Accessibility Assessment. Working with Vendors

The Commitment

The CSU vendor ICT requirements are clearly stated at

The Essentials

Vendors are required to submit some form of Section 508 documentation for any given ICT product, usually a VPAT, the resultant report now more comonly known as a Accessibility Conformance Report.   Every and any report should have:

  1. A proper Header  listing a a product description, who is responsible/author (Contact Information) for the Accessibility Conformance Report and at least an email address and/or telephone number,  and what tools were used to assess the product.
  2. A sensible and complete Chapter 3 section (1194.31 in old form) with all contributing data found in Tables 1 and 2 (1194.21 to 1194.26 in old form).   Further assessment using Sections Chapter 4 and Chapter 5 are desired but not required.
  3. A commitment to support the product throught at least telephone support in Chapter 6 (1194.41 in old form).

ICT is generally a visual experience.   Therefore, an alternate experience to serve the blind is top priority.   A secondary priority, and sometimes conjunction with the visual, is to provide navigation (usually tabs and hot keys) not using a mouse.  

The Importance of Chapter 3

When working with vendors to get a clear assessment on a product's accessibility, campus reviewers should first consider how accessible the product is in a general sense.   Assuming the vendor has completed Chapter 3 (Functional Perfroman Criteria) in the new 2.X form, the answers should be plainly visible.   On the old VPAT form that section, but not as robust, was 1194.31.

Chapter 3 on the new form is as follows:

Chapter 3: Functional Performance Criteria -


Conformance Level

Remarks and Explanations

302.1 Without Vision



302.2 With Limited Vision



302.3 Without Perception of Color



302.4 Without Hearing



302.5 With Limited Hearing



302.6 Without Speech



302.7 With Limited Manipulation



302.8 With Limited Reach and Strength



302.9 With Limited Language, Cognitive, and Learning Abilities




From this general assessment, why compliance cannot be met should be found in the Tables sections of the VPAT.  Most current software has a web interface; so the WCAG sections of the 2.X VPAT, Conformance Criteria for Level A (required compliance), Level AA (desired compliance), and Level AAA (optional compliance) could be read to see where improvements can be made.


Once a product's documentation is worthy to be posted, assuming either compliance or non-compliance,  it is posted to Non-compliant products need to have an accompanying EEAAP (Equally Effective Alternative Access Plan), form 4821, included. When VPATs do not get submitted, it is assumed that product is not compliant, and again an EEAAP must be submitted.   All EEAAPs are subject to review and re-write.

Follow Up Procedures

Virtually all products can be corrected and/or improved over time via re-programming or changes in manufacture.   Vendors should be told that the CSU is serious about accessibility and products achieving superior accessibility will be preferred in the procurement process.  Many vendors have done just so.   The CSU provides a template for improvements, the Accssibility Roadmap at