ICT Accessibility Exceptions

Welcome to the University of Illinois Chicago Information and Communications Technology (ICT) accessibility exception page.

It is not always possible to procure or create ICT that meets that standard. At other times, the intended use of an ICT does not allow for meaningful access for those with a disability.

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.

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:

  1. 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.
  2. 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.

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.

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.

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 ICT accessibility exception, the Requesting Individual must have the following information:

  1. 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.
  2. 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.
  3. 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.

If you are ready to submit an exception request, please complete the  Accessibility Exception Request Form.

The exception review is an annual process and the approval expires from one year from initiation date.

Find answers to Frequently Asked Questions related to Accessibility Exceptions.