher risk level increases the steps to ensure that the purchased product is universally accessible.
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At CSUN, we do not have any exemptions to the ATI procurement procedure. However, the ATI procurement group has pre-reviewed select ICT products and services for the CSUN community and has outlined requirements departments must follow if they are purchasing these items. Refer to the pre-reviewed ICTs page for more information.
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In compliance with California State University Executive Order 1111 and Coded Memorandum AA-2013-03, departments at CSUN have an obligation to analyze the ICT products they purchase and ensure accessibility is addressed for these products. This means departments should strive to procure the most accessible product of its kind in the marketplace and/or create plans of alternate access that outline the departments steps to ensure all students, faculty, staff and the general public and access their technologies regardless of disabilities. Refer to the ATI Procurement Page: Department Responsibilities for more information.
Accessibility Review FAQs
To learn more about the accessibility review for ICT products, go to the ICT Accessibility Review page.
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Products that are placed in queue for an accessibility review are those that are considered to potentially pose a significant risk to the campus community. Below are general guidelines around risk. However, please be aware that these guidelines are not all inclusive and are subject to change..
Critical Risk
- Product will be used campus-wide, by all students, and/or by members of the public
- Product is a strict requirement of academic or administrative procedures
- Usage of product will directly impact access to a specific program and /or service on campus
- Product has high visibility
- Strong likelihood product will impact people with disabilities
- High risk of accessibility barriers
High Risk
- Product will be used by a large campus audience in multiple colleges, divisions or departments
- Product is required for academic or administrative procedures or no convenient alternative exists
- Usage of product could impact access to a program and/or services on campus
- There is a likelihood that this product could impact people with disabilities
- Risk of accessibility barriers
Medium Risk
- Product will be used by a moderately-sized campus audience in a college, division or department
- Usage of product could impact access to a program and/or services within a division, college or department
- There is a likelihood that this product could impact people with disabilities
- The product has potential accessibility barriers
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If a product is determined to be a potentially higher-risk campus purchase, it will undergo an accessibility review by the Universal Design Center. You will receive email from the Universal Design Center with more information as the review progresses.
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The accessibility review can generally take between a few days to a month. This ultimately depends on the product to be reviewed and the kind of accessibility review conducted. The responsiveness of the department and their vendor is another big factor in the timeframe for these reviews.
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Following the accessibility review, you may be required to complete a Plan for Alternate Access (PAA). The PAA is a document that must include what measures a department will take to provide alternate access solutions to users with disabilities. Additionally, some departments may be asked to sit down with the Alternate Access Working Group, a sub-group to the Technology Procurement Accessibility Committee, to further discuss their product and identify the most effective alternate access solutions for users.
Failure to develop an alternative plan of access could result in the denial of approval for purchase or renewal of a product/service. Purchasing and Contracts Administration Department has a list of departments with outstanding documentation and will hold the purchase until it is submitted.
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It depends. While the goal of the ATI procurement procedures is not to prevent ICT purchases, if an ICT product or services is identified to have extensive accessibility barriers and poses significant risk to the campus, a replacement product may be needed instead. The Technology Procurement Accessibility Committee will work with departments on a case-by-case basis.
Accessibility Conformance Report (ACR or VPAT) FAQs
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VPAT stands for Voluntary Product Accessibility Template and it is the first step to understand the accessibility of an ICT product. When this template is completed by ICT vendors, it documents their product's conformance to ICT accessibility standards including Section 508 (U.S.), W3C/WAI WCAG 2.0, and EN 301 549 (EU). The completed template is now called an Accessibility Conformance Report (ACR).
A completed ACR should state which criteria the product supports and explain what features it utilizes to support accessibility. At CSUN, an ACR is required for higher-risk ICT products.
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If you are unable to obtain an ACR from your vendor please contact the UDC for assistance. Ultimately, a vendor’s refusal to address accessibility deficiencies/concerns could result in denial of the product/service.
To provide your vendor the latest VPAT template, refer them to the ACR section in the Vendor Resources Page.
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Refer your vendors to the Vendor Resources Page. In addition, you can direct them to the ATI Procurement Page: Vendor Requirements section.
Plan for Alternate Access FAQs
For more information on Plan for Alternate Access, go to the Plan for Alternate Access page.
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A Plan for Alternate Access or PAA is a document to be completed by departments which outlines the steps a department will take to support users with disabilities. The plan is generally completed after the accessibility review of the product and must be submitted to the alternate access working group before any further purchases or renewals can be completed for the product.
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Departments need to create a PAA for all ICT products that will be used by a large number of people and present known accessibility barriers. Departments will receive a notification from the UDC to complete a PAA following an accessibility review of their product. However, if the department is aware of the accessibility barriers in their product, they can complete the PAA before the purchase and submit it with the campus ATI-ICT Form. Submitting the PAA early in the process can streamline the purchase and future renewals of the product.
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For higher-risk purchases, the UDC will conduct an accessibility review to find the accessibility barriers in the product.
Departments are encouraged to conduct a preliminary, basic accessibility review to self-identify the level of accessibility and the potential accessibility gaps in the ICT product they are purchasing. UDC’s Conducting Accessibility Evaluations page will help departments conduct basic accessibility reviews by offering various testing methods they can use.
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Alternate access solutions are about ensuring equitable and effective access to technology for all individuals regardless of ability or disability. When ICT products have accessibility gaps, the gaps may prevent or make it difficult for users with disabilities to use the product or gather information. Alternate access solutions are required to allow users with disabilities the ability to perform the same tasks or gather the same information as all users.
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Alternate access solutions will vary by department or by product. To come up with alternate access solutions departments can consider the following:
- How critical is the product for the department?
- Are there other processes that can be used to allow a user to achieve the same end goal?
- Are there alternative products a user can use to gather the same information?
- Is there someone in the department who can provide support when users have problems utilizing the product?
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Departments will generally have 30 days to submit a completed PAA to the UDC following an email notification or following the meeting with the PAA group. If needed, departments can request extensions to the UDC.
The PAA for a product should be on file by the next renewal purchase or the department may be unable to renew the purchase.
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To help guide the development of alternate access plans, the ATI procurement team has created the Alternate Access Working Group. The group is comprised of members from the UDC, the Office of Equity and Compliance, Disability Resources and Educational Services (DRES), Deaf and Hard of Hearing Services (NCOD), and the Computer & Mobile Device Committee (CMDC). The members will work with departments to create alternate access solutions for the ICT products being purchased.
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At this moment, the PAA group will be scheduling appointments with departments whose ICT purchases will be used by a high volume of users or whose products present significant accessibility barriers. The committee meets two times a month to review high impact purchases and will schedule a department of a high campus impact request during one of the regular meeting dates.