1. 1 Jeff Kline (@jeffkline2; jeff.kline@dir.texas.gov) Accessibility Author and Consultant / Texas Statewide EIR Accessibility Coordinator AccessU 2013 Note: Refer to speaker notes if you have problems viewing presentation slides

2. 2 We all want more accessible ICT… now…

3. 3 So how are our current methods working for us?  we’ve tried technical standards – that hasn’t done it…  we’ve tried legislating around those standards – that hasn’t done it…  we’ve tried saying accessibility is cheap – it isn’t, and that hasn’t done it…  we’ve made tools to make it cheaper – but they haven’t made it easier, so that hasn’t done it…  we’ve tried to show great ROI – but examples are scant, so that hasn’t done it…  we’ve tried to show the massive spending power of disabled people – that’s debatable, so that hasn’t done it…  we’ve tried to say accessibility = usability – that isn’t always the case, so that hasn’t done it…

4. 4 ICT Accessibility Adoption is Slow Recent US government reports find that current models for encouraging ICT accessibility adoption are not working  “Section 508 Report to the President and Congress: Accessibility of Federal Electronic and Information Technology” 2012 (US DoJ)  Finds that less than 50% percent of agency components incorporated specific applicable Section 508 Accessibility Standards as requirements in each procurement solicitation…  Little to no validation against Section 508 criteria performed on procured products  “US E-Government Website Quality Report” 2012 (WelchmanPierpoint)  The accessibility benchmark shows that two-thirds of federal sites achieved a moderate level of compliance federal sites  28% of sites in the study achieved the lowest compliance band.  Automated testing only; tool(s) not defined  “National Disability Policy Progress Report August 2012” (National Council on Disability)  Rarely mentions ICT accessibility

5. 5 ICT Accessibility Adoption – an International Perspective The situation in Europe isn’t any better…  European Commission research behind Proposed Directive on Accessibility of Public Sector websites Dec 2012 (European Commission)  only one-third of Europe’s 761,000 public-sector and government websites are accessible And G3ict reports indicate the same slow progress in the rest of the world…  “CRPD 2012 ICT Accessibility Progress Report” (G3ict)  Indicates significant deficits to set in place a foundation to promote ICT accessibility

6. 6 Why?

7. 7 The Accessibility Technology Gap “Technical enablement” challenges  Accessible technologies gap  Accessibility not considered in new, mainstream technology creation  Facilitation tools limited and lagging in development technologies

8. 8 Technical Enablement is only half of the adoption problem  Lack of awareness of accessibility requirements  Awareness of accessibility but it’s deemed “unnecessary” or optional  Awareness of accessibility but unwilling to make the investment  Awareness of accessibility too late to be addressed  Lack of technical skills, tools or training programs  No knowledge transfer from previous or other projects in an organization  No organizational policies or objectives related to ICT accessibility  Lack of commitment to accessibility by top management  No one responsible or accountable for accessibility

9. 9 ICT accessibility today is a governance problem more than a technical one Technical specifications / standards are not governance criteria! They’re execution criteria!  Nothing in tech specs requires organizations to do anything  The “teeth” for accessibility are in disability regulations but  Regulations not being enforced to the extent needed  Risk associated with inaccessible ICT isn’t high Where do we go from here?

10. 10 Barriers are barriers. Period.  Barriers to the digital environment are no different than barriers to the built environment with respect to civil rights.  What was the “business case” for access to the built environment? Access to information technology is not a “business case” problem. It’s a civil rights problem. Governments are recognizing this and are creating new accessibility regulations which include policy requirements to facilitate adoption.

11. 11 Policy Driven Adoption The integration of ICT accessibility governance into disability regulations and policies in a way that enables organizations to drive themselves to improve accessibility adoption.

12. 12 Policy Driven Adoption: Benefits  Not prescriptive  Tells organizations “what” to do, not “how” to do it  Can include a technical standard component  Can be governed mostly thru non-technical methods  Makes ICT accessibility difficult to ignore  Accelerates marketplace innovation for development tools, technologies, and other resources that facilitate ICT accessibility  Passenger car emissions standards example

13. 13 Policy Driven Adoption Current Examples: State of Texas State of Texas, USA: Texas Government Code 2054 Subchapter M, Texas Administrative Codes 206, 213  Scope: Texas State agencies and state funded institutions of higher education (Approx. 175)  Uses slightly modified Section 508 technical standards  Goes beyond technical standards to include governance criteria for  Policy  Responsibility  Procurement  Exceptions  Training

14. 14 Policy Driven Adoption: State of Texas How’s it working?  Over 95% of all agencies and state funded higher education institutions  Have a published ICT accessibility policy  Have an accessibility coordinator  Many agencies have very accessible public websites  Exceptions process yields improvements in accessibility of 3 rd party products  State mandated information resources review conducted biannually  Includes ICT accessibility  Department of Information Resources leadership, guidance, and oversight  Establishes ICT Accessibility Rules  Provides resources in support of enabling agency accessibility  Provides a no charge accessibility web scanning program (150 pages per agency) to all state agencies agencies  Chartered the Accessibility Council of Texas to identify and implement key initiatives at the state level  Integrated ICT Accessibility criteria into state co-operative contracts program

15. 15 Policy Driven Adoption Current Examples: Canada Ontario: Accessibility for Ontarians with Disabilities Act (AODA)  Scope: Public and private entities with over 20 employees operating in Ontario  Encompasses the built environment and broad range of ICT  Integrated Accessibility Standards Regulations (IASR) requires organizations to  File Customer Service Accessibility Compliance Reports online  Establish accessibility policies  Establish, implement, maintain and document a multi-year accessibility plan  Incorporate accessibility criteria and features into procurement  Includes timetables for required compliance  Includes fine schedules  WCAG 2.0 used as the technical standard for web accessibility NEW! Government of Manitoba has accepted recommendations to adopt a new Accessibility Act ( Heavily influenced by AODA)

16. 16 Policy Driven Adoption : Canada The effect it’s had…  Requiring organisations to create a policy has forced them to engage with the issues, to a greater extent than reproducing the usual boilerplate  While enforcement is still an issue, organisations feel more accountable once they’ve publicly published their policy  The public now has a formal mechanism for complaints, channeled through the government equality body, rather than to the organisation  And it’s likely that legal cases will take an organisation’s progress against their own policy and action plan into account  But the jury’s still out on the exact effect it will have…

17. 17 Policy Driven Adoption: Possible Provisions Inclusion at Regulatory OR Organizational Levels Organizations of a certain size or business type (TBD) that use or develop ICT must: 1. Develop, implement, and maintain an ICT accessibility policy 2. Integrate ICT accessibility criteria into key phases of procurement, development, and other relevant business processes 3. Provide a process addressing inaccessible ICT which would include  a plan / date for compliance of the ICT  an alternate means of access until the ICT is accessible 4. Ensure that accessibility skills are available within (or to) the organization 5. Develop and maintain an organizational structure that enables and facilities accessibility progress 6. Demonstrate forward progress in accessibility over time through the establishment of metrics and tracking methods 7. Designate one or more individuals responsible for supporting the organization in implementing these provisions

18. 18 “…Regardless of an agency's maturity, effective accessibility outcomes will always depend on a clearly articulated policy… Policy as a means to integrate accessibility into all aspects of the ICT environment and decision tree is fundamentally important.” Sharron Rush, Executive Director, Knowbility Inc.

19. 19 Implementing Policy Driven Adoption

20. 20 Scenario: Online Recruiting Corporation X had just completed the procurement and deployment of a large new web application for recruiting new employees and managing job candidates. Software Company A developed the product. Both Company A and Corporation X’s studies indicated that the new system would offer significant advantages in cost savings, productivity, and candidate quality over the previous, mostly manual processes. Then….

21. 21 What Areas of an Organization May Be Affected by ICT Accessibility? (a non-exhaustive list)  Product development  Internet site and applications development  Intranet site and applications development  Procurement  Legal / civil rights  Executive management  Internal / external communications / PR  HR (employees)  Learning tools (hw/sw)  System admins  Student services  Business controls / compliance office  …

22. 22 ICT Accessibility is a Complex Topic  Many moving parts = many challenges  Technical  Organizational  Legal  Cultural  Touches many areas of an organization in different ways “Organizational Enablement” is required to effectively and successfully address the complexities ICT accessibility within an organization.

23. 23 An Accessibility Framework Organizational Components Gain top level “buy-in” and set organization expectation levels Ensure accessibility policies are defined Develop strategy and implementation plans Create an organizational model Assess business needs and make accessibility investments Implementation Components Plan Strategically Automate for productivity and quality Validate thoroughly, early, and often Grow awareness and provide education / training Measure and track progress

24. 24 Gain top level “buy-in” and set organization expectation levels Getting Started Start at the top: Obtain executive buy-in  Create an executive presentation or “sell” package  Clearly articulate the importance and need for an accessibility program  Business advantages and risk mitigation  The state of ICT accessibility within the organization if known (if not known, that can be a risk in itself)  Examples of adverse impacts  A clearly defined set of accessibility program objectives  Recommended next steps  Gain the commitment of top executives in the form of resources (human and financial)  Obtain an executive sponsor or “champion” to oversee and guide the program Set organization expectation levels  Multi-year initiative  Dynamic, with course and trajectory adjustments as needed

25. 25 Ensure accessibility policies are defined The Organization Policy Develop an ICT accessibility policy ▪ Foundation on which other aspects of ICT accessibility are built ▪ Create a team of SMEs to develop the policy ▪ Should not be voluminous or contain technical specs ▪ Leverage similar, existing policies ▪ The “big stick” Core Team for Accessibility Policy Development Stakeholders Review / Concurrence HR Legal Procurement Development CIO Unit Execs Marketing Other

26. 26 Develop strategy and implementation plans Develop a Strategy Key elements of an organization’s ICT accessibility strategy  Rationale and goals of the program  Linkage to the organization’s ICT accessibility policy, relevant standards, regulations, etc.  Definitions of high-level organizational and governance models  Funding, budget, and other financial considerations  A strategic framework for developing operational work plans  Assumptions, dependencies, and risks

27. 27 Create an organizational Model Neutral Organizational Placement for Centralized Accessibility Program Considerations Is it positioned to reach across the enterprise? Will it have the clout to be effective in driving transformation and policy? Can it maintain its ability to perform without being subjected to the parochial interests of the organization in which it resides? Will it get the care and attention needed over time? Sample Neutral Placement Analysis LocationProsCons Human resourcesGood for driving internal ICT, HR policy components, and enforcement; is familiar with the entire enterprise or organization. Difficult for driving compliance for external products and services. ComplianceConsistency with other compliance programs; associated and strong ability to govern by means of business controls and audits. Far removed from technical work and its management; no ownership of or accountability to the product areas affected. Locating accessibility here means locating technical skills in a nontechnical area. Product development Close integration with development community; strong ability to supply staff with technical skills. Competing business requirements will make accessibility the victim of trade-offs and marginalization; not likely to focus on internal ICT and other affected areas of the organization. Internal ICTEffective for driving internal ICT compliance; potential for strong linkage with HR and other areas of the enterprise. Considered “infrastructure” and more susceptible to budget and funding fluctuations; will find it difficult to drive accessibility to profit-and-loss areas of the organization. Corporate or organization-wide operations Provide ability to reach across the organization and require a level of accountability; the authority of a top-level function of the organization won’t be questioned. Could be viewed as a support function that can be easily dismissed or treated as lower priority by other stakeholder areas; limited accountability for results.

28. 28 Create an organizational Model Organizing Accessibility  Senior manager “executive sponsor”  Centralized accessibility function  Policy and governance  Technical consulting  Business development / sales support  Project office  Other?  Sub-Unit focal points / coordinators  Loosely connected (dotted line) 2 nd level subunit accessibility focal point 2 nd level subunit accessibility focal point 2 nd level subunit accessibility focal point Centralized Accessibility 2 nd level subunit accessibility focal point 2 nd level subunit accessibility focal point Centralized Accessibility Subunit accessibility focal point Subunit accessibility focal point Subunit accessibility focal point Centralized Accessibility Program Centralized accessibility program

29. 29 Develop strategy and implementation plans Prioritize the Work Effort Priority classification hierarchy* example Mission critical, high number of users, high revenue Non-mission critical, high number of users, high revenue Mission critical, low number of l users, low revenue Non-mission critical, low number of users, low revenue Mission critical, high number of users Non-mission critical, high number of users Mission critical, low number of users Non-mission critical low number of users External products, Internet and internet applications, etc. Internal use: Intranet and intranet applications, desktop apps, copy machines, telecommunications, etc. *Priority classification assumptions 1. New applications under development, being updated, or being procured should receive priority within the priority class

30. 30 Assess business needs and make accessibility investments Program Costs Determining Factors  Funding Models  Speed and trajectory of the ICT accessibility initiative driven by  Urgency based on business or other requirements  Budget considerations  Startup and ongoing costs Cost TypeElement Start-up Investment Level Ongoing Investment Level Human resourcesEnterprise/organization staffingHighMedium Human resourcesExternal consultingMedium/highLow/very low Human resourcesSubunit/2nd-level subunit coordinatorsLow Human resourcesOverall Initiative managementMediumLow Human resourcesPolicy and process creation / integrationMediumLow Human resourcesTrainingMedium Human resourcesManual testingMediumMedium/high Human resourcesAccessibility developmentLowMedium Human resourcesManagement system developmentMediumLow Human resourcesMarketing support (private sector)MediumLow ICT hardware/ softwareTracking/reporting toolsMediumVery Low ICT hardware/ softwareEnterprise scan tool(s)MediumLow ICT hardware/ softwareEnterprise scan tool maintenanceLow ICT hardware/ softwareDeveloper toolsMediumLow ICT hardware/ softwareTest toolsMediumLow ICT hardware/ softwareDevelopment and test tool maintenanceLow ICT hardware/ softwareICT hardware (desktop computers, etc.)Low ICT hardware/ softwareICT service (database hosting, etc.)Low

31. 31 Accessibility Program Framework: 2nd level Plan Strategically Automate for productivity and quality Validate thoroughly, early, and often Grow awareness and provide education / training Measure and track progress Obtain initiative support of organization executive team Develop long term organization goals Integrate into or develop processes to ensure consistency over time Select appropriate ICT technologies / suppliers Effectively manage the ICT accessibility exception process Maintain flexibility to adapt to criteria changes (508 refresh, WCAG 2.0, etc) Charter a workgroup with representation from key areas of the organization

32. 32 Accessibility Program Framework: 3rd level detail Creation of action plans, project plans, work breakdown structures, etc. Obtain initiative support of organization executive team Develop long term organization goals Integrate into or develop processes to ensure consistency over time Select appropriate ICT technologies / suppliers Effectively manage the ICT accessibility exception process Maintain flexibility to adapt to criteria changes (508 refresh, WCAG 2.0, etc) Charter a workgroup with representation from key areas of the organization Organization Work Plan Framework ComponentWork plan detailed line items PriorityStatusOwnerTeam Start Date Target Completion Actual Completi on Dependenci es Integrate into or develop processes to ensure consistency over time Review and modify as needed current process(s) for accessibility integration H Not StartedEIRACICT dev 10-Oct11-Jan PM Contracts Integrate into or develop processes to ensure consistency over time Determine appropriate processes and process tools for ICT Accessibility H GreenEIRAC Exec management / IRM 15-Sep10-Oct None Integrate into or develop processes to ensure consistency over time Analyze process(s) effectiveness. Are they being followed? H GreenEIRAC Exec management / IRM 10-Oct10-Jan None Integrate into or develop processes to ensure consistency over time Integrate accessibility criteria and the exception process into development phases M Not StartedEIRACICT dev 10-Oct11-Jan PM Contracts Integrate into or develop processes to ensure consistency over time Develop guidelines for integrating Accessibility development / test into project schedules H Not StartedEIRACICT dev 10-Oct11-Jan PM Contracts Integrate into or develop processes to ensure consistency over time Develop work sizing guidelines for development and test planning H Not StartedEIRACICT dev 10-Oct11-Jan PM Contracts

33. 33 An IT Accessibility Implementation Framework Template Plan Strategically Obtain initiative support of organization executive team Develop long term organization goals Integrate into or develop processes to ensure consistency over time Select appropriate IT technologies / suppliers Effectively manage the IT accessibility exception process Maintain flexibility to adapt to criteria changes (508 refresh, WCAG 2.0, etc) Charter a workgroup with representation from key areas of the organization Automate for productivity and quality Provide developers tools to facilitate and remediate accessibility compliance Integrate accessibility into content management systems / processes Utilize standardized accessible templates (CSS, etc) Ensure browser neutral accessibility Utilize enterprise level scan tools for issue identification / resolution Validate thoroughly, early, and often Test internally developed pages and applications Test externally hosted services Test Published documents / information Perform analysis of vendor VPATs and test vendor solutions to validate Develop or integrate corrective actions process management / tools Grow awareness and provide education / training Evangelize accessibility throughout organization / IT supplier community Build / maintain organization’s technical capacity with SME’s Identify skill gaps, and resolve via and training staffing plans Measure and track progress Develop goal appropriate metrics, and reporting tools / methods Communicate and utilize results to drive initiative trajectory Maintain processes and results for “audit readiness” posture Organization Work Plan

34. 34 Plan Strategically Internal Application Process Analysis/ Recommended Actions

35. 35 Form an Organizational Accessibility Workgroup Plan Strategically An interdepartmental team representing stakeholder areas of the organization that require or may be affected by ICT accessibility  Facilitates progress in ICT accessibility across the organization  Identifies inhibitors and works to resolve them as a team  Sponsors or leads ICT Accessibility workgroup and subgroup efforts  Reports progress and issues to senior leadership  Solicits support of management and others as needed Application / web development Internal ICT Internet site owners Procurement Intranet site owners Communications Medical / occupational health Learning Business controls / compliance office Legal / Civil Rights HR Other?? Project management

36. 36 Grow awareness and provide education / training Identify Skill Gaps and Build “Role Based” Accessibility Training Plans Course LevelCourse Title All Staff Web Content Producers Web & Application Testers Web Application Developers Procurement Staff Contract Writers Contract Compliance Project Managers Fundamentals Introduction to Accessibility (Self) Required Fundamentals Office Documents (Internal) OptionalRequiredOptional Required OptionalRequired Fundamentals PDF (Internal)Required / Optional* RequiredOptional Required / Optional* Fundamentals HTML (Internal or External) Required Fundamentals HTML Forms (Internal or External) RequiredOptionalRequired Fundamentals Testing & Tools (Internal or External) Required Fundamentals CSS (Internal or External) Optional Required Fundamentals Javascript (Internal or External) Optional Required Advanced Sharepoint / Dreamweaver (Internal or External) Required / Optional* Advanced ASP / ASP.Net (Internal or External) Required / Optional* Advanced Java / JSP (Internal or External) Required / Optional* Advanced Web 2.0 Technologies (Internal or External) Required / Optional* Specialized Accessibility Law, and its Impacts Required Specialized Accessibility in Contract Solicitations Required Specialized Understanding/validating Vendor ICT accessibility Required * As needed based on assignment.

37. 37 Measure and Track Progress Set Short and Long Term Accessibility Goals: Example Web Content: Public Facing and General Access Intranet Web pages Maintain less than 2.5% pages with accessibility errors PDFs Reduction of inaccessible PDF Documents by 25% within 1 yr 10% additional reduction each subsequent year Non-PDF documents Reduction of inaccessible non-PDF Documents 50% within 1 yr 10% additional reduction each subsequent year Validation Select and procure accessibility web scanning tool for internet / intranet pages Begin monthly scans and remediation of errors Internal / External Applications New internally developed or purchased applications 75% to be accessible Existing applications 10% per year increase in compliance of existing applications Training Intro level accessibility training to staff 90% staff within 1 yr; remaining 10% in following year Accessible Office Documents training 50% staff trained within 1 yr; 50% balance in following year Web developer accessibility training 100% developers trained within 1 yr

38. 38 Resources for creating an accessibility policy & programme  British standard BS-8878 Web Accessibility Code of Practice  Accessibility business process integration  Forthcoming (Autumn 2013): ‘Implementing BS 8878’ book by Jonathan Hassell  for info email: book@hassellinclusion.com  Strategic EIR Accessibility: Enabling the Organization by Jeff Kline  Organizational accessibility enablement and strategy  Other accessibility guidance documentation  W3C training  AODA documentation

39. 39 Thank you