Ron Lucey, Policy and Accessibility Manager for the Texas Department of Assistive and Rehabilitative Services (DARS) and Dan Kinnunen, Accessibility Specialist for DARS led this session.
Accessibility policy is mandated for every Texas state agency and university, with a deadline of June 30, 2009, including a plan for Web remediation. “Electronic curb cuts.”
Policy development is an ongoing policy, extends to the maintenance of the policy. Texas Government Code 2054.45, Subchapter M - 1 TAC 206, TAC 213. Says much the same thing as Federal 508.
There is a lawsuit from the National Federation of the Blind to the State of Texas. Suing for inaccessible Web-based human resources. The Target lawsuit–place of public accommodation. ADA does not have accessibility guidelines. Section 504 - prohibits discrimination based on disability in programs or activities receiving federal financial assistance. Section 508 - the standards live here.
1. Gain top level support and sponsorship
2. Organize a Web accessibility committee and needed subcommittees with representation from all stakeholders.
3. Apply sound project management principles and a project charter with planned deliverables.
4. Plan for effective governance to address committee process for decision making.
WebAIM
Intranet must be accessible as well. This ensures that qualified individuals with accessibility needs can succeed. Having an accessible intranet can’t wait til after you hire them. Must include other areas of Electronic and Information Resources (EIR). Any interconnected, subsystem that stores or transmits data. Any goods and services contracted by Texas. Phone service has to be accessible as well. Blogs fall under accessibility process.
Accessibility comes about through design. Don’t trust, TEST! Policy must include testing.
What doesn’t come under policy but must be compliant in order to do business with: software applications, multimedia, telecommunications, self-contained products and office equipment, procurement. Self-contained and embedded technologies (kiosks). Electronic voting. Voting kiosk should be self-voicing. Fax/copier, etc. falls under embedded products. Purchasing–write into contract accessibililty requirements.
By all means review what other universities/agencies have done. State borrowed from UT, who borrowed from Cal State. Taxpayers should not have to pay for policies more than once–plagiarism is OK.
Draft guidelines addressing HOW to meed the policy. Policy may be a short, one paragraph, concentrate on how to approach accessibility for each area. Iterative process. Define policy review, comment period, and approval process flow. Who do you need to sell it to next? Who are you accountable to? Build in the time for reasonable review and number of reviews.
Must include remedies to help other agents comply–don’t have to refuse the contract. Remedies should be IN the contract, along with the requirement for compliance.
Policy does not tend to change, until circumstances over time require it.
Procedures = can change frequently. Protocol for implementation (”how to”), are action oriented, outline the steps you expect and sequence to perform those steps. Work group must have the authority to edit procedures. Council of accessibility coordinators. Who is responsible? ID current and ongoing training needs. Integrate acesibility into existing systems: procurement, application/Web development, document control.
Implementation is ongoing. DHHS has 50,000 employees. Will inform/train them all about accessibility compliance, focusing on the various areas. Web-based training on accessibility.
Developing a communication plan to go back and educate where needed. Change management is paramount. Real consequences if we don’t follow. Example of mgr. putting up non-accessible page. Was told could either ask the commissioner for an exception, or make it compliant, or take it down.
Will need tools (WC3 to find free or low-cost tools) to determine initial compliance leves, develop remediation plan, then maintaing and improve compliance. Firefox IE have accessibility tools available. Can’t test large numbers of pages, but should be used on each page.
Audit/compliance - how and by whom the standard will be enforced, and what consequences will befall those who violate the policy? Each content contributor owns their own page. Single solution in footer that lists all approved plug-ins. Implement the same solution agency-wide where possible.
Define exceptions and who can grant them. Continually test and document, including alternative means of access for exceptions. Alternate means must do the same thing. How can a disabled manager access a site that can’t be read by Jaws reader (i.e. training records)? Usually end up with separate but unequal. May have to send it out to another division or agency, and what are the guidelines. Some solutions are tech, some human-based. Instead of entering data through site, enter via phone.
Ex. policies: Texas Health and Human Services (THHS), UT System, Texas Department of Insurance, IBM. Law, Texas Admin Code, policy, procedure, and coding to comply. Self-assessment tools are helpful, including checklists, forms, applications, slide shows, videos, PDFs.
3 million Texans with disabilities, only 700,000 are visually impaired. 1 in 10 have reading or graphic disabilities. People with fine motor challenges benefit. We all benefit. Our friends, our neighbors, relatives, one more tax-payer. As California and Texas go, so goes the nation. We are leaders in developing and implementing accessibility policy and procedures.