Only by collaborating and cooperating can higher education build the ecosystem needed to provide accessible IT to all users.
In Washington State, recent significant updates to state and college system policies addressing technology accessibility have required community colleges to update processes and practices for procuring, evaluating, and testing the technology tools they depend on. Building capacity and sharing information about technology accessibility, at both the system level and at local colleges, has become a key conversation for the Washington Community and Technical College system. As is often the case, policy has preceded the identification and application of the resources necessary to address their requirements.
Making Accessibility a Priority
A previous EDUCAUSE Review article ("When Accessibility Doesn't Make It into the EDUCAUSE Top 10: Turn It Up to 11") highlighted the unique needs of community college populations and the resource constraints faced by colleges attempting to address these issues. Even with system-level support and emergent efforts to share information across our system, no college currently has the ability to "solve" accessibility across all of its business functions. Developing the correct priorities for allocating scarce resources for accessibility is a high-stakes activity. In our student-focused institutions, the accessibility of teaching and learning tools has emerged as the de facto priority of most colleges' efforts.
Prioritizing the accessibility of teaching and learning technologies over the other mission-critical technologies is not, of course, unique to community and technical colleges—although accessibility did not make it into the EDUCAUSE Top 10 IT Issues, it was second in this year's EDUCAUSE Key Issues in Teaching and Learning.
However, the student's technology-mediated experience at our institutions extends outside the classroom. Administrative and communication tools, such as registration, payment systems, and advising, are equally important as students move from admission to graduation. Additionally, we must not overlook the needs of the employees who manage and operate all of our campus systems, from faculty managing textbook websites to system administrators operating our lab scheduling software. In tangible ways, any of these systems and all the people who touch them are deeply integral to the teaching and learning experience, and our accessibility policy applies to all of them. Many of these processes are supported at the enterprise level, in the centralized enterprise resource planning (ERP) system.
Adding Requirements After the Fact
In the Washington Community and Technical Colleges, we are currently undergoing a system-wide, multiyear implementation of a new ERP shared by all 34 colleges. Recent efforts to improve the accessibility of our technology tools came long after we had written the RFP requirements and chosen a product. Local policy declaring the standards for accessibility that we are now attempting to meet were not in play in the procurement of our core technology platform.
Our preliminary assessments strongly suggest that this new system, which will not be fully implemented for several years, will not meet our baseline, policy-mandated accessibility standards. We are in that place everyone fears: out of time, scrambling to work closely with employees with disabilities to ensure their workflow is not unreasonably impacted any more than any other employee having to learn a new platform and process, and ensuring that the student experience is accessible for all.
So how to proceed? Even as a statewide system, we are often only a medium-sized fish in a very large pond, with little claim on the product development priorities of a global corporation. More than that, we were part of the problem, albeit unknowingly—our own requirements did not fully anticipate our current needs. Given this, we have little leverage with the vendor in contractual terms. As our implementation project moves forward, we find ourselves in the unenviable and risky position of renegotiating scope, proposing allocating additional resources, and seeking additional products. The risks of deploying a product that is not fully accessible to all users falls directly to us.
Vendors find it difficult to prioritize accessibility amid the myriad new features, old issues, and necessary updates that characterize large systems. In the worst case, vendors deny the problem exists, or point to "shifting standards." At best, they refer clients to additional vendors who provide bolt-on products to address accessibility issues. Without proper attention to accessibility in the procurement and negotiation phases, expenses and application of human resources required to identify, evaluate, and implement solutions for accessibility issues end up falling on institutions instead of the vendor. Vendors advertising or promising accessibility Band-Aids for nonconforming products are, of course, aware of this and as such are unwilling in some cases to verify the compliance of their own products.
Legal settlements and the Section 508 Refresh have coalesced around WCAG 2.0 AA as the acceptable standard for accessibility. However, lack of consistency within the higher education community around the evaluation and interpretation of accessibility standards, combined with wide variation in risk assessment and timelines for compliance in institutions, creates a chaotic environment for those seeking to understand and prioritize modifications to their products. The legal environment has become confusing too. Institutions are concerned about sharing test results, lest they face legal action from vendors deemed noncompliant. What emerges is a policy environment where no one benefits—neither vendors nor their clients, and certainly not students and staff required to use these products.
Insisting on Accountability
While we develop individualized and sometimes divergent approaches to compliance, one thing we agree on is that as a community, we need to put more pressure on vendors, especially large vendors, to make their products accessible. While any one customer may be in the middle of a multiyear contract, at any given time some customer is renewing their contract. If we all push technology providers to be accountable for accessibility each time we renew an agreement, we will slowly develop the expectations and shared understanding that will ultimately benefit both vendors and clients. That consistency will improve our ability to hold vendors accountable for testing and verifying their own products' accessibility.
As we dive deeper into possible solutions to seek some sense of hope while we work through our ERP challenges, the beginnings of an IT accessibility ecosystem are there, but its structure is unclear. Conversations are taking shape, or morphing between shapes over the years, but nothing solid has emerged or promises to emerge soon.
Perhaps one launching point is the use of the voluntary product accessibility template (VPAT). Currently, some institutions require vendors to provide a VPAT; others, citing a lack of a reliability, want nothing to do with them; and some have developed an alternative questionnaire altogether. Could the VPAT be more valuable if our requirements were more aligned? Would vendors take them more seriously if all institutions of higher education required them as a tool to start/open the conversation? Could we as higher education come together around a way to improve the quality of responses and to use them to start discussions around accessibility instead of being the end point?
The question we pose to the higher education community is this: How can the IT accessibility ecosystem develop a stronger voice when we're battling these issues in isolation? And where can we make sure our call for access is not a collection of disorienting voices singing different choruses but a harmonized melody (à la Twisted Sister's "We're Not Gonna Take It")? Not only do vendors need to hear us, but their stockholders need to feel it. Has that ship already sailed, given that many institutions have had to learn quickly from mistakes and, in isolation, develop procurement policies just in time for the next contract? Can higher education act in concert, with colleges and universities of all types and sizes engaging in community-wide collaboration on accessibility?
Jess Thompson is Program Administrator, Accessible Technology Initiatives, at the Washington State Board for Community and Technical Colleges.
Tim Wrye is Executive Director of IT Services and CIO at Highline College.
Mark Jenkins is Director, eLearning and Open Education, at the Washington State Board for Community and Technical Colleges.
Christy Campbell is ctcLink Project Director at the Washington State Board for Community and Technical Colleges.
© 2018 Jess Thompson, Tim Wrye, Mark Jenkins, and Christy Campbell. The text of this work is licensed under a Creative Commons BY 4.0 International License.