Complying with New York State’s New Web Accessibility Policy

1. Complying with New York State’s New Web Accessibility Policy Debi Orton, IT Manager NYS Governor’s Office of Employee Relations

2. What we’ll cover… • Applicable and related Federal laws • History of NYS accessibility policy • Standards and Guidelines • Overview of current landscape: new laws, standards and guidelines

3. Americans with Disabilities Act (ADA) – 1990: Title I • Title I: Employment • Covers employers with >= 15 employees • Requires equal opportunity to full range of employment-related opportunities available to others • Prohibits discrimination in recruitment, hiring, promotion, training, pay, social activities, etc. • Requires reasonable accommodation for people with disabilities, absent undue hardship

4. ADA: Title II • Title II: State and Local Government Activities • Regardless of size or receipt of Federal funding • Requires that people with disabilities have equal opportunity to benefit from programs, services, activities (e.g., public education, employment, trasnportation, recreation, health care, social services, courts, voting and town meetings) • Covers architectural barriers, fundamental alteration

5. ADA: Title III • Title III: Public Accommodations • Covers businesses and nonprofit service providers that are “public accommodations” (private entities who own, lease, lease to, or operate facilities such as restaurants, retail stores, hotels, movie theaters, private schools, convention centers, doctors’ offices, homeless shelters, transportation depots, funeral homes, zoos, day care centers, sports stadiums, etc.) • Prohibits exclusion, segregation, and unequal treatment

6. ADA: Title IV • Title IV: Telecommunications Relay Services • Covers telephone and television access to people with hearing and speech disabilities • Establishes telecommunications relay services 24/7 • Requires closed captioning of Federally funded public service announcements

7. Telecommunications Act – 1934 & 1996 • Requires manufacturers of telecommunications equipment and providers of telecommunications services to ensure that equipment and services are usable people with disabilities

8. Other Applicable Federal Laws • Fair Housing Act • Air Carrier Access Act • Voting Accessibility for the Elderly and Handicapped Act • National Voter Registration Act • Civil Rights of Institutionalized Persons Act • Architectural Barriers Act

9. Individuals with Disabilities Education Act (IDEA) • Requires public schools to provide a free, appropriate public education in the least restrictive environment appropriate to their individual needs

10. Rehabilitation Act of 1973 • Section 501: Affirmative action and nondiscrimination in agencies of the Executive Branch • Section 503: Requires affirmative action and prohibits employment discrimination by contractors and subcontractors with contracts for more than $10K.

11. Rehabilitation Act of 1973 • Section 504: “No qualified individual with a disability in the United States shall be excluded from, denied the benefits of, or be subjected to discrimination under” any program or activity that receives Federal financial assistance or is conducted by any Executive agency or the USPS

12. Rehabilitation Act of 1973 • Section 508: Establishes requirements for electronic and information technologies developed, maintained, procured or used by the Federal government • Must be accessible to people with disabilities, including employees and members of the general public • NYS Policy adopts two parts of Section 508 explicitly and a third implicitly

13. Web Standards • Established and maintained by the World Wide Web Consortium (W3C) • Markup languages • HTML • XHTML • XML • Presentation language : CSS • Accessibility Standards : WCAG, ATAG, UAAG, ARIA

14. Accessibility Standards • Two major accessibility standards: • Section 508 • World Wide Web Consortium (W3C) • Web Accessibility Initiative (WAI) • Web Content Accessibility Guidelines (WCAG) • 1.0 – May, 1999 • 2.0 – December, 2008 • 2.0 “last call” issued in May, 2004

15. NYS Accessibility Policy • First policy published in 1996 – required reasonable accommodation for IT • Second policy published in 1999 – required conformance to WCAG 1.0 level A • June, 2004: Hybrid standard adopted, amalgam of Section 508 and WCAG 1.0 • Separated into policy document and standard document

16. NYS Validation Tool • 2008 – NYS Forum developed customized testing tool; provided tool free to state agencies and contractors working for state entities for one year • 2009 – CIO/OFT picked up tool for another year • 2010 – No NYS validation tool available

17. NYS Accessibility Policy • Hybrid reviewed and adjusted every two years • 2010 – Policy changed to adopt Section 508 section 1194.22 (web standards, aligned with WCAG 1.0) and 1194.31 (functional testing) • 1194.22 requires web content to meet provisions of 1194.21 (software applications and operating systems)

18. NYS Accessibility Policy • Covers all “state entities” identified in Executive Order 117 • Covers all Internet, intranet, extranet sites and web applications • Covers all content on state entities’ web sites

19. Section 508, §1194.22 • § 1194.22 Web-based intranet and internet information and applications. • (a) A text equivalent for every non-text element shall be provided (e.g., via "alt", "longdesc", or in element content). • (b) Equivalent alternatives for any multimedia presentation shall be synchronized with the presentation.

20. Section 508, §1194.22 • (c) Web pages shall be designed so that all information conveyed with color is also available without color, for example from context or markup. • (d) Documents shall be organized so they are readable without requiring an associated style sheet. • (e) Redundant text links shall be provided for each active region of a server-side image map.

21. Section 508, §1194.22 • (f) Client-side image maps shall be provided instead of server-side image maps except where the regions cannot be defined with an available geometric shape. • (g) Row and column headers shall be identified for data tables. • (h) Markup shall be used to associate data cells and header cells for data tables that have two or more logical levels of row or column headers.

22. Section 508, §1194.22 • (i) Frames shall be titled with text that facilitates frame identification and navigation. • (j) Pages shall be designed to avoid causing the screen to flicker with a frequency greater than 2 Hz and lower than 55 Hz. • (k) A text-only page, with equivalent information or functionality, shall be provided to make a web site comply with the provisions of this part, when compliance cannot be accomplished in any other way. The content of the text-only page shall be updated whenever the primary page changes.

23. Section 508, §1194.22 • (l) When pages utilize scripting languages to display content, or to create interface elements, the information provided by the script shall be identified with functional text that can be read by assistive technology. • (m) When a web page requires that an applet, plug-in or other application be present on the client system to interpret page content, the page must provide a link to a plug-in or applet that complies with §1194.21(a) through (l).

24. Section 508, §1194.22 • (n) When electronic forms are designed to be completed on-line, the form shall allow people using assistive technology to access the information, field elements, and functionality required for completion and submission of the form, including all directions and cues. • (o) A method shall be provided that permits users to skip repetitive navigation links. • (p) When a timed response is required, the user shall be alerted and given sufficient time to indicate more time is required.

25. Reference to §1194.21 • § 1194.21 Software applications and operating systems. • Deals with the convergence of applications and web sites • Applies to NYS sites by virtue of §1194.22(m)

26. Section 508, §1194.31 • § 1194.31 Functional performance criteria. • (a) At least one mode of operation and information retrieval that does not require user vision shall be provided, or support for assistive technology used by people who are blind or visually impaired shall be provided.

27. Section 508, §1194.31 • (b) At least one mode of operation and information retrieval that does not require visual acuity greater than 20/70 shall be provided in audio and enlarged print output working together or independently, or support for assistive technology used by people who are visually impaired shall be provided.

28. Section 508, §1194.31 • (c) At least one mode of operation and information retrieval that does not require user hearing shall be provided, or support for assistive technology used by people who are deaf or hard of hearing shall be provided. • (d) Where audio information is important for the use of a product, at least one mode of operation and information retrieval shall be provided in an enhanced auditory fashion, or support for assistive hearing devices shall be provided.

29. Section 508, §1194.31 • (e) At least one mode of operation and information retrieval that does not require user speech shall be provided, or support for assistive technology used by people with disabilities shall be provided. • (f) At least one mode of operation and information retrieval that does not require fine motor control or simultaneous actions and that is operable with limited reach and strength shall be provided.

30. NYS Policy Requirements • New content must conform immediately • Any content developed by contractor must conform • Provides language to include in any procurement involving web content • Policy requires annual validation and reporting to CIO/OFT

31. How People With Disabilities Use the Web

32. Blindness / Low Vision • People who are blind access the web via: • Screen reading software • Refreshable Braille displays • CANNOT use pointing devices • People with low vision may use those tools or: • Screen magnification software • External (larger) displays

33. Blindness / Low Vision • Visual acuity also a factor for: • People using mobile devices • People using older equipment (smaller monitors, lower resolutions) • Visuals need to be described using “alt text” • Videos or presentations containing instruction needs to be audibly described

34. Low Vision • Cataracts • Glaucoma

35. Low Vision • Macular Degeneration • Retinopathy

36. Magnified graphical text • Difficult to magnify graphical text without distortion

37. Color Blindness Map of Hurricane Isabel (with color)

38. Color Blindness • Map of Hurricane Isabel (simulating red/green color blindness)

39. Color Blindness • Subway maps

40. Deafness / Hearing Impairment • Video or presentation content with audio must be captioned • Elearning content cannot rely on audio cues • People whose computers do not support sound • Can be an issue for mobile device users

41. Mobility Impairments • Cannot use mouse for navigation • Interaction through keyboard only • May have difficulty with timed responses

42. Cognitive Impairments • Images are helpful for many with cognitive impairments • Avoid “Wall o’ Text” • Use headlines and bullets • Attention to “fog index”

43. Principles of Accessibility • Users may require assistive technology to effectively use technology or browse web • Provide information in more than one format • Navigation and layout should be consistent, predictable • Alternate text should describe visual content’s purpose [not necessarily a literal description of the content]

44. Testing for Accessibility • Three basic ways to evaluate • Automated testing • Manual review • Functional testing

45. Automated Testing • Automated testing tools don’t usually fix errors • The best tools link error reports to the standard being violated • Web developers will need a fairly comprehensive understanding of HTML and CSS

46. Automated Testing • Many free, but limited [e.g., can only test a page at a time] • Many for-fee tools customizable and can do batch testing • Most can select either of the two major accessibility standards (Section 508 or WCAG) • Automated testing not all that’s needed

47. Manual Evaluation • Look at alternate text for images • Turn off images and styles • Turn off scripting • Use keyboard to navigate • Data table markup • Look at use of color • Proprietary formats

48. Functional Testing • Have a user of assistive technology test site while you watch • Test with “one of each” • User with visual impairments • User with hearing impairments (if sound on site) • User with cognitive impairments • Etc.

49. The Short-Term Future – Web Standards • HTML & CSS Changing • HTML5 – some backward compatibility, but would deprecate some accessibility features available in HTML 4 • CSS3 – little impact on accessibility • ARIA – Might be used to mitigate some of the accessibility problems currently existing in HTML5

50. The Short-Term Future – Accessibility Standards • WCAG 2.0 • Now a recommendation • Support and implementation materials available on the W3C site, WebAIM, etc.