Accessibility Exception Process

The Accessibility Exception Process is the formal pathway for units to request approval to use an Information and Communication Technology (ICT) product or service that does not fully comply with accessibility standards. This ensures the university meets its legal obligations under ADA Title II and IITAA, while balancing functional and business needs. 

Exception Process Steps

Step 1: Determine if an Exception is Needed

Use the decision guidance chart to determine whether a request is required: 

Categories of Exceptions 

To set expectations, the university outlines categories: 

• Will not be granted: required classroom technologies, public-facing websites or applications, widely distributed campus-wide documents. 
• May be granted: optional classroom tools or supplementary technology, limited distribution or low exposure uses, cases where no fully accessible product exists. 
• Typically granted: legacy or archived materials where retrofitting is impractical. 
• Automatically granted: internal research tools with no impacted users, special-purpose ICT used by a very small group with no impacted users. 

An exception request is NOT required when: 

• The ICT has no human-facing interface. 
• The ICT is special-purpose technology used only by a very small group with no impacted users. 
• The ICT is used internally in a research setting with no impacted team members. 

Even if no exception is required, units are encouraged to draft an Alternative Access Plan (AAP) as a precaution. 

Step 2: Gather Required Documentation 

Before submitting, units must prepare: 

• Accessibility Evaluation Report – conducted by a university employee or an approved third-party. 
• Product Comparison Research – showing that the chosen product is the most accessible that meets the business need (or a written explanation if no comparison was possible). 
• Alternative Access Plan (AAP) – documenting how equal access will be provided for users with disabilities. 

Step 3: Submit the Exception Request 

• Complete the online Accessibility Exception Request Form 
• Upload the evaluation report, product comparison, and AAP with the request. 
• Submission notifies the unit head and the TARC chair/designee. 

Step 4: Committee Review 

• The request is placed on the TARC agenda. 
• TARC reviews the evaluation, product comparison, and AAP. 
• The committee may contact the requester for clarifications or request updates to the plan. 
• If information is missing or insufficient, the request is returned for revision. 

Step 5: Voting and Decision 

• A simple majority of voting members decide whether to approve or deny the request. 

Outcomes: 

•    Approved: The ICT may be adopted for use, with the AAP implemented. 
•    Denied: The ICT cannot be adopted unless the decision is overturned on appeal. 
•    Revise: TARC will provide actionable feedback to the requestor and will review the revised exception upon completion of revisions.  

Step 6: Communication of Outcome 

• The decision is sent to both the requester and their unit head. 
• If approved, the conditions of the AAP are binding. 
• If denied, units must either choose a different ICT or file an appeal with the ADA Coordinator. 

Step 7: Appeals 

The Requesting Individual may appeal a TARC decision to deny an exception request. The Requesting Individual’s Unit Head must agree to the appeal. The following process is utilized for appeals: 

• The TARC is notified by the Requesting Individual that they wish to appeal the denial. 
• Appeals must be accompanied by a rationale for the appeal. 
• The appeal request and rationale are directed to the ADA Coordinator. 
• The ADA Coordinator reviews the exception request and rationale for appeal. 
• The ADA Coordinator may discuss the appeal with TARC and/or the Requesting Individual. 
• The ADA Coordinator makes final determination of the appeal. 
• The ADA Coordinator makes a decision to approve or deny the exception request. Appeal Decisions are Final.  
• The TARC, the Requesting Individual, and Unit Head are notified of the final decision. 

Step 8: Renewal and Compliance 

• Exceptions are not permanent; they expire in 1–2 years. 
• Renewal requires a new accessibility evaluation and an updated AAP. 
• Units are responsible for monitoring expiration and ensuring renewal. 

Typical Timeline 

• Initial review and decision: ~10 business days. 
• Longer if revisions or additional evaluations are required. 
• Units should plan procurement timelines with this review period in mind.