Accessibility Policy Development & Exceptions EIR Accessibility Leadership Conference December 6, 2011

Accessibility Policy Development & ExceptionsEIR Accessibility Leadership Conference December 6, 2011 Texas Department of Assistive and Rehabilitative Services Ron Lucey – Manager, DARS Accessibility Team

Meet Your Instructor Ron Lucey DARS Accessibility Manager (512) 377-0577 ron.lucey@dars.state.tx.us accessibility@dars.state.tx.us

Overview • Process of policy development • Defining the scope of your agency’s EIR accessibility policy • Policy development resources • Reporting Inaccessible Agency Web Content • Exceptions Process • Practice Exercise

Policy Authority State and Federal Legislation • What legislation or regulatory authority guides your policy development? State Law –Texas Government Code §2054.456 Subchapter M – 1 TAC 206, TAC 213

Getting Started • Gain top level support and sponsorship • Organize a Web accessibility committee and needed subcommittees with representation from stakeholders. • Apply sound project management principles and a project charter with planned deliverables. • Plan for effective governance to address committee process for decision making. WebAIM Resource http://www.webaim.org/articles/implementation/

What is the scope of your accessibility policy? Defining Electronic and Information Resources (EIR)? Internal and external content and customers Contracted goods & services Testing - Compliance and Remediation

Beyond Web Accessibility Policy • Software applications • Multimedia • Telecommunications • Self-contained products and office equipment • Procurement

The Process • Review applicable laws and guidelines to establish what is required for compliance • Review policies and guidelines of other agencies, universities, or business units if available. • Draft global policy statement of position and requirements • Draft guidelines addressing how to meet the policy

Communication • Early and frequent communication may reduce later resistance. • Single most important way to combat negativity is to involve users up front. • Their perspective and their information are invaluable to the good decisions and good writing.

Policy Review Comment and Approval • Define policy review, comment period and approval process flow. • Provide multiple opportunities for review • Identify stakeholders • Information Resources Management • Legal counsel • External experts and internal stakeholders • Product management • Content owners • Propose to executive officers for final approval

Policy Writing Guidelines Policies –May be written to govern long-term change Policies are guidelines that regulate organizational action and control conduct of staff and the activities of the system. It explains the agencies stand on a subject and why there is a rule about it. It tells the reader how the agency intends to operate.

Policy Writing Guidelines Procedures – Rapid response to business and technology innovations A procedure is the normal method of handling things. It’s a protocol for implementation, the “how to”. Procedures supplement the policy guidelines with specifics and complete information users need. Procedures are action oriented. They outline the steps you expect staff to take and the sequence in which to perform those steps.

Policy Writing Do’s & Don’ts • Do - publish your policy where stakeholders and employees can easily access it. • Don’t –write your policy into forms, checklists, and other non-policy documents. • Do –review and update your policy annually and as needed. • Don’t - forget to make a plan for your agency’s policy implementation.

Audit and Compliance What is your system for auditing EIR for accessibility policy compliance? • How and by whom the standard will be enforced, and • What consequences will befall those who violate the policy?

Inspect What You Expect • Consider a high level statement of how you plan to verify the your accessibility compliance. • Many tools are available, from small-scale to enterprise. • Test frequency. • Defined roles and responsibilities.

Reporting Inaccessible Web Content • Include a method for members of the public and employees to communicate inaccessible web pages and EIR. • Be proactive and use . • Web contact forms • Accessibility mailboxes • Web Footer with links to Webmaster or A.C. • Work within your agency’s existing Civil Rights process as appropriate .

Defining Policy Exceptions • Exemptions vs. Exceptions • Use of exceptions are acceptable to address significant difficulty or expense. • Exceptions should focus on circumstances in which benefit of noncompliance is minor and cost of compliance is great. • Your commissioner may assign a designee to evaluate requests for exceptions and make recommendations;

Defining Policy Exceptions Approved exceptions must include the following: • date of expiration; • plan for alternate means of access for persons with disabilities; • justification for the exception including relevant cost avoidance estimates; and • executive director’s signature. Under §2054.460, Government Code, the final decision may not be appealed. Agencies must maintain records of all exception requests.

Alternative Methods of Access When compliance imposes a significant difficulty or expense, agencies must provide information and data through a different means of access without delay. Examples of an alternate means of access may include: • Captioning or text transcripts. • Alternate document formats • Live agent assistance

Documenting the Exception

Practice Exercise 1 Your agency is publishing the annual budget to your Internet site as a PDF image. A hard copy is available to your stakeholders upon request. The budget document consists of more than 180 pages of complex financial tables. • Is there a possible need for an exception? • What additional information is needed to recommend an exception? • What alternate means of access might you provide to a customers with a disability?

Practice Exercise 2 Your agency has created an information security CBT using Flash technology. All employees are required to take the training. The learning assessment exercises are inaccessible to anyone who cannot use a computer mouse. • What additional information is needed to recommend an exception? • What alternate means of access might you provide to an employee with a disability? • What could you do to plan

Example Policies • Texas Health and Human Services http://architecture.hhsc.state.tx.us/myweb/Accessibility/policy_htm/default.htm • University of Texas System http://www.utexas.edu/web/guidelines/accessibility.html • Texas Department of Insurance http://www.tdi.state.tx.us/commish/access.html

Texas Health and Human Services HHS EIR Accessibility Policy Statement It is the policy of the Health and Human Services System (HHS) that all HHS agency electronic information resources and web sites shall be accessible to individuals with disabilities and with limited English proficiency (LEP). This policy specifies accessibility of web pages and all other electronic and information resource requirements for the following agencies: • Department of Aging and Disability Services (DADS) • Department of Assistive and Rehabilitative Services (DARS) • Department of Family and Protective Services (DFPS) • Department of State Health Services (DSHS) • Health and Human Services Commission (HHSC)

Texas Health and Human Services http://architecture.hhsc.state.tx.us/myweb/Accessibility/website/index.shtml

Questions

Resources • Texas HHS accessibility center (home page) http://architecture.hhsc.state.tx.us/myweb/Accessibility/website/index.shtml • HHS Policy manual http://architecture.hhsc.state.tx.us/myweb/Accessibility/policy_htm/ • HHS Procedure manual http://architecture.hhsc.state.tx.us/myweb/Accessibility/procedures_htm/ • HHS Checklists… software/website/application http://architecture.hhsc.state.tx.us/myweb/Accessibility/website/web_check.shtml • University of Texas accessibility policy http://www.utexas.edu/web/guidelines/accessibility.html

Accessibility Policy Development & Exceptions EIR Accessibility Leadership Conference December 6, 2011