Software Acquisition and Management Policy

Accessibility Documentation and VPAT Requirements

1. Purpose

Florida State College at Jacksonville is committed to ensuring that all technology assets, including hardware, software, digital tools, and web applications, are accessible to students, faculty, staff, and members of the public.

In alignment with federal and state regulations, including the Department of Justice’s updated ADA rule requiring conformance with WCAG 2.1 Level AA by April 2026, accessibility documentation is required as part of the College’s software review and procurement process.

Accessibility review is integrated into the College’s Software Request Process and Technical Review Board procedures.

2. Accessible Procurement Procedure

When requesting or procuring new software, the requester must obtain a current Voluntary Product Accessibility Template (VPAT) or Accessibility Conformance Report (ACR) from the vendor.

The VPAT must:

  • Use version 2.4 or higher of the VPAT template

  • Have a completion date within the last 12 to 18 months

  • Identify evaluation methods, including manual testing with assistive technology

  • Clearly document the product’s conformance with WCAG 2.1 Level AA

If the product does not fully conform to WCAG 2.1 Level AA, the vendor must provide:

  • A written accessibility roadmap

  • Specific remediation commitments

  • Target dates for achieving compliance

As of early 2025, the College’s expectation is full conformance with WCAG 2.1 Level AA by April 2026 to align with federal requirements.

3. When a VPAT Is Required

A VPAT or ACR is required when:

  • The product will be used by students, employees, or the public

  • The product supports instructional, administrative, or enterprise functions

  • Accessibility compliance is required under ADA, Section 504, Section 508, state law, or institutional policy

  • The product stores or processes institutional data and includes user interfaces

VPATs are strongly recommended for all other software acquisitions, including pilots, trials, grant-funded tools, and department-level purchases, to reduce future compliance risk.

4. Evaluation and Determination

Submission of a VPAT does not guarantee approval.

Accessibility review will consider:

  • Scope of use and user population

  • Severity and number of documented accessibility gaps

  • Availability of accessible alternatives

  • Impact to users with disabilities

  • Vendor responsiveness and remediation commitment

  • Timeline to meet WCAG 2.1 Level AA standards

In limited circumstances where no fully accessible alternative exists, departments must:

  • Document known accessibility limitations

  • Provide an accessible alternative solution

  • Coordinate with appropriate College offices to mitigate user impact

5. Technical Review Board Procedure

When a software demand is submitted through ServiceNow for Technical Review Board review:

  1. A VPAT must be attached to the submission.

  2. The VPAT will be reviewed for the product’s conformance with WCAG 2.1 Level AA.

  3. If the product does not meet compliance standards under IT Policy 5.00, the TRB will work with the vendor and requesting department to determine next steps.

This may include:

  • Requesting a formal accessibility roadmap

  • Obtaining written commitment to remediate by a specific date

  • Evaluating user impact

  • Prioritizing remediation of critical accessibility barriers

The TRB reserves the right to deny or restrict approval if accessibility risk is significant and mitigation is not feasible.

6. Required Accessibility Provision in Contracts

All contracts, agreements, renewals, or purchase orders must include a provision stating that:

  • The product, service, or tool complies with College accessibility standards and WCAG 2.1 Level AA, or

  • Any identified accessibility deficiencies will be remediated within a defined and agreed-upon timeframe

Contracts must also include language holding Florida State College at Jacksonville harmless from claims, damages, expenses, fines, costs, attorney’s fees, or other liabilities resulting from accessibility noncompliance of the vendor’s product.

Accessibility documentation and commitments must be incorporated into contractual records where applicable.

7. Ongoing Review

VPATs must be reviewed:

  • Prior to initial purchase

  • During renewal evaluation

  • When major product updates occur

  • When significant accessibility complaints are received

Accessibility documentation is part of the College’s broader compliance monitoring and asset management process.