A VPAT is a Voluntary Product Accessibility Template (VPAT). It's a standardized form provided by the Information Technology Industry Council so that vendors can evaluate and share how well their products adhere to the accessibility guidelines of the WCAG and Section 508 of the Rehabilitation Act. 

VPATs come in four different types:

• WCAG edition - For reporting compliance to the W3C Web Content Accessibility Guidelines 2.1 or 2.2.
• 508 edition - For reporting compliance to the U.S. Revised Section 508 standards
• EU edition - The European edition used for reporting compliance to the EN 301 549 standard
• INT edition - The international edition used for reporting compliance to all three standards

When a vendor fills out a VPAT, the resulting document is called an Accessibility Conformance Report (ACR). 

VPATs and the resulting ACRs are important so that organizations like UVM can ensure that the products they buy are accessible to people with disabilities.

Any UVM department that is considering purchasing a product for use at UVM must go through an IT Contract Review process before making the purchase. An ACR review is part of the IT Contract Review process.

And while some accessibility issues can be worked around, the majority of major accessibility issues cannot. Therefore, it's best to get an ACR review done early in the process, to ensure that the project you want to purchase for use at UVM can actually be purchased and used with equity across UVM. 

Reach out to OAS as early in the purchasing process as possible.

If, at the end of the review, the product turns out to have major or multiple accessibility issues, or there are major issues with the ACR itself, then one of two things can happen:

1. If there are multiple areas in the ACR where the vendor admits that the product does not meet WCAG 2.1 AA-level guidelines, then OAS will return to the vendor and ask them to share a timeline for when they are planning on remediating the outstanding issues. Depending on the timeline, and how the timeline lines up with the planned use of the product at UVM, that can be sufficient.
2. Otherwise, if the vendor is not currently planning on remediation but the overwhelming majority of the campus would benefit from access to one particular product that is not 100% accessible, OAS can work with the vendor to create an Equally Effective Alternative Access Plan (EEAAP). An EEAAP details how UVM will provide equal access to the product or for completion of the task despite the product's accessibility issues.

If accessibility risk cannot be reasonably addressed, UVM may be unable to approve the purchase.

The OAS Web & Digital Accessibility Specialist will read through the vendor's Accessibility Conformance Report (ACR) and grade it based on an industry-standard rubric. 

The OAS rubric looks at:

• Who did the vendor's accessibility testing
• What kind of accessibility testing the vendor did for the ACR
• When the last round of testing was done
• Which template was used
• Which aspects of the product were tested
• How well the accessibility successes and failures have been documented
• Whether there are any major accessibility failures documented in the ACR.

Each item on the rubric will be assigned one of two states: Pass or Fail. Then at the end of the grading process, the ACR will be assigned a letter grade from A through to F. Letter grades are determined by the percentage of items with a Pass.

A copy of the evaluation can be provided to both the department and the vendor.

If a review of the ACR indicates multiple areas where accessibility needs are unmet, OAS will reach out to the vendor to ask for a timeline for the remediation of these needs. If the vendor is unable to provide one, OAS may need to draft an Equally Effective Alternate Access Plan (EEAAP) specifying how UVM will provide resources to address the accessibility gaps. This will affect the ultimate timeline for delivery.

The University of Vermont depends on accurate, informative Accessibility Conformance Reports from vendors in order to make plans to support all students, staff, faculty, and visitors with disabilities in the campus community. We appreciate the time and effort it takes vendors to produce these documents and keep them updated.

Each ACR is reviewed by a staff member in the Office of Accessibility Services. We're looking for ways to anticipate what the University may need to provide in order to make it possible for people with disabilities to use all the products that make UVM function. We are not looking to disqualify or reject any products. When UVM wants to use a product but there are items labeled Partially Supports or Does Not Support, the Office of Accessibility Services tries to figure out ways we can provide additional resources or workarounds to make sure all people with disabilities can use the product. We do this by writing a UVM-internal document known as an Equally Effective Alternate Access Plan (EEAAP).

When the Office of Accessibility Services reviews an ACR, we use an industry-standard review template and review procedure. Our process allows us to generate a letter grade based on the rigor of the ACR (in other words, how much confidence we have in its accuracy), as well as reviewing all areas where a product may not support full accessibility. When we finish the report, we provide copies of our report to both the requesting UVM department, and to the vendor.

At this time, we need vendors to complete ACRs using the Information Technology Council's official template. We can only accept one of the templates labeled as version 2.5: 

• VPAT Rev 2.5 EU
• VPAT Rev 2.5 INT
• VPAT Rev 2.5 508
• VPAT Rev 2.5 WCAG

VPAT Rev 2.5 508 is preferred, as UVM must meet all WCAG and Section 508 requirements.

During the review process, if the Office of Accessibility Services identifies any items labeled Partially Supports or Does Not Support, we may need to contact the vendor with a list of questions for additional information. We do this so that we have all the information we need to determine what UVM can do to bridge any accessibility gaps with additional resources.

The Office of Accessibility Services assigns each ACR a letter grade, based on how many of 16 different criteria the ACR passes. Every ACR starts at 100%; every criteria where an ACR fails to meet our standards decreases that final score.

ACR Scoring Rubric Details

After evaluating the rigor of an ACR, Office of Accessibility Services reviewers go through each individual criteria included in WCAG A-level, WCAG AA-level, and Section 508 Chapters 3, 5, and 6. We look to see that the ACR includes every criteria, and that every criteria has notes explaining how it Supports, Partially Supports, Does Not Support, or is Not Applicable to the product. 

• If notes are included and make sense, then the reviewer marks the item as a Pass.
• If there are no notes included, or the notes do not make sense, the reviewer marks the item as a Fail.
• If an item is missing entirely from the ACR, the reviewer marks the item as a Fail.

At the end of the review, the report sums up how many of the criteria pass, how many fail, and whether any are missing. This information is contained in a narrative section of the review report. 

The section looks like:

"This ACR passes:

• [number] of 31 WCAG A-level criteria
• [number] of 24 WCAG AA-level criteria
• [number] of 9 listed Section 508 Chapter 3 criteria
• [number] of 28 listed Section 508 Chapter 5 criteria
• [number] of 5 listed Section 508 Chapter 6 criteria

There is [some / no] information missing for either WCAG or Section 508 criteria, and overall, this is a [letter grade] ACR."

After that, the reviewer writes up any questions that came up during the review, and lists any places where the Office of Accessibility Services will need more information in order to write their EEAAP. They may also assign a potential accessibility risk value to the product. 

Important note:

Reviewers are looking to find ways to approve every product for use at the University of Vermont. We are very aware of the amount of time and effort it takes departments to research and evaluate products for use at the University, and we seek to honor that effort -- at the same time, every product in use at UVM must be available for full use by people with disabilities on the campus.

UVM does not use the ACR review process to automatically reject products. The review helps UVM understand accessibility risk, request remediation information, and determine whether an Equally Effective Alternative Access Plan is needed.

Because of the rapid pace of software development, UVM reviews the ACRs of products in use at the University every 24 months, or whenever a contract renewal process is initiated.

UVM reviews the ACRs of products for potential use at the University during the purchase process.

Additionally, UVM requests that all vendors provide UVM with any updated ACR they produce, especially when new versions of products are released.

UVM aligns with current federal requirements for WCAG 2.1 AA and is actively working toward WCAG 2.2 AA as the institutional standard. Vendors are expected to provide WCAG 2.1 AA conformance and should include WCAG 2.2 AA information where available.