ICT Accessibility Exceptions
Welcome to the University of Illinois Chicago Information and Communications Technology (ICT) accessibility exception page.
About IT Accessibility Exceptions
In these situations, the university must be able to demonstrate that reasonable efforts were made to procure an accessible ICT and an equally effective alternative method of access must be provided. As such, a request to use an inaccessible ICT or to use an ICT in an inaccessible context must be reviewed and approved.
Intent of the Exception Process
The exception process is intended to support procurement and the university’s mission to create an inclusive environment. It is in place to ensure that the university is maintaining an inclusive and welcoming educational and workplace environment and to demonstrate due diligence under accessibility law.
To fulfill its obligations under federal and state accessibility law, the university must do two things:
- Procure and utilize only the most accessible products available on the market, if no fully accessible product is available, that best meets the business need.
- Document a plan for providing equally effective alternative access to those who encounter access barriers due to the accessibility flaws in an ICT product.
The exception process is utilized to ensure that the above conditions are met. It is only in cases where it is clear that due diligence was not performed when procuring a product and no meaningful alternative access can be provided that an exception request may be denied, and a product may not be used.
If it seems likely that an exception will not be approved by the Digital Accessibility Steering Committee (DASC), then it may be prudent to pause the procurement process until the exception process has been completed and the outcome is known. While an approved exception is required for an inaccessible product to be used for the mission of the university, it is left to individual units to determine when in the procurement process they wish to seek an exception and if procurement will be suspended until the outcome of an accessibility exception request is determined.
When An Exception Is Needed
An exception is typically needed if an accessibility evaluation found any issues in an ICT product, regardless of priority assigned in an evaluation report. This is for two reasons.
- The first is because all issues found negatively impact those with disabilities, resulting in anywhere from an outright inability to use a product to wasting valuable time and effort as an individual grapples with access barriers in the product.
- The second reason is that accessibility law does not make mention of issue priority and all accessibility issues found in a product, regardless of the priority assigned in an evaluation report, constitute violations of legal requirements.
You can use the Digital Accessibility Decision Tree to help you determine the most appropriate course of action.
When An Exception Is Not Needed
An Accessibility Exception is not needed in the following circumstances:
- The ICT product has no human-facing interface
- The ICT product is special-purpose software that will be used by few individuals, none of whom have an identified disability that will be adversely affected by product accessibility issues
- The ICT product is for use internally by a research team where no members of the team have an identified disability that will be adversely affected by product accessibility issues
In the latter two situations, it is be prudent to create an alternative access plan in case someone who must use the product develops a disability or a new team member is introduced who has a disability that will be adversely affected.
Evaluating Vendor's Commitment to ICT Accessibility
Selecting accessible technology is crucial for creating an inclusive digital environment. UIC employees procuring technology services need to evaluate a vendor’s commitment to accessibility and compliance with industry standards.
Employees can reference the Exception Review Guidelines and use the Vendor Questions section to:
- Understand a vendor’s approach to accessibility in their products and services.
- Evaluate their compliance with accessibility regulations and best practices.
- Determine their willingness to provide documentation, testing results, and ongoing support.
By asking the right questions, you can ensure the technologies you procure align with accessibility requirements and support all users effectively.
Before Requesting an Exception
Before requesting an ICT accessibility exception, the Requesting Individual must have the following information:
- An accessibility evaluation report for the ICT product that will receive the exception. The evaluation must have been performed by an employee of the university or by an approved third-party.
- If the request is to renew an expiring exception, the evaluation must be a follow-up evaluation conducted on the most recent version of the ICT product; ie., the evaluation report that was submitted with the expiring request may not be resubmitted for the renewal. This helps ensure that any updates to the ICT product are evaluated and addressed as needed by updates to the alternative access plan.
- Documentation of the product comparison research demonstrating that the ICT to be excepted is the most accessible product available product on the market that meets business need.
- If no product research was performed or the ICT to be excepted is not the most accessible, document rationale for why this product was chosen.
- A completed Alternative Access Plan template which documents the equally effective alternative access that will be provided by the requestor, the requestor’s unit, or the product service management team.
Submit an Exception
If you are ready to submit an exception request, please complete the Accessibility Exception Request Form.
Annual Expiration
The exception review is an annual process and the approval expires from one year from initiation date.
Frequently Asked Questions
Find answers to Frequently Asked Questions related to Accessibility Exceptions.
Equally Effective Alternative Access Plan (EEAAP)
What is EEAAP and why do we need it?
When the university must procure ICT products that cannot be considered accessible, federal and state law requires organizations to document and implement an Equally Effective Alternative Access Plan (EEAAP) that will mitigate the access barriers presented by the inaccessible digital product or service.
Who is responsible for an EEAAP?
In most instances, the unit that is procuring an ICT product will be responsible for defining and maintaining the EEAAP and reviewing it for effectiveness. For unit- and campus-wide ICT services, this duty would fall on the service management team.
What are the concepts of an EEAAP?
An Equally Effective Alternative Access Plan (EEAAP) considers
- How alternative access will provide a timely and accurate way to access information and data
- How it will be actively maintained to ensure the alternative access remains viable
- How it will be examined periodically to ensure no changes are needed
Please note that an equally effective method of alternative access will NOT require an individual to disclose their disability and, where possible, will NOT require an individual to request the alternative access.
What guides or resources are available for vendor management?
Where can I submit my request?
You can submit the request here: Digital Accessibility Exception Review Request.
What is the Exception Review Process?
Once the request form is completed and submitted, the following steps will occur:
- College/Vice Chancellor Unit internal review by subject matter experts/IT staff who may verify or gather additional information.
- Submission to the Exception Request Process and Review by ICT Accessibility Exception Review Committee who may verify or gather additional information.
- Approved or denied by the Chief Information Officer or designee
- The request will be logged into a centrally managed database of exception requests and the requestor will be notified of the decision.
- The requester can appeal the decision to CIO, upon whose decision is final. Prior to the exception expiration, the responsible unit must complete remediation or request a renewal of the exception.