Accessibility from Scratch: One Library’s 
Journey to Prioritize the Accessibility of 
Electronic Information Resources
Author: Kirsten Ostergaard
This is a postprint of an article that originally appeared in The Serials Librarian on Sept 11, 
2015.”. http://dx.doi.org/10.1080/0361526X.2015.1069777
Kirsten Ostergaard (2015): Accessibility from Scratch: One Library’s Journey
to Prioritize the Accessibility of Electronic Information Resources, The Serials 
Librarian,69:1–14, 2015 DOI: 10.1080/0361526X.2015.1069777
Made available through Montana State University’s ScholarWorks 
scholarworks.montana.edu 
The Serials Librarian, 00:1–14, 2015
Published with license by Taylor & Francis
ISSN: 0361-526X print/1541-1095 online
DOI: 10.1080/0361526X.2015.1069777
Accessibility from Scratch: One Library’s
Journey to Prioritize the Accessibility of
Electronic Information Resources
KIRSTEN OSTERGAARD
Montana State University, Bozeman, Montana, USA 5
The increased development and use of electronic and information
technology in higher education raises questions about accessibility
for individuals with disabilities. In academic libraries, providing
accessible electronic information resources ensures equal access
and opportunity to information. This article provides a contex- 10
tual understanding of accessibility in higher education as well
as strategies for evaluating, negotiating, and procuring accessible
electronic resources licensed through third party vendors.
KEYWORDS accessibility, academic libraries, electronic infor-
mation resources, electronic and information technology (EIT), 15
voluntary product accessibility template (VPAT), Web content
accessibility guidelines (WCAG), Section 508
INTRODUCTION
The Montana State University (MSU) Library is implementing an accessibility
plan to acquire accessible electronic information resources. The growing use 20
of electronic and information technology (EIT) in the classroom is changing
the landscape of education, connecting students to a wealth of information,
and creating dynamic new learning experiences. In many cases, however,
EIT has created barriers to education for students with disabilities. As a result,
equal access and opportunity in education has been compromised. 25
© Kirsten Ostergaard
Address correspondence to Kirsten Ostergaard, Electronic Resources & Discovery Services
Librarian, Montana State University, P.O. Box 173320, Bozeman, MT 59717-3320, USA. E-mail:
kirsten.ostergaard@montana.edu
1
2 K. Ostergaard
Library users have diverse needs. Regardless of visual, physical, devel-
opmental, or learning abilities, it is our role to ensure these needs are met.
Accessible EIT is designed for use by people with the widest range of abilities
and disabilities.1 The first principle in the American Library Association (ALA)
Code of Ethics expresses a commitment to providing the highest level of 30
service to all library users.2 By establishing an understanding of what acces-
sible EIT means and a commitment to improved access, academic libraries
can develop and incorporate a plan into their workflow that supports the
inclusivity of our diverse user communities.
This article will establish concepts of accessible EIT and review recent 35
cases involving inaccessible EIT in higher education. From there the arti-
cle turns to federal legislation for an understanding of how individuals with
disabilities are protected from discrimination in the United States. Lastly,
the article will explore strategies to implement an accessibility plan in your
acquisitions process. The University of Montana (UM) recently reached a 40
resolution agreement with the U.S. Department of Education, Office for
Civil Rights to make all EIT on campus fully accessible. This legal case is
particularly notable because it is the first involving a branch of the fed-
eral government that cites inaccessible library resources. Members of the
Montana State University (MSU) Library, “sister institution to the University 45
of Montana,” have gleaned from the experiences at UM in the creation and
implementation of their accessibility plan. It should be noted that this article
will not provide an examination of accessibility and usability testing. While
the value of usability testing cannot be underscored, this article will focus
on providing a contextual framework for incorporating accessibility in the 50
procurement process.
ACCESSIBLE EIT
The use of technology and the Internet are increasingly essential components
of education, the modern workplace, and everyday life. The web serves as
an access point to a wealth of information and interaction. EIT presents 55
many opportunities for education, innovation, commerce, and community.
When EIT is developed with accessibility in mind, all users have equal access
and opportunity to interact with, contribute to, and understand information.
Accessible EIT removes barriers and enables people with disabilities to more
actively participate in society.3 60
EIT, including Internet websites, databases, learning management sys-
tems, or classroom technologies, is made accessible when it needs no assis-
tive technologies or is compatible with assistive technologies.4 Inaccessible
EIT presents barriers to information and interaction for the disabled and
can range from websites with poorly labeled page elements, to unreadable 65
Portable Document Format (PDF) files, or streaming media services without
Accessibility from Scratch 3
closed captioning for viewers. Inaccessible EIT not only negatively affects
students with disabilities, but may require additional modifications to com-
ply with accessibility standards. For example, a streaming audio service that
does not provide transcripts for the hearing impaired may warrant additional 70
labor to produce transcripts. These one-shot modifications, however, can be
time consuming, cost prohibitive, and redundant.
Katie Ellis and Gerard Michael Goggin encourage us in Reimagining the
Good Life with Disability, to think about new ways of creating that embrace
disability rather than reject it as something that needs to be overcome or 75
cured.5 In higher education, this means establishing an institutional commit-
ment to creating a more holistic learning environment for all students; one in
which disability does not impede the learning experience, but is rather incor-
porated into the environment.6 History has shown that when products and
services are designed for the disabled, there are unintended, yet serendip- 80
itous, benefits for other segments of the population. For example, closed
captioning on televisions is used widely at gyms and in restaurants. Curb
cuts, the ramps found transitioning from sidewalks to roadways, originally
intended to accommodate individuals in wheelchairs, are used heavily by
people pushing strollers or riding bikes, and servicemen and women trans- 85
porting goods into stores. Improving access to products and services not
only serves individuals with disabilities, but enriches society by encourag-
ing understanding, perspective, and increased involvement through inclusive
practices. Accessible EIT is the next step in that legacy.
KEY CASES 90
In higher education, colleges and universities are required to comply with
disabilities rights laws that protect students with disabilities from discrimina-
tion. However, accessibility for EIT is complex and wide-ranging. Some key
cases involving library resources, include:
● 2013, University of California, Berkeley. In 2013 the University 95
of California, Berkeley entered into a Settlement Agreement with the
Disability Rights Advocates to improve access to school materials for
students with print disabilities.7 A print disabled person “cannot effec-
tively read print because of a visual, physical, perceptual, developmental,
cognitive, or learning disability.”8 The Disability Rights Advocates, an orga- 100
nization dedicated to protecting the civil rights of people with disabilities,9
represented three students at UC Berkeley and successfully negotiated a
solution with UC Berkeley. New policies and procedures now ensure the
resources are in place to provide access to written material for the print
disabled. 105
4 K. Ostergaard
● 2013, Penn State University. In 2013 Penn State University agreed to a
voluntary Resolution Agreement with the National Federation for the Blind
“as part of the U.S. Department of Education, Office for Civil Rights (OCR)
Early Complaint Resolution (ECR) process”10 to resolve access issues to
computer and web-based technologies that were inaccessible to blind stu- 110
dents and faculty. The National Federation for the Blind is committed to
equal rights for the blind by removing legal, economic, and social discrim-
inations.11 As a result of this resolution agreement, Penn State University
committed to making all EIT accessible to blind students, faculty, and staff.
● 2014, University of Montana. In 2014 UM reached a Resolution 115
Agreement with the U.S. Department of Education, OCR to resolve the
inaccessibility of electronic and information technology across campus.12
Similar to Penn State, UM committed to implementing a plan that makes
all EIT fully accessible. As a part of their resolution agreement, UM
must provide the OCR with reports documenting progress of accessibility 120
measures.
In all of these cases library resources are explicitly referenced. The inacces-
sible library resources cited in complaints include websites, databases, and
an online catalog system. Of these three cases, the University of California,
Berkeley and Penn State University reached settlement agreements with non- 125
profit organizations. The University of Montana is the only case in which
library resources are referenced, to reach a resolution agreement with a
branch of the federal government. With that in mind, let’s explore how
accessibility is defined in the UM Resolution Agreement as well as review
legislation in place to protect the disabled from discrimination in higher 130
education.
LAW
According to the UM Resolution Agreement, when something is accessi-
ble, it means that “individuals with disabilities are able to independently
acquire the same information, engage in the same interactions, and enjoy 135
the same services within the same timeframe as individuals without dis-
abilities, with substantially equivalent ease of use.”13 Accessible EIT does
not require delayed accommodation. Angela Dresselhaus defines an acces-
sible library resource as “the ability [of persons with visual, perceptual or
physical disabilities] to obtain the same information, at the same time, for 140
the same price and at the same quality [as persons with no disability].”14
Accessible EIT empowers disabled students, faculty, and staff to participate
in the educational process in real time, without undue burden. In 2010, the
U.S. Department of Justice, Civil Rights Division (DOJ CRD), and the U.S.
Department of Education, Office for Civil Rights (ED OCR) together wrote 145
Accessibility from Scratch 5
a “Dear Colleague” letter stating that the required use of technology that
is inaccessible to an entire population of individuals with disabilities is dis-
crimination prohibited by the Americans with Disabilities Act of 1990 (ADA)
and Section 504 of the Rehabilitation Act of 1973.15 The Departments request
that all colleges and universities work to ensure that technology used in 150
education is accessible to all individuals, regardless of ability.
Both the departments of Education and Justice share responsibility for
enforcing the ADA and Section 504 of the Rehabilitation Act. Table 1 details
the legislation in place to protect the rights of individuals with disabilities in
higher education. 155
In the last five years, many lawsuits between academic institutions and
the federal government have centered on the accessibility of EIT. Electronic
and information technology is defined as “information technology and
any interconnected system or subsystem of equipment that is used in the
creation, conversion, or duplication of data or information.”23 EIT can 160
include Internet websites, databases, learning management systems, and
classroom technologies, among other things. Currently, standards defined in
Section 508 of the Rehabilitation Act require federal agencies to make their
EIT accessible to people with disabilities.24 By requiring federal agencies
to develop, procure, and maintain EIT that is accessible, Section 508 calls 165
for proactively accessible EIT. This reframes expectations about how
services and products are available to the disabled. The standards set
forth in Section 508 of the Rehabilitation presently only apply to federal
agencies. However, the Department of Education is increasingly referencing
Section 508 for guidance or as a requirement for accessible EIT in lawsuits 170
with academic institutions, including the University of Montana (http://
www.umt.edu/accessibility/docs/FinalResolutionAgreement.pdf), University
of Cincinnati (http://www.nacua.org/documents/UniversityCincinnatiDOE
WebsiteAagreement.pdf), and Youngstown State University (http://www.
nacua.org/documents/YoungstownStateUniversityAgreement.pdf), to name 175
a few.
Ready-made, accessible EIT is still a work in progress. However, the
federal government and academic institutions can cooperate and move the
market to improve access by creating accessible content and contracting with
vendors that provide accessible EIT products and services. 180
ASSESSMENT TOOLS
When acquiring new electronic information resources, it is important to
understand what is required for a product or service to be accessible and to
document procurement decisions relative to accessibility compliance. There
are two tools in place to guide accessible acquisitions, the Voluntary Product 185
Accessibility Template (VPAT) and the Web Content Accessibility Guidelines
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Accessibility from Scratch 7
(WCAG). The purpose of the VPAT is to assist Federal agencies and other
buyers assessing commercial EIT products and services for features that sup-
port accessibility.25 These could include, for example, software and hardware
products. The Web Content Accessibility Guidelines are industry best prac- 190
tices used to evaluate accessible web content.26 Let’s take a closer look at
each of these tools and how they can be used in the procurement process.
Voluntary Product Accessibility Template (VPAT): The VPAT was devel-
oped for federal contracting officials to acquire accessible EIT. It is a tool
created for vendors to assist with this process. A VPAT is a document that 195
details requirements for compliance with Section 508 of the Rehabilitation
Act. Vendors respond to relevant sections of the document disclosing how
their software or IT products support each criteria.27 Once completed,
federal agencies and buyers can then review VPAT forms to evaluate the
accessibility of a product and identify any potential deficiencies. There are 200
eight criteria in a VPAT form that reference elements of Section 508 of the
Rehabilitation Act, including:
1. Section 1194.21 Software Applications and Operating Systems
2. Section 1194.22 Web-based Internet Information and Applications
3. Section 1194.23 Telecommunications Products 205
4. Section 1194.24 Video and Multi-media Products
5. Section 1194.25 Self-Contained, Closed Products
6. Section 1194.26 Desktop and Portable Computers
7. Section 1194.31 Functional Performance Criteria
8. Section 1194.41 Information, Documentation and Support 210
Official VPAT forms can be accessed on the U.S. Department of State
website: http://www.state.gov/m/irm/impact/126343.htm.
Web Content Accessibility Guidelines (WCAG): The World Wide Web
Consortium (W3C) established standards for accessible web content called
the Web Content Accessibility Guidelines (WCAG). The federal govern- 215
ment uses WCAG as a metric for evaluating web content.28 Web content
constitutes information in a web page or a web application, including
text, images, and sounds.29 WCAG 2.0 is a technical standard that can be
applied to academic institutions. It consists of 12 guidelines organized into
four principles: perceivable, operable, understandable, and robust. The 220
W3C has organized each guideline so that it can be measured by success
criteria at one of three levels: A, AA, or AAA.30 The University of Montana
Resolution Agreement requires bidders to meet the accessibility standards
of WCAG 2.0 Level AA for web-based technology.31
Libraries can take advantage of these tools when negotiating with vendors 225
during the acquisitions process. A VPAT would be requested in instances
where a library is procuring an EIT product or service. Information about
8 K. Ostergaard
WCAG 2.0 compliance would be requested when negotiating with vendors
or publishers that maintain a web interface. In many cases, requesting a
VPAT as well as a WCAG statement may be appropriate. 230
With an understanding of accessible EIT, the laws in place to protect
the rights of the disabled, and tools to evaluate EIT, let’s turn now to strate-
gies you can employ at your library. The Montana State University Library is
implementing a plan that prioritizes the accessibility of electronic informa-
tion resources. The following steps describe strategies and considerations to 235
incorporate into your procurement processes.
Strategies for Acquiring Accessible Electronic Information Resources
STEP 1: CONNECT WITH INSTITUTIONAL ADMINISTRATION AND DISABILITY
SERVICES
One of the first steps to begin analyzing the library’s role in accessible elec- 240
tronic resource acquisitions is to connect with university administration and
disability services to learn about accessibility on campus.
● Research federal and state laws that protect the disabled and apply to your
academic institution. Determine what level of accessibility is required for
EIT products and services. 245
● Inquire about campus policies and resources in place for faculty and staff
in support of accessibility compliance.
● Establish an understanding of the role of disability services. What does the
disabled population on your campus look like? What services and assistive
technologies are available? 250
Connecting with departments across campus presents numerous opportuni-
ties for increased awareness, understanding, participation, and partnership
that benefit and further the mission of accessibility. The library can learn
about challenges that disability services faces and perhaps identify opportu-
nities for improved products and services. Furthermore, libraries gain insight 255
into requirements for accessibility, which in turn, instructs communication
with third party vendors.
STEP 2: MODIFY COLLECTION DEVELOPMENT POLICY
The second step is to modify your Collection Development policy to include
language valuing accessible electronic resources. The following example is 260
in effect at the MSU Library:
CD Policy: The Montana State University Library is committed to pro-
viding accessible electronic information resources to individuals with
Accessibility from Scratch 9
disabilities. We make every effort to gather information and prior-
itize the acquisitions of accessible electronic information resources, 265
except in cases where a product or service would be fundamentally
altered.
The MSU Library is still actively learning about accessibility and all the ways
in which the library can improve services. By modifying our Collection
Development policy, we express a commitment to improving access to 270
electronic products and services.
STEP 3: COMMUNICATE WITH VENDORS
Electronic information resources can include eJournals, eBooks, database
collections, streaming media services, and other interactive web services.
It is important to ensure that the content and the platforms of electronic 275
information resources are accessible. Communicate with vendors about your
institution’s accessibility needs. When negotiating with vendors:
● Inquire about the accessibility of electronic products.
● Require that vendors adhere to legal requirements (federal, state, and
provincial laws) for accessibility. Accordingly, request VPATs in support 280
of this mission and to inform electronic resources acquisitions.
● Request that vendors meet WCAG 2.0 best practices for accessible web
content.
● Inquire about content file formats (e.g., Portable Document Format [PDF],
TXT, or Hyper Text Markup Language [HTML]). Is the content directly 285
accessible or is it compatible with assistive technologies? If not, does the
vendor plan to meet accessibility requirements in the future?
● Require vendors to incorporate a clause in license agreements that clearly
defines the accessibility of their products. The 2012 Report of the ARL Joint
Task Force on Services to Patrons with Print Disabilities includes model 290
licensing language for consideration.32
● In the event that a vendor’s product is inaccessible, explore negotiations
allowing for the content to be adapted into accessible formats at your
academic institution or by a third party.33
Gathering information empowers your library to make informed procure- 295
ment decisions. Furthermore, communicating with vendors and explaining
your institution’s accessibility requirements leads to improved product
development. As vendors learn what is important to libraries, they can
begin to think strategically about where and how to improve their
products.34 300
The following template was designed and adapted from the University
of Montana’s Mansfield Library. It is employed by MSU Library and serves as
10 K. Ostergaard
a starting place to begin thinking about how you communicate with vendors
about current subscriptions. As you draft up language, define your insti-
tution’s requirements. You may consider contacting your institution’s legal 305
counsel or procurement office if further review is necessary.
TO THE WEB ACCESSIBILITY COORDINATOR:
The _______________ Library has modified its Collection Development
policy to prioritize the accessibility of electronic and information tech-
nology resources. In accordance with Section 504 of the Rehabilitation 310
Act and Title II of the Americans with Disabilities Act, our goal is to
provide equal access and opportunity to our patrons. Accordingly, we
request that each electronic resource provider adhere to Level AA of the
Web Content Accessibility Guidelines (WCAG) 2.0 published by the W3C’s
Web Accessibility Initiative. 315
We ask that you submit documentation about WCAG conformance as well as
a Voluntary Product Accessibility Template (VPAT). The VPAT Documentation
can be found on the U.S. Department of State website: http://www.state.gov/
m/irm/impact/126343.htm. Please send a completed VPAT to ____________
by __________. 320
STEP 4: DOCUMENT FEEDBACK AND ASSESS PRODUCT ACCESSIBILITY
Carefully document communication with vendors and any procurement
decisions. Gather forms for review and work in collaboration with your pro-
curement or disabilities services offices to identify someone to assist with
reviewing VPATs. Pledging to evaluate and procure accessible electronic 325
information resources and allocating the personnel and financial resources
to do so is critical for the success of improved access.
Acquisitions budgets have historically been defined as monies des-
ignated for procuring new resources. Academic libraries acquire new
resources to provide access to information. These resource types include 330
print resources, electronic resources, maps, movies, and music, to name a
few. As libraries increasingly encourage open access publishing models and
acquire electronic information resources to optimize discovery, remote, and
mobile access, improved accessibility can be integrated into this budgeting
model. The MSU Library has renamed the Acquisitions Budget to Access 335
Budget. Allocating funds to review, acquire, and in some cases convert elec-
tronic resources to an accessible format falls under the purview of this new
budgeting model and supports access to information.
Accessibility from Scratch 11
STEP 5: DESIGNATE A LIBRARY LIAISON TO DISABILITY SERVICES
Designate a liaison to partner with disability services. Liaisons maintain 340
open lines of communication between departments that may not otherwise
interact. A liaison to disability services can keep abreast of developments
and trends in assistive technologies and participate in the campus accessi-
bility dialogue. By understanding the changing needs and practices of our
students and disability services, library liaisons are poised to support student 345
success, improve access to information, and advance the library’s mission
within the larger institution.35
The next, more advanced step to ensuring accessibility is usability test-
ing. Accessibility does not necessarily equate to or guarantee the usability
of a service or product. Usability is a system’s ability to perform the specific 350
task for which it was designed when utilized by individuals with the widest
range of capabilities.36 For students interacting regularly with electronic infor-
mation resources, usability is essential for student success. Conduct usability
tests with disabled students, faculty, and staff for more comprehensive prod-
uct evaluations. In fact, accessibility scans of electronic resources often reveal 355
performance problems and discrepancies with information in a vendor VPAT.
Libraries can help overcome barriers to information by working with disabil-
ity services and vendors to document and address the usability barriers users
encounter.37 Usability tests expose flaws in vendor products and increase
an understanding of the difficulties that students with disabilities face when 360
interacting with EIT.
CONCLUDING THOUGHTS
The rapid development and use of EIT in everyday life presents new
opportunities for interaction, education, commerce, and community. EIT is
connecting people and information in radically new ways. Accessible EIT 365
is critical to ensuring equal access and opportunity to information, services,
and products for all segments of the population, including the disabled.
In higher education, academic libraries can support and improve access
to electronic information resources by embedding accessibility measures in
the acquisitions process. In addition to integrating accessibility locally, pro- 370
fessional collaboration is essential to reduce redundancies and work more
efficiently. Laura DeLancey created a VPAT Repository (http://uniaccessig.
org/lua/vpat-repository/) to house vendor VPATs, accessibility statements,
and finding aides. Libraries can contribute by requesting vendors to submit
VPATs and any other supporting documentation to the repository during the 375
negotiation process. Likewise, it is important for usability test results to be
shared broadly and widely. Inaccessible electronic information resources are
unacceptable. As vendors continue to develop and update their products
12 K. Ostergaard
and services, it is critical that libraries stay abreast of changing legislation
and accessibility standards to effectively negotiate and demand accessi- 380
ble electronic information resources. Together, the work of libraries and
profressional organizations, like the Association of College and Research
Libraries (ACRL)’s Universal Accessibility Interest Group (http://www.ala.
org/acrl/aboutacrl/directoryofleadership/interestgroups/acr-igua) and LITA’s
Accessibility InterestGroup (http://www.ala.org/lita/about/igs/universal/lit- 385
iguacc)cansupporttheneedsofourusercommunitiesand improveaccess
toinformation.Togetherwecanadvocateforthedevelopmentandrigorous
testingofproactivelyaccessibleelectronicinformationresources.
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14 K. Ostergaard
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