ITS Solutions · Procurement

Buying Accessible Technology

Every new software platform or digital service you purchase becomes part of CMC's digital footprint. Require accessibility before you sign — not after.

Why Procurement Is the Right Moment

Remediating inaccessible technology after purchase is expensive and often impossible. Vendor contracts rarely include mandatory remediation timelines, and post-purchase leverage over vendors is minimal. CMC policy requires all software acquisitions to pass an accessibility review, integrated into the existing HECVAT process.

The moment of negotiation is the moment of power. Accessibility requirements inserted as contract conditions carry legal weight and create accountability. Waiting until after deployment means accepting the risk of non-compliance and the cost of remediation — costs that consistently exceed the price of prevention.

Who Does What

You do not need to evaluate a vendor’s accessibility yourself. ITS handles the review — your job is to tell us early.

What you do

  • Tell ITS what you want to buy before you sign anything
  • Send the vendor name, the product, and a link to their accessibility documentation if you have one
  • Loop ITS in early enough that accessibility can still be negotiated

What ITS does

  • Requests and reviews the vendor’s ACR
  • Identifies WCAG 2.1 AA gaps and documents the findings
  • Negotiates a remediation roadmap as a condition of the contract
  • Documents the review in the procurement file
Contracts require ITS approval before signature. Under the Digital Accessibility Policy, no contract for third-party services can be signed until it has been reviewed and approved by the Director of Administration and Finance for IT Services.

The CMC Process

1

Tell ITS What You Want to Buy

Email ITS Solutions at help@cmc.edu before signing any contract. Accessibility review runs alongside the existing HECVAT security review.

2

ITS Requests the VPAT/ACR

ITS requests the VPAT/ACR (Accessibility Conformance Report) from the vendor. A current ACR is required, with no exceptions.

3

ITS Reviews the Documentation

ITS reviews the documentation for WCAG 2.1 AA gaps and documents findings.

4

Negotiate a Remediation Roadmap

Where gaps exist, ITS negotiates a remediation roadmap with a defined timeline as a condition of the contract. Some vendors call this an Accessibility Roadmap, a remediation plan, or a statement of direction — the substance matters more than the label.

5

Recommend WCAG 2.2 AA Vendors

ITS recommends vendors meeting WCAG 2.2 AA where available, as this is the current best-practice standard.

6

Document for Audit

Accessibility criteria are documented in the procurement file for audit and compliance purposes.

VPATs and ACRs Explained

A VPAT is the blank form. An ACR (Accessibility Conformance Report) is the completed assessment. Always request the ACR — the blank template is not useful. Request VPAT 2.4 (WCAG 2.1 edition) — older 1.x versions assess Section 508 only and do not map to current web accessibility standards.

Read a VPAT with appropriate skepticism. A VPAT/ACR is completed by the vendor that wants to sell you the product. There is no certifying body, no audit requirement, and no oversight of what a vendor claims in a VPAT/ACR. Treat the ACR as the vendor’s own assertion — ask who performed the evaluation and what their credentials are, ask whether an independent third party was involved, and test the product directly where possible.

When you receive an ACR, look for the evaluation date — reports older than 24 months may not reflect the current product. Also check whether the assessment was conducted internally by the vendor or by an independent third-party auditor. Third-party audits carry more weight.

When a Product Isn’t Accessible Yet

A product that does not meet WCAG 2.1 AA today is not automatically disqualified. If the vendor has a credible, dated remediation roadmap and the gaps will close within a defined window, it may still be the right choice.

When CMC proceeds on that basis, ITS documents an Equally Effective Accessibility Plan (EEAP) — the specific steps CMC and the vendor will take in the interim so that no member of the community loses access while the product is being remediated. The EEAP is developed with the vendor, documented in the procurement file, and reviewed against the roadmap’s milestones.

Questions ITS Will Ask the Vendor

These are the questions ITS works through in every vendor evaluation. You are welcome to raise them directly with a vendor, but you are not expected to — ITS runs this part.

  • Do you have a current ACR (VPAT) for WCAG 2.1 AA?
  • Which version of WCAG does your ACR address — 2.0, 2.1, or 2.2?
  • What are the known accessibility gaps in your product and what is your remediation timeline?
  • How do users report accessibility issues, and what is your response SLA?
  • Does your product meet WCAG 2.2 AA? (CMC preference)
  • Was this ACR conducted by an independent third-party auditor or internally?
  • Do you have a published accessibility roadmap with dates?

Consortium Platforms

For Claremont Colleges shared platforms managed by TCCS (The Claremont Colleges Services), ITS coordinates with TCCS on joint vendor accessibility requirements. Consortium purchasing carries additional leverage — shared requirements across multiple institutions are more effective than individual institution requests.

For CMC-independent licenses, ITS handles the accessibility review directly. Contact the ITS Solutions team at help@cmc.edu with subject "Accessibility Procurement Review" to initiate the process.

Ready to Start a Procurement Review?

Submit a HECVAT request or talk to an ITS consultant before signing any new software contract. We review ACRs, negotiate remediation timelines, and keep your purchase compliant.

Start a HECVAT Review → Talk to a Consultant →