Procurement FAQs

Background and requirements

ACR/VPAT and the ACE Tool

Digital accessibility compliance reviews

Digital Resource Accessibility exception requests

Potential procurement scenarios

Moving forward

Background and requirements

What is Digital Resource accessibility?

Digital Resource accessibility is the set of strategies, guidelines, and resources that make Digital Resources accessible to everyone. It involves developing policies and implementing processes to ensure the functional use of Digital Resources by people of all abilities in an independent manner.

What areas of Digital Resource compliance are covered by state and federal regulations?

Texas A&M Standard Administrative Procedure 29.01.04.M0.02 supports state and federal laws that govern Digital Resources which include, but are not limited to:

  • Software applications and operating systems
  • Websites, including public-facing and intranet
  • Telecommunications products
  • Video and Multimedia products
  • Hardware, including desktop computers, laptops, and closed products such as copiers, printers, kiosks, digital signage, etc.
  • Functional performance criteria described in 1 TAC §213.35
  • Information, documentation, and support described in 1 TAC §213.36
  • Emerging technologies

Is procurement of accessible Digital Resources required?

Yes, federal and state laws require institutions of higher learning to procure accessible Digital Resources. In other words, Digital Resources must comply with WCAG 2.1 Level AA criteria in accordance with ADA Title II and any other associated state and federal laws.

What laws are the basis for procuring accessible Digital Resources?

Texas A&M employees and affiliates must comply with state and federal digital accessibility requirements, including:

  • Texas Administrative Code, Title 1, Chapters 206 (TAC 206) and 213 (TAC 213)
  • Texas Government Code (TGC) Chapter 2054 Subchapters M and S
  • Section 504 of the Rehabilitation Act
  • Americans with Disabilities Act (ADA) Title II

The following specific criteria and requirements are incorporated into these policies:

  • “Functional Performance Criteria” described in 1 TAC §213.35
  • “Minimal impact on access” as described in ADA Title II §35.205
  • “Conforming Alternate Versions” as described in ADA Title II §35.202

Why is procurement of accessible Digital Resources so important?

Ensuring the procurement of accessible Digital Resources is the first step to enabling everyone to perceive, understand, navigate and interact with useful technologies. Specifically:

  • It makes sense. As an institution, it allows us to reach more individuals with our teaching and learning initiatives, with our research findings and with the real-life applications associated with each of them.
  • It's required by law. As a state-supported institution, as well as one that receives federal funding for grants and initiatives, our university is required to provide accessible Digital Resources.

ACR/VPAT and the ACE Tool

What is a VPAT®, and how is it used?

The Voluntary Product Accessibility Template®, or VPAT, is a formal accessibility report that explains the extent to which a digital product (software, website, app, hardware, platform, etc.) supports accessibility requirements. It contains:

  • A breakdown of each accessibility standard
  • A vendor’s claim of conformance (Supports / Partially Supports / Does Not Support)
  • Explanations of limitations
  • Evaluation methods used

A VPAT does not certify a product as accessible, but it documents current accessibility performance so buyers can make informed procurement decisions when acquiring Digital Resources. The current WCAG VPAT® can be found on the ITI website in the "Resources" section of the VPAT® page.  

Completing a VPAT results in an Accessibility Conformance Report (ACR), and the terms VPAT and ACR are often used interchangeably. The documentation gives vendors both business advantages and risk‑reduction benefits. Federal and higher‑education buyers increasingly require VPATs during procurement, meaning vendors who proactively prepare them become more competitive and credible.

How should I obtain an ACR/VPAT?

Vendors may voluntarily provide an ACR/VPAT on their websites as part of their product or service offerings, however you may need to request it when contemplating a Digital Resource purchase. See procurement tips including use of the VPAT®.

What is the ACE Tool, and how can it help me adhere to accessibility requirements?

The ACE Tool—Accessibility Conformance Evaluation Tool—is a searchable web page that allows you to see if System or campuswide exceptions are already in place for certain Digital Resources. If “System-wide” or “University-wide” is indicated and the exception has not yet expired, you may notify procurement personnel that an exception is already in place. This allows any accessibility holds to be removed so the purchase or contract can be completed. The ACE Tool is also helpful when you’re vetting IT solutions to meet a particular business need. If available, an ACR/VPAT can be downloaded for each Digital Resource from the tool to allow you to determine which product is the most accessible.

If the vendor does not already have an ACR/VPAT, which version should I ask them to complete?

The vendor should fill out the current WCAG VPAT®; it can be found on the ITI website in the "Resources" section  of the VPAT® page.

I'm having trouble finding a Digital Resource that is 100% WCAG 2.1 Level AA compliant; what should I do?

Oftentimes, there may be no perfectly accessible product or service to meet a given business need, however with proper research and/or modifications to configurations and settings, users with disabilities may still be able to utilize it effectively.

What happens if I cannot secure an ACR/VPAT for the Digital Resource I intend to procure?

If you cannot secure an ACR/VPAT® from the company website or from the vendor, try one of the following:

  • Check the ACE Tool, an online searchable resource which could potentially contain the ACR/VPAT you need.
  • Ask the vendor to complete a VPAT®; the current WCAG VPAT® can be found on the ITI website in the "Resources" section near the bottom of the VPAT® page.
  • Ask the vendor for evidence of their capability to produce accessible Digital Resources; this may include an accessibility statement, an accessibility roadmap, examples of previous work, etc. Encourage them to complete a VPAT® to keep on file in the event of future purchases.
  • If neither of the previous is available, fully document your attempts to retrieve the information and submit to the IT accessibility team with your compliance review request or your Digital Resource Accessibility Exception Request form. Encourage the vendor to complete a VPAT® to keep on file in the event of future purchases. Note: For contract renewals in subsequent years, inability to produce a vendor-completed VPAT® could jeopardize approval of the Digital Resource Accessibility exception request.

Digital accessibility compliance reviews

What is involved in a digital accessibility compliance review?

An accessibility conformance review is completed for the purpose of procuring accessible Digital Resources or for ensuring that an existing Digital Resource is compliant with state and federal laws. You can review an ACR/VPAT in order to see how it measures up to the accessibility criteria which are applicable for that particular resource. If unsure of the process, you may contact the IT accessibility team to review the Digital Resource and provide helpful information regarding its limitations, accessibility enhancements and/or potential methods of alternative access for those with disabilities. Steps include:

  • A request for an accessibility conformance review can be submitted via email to itaccessibility@tamu.edu, or a request prior to procurement of Digital Resources may come in via an AggieBuy comment.
  • Upon receiving the request, the IT accessibility team will email the requester within 24 hours with a few questions to verify that a review is actually needed and/or to expedite routing.
  • Within 24 hours of receiving answers to the questions, the IT accessibility team will inform you about a preliminary decision. Some possible decisions are:
    • Not a Digital Resource, so no accessibility compliance review is needed; requester can forward the decision to procurement personnel for removal of accessibility hold
    • No user interface; no accessibility compliance review needed and requester can forward the decision to procurement personnel for removal of accessibility hold
    • Digital Resource being used by a single individual only; user is responsible for determining accessibility of the Digital Resource, but no formal accessibility compliance review by the IT accessibility team is needed; requester can forward the decision to procurement personnel for removal of accessibility hold but must adhere to requirements of single-use Digital Resource
    • Digital Resource conforms to Level AA criteria; requester can forward the decision to procurement personnel for removal of accessibility hold (or the Digital Resource is deemed in compliance, if not associated with a purchase)
    • Digital Resource may be registered with a quick e-form; the form should be validated by the IT accessibility team within 24 hours of form completion, requester to forward the validation message to procurement personnel for removal of accessibility hold (or the Digital Resource is deemed in compliance, if not associated with a purchase)
    • Digital Resource Accessibility Exception Request form needed with routing to your dean or vice president and subsequently the President or designee; typical review time is five to ten business days. If approved, forward the decision to procurement personnel for removal of accessibility hold (or the Digital Resource is deemed in compliance, if not associated with a purchase)

Does the IT accessibility team or the Digital Accessibility Officer approve or reject the use of a particular Digital Resource?

No, the role of the IT accessibility team with regard to procurement of Digital Resources is one of advising and consulting as well as facilitating the routing and review of Digital Resource Accessibility exception requests, if applicable. The team begins a compliance review for a particular Digital Resource upon request or once an accessibility hold is placed on a requisition, and facilitates routing of exception requests.

Digital Resource accessibility exception requests

What should I do if there is no accessible Digital Resource available to meet my business need?

All websites, web applications, and other Digital Resources must comply with technical accessibility standards, in our case, W3C Worldwide Consortium (W3C) Web Content Accessibility Guidelines 2.1 (WCAG 2.1), Level AA. If achieving compliance with these standards is not possible, the online Digital Resource Accessibility Exception Request form must be submitted for each non-compliant Digital Resource. It is important to note that an approved exception is not an exemption from making the Digital Resources accessible. Instead, it is documentation of temporary acceptance of risk until the Digital Resource or associated service can be brought into compliance through modification, substitution with a comparable Digital Resource, or discontinuation of use due to end of life (EOL).

Will I need to fill out a Digital Resource Accessibility Exception Request form for every Digital Resource that is not 100% compliant?

No, since the implementation of a more streamlined workflow for accessibility compliance reviews, not every noncompliant Digital Resource will require a Digital Resource Accessibility Exception Request form. Depending on the type of Digital Resource you are choosing to procure, expedited routing may be possible. The IT accessibility team will inform you if this is the case, allowing the use of a quick electronic form instead.

Are there any instructions or tips for filling out the Digital Resource Accessibility Exception Request form?

Yes, an online Digital Resource Accessibility Exception Request form must be submitted for non-compliant Digital Resources; see instructions for filling out the exception request form.

What steps are involved once I complete an Accessibility Exception Request?

See all the steps in the exception process.

What factors impact approval of accessibility exceptions?

Many factors are considered when determining if inaccessible Digital Resource accessibility exception requests are approved. Some considerations are:

  • Degree of compliance with WCAG 2.1 Level AA conformance, functional performance criteria, and/or accessibility of support documentation and associated materials.
  • Scope of use, when combined with degree of compliance can help determine potential risk for the university
  • Business justification
  • Willingness of the vendor to make accessibility improvements and enhancements
  • Consideration of other more accessible Digital Resources which could perform the same business function
  • Analysis of the alternate means of accommodation to ensure equitable access.

Potential procurement scenarios

Why is an accessibility hold placed on my requisition, and what do I need to do to resolve the issue?

Procurement Services or Contract Administration will place a hold on your requisition if the item being procured is a Digital Resources. The hold will be removed if the IT accessibility team determines that one or more of the following apply:

  • The resource is not a Digital Resource
  • The Digital Resource does not need an exception because it:
    • has a valid System-wide or campuswide exception, or there is a valid exception in place for your particular unit
    • is Level AA compliant and meets associated functional performance criteria
    • does not have a user interface, i.e., no way for users to interact with the technologies and/or resulting output or data
    • is being used for one individual only; see information about single-use Digital Resources
    • is a device containing embedded information resources that are integral to the product, but the principal function of the product is not to be an information resource
    • is medical equipment in which Digital Resource are integral to operation but whose primary function is not collection, transmission or distribution of date
  • The Digital Resource needs an exception and:
    • it falls into a category that allows completion of a quick electronic form to register the exception; this can only be determined by the IT accessibility team
    • although not 100% compliant, it has been reviewed for accessibility conformance and the online Digital Resource Accessibility Exception Request form has been approved by the President or designee.

If an institution or agency within the Texas A&M System has an exception in place, will I be able to procure that resource without internal vetting?

No. Every institution or agency must determine if it is appropriate to accept the risk of using a Digital Resource which is not 100% compliant. Each unit requesting the exception must also determine how to provide comparable access when needed by students, staff or visitors with disabilities. Exceptions must be approved by the President of Texas A&M, or designee.

Certain Digital Resources may be a part of System-wide shared services contracts. If this is the case, and an unexpired exception has been approved by the A&M System CIO, you may procure the resource. Check the ACE Tool prior to procuring Digital Resources to see if the “System-wide” designation applies.

Do I need to consider accessibility compliance for open source (free) Digital Resources?

Yes, accessibility compliance needs to be considered for all Digital Resources which are developed, utilized, changed, procured, distributed or referenced, including those which are open source.

The Digital Resource I want to purchase is being used by a very small team, none of whom have a disability; why can’t I just purchase it without an accessibility conformance review?

  • Accessibility is a requirement of state and federal law. Accessibility conformance reviews ensure that either a Digital Resource is compliant or that an alternate means of access can be provided for those who may have a disability.
  • Some disabilities are not visible, so assumptions about users of the Digital Resources may be inaccurate.
  • Future users may need to have fully accessible Digital Resource or an accommodation due to a disability
  • A temporary disability may present itself at any time, including but not limited to temporary vision loss, inability to use a mouse due to an injury, etc.
  • Accessible Digital Resources are typically created using principles of universal design, which consider multiple modes of access and user preferences to create a better experience for everyone.

Moving forward

How can I make a difference regarding procurement of accessible Digital Resources within my campus unit?

  • Do your homework by researching the accessibility of a given product or service before taking steps to purchase it.
  • Request an ACR based on the VPAT® from vendors or search for the ACR of the specific product and version online. If neither is available, ask vendors to complete a blank VPAT®. Note: The current WCAG VPAT® can be found on the ITI website in the "Resources" section near the bottom of the VPAT® page.
  • Ask questions; if vendors have never heard of accessibility, chances are their products and services are not accessible. Don't just ask if their product or service is accessible; ask how it can be accessed by user groups with a particular disability, including individuals who
    • are blind or have low vision,
    • are Deaf or hard of hearing,
    • have motor skill impairments, and/or
    • cognitive conditions that may impact access.
  • Compare several products or services that meet your business need, and choose the one best fits your need as well as accessibility requirements.
  • Make accessibility a part of RFPs, Purchase Order requests, and other essential parts of your business processes.
  • Get your procurement and contract offices involved. They oftentimes have accessibility language ready to insert into contracts and can work with specific vendors to ensure compliance.
  • For additional information, contact the IT accessibility team.
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