Why am I being asked to provide information about our Electronic and Information Resources (EIR)?

• Texas A&M received a letter from the Department of Justice (DOJ) dated December 23, 2019, in which they informed us about an audit of TAMU’s non-public systems.

Why is the deadline so soon?

• We were only notified by the university on Tuesday, January 28.

Why is Texas A&M being asked to provide this information?

• We were informed in the letter that it is an investigation to conduct a compliance review under Title II of the American with Disabilities Act of 1990, as amended (ADA), 42 U.S.C. §§ 12131-34, and the OOJ implementing regulation, 28 C.F.R. Part 35.

What is the purpose of Title II?

• Title II of the ADA prohibits discrimination against individuals with disabilities by public entities.

What is accessibility, and why should I be concerned?

• Accessibility is ensuring that everyone can utilize Electronic and Information Resources, including online course offerings, regardless of abilities. Practices that ensure accessibility, such as Universal Design for Learning (UDL), are helpful for everyone, not just individuals with disabilities.

What is the focus of the compliance review?

• The focus is to determine if Texas A&M’s (“TAMU”) website (addressed earlier by DOJ) and course offerings are in compliance with the ADA. Specifically, are course offerings accessible to individuals with disabilities (e.g., vision, hearing, learning, and manual dexterity disabilities)?

What resources should be included on the Google Sheet?

• Data are being collected for resources utilized for teaching and learning purposes. This includes, but is not limited to: the LMS you are utilizing (if other than Blackboard/eCampus), course and/or faculty websites, web applications, student application and information portals, any other Electronic and Information Resources (EIR) required for use by students and/or recommended to enhance student education. Additionally, it involves any online content that a student would interface with when involved with course instruction and is necessary to access for completion of coursework.

Do I need to include resources utilized in the past?

• No. You only need to submit resources being used for the current term and moving forward.

Does this involve textbooks and associated online resources?

• At this time, this is not within the scope of the current inquiry.

What is the deadline for submission?

• Currently, the deadline for submission of unit EIR is Wednesday, February 12. There are other steps within our internal review process which will better prepare us for DOJ testing, and these deadlines can be found in DOJ Process Steps and Timelines. Please consult this frequently, as timelines may change.

How can I submit my information?

• Utilize the Google Sheet for EIR entries.  The link was sent in the accompanying email.

Do continuing education resources need to be submitted? 

• We will be receiving clarification as to the scope of the inquiry and update as soon as possible.

What about social media and other apps like Facebook, Instagram, Twitter and GroupMe?

• These would be considered applications, and if students are pointed to these resources during a course, those would apply.

What is an Accessibility Conformance Report (ACR,) and why is that needed?

• An ACR is a vendor-completed Voluntary Product Accessibility Template (VPAT) which indicates how a particular EIR measures up to accessibility compliance criteria required by law. Oftentimes an ACR is referred to as a VPAT, and those terms are used interchangeably.

How do I secure an ACR, and where should that be added?

• Sometimes a completed VPAT, or ACR, can be found online as part of vendor resources. You may try searching “PRODUCT-NAME VPAT” or “PRODUCT-NAME ACCESSIBILITY.” If you don’t find any search results, contacting the vendor will be necessary.

NOTE: It is very important that you pay attention to the version number of the product, as accessibility features can be enhanced or even broken from version to version.

Once information is submitted, is our unit’s work complete?

• No. It is our goal to gather information, document deficiencies, if any, and work to remediate any deficiencies prior to DOJ testing. This will probably take assignment of additional personnel within your unit, and more information may need to be submitted as remediation efforts progress. These can be found in DOJ Process Steps and Timelines.

How should I prioritize remediation of resources, once our initial resource submission is complete?

It is important to consider:

• Scope: how widespread is the resource deployed across campus; the more widely distributed, the greater the need for remediation.
• Access: how many students access the resource; the more access, the more critical the need for remediation.
• Criticality: is the resource critical to academic success or academic operations; the more critical, the greater the need for remediation.
• Estimated time required for remediation: when comparing resources, if all the above are the same, which could be tackled more quickly and efficiently, given your unit resources; those resources that can be remediated more quickly, should be given a higher priority for remediation.