SYS 655 Policy & Guidance University Comments and Concerns
SYS 655 Policy & Guidance University Comments and Concerns
Stakeholder Feedback on Draft Policy
Comment 1: Commenters from UW-La Crosse requested that the policy be modified to exclude faculty-written software.
Response: No change was made to the policy. Faculty may write software for their own use, which would not be required to comply with the policy. If faculty write software for use in a university program, service, or activity (including for use by students in coursework), that software should be made accessible in accordance with the policy. If making a specific piece of software accessible would constitute a fundamental alteration or undue financial and administrative burden to the university, this would be addressed through the exemption process.
Comment 2: Commenters from UW-La Crosse requested that the policy be modified to exclude student-written software.
No change was made to the policy. Students may write software for their own use or as submitted coursework, which would not be required to comply with the policy.
Comment 3: A commenter from UW-La Crosse also requested that the policy exempt software that supports narrowly tailored objectives (teaching, research, or other functions).
No change was made to the policy. If faculty write software for use in a university program, service, or activity (including for use by students in coursework or research), that software should be made accessible in accordance with the policy. If making a specific piece of software accessible would constitute a fundamental alteration or undue financial and administrative burden to the university, this would be addressed through the exemption process.
Comment 4: A commenter from UW-Milwaukee requested clarification on the terms “fundamental alteration” and “undue financial/administrative burden” in the last sentence of Section 6.A.
No change was made to the policy. Any undue hardship or fundamental alteration would be evaluated under RPD 14-10 and evaluated by the chancellor or designee. This is echoed in section 6.A of the policy, as well as Section F.III of the guidance.
Comment 5: A commenter from UW-Parkside requested clarification on how this policy affects programming offered in partnership with external parties, or provide guidance as to how much external partner organizations must comply with WCAG 2.1 standards in order to allow a partnership to continue.
No change was made to the policy. Any university program, service, or activity offering digital content is required to comply with the policy. Whether the content for collaborative programming offered via a partnership would be covered as a university program will depend on factors specific to a given partnership. Individuals should consult with their university’s ADA coordinator or digital accessibility designee to make a determination.
Comment 6: A commenter from UW-Stout requested that the content from the Exceptions and Exemptions section of the guidance document and clarification on documentation of limited exceptions and exemptions be added to the policy.
Change made. The drafting team elevated the Rule’s exceptions to Sec. 6.A of the policy for awareness while keeping definitions/explication in the Guidance for practitioners and others with relevant decision-making authority. Section 4.C of the guidance is also reflected in Section 6.A of the policy.
Comment 7: A commenter from UW-Stout recommended further clarification on the term “web content.”
No change was made to the policy. “Digital content” is the common terminology versus “web content,” which may narrowly focus on web pages as opposed to applications hosted on the web.
The guidance emphasizes that LMS (i.e., Canvas) content is included in the definition of web content. Each university should be providing training and education related to the policy to advance common understanding of terms.
Comment 8: A commenter from UW-Stout recommended the use of additional hovering definitions capabilities for “mobile apps.”
The final policy and guidance will link to defined terms as deemed appropriate by the policy office.
Comment 9: A commenter from UW-Superior and a commenter from UW-Madison noted typographical typos in the policy.
Changes made.
Comment 10: A commenter from UW-Milwaukee requested the following language be removed from Section 6.A: “and as supplemented by the Accessibility in Web Content and Mobile Applications Guidance accompanying this policy …”
Changes made. The drafting team restructured Sec. 6.A to more clearly indicate that the Guidance is informational and not a set of standards against which compliance is to be measured.
Comment 11: A commenter from UW-Milwaukee recommended “at least one employee” be removed from the first sentence of Section 6.D and be replaced with “a role or unit.” They also recommended the following language and subsequent sections (I, II, III, and IV) be removed, “The designee must be able to provide guidance on the following regulatory exceptions:”.
No change made to the policy. This language (“at least one employee”) is consistent with other system policies. As written, this does not assume that a designee must be able to provide guidance for all content; instead the university may have more than one designee that is able to review, consult, and decide.
Comment 12: A commenter from UW-Milwaukee recommended that Section 6.E be revised to read, “Provide a mechanism to report and resolve accessibility issues for making complaints of web content and mobile apps.” They also suggested striking subsections I and II.
No change was made to the policy. The policy language provides sufficient flexibility for universities; beyond requiring reporting mechanisms and processes for review and resolution of reported accessibility barriers, universities have discretion as to what those are.
Section 6.E.II is intended to provide UW Administration with aggregated information about universities’ ongoing compliance efforts for awareness. It is relevant to the reporting and resolution processes required in the rest of 6.E.
Stakeholder Feedback on Draft Guidance
Comment 1: A commenter from UW-Milwaukee recommended changing the mention of “digital tools” in Section 5.E.I to “digital content” for consistency.
Change made. Updates and clarification of language was completed for continuity between policy and guidance.
Comment 2: A commenter from UW-Milwaukee recommended clarifying the term “notifying” in Section 5.E.III.2.
Change made. This was clarified and updated in 5.E.III.2.
Comment 3: A commenter from UW-Milwaukee noted a discrepancy in numbering in Section 5.E.II.
Discrepancy corrected.
Comment 4: A commenter from UW-Milwaukee recommended that in Section 6.IV.1 in the sentence beginning “If the vendor does not achieve product or service accessibility …”, that the following language be removed: “and any damages for which the Vendor may be responsible …”
No change to the guidance. The original language remains (now in Section 5.E.IV.1), as the drafting team are aware that other covered entities are issuing similar notices to digital content vendors. Note that this language is a template and may be modified by universities.
