Communicating Digital Accessibility Requirements
When procuring digital materials and technologies from a publisher or vendor, it's essential that you and your team communicate accessibility requirements to ensure federal statutes and regulations are met. Your team may also choose to provide accessibility guidance to supplement the accessibility requirement language. This guidance includes a rationale for the requirements, best practices for manual accessibility testing of products, and information on how the vendor can optimize and communicate their product's accessibility in order to assist you in making purchasing decisions.
Please use and adapt this sample language in RFPs, Instructional Materials Adoption, and in contracts. If there is a requirement to also submit files to the National Instructional Materials Access Center (NIMAC), see NIMAS in Purchase Orders and Contracts.
Sample Language for Accessibility Requirements
[Agency name] requires digital materials and technologies to be accessible to students, employees, and community members with disabilities. Digital materials and technologies should conform to the standards for accessibility set forth in Section 508 of the Rehabilitation Act of 1973, as amended (29 U.S.C. § 794d), and its implementing regulations (36 C.F.R. § 1194). The Revised Section 508 incorporates the Web Content Accessibility Guidelines (WCAG) by reference. Web and non-web content (including websites and documents) is required to conform to the most current version of WCAG at level AA in order to meet Section 508 requirements. Beyond Section 508, additional specifications are defined according to the type of material or the delivery format. Please refer to the attached guidance for additional information on those specifications.
Conformance to the specified standards can be documented through the submission of an up-to-date, complete, and accurate Accessibility Conformance Report (ACR). The ACR should be based on the latest version of the Voluntary Product Accessibility Template (VPAT®), which can be obtained from the Information Technology Industry Council (ITI) website.
The ACR’s Remarks and Explanations for each criterion should include an explanation of not only how the criterion is supported, but also how that support was validated and tested. For any criterion that is not fully supported, an explanation of the barriers created by the criterion not being supported should also be included. If the criterion does not apply, an explanation should be provided.
In addition to a current and accurate ACR, priority will be given to product submissions whose conformance is documented through the completion of an independent, third-party audit that does not rely solely on an automated scan but also includes manual testing. If the ACR is completed by a third party and includes verification of manual testing, that ACR can serve as the independent audit.
Updated documentation, including an assurance of continued compliance, should be provided on an annual basis, or whenever a significant product update takes place. Any questions about documentation requirements should be directed to [accessibility team] at [email address and telephone number].
Referenced Standards and Specifications
Specifications by Material Type or Delivery Format
These additional specifications are defined according to the type of material or the delivery format. They should be included with the sample language to provide helpful guidance to vendors based on their products.
Web-based materials should conform to the most current applicable versions of the following standards:
- The Web Content Accessibility Guidelines (WCAG) at level AA
- The Web Accessibility Initiative (WAI) Accessible Rich Internet Applications (ARIA) specification
- The MathML specification for digital mathematical notation
Publications and Documents
Portable Document Format (PDF) documents should be tagged and conform to PDF/UA (PDF/Universal Accessibility).
EPUB publications should conform to the most current version of the EPUB specification. They should also conform to the EPUB Accessibility specification. A third-party certification can help vendors confirm that their publications meet these specifications. This certification should be noted in the publication’s metadata along with other required metadata needed to determine how the publication meets specific learner needs. EPUB publications should also conform to the most current ARIA specification and use MathML for digital mathematical notation.
Software and Apps
For optimal interoperability, it is recommended that software and mobile applications (apps) conform to the latest version of the User Agent Accessibility Guidelines (UAAG). If the software or app can be used to author content, the Authoring Tool Accessibility Guidelines (ATAG) may also apply.
This section includes information to help publishers and vendors better understand the requirements in the previous section and communicate how they are meeting those requirements in their documentation submitted to the purchasing agency.
Rationale for Accessibility Requirements
The Office for Civil Rights at the U.S. Department of Education defines “accessible” to mean that a person with a disability is afforded the opportunity to acquire the same information, engage in the same interactions, and enjoy the same services in an equally effective, equally integrated manner, and with substantially equivalent ease of use as a person without a disability 1.
Accessibility applies to both materials (the content or information to be learned) and technology (the hardware or software that delivers material). Accessible materials are designed or enhanced in a way that makes them usable by the widest possible range of learner variability, regardless of format (print, digital, graphical, audio, video) 2. Accessible technologies are usable by people with a wide range of abilities and disabilities and are directly usable without assistive technology (AT) or usable with it 3. Individuals with disabilities use a range of AT for perceiving and physically interacting with technologies.
The use of accessible educational materials and accessible technologies strengthens opportunities for learners to experience independence, participation, and progress. When learners have difficulty using educational materials and technologies due to a lack of accessibility, they are at risk of falling behind their peers. Timely access to accessible materials and technologies for learners with disabilities results in the same opportunities to fully and independently participate and make progress in the curriculum.
Best Practices for Manual Testing
A robust process for determining the accessibility of digital materials and technologies should include the following manual testing:
- Manual checks of a representative sample of pages to determine that alternative text on images and graphs are appropriate for the instructional context in which the materials will be used.
- Manual checks of a representative sample of pages with tables, forms, dynamic content and other applications that are known to present accessibility challenges.
- Manual checks of any video content to ensure the inclusion of high-quality closed captions.
- Testing to determine whether page content and controls can be accessed, operated, and reset when necessary using only a keyboard.
- Testing with screen-reader software.
- Documentation of the experience of users with disabilities, including basic information about the assistive technology used.
Optimizing & Communicating Product Accessibility
There are certain actions vendors can take to optimize and communicate product accessibility. They include:
- Complete the free training, Section 508: What Is It and Why Is It Important to You?, available at dhs.gov.
- Review and understand the latest version of the Web Content Accessibility Guidelines (WCAG), available from the World Wide Web Consortium (W3C).
- Ensure staff tasked with completing the Accessibility Conformance Report are not only familiar with the product’s key features, but are also trained in accessibility best practices.
- Identify product accessibility requirements at the beginning stage of design and integrate those requirements throughout the development cycle.
- Include iterations of accessibility testing throughout the development workflow in order to identify barriers as early as possible.
- Enlist individuals who rely on assistive technologies in their daily lives to participate in product testing and provide authentic feedback about accessibility support.
- Prepare a product accessibility statement that clearly states the standards addressed and the level of conformance for each, along with information about supported accessibility features. This product accessibility statement should also discuss where and how accessibility is addressed in the product development process.
- Provide a single point of contact for addressing accessibility questions in the accessibility statement, and make sure those experiencing accessibility challenges have a variety of ways to contact the product’s accessibility team.
- Obtain certification under the Department of Homeland Security Trusted Tester Process and Certification Program and include notice of that certification in the product accessibility statement.
1Joint “Dear Colleague” Letter: Electronic Book Readers (June 29, 2010)
2As used in the 84.327Z priority, ‘‘accessible educational materials’’ means print- and technology-based educational materials, including printed and electronic textbooks and related core materials that are required by SEAs and LEAs for use by all students, produced or rendered in accessible media, written and published primarily for use in early learning programs, elementary, or secondary schools to support teaching and learning.
3As used in the 84.327Z priority, ‘‘technology’’ means any equipment or interconnected system or subsystem for which the principal function is the creation, conversion, duplication, movement, control, display, switching, interchange, transmission, reception, or broadcast of data or information. It includes, but is not limited to, electronic content; telecommunication products; computers and ancillary equipment; software; information kiosks; transaction machines; videos; information technology services; and multifunction office machines that copy, scan, and fax documents.