Digital Accessibility Procedure | Accessibility & Accommodations

This Digital Accessibility Procedure effectuates the standards for the accessibility of electronic information and technology (EIT) as established in the Digital Accessibility Policy (referred to as “Policy”). The Policy recognizes that every person who creates, purchases, and or facilitates the use of EIT plays a role in ensuring accessibility for persons with disabilities. The Policy and procedure descended from Stony Brook University's Digital Accessibility Plan, enabling the implementation of the plan's objectives. Schools/colleges, departments, and divisions (collectively referred to as “areas”) have agency over and responsibility for how they will best meet the Policy’s requirements, and should use this procedure to support their efforts. Areas are encouraged to contact OEA for assistance in understanding their obligations related to compliance.

I. Definitions

Please refer to the Digital Accessibility Policy (Policy 800) for definitions of the terms used in this Document.

II. Standards for Measuring Accessibility

Stony Brook University has adopted and incorporated the following standards by which we will measure accessibility conformance:

Web Content Accessibility Guidelines (WCAG) 2.1 at level Double-A for all Web-based applications, web content, and digital documents
Revised Section 508 Standards for all Software and Hardware EIT.

Initial implementation plans and annual progress reports are designed to allow the University to continuously improve and progress toward full inclusion for persons with disabilities in our digital environment. The key focus is on identifying areas for improvement across the University as a whole. As set forth more fully below, to best support this focus on continuous improvement, all areas will engage in constant or regular progress monitoring and assessment through initial area implementation plans and annual progress reports. In addition, an internal review process is included as a more robust check on institutional compliance with the policy.

I. Initial Area Implementation Plans

All areas are required to create a 4-year initial implementation plan following the adoption of the University’s Digital Accessibility Policy which must be submitted to OEA by December 1, 2022. These plans allow areas to communicate individual decisions and strategies about how to best meet the requirements of the Policy, while providing OEA with a roadmap against which to measure annual progress.

Initial implementation plans ask for the following information:

Categorization of an area’s existing EIT as Fundamental or Secondary
An implementation timeline with compliance targets and actions
Area-specific supports and structures
Area digital Accessibility Liaisons. (larger areas may have multiple liaisons).

II. Digital Accessibility Liaisons

As part of their initial implementation plan, all areas must appoint one or more Digital Accessibility Liaisons. Digital Accessibility Liaisons will assist in developing and continuously improving the digital accessibility program throughout their area. Digital Accessibility Liaisons should be familiar with the EIT, processes, procedures, and tools used throughout the area when creating digital content. Liaisons will receive additional digital accessibility requirements, processes, and resources training. They will also provide a channel for the EIT coordinator to receive continuous feedback on the successes and necessary improvements as our digital accessibility program evolves.

III. Annual Progress Reports

All areas must submit an Annual Digital Accessibility Progress Report to OEA beginning July 1, 2023. The Progress report provides an opportunity for areas to internally monitor and report on the previous year’s accessibility improvements, successful accessibility processes and supports, and response to complaints.

OEA will review all progress reports to ensure each area is making adequate progress towards accessibility and policy compliance. They also allow the University to assess its institutional progress year over year. Outcomes may lead to additional support and intervention. In compliance with SUNY EIT policy, an institutional report will also be generated, drawing from the trends exhibited across all areas to assess overall University progress.

IV. Internal Reviews

OEA, and key partners (as appropriate), may conduct an internal review of areas as needed. OEA will select areas based on accessibility progress, the number of accessibility inquiries received, timelines of issue resolution, website traffic, website size, and the amount of online course content. This process will provide a more robust check on institutional compliance with the Policy.

The internal review process will utilize 3 main mechanisms:

Automated testing deep dive – During the internal review process, scans will be run to identify areas on identified websites that do not meet accessibility standards, and historical data will be reviewed to understand growth and accessibility updates that have been made to the websites thus far.
Manual testing sample – Automated testing is only able to identify roughly forty percent of accessibility issues. Manual testing will be conducted to reveal additional accessibility barriers on identified websites.
Process review – A review will be conducted of the processes and supports in place within the area under review. The purpose of this process review is to identify systemic areas that could be improved to enhance EIT accessibility.

The Internal Review process will conclude with a report and recommendations provided to the area. Subsequent Implementation Plans should incorporate and address the Internal Review Report and Recommendations.

Implementing accessibility across a large organization cannot be completed at once, and must be prioritized based on the likelihood of a barrier preventing participation for a person with a disability. Stony Brook University’s recommended priority order for accessibility compliance follows:

New EIT: Any EIT that is acquired, purchased, or renewed after July 1 2022. New EIT must be in compliance with the applicable standards and guidelines described in this procedure (effective July 1, 2022), or satisfy an exception.
Any EIT that is identified by a person with a disability which poses a barrier to their participation in a University program or service. If a barrier is identified by a person with a disability, areas must work to implement their equally effective alternative access plan (EAAP). If no EAAP is in place, the area must respond to the person reporting the barrier within ten (10) days and notify OEA.
Fundamental EIT: Any EIT that is either public facing, or significant and used in the normal course of operations at the University to support teaching, research, or administrative functions, as determined by the relevant area in partnership with OEA. Fundamental EIT must conform with the applicable standards and guidelines described in this procedure as soon as possible, but no later than July 1, 2024, or satisfy an exception, except as noted below:

Fundamental course content that existed prior to the effective date of the Policy must conform with the applicable standards and guidelines described in this procedure as soon as possible, but no later than July 1, 2025.

Secondary EIT: Any EIT acquired, created, purchased, or renewed before the Policy’s effective date and is not Fundamental EIT. Secondary EIT must be updated to conform with the applicable standards and guidelines described in this procedure, or the content must otherwise be made available in an equally effective accessible format, and in a timely manner, to any individual requesting access. The area responsible for its maintenance must make it compliant with the applicable standards or provide an equally effective accommodation.

All websites, Digital content, and media must conform to WCAG 2.1 AA unless an exception has been approved.

I. Websites

All University webpages (whether hosted in the CMS or on other platforms) that are either created or undergo significant modifications after July 1, 2022, must conform to the Web Content Accessibility Guidelines 2.1 at level AA. All content creators must follow the Accessibility Checklist when creating content for Stony Brook University |Websites.

A link to the University’s accessibility barrier report website must be placed on every University webpage. For websites on the University CMS OU Campus, this link is already present in the footer of the site. Site owners must undertake accessibility reviews of their websites at regular intervals and no less than each time major modifications are made.

Archived Web Content

Web content that is kept online exclusively for archival purposes does not need to be brought into compliance with the policy. Archived content must conform to the following:

Is at a minimum five years old upon the effective date of the policy
Is maintained exclusively for reference, research, or recordkeeping;
Is not altered or updated after the date of archiving;
Is organized and stored in a dedicated area or areas clearly identified as being archived.

If an area receives a request to make archived content accessible for a person with a disability, the area will be responsible for providing an equally effective alternative format of the content.

II. Digital Content

All content must be created in an accessible format to the greatest extent possible. It is never safe to assume that the material does not need to be accessible since content creators may not know the accessibility requirements of their audience. Digital content includes but is not limited to documents, presentations, electronic messages, spreadsheets etc.

All content creators should:

Review the training opportunities available through OEA and Partner Offices and enroll in training that aligns with the content they create.
Follow the best practices outlined in the Accessibility Checklist.
Verify that their content conforms with the Digital Content Accessibility Standards

III. Media

Videos

All videos that are posted on public-facing areas of the Stony Brook website must have captions that:

Accurately convey all spoken content at a minimum rate of 98%
Have no more than 3 seconds delay from the audio
Include speaker identification
Include punctuation and grammar
Include sounds and non-verbal information

Videos posted on public-facing areas of the Stony Brook website must contain all informational content within the narrative of the video. Videos that present informational content on screen that is not addressed in the narrative must have an audio description track describing the on-screen information.

Live Stream Presentations

Live stream presentations that are open to the public and are expected to have an audience of more than 1000 persons must be captioned. Captions must:

Accurately convey all spoken content at a minimum rate of 98%
Have no more than 3 seconds delay from the audio
Include speaker identification
Include punctuation and grammar
Include sounds and non-verbal information

Live stream presentations That are open to the public and are expected to have an audience of less than 1000 persons may use automated captions to provide access unless the event organizer receives a request for access by a person with a disability. Automated captions are not sufficiently accurate to provide accessibility for a person with a disability.
Live Stream presentations that are recorded and that will be hosted on a University website or social media account must be captioned. Captions must:

Accurately convey all spoken content at a minimum rate of98%
Have no more than 3 seconds delay from the audio
Include speaker identification
Include punctuation and grammar
Include sounds and non-verbal information

Audio

All audio only content posted to the Stony Brook website must be accompanied by a transcript that:

Accurately conveys all spoken content
Includes speaker identification
Includes punctuation and grammar
Includes sounds and non-verbal information

Social Media

To meet the requirements of the policy, this procedure incorporates the University social media guidelines.

As set forth in the Policy, all procurement of EIT goods and services or purchasing contracts with EIT vendors must reflect the University's commitment to accessibility. To implement this directive, all Request for Proposals (RFPs) and contracts must include the following:

I. Required Contractual Language

Contractual language stipulating the need for conformance with WCAG 2.1 should be included in all EIT contracts. Even if the product is currently accessible, the contract must include language that assures continued accessibility as the product is updated. Contractual language approved by the Office of General Counsel is available from Procurement.

II. Vendor conformance Documentation

When purchasing or renewing EIT, the purchasing area must request written evidence from the vendor that their product or service conforms to each of the WCAG 2.1, or the most current version of WCAG, Level AA criteria. Vendors may do so by submitting a VPAT® in which they address each of the WCAG 2.1, or the most current version of WCAG, criteria. The minimum acceptable version of the VPAT is Version 2.4 (February 2020), available from the Information Technology Industry Council. The most reliable conformance documentation is completed by companies that specialize in evaluating digital accessibility rather than by the vendor themselves.

III. Conformance Determination

As discussed above, it is essential that areas looking to purchase or implement EIT incorporate accessibility into their selection criteria as early as possible. To assist the campus in engaging the appropriate partners and before requests are entered into the Wolfmart system, the information required to evaluate accessibility will be collected through an online form.

Once completed, the responses to this form will be evaluated by OEA (and Information security when applicable). EIT that is determined to be high impact will undergo a review by the EIT Accessibility Review Committee. The committee is composed of key University partners who will determine:

Whether the requested Products or services meet SBU’s adopted Accessibility standards.
Whether products and services that do not meet the standards have an appropriate Equally effective alternative access plan in place.
Whether vendors are adhering to their accessibility roadmap and making accessibility improvements to approved products and services.

For those products/services that meet some but not all WCAG 2.1, or the most current version of WCAG, criteria, the university requires that a roadmap for compliance be included in the contract at no charge to the university. Vendors should at a minimum be willing to make a commitment to address their accessibility deficiencies in a timely manner.

If more than one equivalent product/service is available, it is advisable to choose the most accessible product. However, the most accessible choice may not align with other dominant selection criteria, and the less accessible product may be chosen. If that occurs, an exception must be sought.

IV. Exceptions

When purchasing, implementing or hosting EIT or Digital content, exceptions may be granted if any of the following circumstances are demonstrated.

Where conformance is not technically possible or may require extraordinary measures due to the nature or intended use of the information resource, application or service. Lack of sufficient funding for any particular area of the University would not be considered as the sole reason for an exception.
Where conformance would result in a fundamental alteration of the information resource, application, or service, and not satisfy the original intent.
Where, in the case that information resources, applications and services that are procured through third party vendors or contractors; and that no alternative accessible products are available from other third-party vendors or contractors, procurement may be made of a non-conforming product.
Where the product is not currently in conformance, but efforts are underway to fix the defects by a defined date.

To demonstrate that any of those circumstances exist, purchasers and owners of EIT must complete the EIT Exceptions Form and submit it to OEA for review. The form requests the following information:

Description of software, hardware or third-party vendor product and intended use.
Completed Vendor Compliance Documentation.
Explanation about why accessibility compliance is not possible.
Timeline for when vendor intends to address shortcomings outlined in compliance documentation. Timelines should be reflective of the length of the contract and the scope of the accessibility issues.
A plan for how equivalent alternate access will be provided, when needed, which:

Outlines how the area will make information/services attained through this technology available to people with disabilities in a timely and an equally effective alternate format;
Identifies the individual responsible for providing the accommodation.
Identifies the areas available resources to ensure implementation of the proposed Equally effective alternative access plan.

Signature from area leadership (e.g.: director, or Dean, or VP, etc.)

OEA and/or the EIT Accessibility Review Committee will examine all exception requests and make final determinations. Written decisions and rationale will be shared with the requester. If the exception is granted, areas may move forward with purchasing the EIT.

All exceptions contain an expiration date. When an exception has expired, owners of the EIT must provide evidence that the product/service is now accessible or request an additional exception.

I. Complaints

A link to the University’saccessibility barrier report website must be placed on every University webpage. For websites on the University CMS OU Campus, this link is already present in the footer of the site. The page provides the digital accessibility email address as well as the form to report accessibility barriers.

All comments, suggestions, and complaints about accessibility issues sent to Digital_accessibility@stonybrook.edu will be reviewed by the EIT Coordinator, communicated to the relevant area, and addressed promptly by the area in consultation with OEA.

Reports made through the online form will also be reviewed and documented by OEA and communicated to the relevant area for prompt resolution. Any accessibility complaints communicated directly to an area must be forwarded to Digital_accessibility@stonybrook.edu by the Digital Accessibility Liaison within two business days of receipt. Some complaints about inaccessible EIT can be resolved easily through internal remediation, while others will require more substantial efforts and sometimes require the coordination of outside vendors.

If an exception has already been granted, the Equally effective alternative access plan should be implemented. If an exception had not previously been requested, the area must:

Correct the identified accessibility issues in a timely fashion; or
Identify a reasonable accommodation that provides equivalent access in a timely fashion and then submit an exception request.

The area must report details of the resolution back to OEA.

II. Remedies for Noncompliance

Areas that fail to respond to a complaint within 10 business days will have the complaint forwarded to the respective Vice President or Dean for a response. If after 30 days, the barrier persists, and an EEAAP is not in place, OEA may coordinate with senior leadership and stakeholders to limit or remove access to the inaccessible EIT until the area is able to remediate the EIT.