1. Purpose 

Ensure that product owners and purchasers have a clear process and designated staff responsible for evaluating digital accessibility scope and risk for acquired web applications and mobile apps.     

2. Scope 

This procedure applies to all applications acquired or purchased by or for the University and used to provide University services, programs, or activities regardless of the source of funding. This procedure governs digital accessibility review only and does not supersede, replace or modify the University’s procurement or supplier selection processes.

3. References 

• APS 2.3 Information Technology, Telecommunications and Networking Projects, and Acquisitions
• APS 9.0 Digital Accessibility
• Minimum Digital Accessibility Standard (Interim)  
• DOJ Final Rule on Web Accessibility under Title II (2024)
• WaTech USER-01 Digital Accessibility Policy
• Procurement Policy 7.2.15 

4. Definitions

Mobile applications (“apps”)

Mobile applications mean software application developed for a mobile device platform (e.g., iOS, Android) that is public-facing and distributed via an app store or similar channel, and affiliated with a UW unit.   

Provisional approval

Provisional approval means a product which does not fully meet the Minimum Digital Accessibility Technical Standards is approved for use within defined requirements. Provisional approval must include an expiration date, by which time the product must either be submitted for a new scope and risk review or stop being used.

Temporary Alternative Access Plan (TAAP)

Temporary Alternative Access Plan outlines known accessibility barriers in a product, identifies which disability groups are affected, and provides alternative means of access that the university will implement while the vendor works toward compliance. This ensures we do not shift the burden of workarounds to users with disabilities.  

5. Roles and Responsibilities  

Roles and Responsibilities in two columns

Role	Responsibility
Product Owner / Purchaser	Submit Scope and Risk Assessment form. Manage relationships with product content creators, designers, developers, and/or suppliers. Work collaboratively with Civil Rights Compliance Office, Accessible Technology Services, and other process partners to ensure a smooth and effective process. E.g., identify test scenarios/workflows, provide timely feedback on questions.
Compliance and Risk Services, Civil Rights Compliance (CRC)	Develop and maintain criteria for determining scope and risk level. Evaluate Scope and Risk Assessment form. Determine if products are in scope of the Digital Accessibility Policy. Determine products’ risk level.
Information Technology, Accessible Technology Services (UWIT ATS)	Develop and maintain evaluation criteria for determining if Accessibility Conformance Reports (ACRs) and Roadmaps demonstrate compliance. Develop and maintain evaluation criteria for determining if Manual Review of test environments demonstrates compliance. Designate and train testers to evaluate ACRs, Roadmaps, and Products.
UWIT ATS or Designated Tester	Evaluate ACRs and Roadmaps and determine if they are complete and credible. Evaluate ACRs and Roadmaps and determine if they meet evaluation criteria. Evaluate products and determine if they meet evaluation criteria.
Supplier	Submit ACR and roadmap upon request. Provide access to test environment upon request. Work collaboratively with product owner / purchaser to ensure a smooth and effective process. E.g., identify test scenarios/workflows, provide timely feedback on questions.

6. Procedure Steps

1.       Initiation

1. Product Owner / Purchaser submits a Digital Product Accessibility Review Scope and Risk Assessment form.

2.       Scope and Risk Review

1. CRC uses scope criteria to determine if products are in scope of the Digital Accessibility Policy.
   1. Out of scope products may continue to procurement.
2. CRC uses risk criteria to determine if in-scope products are low, medium, or high risk.
3. CRS delivers findings to Product Owner / Purchaser  
4. Product Owner / Purchaser proceeds to the next step based on the following outcomes:    
   1. Products with Medium and High Risk Scores proceed to Step 3: ACR and Roadmap Review.
   2. Products with Low Risk Scores proceed to Step 4: Provision Approval.

3.       ACR and Roadmap Review

1. Supplier submits an ACR and roadmap.
2. UWIT ATS or Designated Tester evaluate ACR and roadmap.
   • If an ACR or Roadmap is incomplete, Product Owner / Purchaser communicates with Supplier for more information and returns with new documentation for reevaluation. Products will only be re-evaluated once.
3. UWIT ATS or Designated Tester delivers ACR score and findings.  
4. Product Owner / Purchaser proceeds to the next step based on the following table:

Scores	Medium Risk Score	High Risk Score
Meets expectations	Proceed to Step 4: Provisional Approval	Skip to Step 5: Baseline Manual Accessibility Test
Partially meets expectations	Skip to Step 5: Baseline Manual Accessibility Test	Skip to Step 6: Extended Manual Accessibility Test
Does not meet expectations	Skip to Step 6: Extended Manual Accessibility Test	Skip to Step 6: Extended Manual Accessibility Test

4.       Provisional Approval

1. CRC determines provisional requirements and reassessment schedules.
2. CRC communicates provisional approval, requirements, and reassessment schedule to Product Owner / Purchaser.
3. Product Owner / Purchaser continues product acquisition.

5.       Baseline Manual Accessibility Test

1. UWIT ATS or Designated Tester communicates need for manual accessibility testing to Product Owner / Purchaser.
2. Product Owner / Purchaser contacts Supplier for access to test environment.
3. UWIT ATS or Designated Tester uses Baseline Manual Accessibility Test assessment criteria to evaluate product.
4. UWIT ATS or Designated Tester delivers Accessibility Test Score and findings to Product Owner / Purchaser.
5. Product Owner / Purchaser proceed to the next step based on the following outcomes:
   • Pass – Product Owner / Purchaser continues product acquisition and use.
   • Fail – Product Owner / Purchaser stops using the product or continues to the Exception Procedure for the Minimum Digital Accessibility Technical Standard.

6.       Extended Manual Accessibility Test

1. UWIT ATS communicates need for manual accessibility testing to Product Owner / Purchaser.
2. UWIT ATS, the Product Owner / Purchaser, and the Supplier collaborate to get access to test environment and identify test scenarios and workflows. 
3. UWIT ATS conducts an Extended Manual Test to determine if product passes or fails to meet the Minimum Digital Accessibility Technical Standard.
4. UWIT ATS delivers findings to Product Owner / Purchaser.
5. Product Owner / Purchaser proceeds to the next step based on the following outcomes:
   • Pass – continues product acquisition and use.
   • Fail – stops using the product or continues to the Exception Procedure for the Minimum Digital Accessibility Technical Standard.

7.       Documentation

1. CRC confirms documentation of decisions, provisional requirements, outcomes, and expiration dates.

7. Compliance and Enforcement

Describe how compliance will be monitored and what consequences apply for non-compliance.

• A product granted provisional approval must have an expiration date to assess if the product has reached compliance or validate that the product continues to meet provisional requirements.
• A product that is not granted provisional approval may be submitted for an exception.
• A product that is not granted provisional approval may be resubmitted if the product has substantially changed.

8. Revision History

Version	Date	Author	Description
1.0	01/14/2026	Beth Somerfield	Initial release

Related Policies

• APS 9.0 Digital Accessibility Policy

Related Standard

• Minimum Digital Accessibility Standard (Interim)  

Related Procedures

• Exception Procedure for the Minimum Digital Accessibility Technical Standard (Interim)