Questions · Procurement, updates and cost
A university wants an EEAAP for our software. What is it, and what do we commit to?
An Equally Effective Alternate Access Plan (EEAAP) is a university’s written plan for giving people with disabilities equivalent access while your product has barriers, often those in your ACR. Campuses differ: Cal State San Marcos treats it as an internal plan, not a vendor duty; Nevada, Reno has the vendor sign its fix commitments; USC writes it with the supplier.
When a university asks for one
- Cal State San Marcos: when the vendor has no documentation, the VPAT looks incomplete or inaccurate, the VPAT reports barriers, or campus testing finds them. The plan is reviewed at each renewal.
- University of Nevada, Reno: for every product found non-conformant, alongside a vendor remediation plan whenever an applicable criterion is “Partially Supports” or “Does Not Support”.
- Cal State LA: when a product with accessibility problems, or without a VPAT, which is then assumed inaccessible, will be used for classwork or by 10 or more people.
What it contains, and who signs
Reno lists the barriers, their functional impact on users with disabilities, interim accommodations or alternative access, the vendor’s remediation commitments when available, and roles for implementation and monitoring. It is signed by the requesting department, the vendor (acknowledging remediation commitments where applicable) and the Office of Digital Accessibility, and approval “does not constitute acceptance of inaccessible technology.”
USC asks suppliers to disclose known gaps with remediation timelines and to co-create the plan: barriers, alternative methods, responsible parties including supplier roles, a timeline for reassessment or remediation, and a communication plan for an affected user. It notes that EEAAPs are temporary and generally not accepted as a long-term solution.
Why dates still matter
Under 28 CFR 35.200, a public university must ensure that web content and mobile apps it provides through contractual or licensing arrangements meet WCAG 2.1 AA from April 26, 2027 if the public entity it belongs to has a population of 50,000 or more, or from April 26, 2028 for smaller public entities and special district governments. The rule allows conforming alternate versions only where it is not possible to make content directly accessible because of technical or legal limitations (35.202). Expect a public buyer to want repair dates you can keep, not only a workaround.
How ACR Desk handles this
Our ACR gives every Partially Supports or Does Not Support row a specific remark, and the prioritized fix list names each issue, where it is, the criterion, who it affects and how to fix it: the barrier and impact parts of an EEAAP. You decide the remediation commitments and dates, and you sign them; we don’t sign plans for you or give legal advice. One retest within 90 days updates the ACR once fixes ship. Web-based products only. $1,490 (WCAG edition) or $1,990 (Section 508, EU or INT), fixed, in 5 business days.
Last reviewed: November 2, 2026. Not legal advice: rules change, and your buyer’s solicitation or contract governs what they require.
Sources
Primary sources only. Each was read on November 2, 2026.
- EEAAPs and Examples (what an Equally Effective Alternate Access Plan is, when it is needed) — California State University San Marcos, Instructional and Information Technology Services.
- ICT Procurement Process (VPAT, vendor remediation plan, EEAAP) — University of Nevada, Reno, Office of Digital Accessibility.
- EIT Forms Step-by-Step Guide: product not accessible or no VPAT (low impact or EEAAP) — California State University, Los Angeles.
- Accessible Procurement (supplier expectations, Equally Effective Alternative Access Plans) — University of Southern California, Institutional Accessibility and ADA Compliance.
- 28 CFR 35.200 — Requirements for web and mobile accessibility (ADA Title II) — eCFR, current text.
- 28 CFR 35.202 — Conforming alternate versions — eCFR, current text.