University Procedure #101.5
Section 1. Purpose
This procedure sets forth the accessibility standards and courses of action the University will take to adhere to those standards as set forth in University Policy 1015 (Accessibility Policy).
Section 2. Definitions
- Access and/or accessibility: The quality of being reached, entered, obtained, used or easily understood in the same or equivalent degree as for others
- Disability: A physical or mental impairment that substantially limits one or more major life activities
- Electronic and Information Technology (EIT): EIT 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 term electronic and information technology includes, but is not limited to, the internet and internet websites, content delivered in digital form, electronic books and electronic books, reading systems, search engines and databases, learning management systems, classroom technology and multimedia, office equipment such as classroom podiums, copiers and fax machines. It also includes any equipment or interconnected system or subsystem of equipment that is used in the automatic acquisition, creation, storage, manipulation, management, movement, control, display, switching, interchange, transmission, or reception of data or information. This term includes telecommunication products (such as telephones), information kiosks, Automated Teller Machines (ATMs) transaction machines, computers, ancillary equipment, software, firmware and similar procedures, services (including support services), and related resources.
- Employees: Metropolitan State personnel, including all faculty, staff, administrators, teaching assistants, graduate assistants, and student employees
- Learning Environment: All physical, digital/online locations, contexts, and cultures in which students learn
- Natural Users: Individuals with a variety of disabilities, including but not limited to, blind, deaf, and fine motor skills impairments
- Physical Space (facility): Includes but is not limited to the places, including buildings, classrooms, common gathering spaces, access routes to and from, parking lots and ramps and grounds owned, leased or used by the University
- Product: A good or service that corresponds to a unique company offering (equipment, software package, consulting offering, etc.) that has typically gone through a formal process for development and market introduction and usually has a proprietary name (often with a trademark or ™ or ® symbol). i.e., a screwdriver
- Service: A system supplying a public need such as transport, communications, or utilities such as electricity and water, i.e., a carpenter
- Solution: The application of a product to solve a specific industry need or business problem. For example, when paired with a screw (another product) and a carpenter (a service), the screwdriver is part of a solution for building a home.
- Universal Design (UD), also known as "inclusive design" and "design for all": an approach to the design of products, places, policies and services that can meet the needs of as many people as possible throughout their lifetime, regardless of age, ability, or situation
- Vendors/Contractors: An individual or organization doing business with the Metropolitan State University
- Visitors/Community Members/Volunteers: Anyone not otherwise affiliated with the University that requires access to university information, spaces (physical and virtual), and/or events.
- Voluntary Product Accessibility Template (VPAT): A document which evaluates how accessible a particular product is according to the Section 508 Standards. It is a self-disclosing document produced by the vendor which details each aspect of the Section 508 requirements and how the product supports each criterion.
- Web Content Accessibility Guidelines (WCAG): Web Content Accessibility Guidelines (WCAG) is developed through the W3C process in cooperation with individuals and organizations around the world, with a goal of providing a single shared standard for web content accessibility that meets the needs of individuals, organizations, and governments internationally. The WCAG documents explain how to make web content more accessible to people with disabilities. Web “content” generally refers to the information in a web page or web application, including: (a) natural information such as text, images, and sounds, (b) code or markup that defines structure, presentation, etc.
Section 3. Procedure
A. Course Materials
1. Course Materials Standards
To ensure an accessible learning environment, faculty shall whenever possible:
- Adopt any prescribed accommodations/modifications in a fair, non-judgmental and timely manner.
- Maintain the student’s right to privacy concerning the disability and any accommodations.
- Include university adopted accessibility statements in their syllabi.
- Design their courses and course material in an accessible manner following guidelines and accessibility best practices such as Universal Design, including, but not limited to:
- Syllabi
- Texts
- Open Educational Resources
- Course supplements and platforms
- Assignments
- Handouts
- Tests and/or Quizzes
- All third-party media
2. Course Materials Support
- The Centers for Faculty Development and Accessibility Resources in collaboration with instructional designers and other specified access support staff will provide instruction and support for campus community members creating courses and instructional materials.
- Institutional Effectiveness and Technology will use only accessible electronic and information technology and coordinate support for campus units needing assistance with accessibility.
- Library and Information Services will provide support to faculty and students seeking accessible books, e-books, journals, videos and other course materials.
B. Marketing/Promotional Materials and Website
1. Marketing/Promotional Materials and Website Standards
- All marketing and promotional materials shall whenever possible be designed in an accessible manner and include approved accessibility statements. This requirement includes materials created by departments, colleges, student organizations, or other representatives of the University community.
- All web pages, websites and web-based software published, hosted or used (including remotely hosted sites and software) by the University shall meet the standards and guidelines outlined in the Web Content Accessibility Guidelines (WCAG 2.1). All pages will meet level AA guidelines with limited exceptions.
- All departments shall whenever possible comply with the web accessibility standards when creating web content, sites, and programs.
2. Marketing/Promotional Materials and Website Support
- Institutional Effectiveness and Technology will provide instruction and support for campus community members creating websites and content so that individuals who author web content can be trained according to the adopted standards.
- Institutional Effectiveness and Technology will ensure that any content management system and other web production or web object creation software proposed and supported by IET will be accessible and will produce accessible web pages in accordance with the WCAG 2.1 standards.
C. Procurement
1. Procurement Standards
Whenever possible, products purchased by Metropolitan State University shall be Section 508 compliant and meet or exceed WCAG 2.0 Level AA standards. All products and solutions are required to undergo an accessibility audit. Examples of software, hardware, and systems include, but are not limited to, learning and content management systems, library and email systems, and administrative management systems such as finance, registration and human resources, and all software, hardware and software services used for student services. Software includes freeware, shareware, desktop, enterprise, subscription, and remotely hosted options. Software that is accessed through a web-browser shall also be accessible. An accessibility audit shall occur prior to purchasing or implementation and may include, but is not limited to:
- the testing of products and solutions by natural users with disabilities,
- a letter of conformance (VPAT),
- testing and vendor demonstrations of accessibility.
All contracts and purchase orders for EIT shall normally include the following clause:
“Contractor acknowledges that no University funds may be expended for the purchase of information technology equipment and software for use by employees, program participants, or members of the public unless it provides all individuals with disabilities with access, including interactive use of the equipment and services, that is equivalent to that provided to individuals who are not disabled. In addition, Contractor acknowledges that such information technology equipment and software will provide equal and effective access to all individuals in accordance with federal and state laws and regulations, including, but not limited to the Americans with Disabilities Act of 1990 (ADA), Section 504 of the Rehabilitation Act of 1973, and Section 508 of the 1973 Rehabilitation Act.”
2. Procurement Supports
- Financial Management and Institutional Effectiveness and Technology shall whenever possible ensure that all software, hardware, local interfaces, modifications and electronic systems are accessible prior to purchase or acquisition.
- In collaboration with Center for Accessibility Resources, department managers/designees shall ensure that assistive technologies are available to any University community member who may need access.
3. Legacy Information and Communication Technology (ICT) Exception
Metro State University will adhere to the Section 508 E202.2 Legacy ICT General Exception which indicates: Any component or portion of existing ICT that complies with an earlier standard issued pursuant to Section 508 of the Rehabilitation Act of 1973 as amended, and that has not been altered on or after January 18, 2018, shall not be required to be modified to conform to the revised 508 standards.
D. Contract Renewal
Contract Renewal Standards
Upon renewal of existing contracts, an accessibility audit is required in the same manner as procurement. See Section 3.C.1: Procurement Standards. Part 3.C.3: Legacy ICT exceptions also apply to contract renewal.
E. Group Gatherings and Events
1. Group Gathering and Event Standards
- Sound-assistive technology (for example, microphones) shall normally be used at all trainings, meetings, classes, and/or events with 20 or more people.
- Events and gatherings taking place in the Auditorium, Library 302 (Ecolab), Library 301, Great Hall, Student Center 101, and/or being webcast shall also have real-time captioning (CART).
- Virtual gatherings shall normally have live captions using the following guidelines:
- Gatherings/meetings with fewer than 35 participants with no request for accommodation shall use artificial intelligence (AI) generated captions.
- Gatherings/meetings that will be recorded for future access by unknown users shall either have professional CART services or if using AI for captioning the captions must be edited and verified prior to the video being posted for viewing.
- All visual components of presentations, such as images used in power point presentations, shall normally be audio described by the presenter or third-party audio description professional.
2. Group Gathering and Event Supports
- Center for Accessibility Resources will facilitate requests for CART/Interpreters and/or alternative format print materials when made at least one week in advance.
- Institutional Effectiveness and Technology will facilitate all electronic equipment needs and support services.
- Operations/Facilities Management will coordinate with CAR/ITS to ensure access needs are appropriately addressed at that time of room reservation.
F. Design, Planning and Implementation
Design, Planning and Implementation Standards
All University spaces, whether rented or owned, shall meet or exceed current ADA Standards for Accessible Design and Minnesota Building Code MN statutes 16B.59-16B.75 and 326B]. The university will conduct a comprehensive evaluation of the Americans with Disabilities Act accessibility compliance of Title II facilities, programs, services, and communications. The university will also create a complete transition plan based on the results of the evaluation.
Design, Planning and Implementation Supports
All university personnel involved in design, planning and implementation of physical spaces and wayfinding shall collaborate with the appropriate points of contact identified in this policy.
G. Employees
Employee Standards
To ensure an accessible working environment, employees shall:
- Follow any adopted accommodations/modifications in a fair, non-judgmental and timely manner.
- Maintain the individual’s right to privacy concerning the disability and any accommodations.
- Use at least 12 pt. Sans Serif fonts for print and digital communications.
- Design their work materials in an accessible manner following guidelines and accessibility best practices such as Universal Design, including, but not limited to:
- Emails
- Training materials
- Meeting materials
- Flyers
- Timesheets
- Forms
2. Employee Supports
- The Centers for Faculty Development and Accessibility Resources in collaboration with instructional designers and other specified access support staff will provide instruction and support for campus community members creating information and other university materials.
- Institutional Effectiveness and Technology will use only accessible electronic and information technology and coordinate support for campus units needing assistance with accessibility.
- Human Resources and/or the designated ADA coordinator will provide access to instructional materials and other training opportunities to support campus community member’s professional development related to but not limited to creation of accessible documents and other materials.
Section 4. Authority
This procedure is issued pursuant to the authority granted the Americans with Disability Act of 1990 (ADA); Sections 504 and 508 of the Rehabilitation Act; WCAG 2.0 Level AA; MN Statutes 16E.03; MN Statutes 363A.42; MN Statutes 363A.43; State of Minnesota Accessibility Standard; Minnesota Human Rights Act MN Statute 363A; the 21st Century Communications and Accessibility Act (CVAA) Pub. L. 111-260; and Minnesota State Policy 1B.4 Access and Accommodation for Individuals with Disabilities; The Architectural Barriers Act of 1968. Other authority may also apply.
Section 5. Effective Date
This University procedure shall become effective upon signature by the President and shall remain in effect until modified or expressly revoked.
Section 6. Responsibility
The President or their designee is responsible for implementation of this procedure.
Section 7. Review
This procedure shall be reviewed on a biennial basis or as needed.
Section 8. Signature
Issued on this date: August 31, 2023
Virginia “Ginny” Arthur, JD
President
Date of Implementation: 09/06/23