Exceptions and Equally Effective Access Accommodation Plan (EEAAP)

What if the product/service I want to use is not accessible?

If an exception is required, the college or requestee must document the process by which the college will ensure to provide effective access, with substantially equivalent ease of use, to digital information and digital services for eligible individuals in a timely manner.

Exceptions must contain the following elements to be considered:

  1. Contact information the following parties:
    • The individual making the request (staff member or department).
    • The requesting unit (college).
    • The staff responsible for oversight and administration of the Equally Effective Access Accommodation Plan (EEAAP). This staff (IT Procurement Accessibility Team) consists of four members: Dave Ferreira Sarah Ellis, the Charter Oak CIO and a staff member TBD.
  2. Rationale
    • The requesting unit/individual must document how this request fits into one or more of the following categories:
      • Compliance is not technically possible or feasible given current technology.
      • The digital information or digital service is used by a limited audience, when the audience is known, and whose needs can be accounted for in advance.
      • For third party, vendor delivered products, no accessible alternative for the digital information or digital service exists.
      • The EIT that best meets the college or university needs is not the most accessible option, when other more accessible options have been considered.
      • Making the Digital Information or Digital Service accessible would require extraordinary measures that constitute an undue burden to the university.
      • Note: For the purposes of determining if an undue burden exists, CSCU is considered to be a single entity, and thus a burden would be analyzed according to the impact to the system as a whole and not to the unit requesting the exception.
  3. Equally Effective Access Accommodation Plan (EEAAP)
    • An Equally Effective Alternate Access Plan (EEAAP) is a valuable resource that an institution can use if it is necessary to buy, develop, or use a technology that is not fully accessible. This plan describes how to provide alternate access to the same information or services offered by a less-than-accessible technology. Having an EEAAP in place for technologies that are not fully accessible will help ensure that all students will have fair and equal access in a timely manner as required by law.
    • This plan should address how access barriers in the digital information or digital service will be mitigated, and any benefits or opportunities afforded by the digital information or digital service will be provided, in a timely manner for eligible individuals who are unable to effectively use or interact with the digital information or digital service.
    • Depending on the nature of the digital information or digital service, examples of an EEAAP might include:
      • Providing an alternative that effectively provides an equivalent result, e.g., an alternative software that performs the same or similar function.
      • Providing assistance to the eligible individual either in-person or over the phone.
      • Providing the digital information in a format that meets our accessibility standards.

Communication Plan:

The requesting unit (college) must document a plan to ensure eligible individuals are made aware of the availability of the EEAAP, and the steps needed to request access, if applicable. These communications should be readily accessible in the same places that any other general communication regarding access to the digital information or service are available.

Compliance Plan:

The requesting unit (college) should document plans to bring the digital information/service into compliance with the CSCU Accessibility Policy Standards.

This plan can include:

  • Contract language obligating the vendor of third-party digital information or services to bring their software or content into compliance within a specified time period.
  • For internally developed digital information/services, a timeline for making the EIT accessible and compliant with CSCU Accessibility Policy Standards.
  • Detailed collaboration with vendors to bring their digital information/service into compliance.
  • Advocacy for accessibility by contributing to open-source products and services.

The requesting unit (college) must have a compliance plan if the third party fails to make their digital information/service accessible (if the information/service is not internally developed). Some examples are:

  • Contract termination
  • Financial penalties
  • Selection of an alternative product

Accessible Alternative Justification

The requesting unit (college) must document if the purchasing process evaluated other alternatives that were more accessible. If so, the requesting unit must explain what accessibility reasons required the less accessible option. If accessible alternatives did not exist at the time of purchase or use, the requesting unit must document their plan to ensure that a search for more accessible alternatives is conducted when the contract or exception expires.