Kansas Partnership for Accessible Technology April 14, 2015 Meeting

KANSAS STATE CAPITOL KIOSKS Matt Veatch Assistant Division Director / State Archivist, State Historical Society

STATUS UPDATES AND ANNOUNCEMENTS

Deque University  Web accessibility training from Deque  Online and Instructor-led classes  Curriculum packages and boot camps 

AMP Training  Held another AMP Training session last month  Trained 13 people from 10 organizations  The next session is scheduled for Thursday, June 11  Info and registration at

AMP Release  AMP has been updated to the Winter 2015 Release since we last met.  Features include:  Editable instance severity  Ability to attach screenshots to reports for individual violation instances  Info on what’s new at  Demo video at

AMP for Mobile  New product from SSB BART Group  Beta release  Tests accessibility of mobile apps and content  Tests native mobile and hybrid apps  Tests the on-device experience  Supports iOS and Android  Seamlessly integrated with AMP

AMP for Mobile  Partnership with IBM  Incorporates IBM AbilityLab Mobile Accessibility Checker  Offered as an add-on to the AMP Enterprise License  More information:  Home page:  Blog announcement:  Press release:  IBM AbilityLab Mobile Accessibility Checker:  Interest?

Mobile Accessibility  On February 26 the W3C Mobile Accessibility Task Force published a First Public Working Draft entitled Mobile Accessibility: How WCAG 2.0 and Other W3C/WAI Guidelines Apply to Mobile.  Describes how WCAG applies to mobile, provide guidance on mobile accessibility issues, and links to WCAG Techniques that apply to mobile. Also highlights the relevance of UAAG and ATAG to mobile.  Document:  Blog announcement:

DOJ ANPRM Accessibility of Web Information and Services of State and Local Governments  Listing in the Fall 2014 Reginfo.gov agenda changed the date for NPRM from unspecified August to unspecified December. 

DOJ ANPRM & NASCIO  However, NASCIO issued an inquiry April 2 about the proposed rule, introducing it and seeking feedback on burden, economic impact, costs of assessment and remediation, and compliance data.  It also stated: “The proposed rule is currently at the Office of Information and Regulatory Affairs (OIRA), located within the White House Office of Management and Budget. OIRA is conducting its own review of the rule and must sign off before DOJ can issue the proposed rule for public comment.”

Other NASCIO Activity  Earlier, in January, NASCIO announced a list of four federal advocacy priorities for 2015, the second of which is to modernize outdated federal regulations impacting state IT.  I responded by suggesting that the Section 508 / ICT Refresh be included in that, to which representatives from Massachusetts, Minnesota, Texas, Oregon, and Utah expressed agreement, and which the NASCIO Director of Government Affairs and Executive Director acknowledged.  (This was before the announcement of the NPRM.)

PDAA  Upon seeing my message, a few of the other state representatives reached out to me to include me in a network of state accessibility officers/directors that they are trying to build.  In particular, they shared with me a project they’ve been working on that is designed to help vendors improve the accessibility of their products over time, called Policy Driven Adoption for Accessibility (PDAA).  Overview presentation at

STATE ADA COORDINATOR REPORT Anthony Fadale State ADA Coordinator

ICT STANDARDS AND GUIDELINES

ICT Standards and Guidelines  Proposed Information and Communication Technology (ICT) Standards and Guidelines  Notice of Proposed Rulemaking (NPRM) published in February  Latest stage in the rulemaking process for the update, or “refresh”, of the federal Section 508 standards and Section 255 guidelines  Updates accessibility requirements for ICT in the federal sector covered by Section 508 and, jointly, telecommunications equipment subject to Section 255

Timeline  §255 guidelines effective (1998)  §508 standards effective (2001)  Refresh process starts (2006–2008): TEITAC  TEITAC report: April 2008  Advance notice and first draft text released: March 2010  Advance notice and second draft text released: December 2011  Proposed rule submitted to OMB: February 2014  Proposed rule released for public comment: February 2015

Next Steps  Public comment period  42 questions  Ends May 28, 2015  Analyze comments  Develop final rule  Develop regulatory assessment  Submit to OMB for review  Publish final rule in the Federal Register  FAR Council incorporates new Section 508 rule into Federal Acquisition Regulations

Documents Released  Proposed Rule   Overview of the Rule   Regulatory Assessment   News Release   Public Comments Docket  All of these are available on the main ICT Refresh page at

Structure and Organization  Similar format to ADA and ABA Accessibility Guidelines  Advisories and links to technical assistance provided  Adopts functionality-based approach vs. product categories

Structure and Organization  Single document for both 508 standards and 255 guidelines  Two Application and Administration chapters  One for each rule  508 = E, 255 = C  Two Scoping chapters  One for each rule  Common chapters:  Chapter 3: Functional Performance Criteria  Chapter 4: Hardware  Chapter 5: Software  Chapter 6: Support Documentation and Services

Highlighted Issues  Broad application of WCAG 2.0  Incorporated by reference  Delineation of covered electronic content  Public and non-public facing  Expanded interoperability requirements  Software compatibility with AT  Requirements for RTT functionality  Real-Time Text

Broad Application of WCAG 2.0  Incorporation of WCAG 2.0 Success Criteria by reference  Propose to also apply WCAG Success Criteria to software and some offline electronic documents  E205 Content  E205.4 Accessibility Standards  Content must conform to Level A and Level AA Success Criteria and Conformance Requirements specified for Web pages in WCAG 2.0 (incorporated by reference in Chapter 1) or, where applicable, ISO (PDF/UA-1) (incorporated by reference in Chapter 1).  E207 Software  E207.2 WCAG Conformance  User interface components, as well as the content of platforms and applications, must conform to Level A and Level AA Success Criteria and Conformance Requirements specified for Web pages in WCAG 2.0 (incorporated by reference in Chapter 1).

Delineation of Covered Electronic Content  Covers “Agency Official Communication” that is:  E205.2 All public facing content: such as websites, posted documents, blog posts, agency social media  E205.3 Eight categories of non-public facing electronic content covered 1.An emergency notification 2.An initial or final decision adjudicating an administrative claim or proceeding 3.An internal or external program or policy announcement 4.A notice of benefits, program eligibility, employment opportunity, or personnel action 5.A formal acknowledgement or receipt 6.A questionnaire or survey 7.A template or form 8.Educational or training materials  Exception: Only for National Archives and Records Administration (NARA)

Delineation of Covered Electronic Content  Content “broadly disseminated throughout an agency” was dropped from the 2011 draft.  An exception for draft materials was dropped from the 2011 draft.  The rationale is that public-facing content should be accessible regardless, and non-public facing drafts won’t fall within the eight categories anyway.

Expanded Interoperability Requirements  Proposed rule describes required compatibility of covered technologies, including operating systems, software development toolkits, and software applications with assistive technology.  Documented Accessibility Features  User Control of Accessibility Features  No Disruption of Accessibility Features  Accessibility Services  Object Information  Row, Column, and Headers  Values  Label Relationships  Hierarchical Relationships  Text  Actions  Focus Cursor  Event Notification  Platform Accessibility Features

Requirement for RTT Functionality  Real-time text functionality (text that is transmitted character by character as it is being typed) for products providing real-time, two-way voice communication  Display of Real-Time Text  Text Generation  Interoperability  PSTN  VoIP Using SIP  Voice Mail, Auto-Attendant, and IVR Compatibility  HCO and VCO Support

Functional Performance Criteria  Functional performance criteria apply when there are gaps in the technical requirements and when evaluating equivalent facilitation.  This is a reversal from the 2011 ANPRM, which proposed to require conformance to the functional performance criteria in all cases, and is consistent with the existing standards.

Miscellaneous Notes  “… an updated product accessibility template that includes WCAG 2.0 and the other referenced standards… available through the GSA Section508.gov site…. We expect GSA will update this tool so that it will be available for use by agencies on or before the effective date of revised 508 Standards.”  E proposes to require that agencies document in writing the basis for determining that ICT fully conforming to applicable 508 Standards is not commercially available.

KPAT Response  Decide whether we want to submit a comment  Previous first and second draft comments available:  Public comment period ends May 28,  Determine policy revision recommendations for adopting the new rule when it goes into effect  ITEC Policy 1210  Other ICT

ACCESSIBILITY STATUS OF STATE OF KANSAS WEBSITES

Assessment  Matches last year’s for direct comparison  182 entity home page domains, as represented in the Agencies & Associations Listing page on the Kansas.gov website (with corrections and a few additions)  Spidered each site up to 50,000 pages  Automated testing

Pages  886,877 pages scanned  385,989 last year

Numbers of Violations Δ Total Violations3,205,7628,897,447 Average Violations Per Page ↑ 1.73

Violation Severity Δ High Severity Violations1,768,937(55%)3,849,439(43%)↓ 12% Medium Severity Violations212,193(7%)3,667,034(41%)↑ 34% Low Severity Violations1,224,632(38%)1,380,974(16%)↓ 22%

Most Frequent Violations (by Pages Affected) Best PracticeViolations Percentage of Pages with ViolationSeverityNoticeabilityTractability 1. Ensure link text is meaningful within context (–) 2,881,976 54% (0%) Ensure the language of a document is set (1) 407,859 46% (46%) Provide alternative text for images (2) 2,170,588 30% (32%) Ensure text can be resized (12) 87,080 24% (5%) Provide valid, concise, and meaningful alternative text for image buttons (5) 301,10119% (10%) 682 Last year’s info in parentheses

Most Frequent Violations (by Violation Count) Best PracticeViolations Percentage of Pages with ViolationSeverityNoticeabilityTractability 1. Ensure link text is meaningful within context (–) 2,881,976 54% (0%) Provide alternative text for images (3) 2,170,588 30% (32%) Avoid unnecessary use of heading elements (2) 814,490 8% (10%) Provide valid labels for form fields (5) 671,125 19% (20%) Avoid the sole use of device dependent event handlers (4) 625,29510% (5%) 872 Last year’s info in parentheses

Most Severe Violations Best PracticeViolations Percentage of Pages with ViolationSeverityNoticeabilityTractability 1 (T). Provide alternative text for images (1(T)) 2,170,588 30% (32%) (T). Provide valid labels for form fields (1(T)) 671,125 19% (20%) (T). Ensure headers and cells are properly associated (1(T)) 1,170 0% (0%) (T). Provide alternatives for server- side image maps (4(T)) 1,359 1% (0%) (T). Avoid utilizing sub-tables in header elements (4(T)) 1,034 0% (1%) 935 Last year’s info in parentheses

Most Tractable Violations Best PracticeViolations Percentage of Pages with ViolationSeverityNoticeabilityTractability 1 (T). Provide alternative text for images (1(T)) 2,170,588 30% (32%) (T). Provide valid labels for form fields (1(T)) 671,125 19% (20%) (T). Avoid the sole use of device dependent event handlers (1(T)) 625,295 10% (5%) (T). Provide valid, concise, and meaningful alternative text for image buttons (1(T)) 301,101 19% (10%) (T). Ensure frame titles are meaningful (1(T)) 118,147 9% (8%) (T). Ensure link text is meaningful within context (–) 2,881,976 54% (0%) (T). Ensure hr elements utilize relative sizing (1(T)) 2,042 0% (0%) (T). Avoid unnecessary use of heading elements (1(T)) 814,4908% (10%) 332

OPEN DISCUSSION

Next Meeting Tuesday, July 14, 2015 Time: 2:30–4:30 PM Location: Landon State Office Building Room SW Jackson Street