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Kansas Partnership for Accessible Technology

State of Kansas Web Accessibility Requirements Implementation Guidance Version 2.0 (August 23, 2010)

Abstract

This document is intended to provide guidance to state entities in becoming compliant with Information Technology Executive Council Policy 1210 Web Accessibility Requirements. It outlines a suggested approach to inventory and assessment of an entity’s web content to determine compliance, as well as guidance on methods for determining priorities and planning for remediation.

This document is to be used in conjunction with ITEC Policy 1210, which details the requirements.

This document was produced by the Kansas Partnership for Accessible Technology (KPAT).

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Developing a plan for implementing the requirements

Those state entities or their contractors responsible for implementing ITEC Policy 1210 must

  1. ensure that all new content meets the requirements, and,
  2. where existing content is determined to not meet these requirements, develop and implement a plan for making existing content compliant.

To provide those responsible for ensuring compliance a starting place for planning to assess and potentially remediate content and services, the following sections outline a high-level planning approach that may be utilized.

Ensuring Compliance: A Suggested Approach

In general, web authors and administrators are advised to identify and prioritize the full extent of their sites’ content, and then make corrections as necessary in a priority-based order, with consideration to both the actual content (site prioritization) and the “problem” severity (accessibility requirement level).

Step One: Inventory content

The first step in assessing the compliance of your site and determining the scope of any required remediation efforts is to produce an inventory of your site. The inventory is essentially a list of all site content. The inventory will help you to understand how much content you have, and of what types, etc., so you know just what there is to be addressed.

You may already have such an inventory, or be able to generate one relatively easily with your existing toolset. If not, there are a number of low cost possibilities for producing an inventory, including:

  • using a sitemap generator (Note that these typically generate Sitemap files, a specific file format readable by search engines that is not directly useful as an inventory. Such generators often include additional export options, however, which can be used.)
  • using a link checker, such as the free Xenu’s Link Sleuth, which can produce a list of URLs as a by-product
  • for small sites, manual inspection of the server directories

A list of files is central to a site inventory, but you’ll also want to draw upon your entity’s experience with your site for understanding of what those files represent. A web application, for instance, may be comprised of relatively few files, but correspond to a tremendous amount of content due to its dynamic nature. Different file types, differing management scenarios for various collections of files, etc., may require different approaches, and so will likewise contribute to the overall interpretation of scope and inform your remediation planning.

Step Two: Assess Content for Compliance with ITEC Policy 1210

Once you have determined the nature and extent of your web content, you need to assess where accessibility standards compliance issues may exist, and what those issues are in order to determine what remediation is required. The W3C has a good overview of how to approach this process, and you may also find helpful information in the WebAIM article Planning, Repair and Maintenance.

While not a complete solution, there are many software tools which can be of great assistance in performing your accessibility evaluation. A list of what is available is maintained by the W3C.

The results of your evaluation should include specific details about both which, if any, of the requirements of ITEC Policy 1210 (i.e., Web Content Accessibility Guidelines (WCAG) Level A and AA success criteria and Section 508 Standards) are not met, and where in the content the issues exist.

Step Three: Prioritization for Remediation

Essential factors for determining priority within a site are traffic and criticality. That is, high traffic pages and pages that are on critical task paths, or otherwise especially important to the business of the entity, make up a site’s highest priority pages.

High priority pages will generally include the home page and any other landing pages (pages commonly accessed or linked to directly by users or other websites), as well as others that are heavily used (high traffic). Other high-priority pages would be those focused on delivering information or services specifically to members of the disability community, as well as any content widely reused within the site (e.g., templates, “include” files, etc.) where remediation would apply broadly, as fixes applied in one place would be replicated throughout the site. These pages should be foremost among content prioritization criteria. Other factors may also be taken into consideration for further “categorization” of the content, as called for by the unique context and purpose of each particular site. Considering content through use of these categories, coupled with an assessment of available resources, the complexity of the content, and the potential impact of remediation can be helpful in establishing priorities and approaches for any required remediation.

Categorizations may include:

Forms of technology used
Static HTML, content management systems, dynamic applications, rich internet application interfaces, PDF, audio/video, etc.
Development and maintenance scenario
In-house, contracted third party, commercial off-the-shelf products, software as a service, etc.
Nature of content production
Developed directly, supplied by non-technical content owners (e.g., as with a content management system), independently produced (e.g., video recordings), etc.
Currency of material
Current vs. past relevancy, enduring vs. transient value
Audience
Public-facing, partners, internal to entity, specific group of known individuals, etc.

Note that while some categories of content may represent lower prioritization for compliance than others, or differences in manner of remediation, all are ultimately subject to the compliance requirements.

Another factor to consider, particularly once some determination of what issues exist has been made (see above), are the conformance levels of the standards not met. ITEC Policy 1210 requires (1) conformance to the Federal Section 508 Electronic and Information Technology Accessibility Standards, Web-based intranet and internet information and applications (36 CFR § 1194.22) and (2) Level AA conformance to the World Wide Web Consortium (W3C) WCAG 2.0. The WCAG success criteria are designated as Level A, AA, or AAA. Accordingly, addressing Level A violations should take precedence over Level AA. (Level AAA conformance is not required by ITEC Policy 1210.) The Section 508 Standards are not subdivided into levels, but should all be considered to be of the highest priority. Prioritization that addresses Section 508 Standards issues first, then remaining WCAG Level A concerns, followed by WCAG Level AA is advised.

Taken all together, this analysis should result in the division of the content inventory into manageable groups, each with a place in a prioritized sequence and a suitable remediation approach.

Step Four: Create a Plan for Remediation

Once you have completed an assessment of your content for compliance with ITEC Policy 1210, you should have the information needed to develop a plan for remediation. This plan should take into account the findings from the above, available resources, etc., to present concrete steps and a specific timeline that will be followed to achieve full policy compliance.

The plan will likely be multi-faceted, reflecting a combination of possibly differing approaches for various content categories and perhaps different timelines for different prioritized levels, etc. Utilization of whatever grouping of content emerges from your prioritization and categorization activities should be beneficial in making the plan practical.

Step Five: Prepare a Timeline for Compliance

ITEC Policy 1210 was originally implemented by the Information Technology Executive Council on October 26, 2000. The policy has been updated twice since that date, on October 26, 2006 and April 23, 2009. For each update, the policy has prescribed an eighteen month period for implementation of changes since the previous update. The final date for complete compliance with the current revision (Revision 2) of ITEC Policy 1210 is October 23, 2010, which represents an 18-month rollout period from the date this revision went into effect. As the prior revision of the policy was already in effect, this rollout period should effectively apply to addressing differences between revisions, which are documented in the Transition to 2.0 section of the KPAT's Guidance for Web Developers, and the articles linked therein.

Undue Burden

For any cases where achieving compliance would constitute an undue burden to an entity—including cases where compliance is achievable but will take longer to complete than is consistent with the October 23, 2010 deadline—section 7.4 of ITEC Policy 1210 includes an exception request process:

7.4.1 The request for an exception shall be in writing, shall state the reason(s) that compliance will create a financial or administrative undue burden, and shall be submitted to the State ADA Coordinator. Such requests must receive approval by the State ADA Coordinator prior to deployment.

7.4.2 Entities shall describe in detail the challenges faced in making the webpage, web service, or web application accessible, including an estimate of hard and soft costs that would be incurred in doing so.

7.4.3 Entities shall describe their short-term and long-term solutions for making the webpage, web service, or web application accessible.

7.4.4 Entities shall submit a timeline in which the webpage, web service, or web application will be made accessible, and provide progress updates as requested by the KPAT.

The guidance contained in the proposed planning approach outlined above—inventorying content, prioritizing it in terms of impact, assessing its compliance, and developing a remediation plan and timeline—can be useful not only in developing an approach to successful remediation, but also in fulfilling the documentation requirements for an undue burden exception (as needed).

Additional resources

The Kansas Partnership for Accessible Technology Guidance for Web Developers page provides helpful information for conforming to ITEC Policy 1210. It and other resources can be found on the KPAT Resources page. For questions and additional support, please contact Cole Robison, Director of IT Accessibility.

Maintaining accessibility

Once your site has met the State of Kansas web accessibility requirements it is imperative that it continues to remain in compliance on an ongoing basis. Web authors and administrators must assure that all new pages and changes to site design (e.g., changes in organization or appearance) maintain full accessibility to the site.

 

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Landon State Office Building, 900 S.W. Jackson Street, Room 751-S, Topeka, KS 66612-1275
(785) 291-3016 · Fax: (785) 296-6594 · kpat@da.ks.gov

Page last modified on:  January 09, 2012