BACK TO THE ITR PROCESS

The CSUSM ATI team adopted the CSU approved framework to assess Information and Communication Technology (ICT) acquisitions. The intent of this impact assessment framework is to promote a consistent approach to assessing high, medium or low impact on ICT products/services for an individual user or the campus population to perform their tasks. This framework will also determine if an Equally Effective Alternate Access Plan (EEAAP) is needed to supplement the ICT acquisition.

The ATI Impact Assessment involves a 3-step approach:

• Step 1: Assess Risk Factors

  Instructions:

  Complete the ITR form which will prompt you for a variety of information that will help IITS gauge the Impact and Probability sections below.

  Impact:

  Several factors contribute to assessing the impact of ICT products or service(s) acquisitions. Each of these factors are outlined below; along with sample questions for gauging the relevance of those factors.

  Will there be a barrier?

  • If non-ATI compliance purchase is processed, will persons with disabilities be denied access to a university program or service?
  • If non-ATI compliance purchase is processed, will persons with disabilities receive erroneous, incomplete, or untimely information?

  Is it a critical barrier?

  • Does this ICT acquisition relate to an essential academic or administrative function?
  • Does the lack of non ATI compliant purchase contribute to ineffective operations (i.e. would the cost/complexity of providing accommodations be burdensome or disruptive)?

  What are the risks associated with the barrier?

  • Does the lack of this non ATI compliant purchase increase the risk of the University being exposed legal ramifications?
  • Has the University received complaints from persons with disabilities due to lack of meeting ATI Section 508 compliance mandates?

  Are there workarounds for the barrier until resolved?

  • Are there accessible ICT products, alternative ICT products, or workarounds to provide the related academic or administrative function?

   

  Probability

  • How many people would be impacted by a non ATI compliant purchase?
  • Would members of the public be impacted by the lack of this activity or process?
  • Will the lack of these actions create barriers that reoccur or persist over time?
  • Is the lack of non ATI compliant purchases likely to impact programs or services with a primary audience of persons with disabilities?
• Step 2: Assign a Risk Level

  Instructions:

  First, determine a Risk Level (high/medium/low) for each of the Impact and Probability factors.

  1. Compare your answers from the Impact and Probability questions above to the expected outcomes in the Risk Assessment Framework table below.
  2. Select a risk level which best corresponds to your answers.

  Next, assign an overall Risk Level (high/medium/low) that incorporates both Impact and Probability levels. The Overall Risk Assessment chart below illustrates the following points:

  • A Risk Level of high should be assigned to ICT purchases in which both Impact and Probability factors are rated high
  • A Risk Level of medium should be assigned to ICT purchases in which one factor is rated high and the other rated low
  • A Risk Level of low should be assigned to ICT Purchases in which both Impact and Probability factors are rated low

  Risk Assessment Framework

  Risk Level	High	Medium	Low
  Impact	Denies access to a program/service Impacts a critical program/service Creates high accommodation costs Creates significant legal exposure No available workarounds	Limits access to a program/service Impacts an important but non-critical program/service Creates moderate accommodation costs Creates moderate legal exposure Workarounds for some functions	Does not limit access to a program/service Impacts an optional program/service Creates little or no accommodation costs Creates little or no legal exposure Workarounds for all functions
  Probability	Impacts a large audience or members of the public Creates frequently-recurring barriers Strong likelihood of impact for persons with disabilities	Impacts a moderately-sized audience, not public-facing Creates occasionally-recurring barriers Moderate likelihood of impact for persons with disabilities	Impacts a small audience, not public-facing Does not create recurring barriers Low likelihood of impact for persons with disabilities

   
• Step 3: Determine Campus Capacity Level

  Instructions:

  First, complete the questions provided below:

  • Does the institution have personnel with sufficient technical knowledge to address accessibility gaps?
  • Does the institution have personnel with appropriate tools (software/hardware) to address accessibility gaps?
  • Does the institution have sufficient financial resources to address accessibility gaps?

  Next, determine your campus Capacity Level by assessing the sufficiency of available resources. Select a Capacity Level that most closely corresponds to the answers to the questions above. A description of the 3 possible Capacity Levels is provided in the table below.

  Capacity Level By Available Resources

  Capacity Level	Description
  High	Institution has sufficient resources (knowledge, tools, and funds) to address all issues
  Medium	Institution has sufficient resources (knowledge, tools, and funds) to address some of the issues
  Low	Institution has sufficient resources (knowledge, tools, and funds) to address few (or none) of the issues

  If the Capacity Level is determined to be a High or Medium level, then an Equally Effective Alternate Access Plan (EEAAP) shall be required before Purchasing approves the ICT acquisition.

  If a product is verified as low impact by the ATI team, it will be excluded from further ATI review.