Accounting for Accessibility in Library Acquisitions: the University of Tennessee Experience

By Elyssa M. Gould (Department Head, Acquisitions & Continuing Resources, University of Tennessee, Knoxville) and Leigh Mosley (Accessibility Coordinator, University of Tennessee, Knoxville)

At the University of Tennessee, Knoxville, Elyssa Gould and Leigh Mosley have created a complete process for discovering, documenting, and communicating accessibility compliance for the library’s electronic collections. This interview describes the program’s genesis, development, and constant cultivation and improvement. Our talk has been edited for clarity, conciseness, length, and grammar.

How did you discover the need for your process and documentation?

Elyssa: In 2019, the UT General Counsel’s office determined that the University needed to heighten awareness of and more tangibly assure accessibility regarding all student-facing technologies on campus. Naturally, since the library possesses a great deal of these types of resources in our collection, essentially all of our electronic resources would be part of this policy … we’re probably the most impacted campus unit. From at least 2016, before I started working here, we’d already had language in all our license agreements that licensed resources were to be accessible, but General Counsel now required documentation that all resources be tested to be WCAG 2.0-compliant1 and that VPATs2 and accessibility roadmap plans be requested from all external vendors. Another staff member and I scrambled to ask every single library vendor for their VPATs; I don’t remember the return rate, but it wasn’t very impressive. The UT Office of Innovative Technologies was pulled in to help us test our resources against the VPATs and, after a short while, we quickly realized that, with the number of products and the number of staff we had at the time, this time-consuming process requiring detailed notes and documentation would not scale very well. With the campus priority and support from library administration and our provost, a new position, Accessibility Coordinator, was created within the Acquisitions & Continuing Resources department in 2022. We were really lucky to find Leigh, who had plenty of existing experience and dedication in accessibility and compliance, and also a library degree!

How did you gain your initial experience in accessibility matters, Leigh?

Leigh: I’d been working for the University of Tennessee system, creating annual compliance training for the Human Resources department. Soon after I was hired, we got feedback from users that our courses were inaccessible! No one in our office had any training or knowledge; a faculty member who was hearing impaired told us that our videos didn’t have any captions. So basic — our minds were blown. A brand new world opened … and I wanted to figure it out. I took whatever training I could find in digital accessibility. The Tennessee Board of Regents has a wonderful online course and I met others who know so much about the issues and how to support accessibility. I have to point out that community colleges often do the lion’s share of championing accessibility and I learned so much from these colleagues at other institutions. I also took a course here on campus in Knoxville from the Office of Innovative Technologies about universal design and was introduced to the WCAG and used these lessons to try to improve our annual compliance training.

When I heard about the new job at the library, I was so excited. I think this is my dream job. My job focuses on digital accessibility, however … I don’t have an ADA background so I don’t monitor the “built environment,” such as stairs or corridors, for example.

How does the library coordinate its activities around accessibility with other campus departments in general?

Leigh: I focus on the resources that are part of the library electronic collections. The Office of Student Disability Services on campus takes responsibility for remediating any resource that has been assigned to a disabled student as part of their coursework, something listed on a syllabus. But if a student is using library resources as part of their general research, for example, working on a paper, then providing accessible materials to them is the library’s responsibility. There is also an ADA coordinator on campus who looks after ADA concerns and requirements in general for all campus users, including staff.

How does the library track and manage accessibility for its products?

Leigh: It’s part of our acquisitions workflow. When a product is made available for a trial or is under consideration by a selector, or coming up for renewal, I request a VPAT from the vendor. This might be a straightforward request or it might involve more digging, detective work, or multiple correspondence. Then I create a “scoring rubric” for the rest of this initial process, which covers some key aspects of accessibility as I work to test the resource against what is stated in the VPAT, using WCAG 2.1 requirements. This rubric is my internal notes, so it’s subjectively constructed, but it includes major, obvious things like keyboard navigation — if you need to use a library resource but you’re unable to use a mouse — then that’s a pretty big requirement. I also note whether the VPAT was hard to obtain; whether the entries “make sense” — if it’s written in a transparent way. Does the product’s technical assistance page even mention “accessibility” … does anyone answer the Accessibility email address posted? Was the VPAT filled out by someone internal to the vendor, or a third-party accessibility consultant? What is the date on the VPAT in relation to the date of the product we are evaluating? Is every item on the VPAT listed as supported, with no explanatory notes to back up that claim?

After I review the VPAT and complete my own manual testing and scan of the code, I create a second document, the Accessibility Roadmap . UT based ours on one used at California State University. This is a document required by our campus procurement and must be included with the product contract. I use it to communicate with the vendor, to list the biggest accessibility problems I uncovered in testing, and to request information from the vendor about what corrective action they plan to take: where do these fixes sit in their own development roadmap? We assume that all products have constant development, including security patches, bug fixes, etc., and UT takes the perspective that accessibility issues are bugs, not that supporting accessibility is a product enhancement or a feature request.

Many vendors are extremely grateful to receive the UT Libraries Accessibility Roadmap document! They recognize that although it is a general check of the product’s accessibility, it’s professional, knowledgeable feedback, and they may pass it on directly to developers. I’ve had at least one case where issues I cited in a Roadmap document were fixed by the following week. Other vendors must respond on the roadmap to agree that the functionality is missing and supply an estimate for when the cited support for accessibility will be released.

Elyssa: We won’t purchase the resource without this written vendor commitment.

Leigh: Another document that is used internally, and also filed with the Office of General Counsel with the contract, is the Alternate Access Plan. I develop this document, and it’s reviewed and approved by Elyssa, our Associate Dean, and then the campus ADA Coordinator. It describes the accessibility issues and provides actions that we’ll take — in the short term — if a disabled user comes forward with a need. All of these documents are part of the contract and filed in the UT contract system. The presence of these documents is a recognition that we’ve done due diligence. UT wants to document that vendors are aware of the issues and that they are making good faith steps to improve, so that they can’t rely on any defense that they didn’t know there were accessibility problems with their product.

Do end users see any of this material you’ve so painstakingly organized?

Elyssa: The last artifact we create is the Accessibility Note, which is included in our catalog record and Database A-Z list entry. It notes the defects in accessibility support that Leigh listed in the Alternate Access Plan and requests users in need contact the electronic resources help email, where their note is routed to Leigh for follow-up per the actions listed on the Alternate Access Plan.

I have to admit we don’t have Accessibility Notes for all our resources yet, but it is my five-year goal to have them for our entire collection. Nothing is 100% accessible, admittedly, but while we don’t require all of our suppliers to be perfect, we do require them to commit to improving.

How can you review improvement?

Leigh: I make a note of the promised dates for accessibility improvements listed on the Accessibility Roadmap, and follow up on these items as development dates pass. What did they promise? Did they deliver? I can check the product directly and contact the vendor if needed. Sometimes I see the issues are fixed and I’ll update the Alternate Access Plan and Accessibility Notes. Sometimes the dates for support change… but I will also note how many times the can gets kicked down the road, for inclusion in future negotiations.

I am also working on transferring my own accessibility notes from detailed spreadsheets into outputs that are more visually- oriented. For example, I can see how many of our resources are keyboard inaccessible, or how many multimedia resources don’t support captions, and note over time how that number may change. This helps the library understand its collection better, keep track of our efforts in accessibility, and support the broader vendor communications that need to happen.

What are some of your planned enhancements to your own process?

Leigh: Oh, we are definitely working on continual improvements. A bit of a longer-term project: we are trying to assemble a funding plan to enable students with specific disabilities to become more involved with testing, and pay them for the work. A little while ago I put out an anonymized survey that the Office of Student Disability Services helped promote, asking users with disabilities about their use of library resources. One item was to request any volunteers to allow me to watch them use resources. This gave me better intelligence about their perspectives and uncovered new obstacles that I can add to my general test plan. But we can’t rely on volunteers for this input all the time.

If we had funding to support such a user-testing program, we could be more confident that we’re able to support the range of disabilities that we need to. Some users are visually impaired, some are dyslexic, some suffer from ADHD or general information processing disorders. There is no one-size-fits all disability fix and we will all need to continue evolving how we make resources accessible and usable to different audiences.

What are your general accessibility tips or requests for vendors or content providers?

Leigh: Please post your VPAT in an easy-to-find area of your website. Don’t make us log in to get it; don’t make us email someone … please just put it there, maybe on your page about accessibility support! If you have an accessibility email address, please ensure that inbox is monitored and that emails will get replies. Review and update your VPAT together with your product updates. But also recognize that VPATs aren’t the end of the conversation; they can be the beginning!

Elyssa: It’s also helpful if vendors list how they are testing the resource, for example, detailing if they used NonVisual Desktop Access (NVDA) or JAWS in their own environment. We are seeing more of this recently and it’s very helpful … it helps us to decide where we should focus our local testing, and it shows that they understand the details on accessibility support. A lot of companies seem to think they can use an automated code scanner, but those often don’t catch major issues.

Please provide your staff with accessibility training and awareness. It takes time and money, but it is an investment that will pay off. Many resources and educational tools are freely available and easily findable via general web searching. But we also need people high on the company structure to prioritize accessibility support in product development, so talk about it with your managers as well.

What are your general accessibility tips or requests for librarians?

Elyssa: Participate in the Library Accessibility Alliance3 and communicate with your consortium partners about these issues. The Library Accessibility Alliance is an amazing organization that also does comprehensive testing of resources by third-party companies, documents issues, and organizes vendor responses and reports. It’s such a good place to make connections and hear about what is going on in other libraries. We rely on it for much of the information we use in our process and local discussions.

Top-down support and policies that you can point to, ideally at the campus level, are also helpful in prioritizing your work.

Leigh: Ask your vendors for their accessibility VPAT, even if you don’t think you have time to examine it in detail! It doesn’t take much time to ask for it. If they hear about it from all of their customers, they will realize how core a tool it is in any product release. Ideally, it would be a really common request. Ask the company reps what they are doing to improve their accessibility support. If vendors and content providers hear the same questions from different customers, they’ll recognize the lingo and be able to follow up internally.

We are all partners trying to ensure successful experiences for our users and need to work together, no matter which library we work for. We’re here for everyone … that’s part of being a librarian!

U Tennessee Resources:

Leigh Mosley’s internal rubric: https://docs.google.com/ document/d/1yUuJkPb4TI9lXVs3GrwaawXs3uaBUJFk/edit Accessibility Roadmap (California State University): https:// ati.calstate.edu/sites/default/files/documents/templates/ Accessibility_Roadmap_template_v1.02.docx

Alternate Access Plan: https://oit.utk.edu/software-hardware/ accessible-evaluation/#custom-collapse-0-3

Endnotes

1. W3C Web Accessibility Initiative (WAI), WCAG 2 Overview, https:// www.w3.org/WAI/standards-guidelines/wcag/, Accessed 2 April 2024.

2. U.S. General Services Administration, Section508.gov. Voluntary Product Accessibility Template (VPAT®), May 2022. https://www. section508.gov/sell/vpat/, Accessed 2 April 2024.

3. Library Accessibility Alliance, https://www.libraryaccessibility. org/

Example of Accessibility Note: