Web Accessibility Priority 1 Implementation Plan

Introduction

The following plan is as outlined by coded memorandum AA-2007-04 (pdf) titled "Access to Electronic and Information Technology for Persons with Disabilities." The Accessible Technology Initiative (ATI) reflects the California State University's (CSU) ongoing commitment to provide access to information resources and technologies to individuals with disabilities. This commitment is articulated in Executive Order 926 (EO 926), the CSU Board of Trustees Policy on Disability Support and Accommodations:

"It is the policy of the CSU to make information technology resources and services accessible to all CSU students, faculty, staff, and the general public regardless of disability."

The overall campus directive for accessibility compliance was communicated to campus through an e-mail from the president on December 1, 2006. The implementation plan, along with all other compliance information, is posted at the Information Resources ATI Project site.

Chico has also completed a First Year Web Report, included as Appendix A, which gives a baseline assessment for the accessibility of our web content.

Table of Contents

Roles and Responsibilities

ATI Steering Committee

The ATI Steering Committee has ultimate responsibility for ensuring compliance with web accessibility standards. This committee is chaired by the campus Executive Sponsor and includes the head of Disability Support Services, a Faculty Senate representative, and other key decision-makers.

Web Accessibility Team

The Web Accessibility Team, chaired by the head of Web Development, is comprised of representatives from several campus units involved heavily in web development. This team will direct the monitoring of compliance with accessibility standards as well as communicate accessibility information to the appropriate stakeholders through training and online resources.

Content Owners

Content owners are the individuals responsible for the content of web sites in their respective areas. Typically, this includes deans, chairs, and directors and their designees. Content owners typically designate maintenance of content to web contributors.

Web Contributors

Campus web contributors generate web content or develop web-based applications under the direction of the content owners. Web contributors may be staff, faculty, or student staff.

Current Campus Web Content & Development

In general, campus web content is derived from one of four sources:

  1. Self-generated by departments or individuals
  2. Self-generated via a Web Content Management System (WCMS)
  3. Campus service & support departments (Web Services, Web Application Development, etc.)
  4. Off-campus vendors

Self-generated by Departments or Individuals

For areas that are self-generating web content the campus provides support and training through Technology & Learning Program (TLP) and User Services (USRV) for Dreamweaver that includes necessary information on accessibility. Self-supported areas also have access to 508-compliant templates developed by Web Services.

This is the content owner control model, where content owners control all aspects of the site, its structure, design, and content. Some content owners may have lower levels of technical and accessibility knowledge with regard to web development. As a result, sites maintained under this model are the most likely to have recurring accessibility problems.

Self-generated via a WCMS

This is in a somewhat different category since a WCMS can be used to impose more (but not total) control over accessibility. Templates can be designed with accessibility in mind, providing built in "skip to content" links on every page, as well as requiring ALT tags on all images. A WCMS is not a silver bullet but can dramatically reduce potential accessibility problems.

A WCMS is a hybrid control model, where control over the actual content is in the hands of the content owners, while the templates and HTML/CSS code are in the hands of the WCMS administrators (and the WCMS application to some degree). The hope is that the site is set up correctly and that the WCMS's accessibility tools work well enough to keep accessibility problems at a minimum.

Campus Service & Support Departments

Campus service & support departments within Information Resources are currently adhering to ATI requirements for new and redesigned sites. The web contributor community will be used to share strategies and information with other departments on campus.

This is a technical control model, where content is actually maintained by people with technical and accessibility knowledge and who adhere to ATI requirements. These sites are potentially the least likely to have accessibility problems now and in the future.

Off-campus Vendors

Contracts with vendors that provide content management services are reviewed for accessibility by Information Resources before implementation.

Vendors are essentially a wild card. While some are quite aware of accessibility issues and take extra steps to ensure compliance, others have little knowledge of or concern for accessibility issues. The potentially most problematic cases involve small, custom-designed content management systems, produced by vendors that lack the resources to redesign their products to meet accessibility requirements.

Monitoring/Auditing

Monitoring

Monitoring involves reviewing web sites for accessibility compliance. Our campus, along with the other CSU campuses, has purchased AccMonitor from HiSoftware, which provides centralized monitoring capabilities. The campus will take a phased approach to the monitoring and auditing of web sites. For the First Year Report, we identified approximately 50 sites to perform our initial evaluation on to help set a baseline standard to work from. These fifty sites were loaded into AccMonitor and set up for scanning. These sites will be configured to have any accessibility error notices e-mailed to the content owner. After the remediation of the initial sites, an addition 50 sites will be added to the list of sites that are monitored by AccMonitor. These additional sites will be chosen based on extending the guidelines used to select sites for the First Year Web Report. This phased approach will allow the support organization on campus to handle remediation efficiently.

Our target is to provide all current web sites with a monitoring report showing the current state of accessibility compliance by June 15, 2008.

Auditing

Auditing involves reviewing the output of AccMonitor and communicating the issues to the content contributors and owners. The content contributors would get detailed information which would point to specific locations and issues. The content owner would receive a summary of the information. The Web Accessibility Team will be responsible for auditing and communication.

Critical Administrative Sites

One goal of the implementation plan is to ensure that critical administrative sites are accessible. The Web Accessibility Team will survey the campus administrative units to determine which sites are deemed critical.

Remediation

Remediation is the process of making changes to web content to ensure equal effective access to all persons by conforming to the web accessibility standards defined by the Chancellor's Office. Developing web content that adheres to W3C (World Wide Web Consortium) and Web Services standards will reduce the amount of remediation needed.

Accountability

Although web contributors will be charged with the technical details of remediation, accountability to ensure that remediation is completed will fall to the content owner. Content owners will be accountable for ensuring remediation by vendors or contractors that generate web content for their areas.

Equally Effective Alternatives

In situations where online content cannot comply with Section 508 standards due to the nature of the content or constraints of the technology, requests for exceptions shall be considered on a case-by-case basis. All requests for exceptions shall be made to the Web Accessibility Team via the exception request process. The Web Accessibility Team shall evaluate the request to determine if Section 508 compliance can be achieved through applying a higher level of expertise or if the request is a valid candidate for consideration for an exception. Since the University bears the responsibility for effectively communicating the online information in situations where an exception to Section 508 compliance has been granted, the Web Accessibility Team shall ensure a procedure to provide timely access to that information has been established and documented.

When an exception is granted, there must be an alternate way for the user to access this information in a timely manner. Online content that has been granted an exception must contain directions to the user for accessing it in a format that is accessible to him or her. These directions must be prominently located and presented in a 508-compliant format. A contact person responsible for Section 508 compliance for the online information shall be included on all online content granted exceptions.

All exceptions will be logged by the Web Accessibility Team and reviewed prior to each semester for renewal.

Alternative Delivery during Retrofit

Pages that do not meet accessibility requirements must provide alternative methods for obtaining information during any period in which those pages are undergoing retrofits. Inaccessible material shall be delineated on the page in the production environment and shall include an explanation of how to obtain the information. The response will be dependent on the extent of the accessibility problem. For example, a page with inaccessible navigation elements should be replaced with a temporary, accessible page. A page with an inaccessible form could remain in place with the addition of language describing an alternative way to complete the form.

Documentation Policy

If a monitored sites falls out of compliance the content owner will be notified and the issues and date will be documented. When the site has been remediated the documentation will be updated to reflect that the site is back in compliance.

Training & Resources

In the early part of the first year an accessibility resources web site will be launched containing documents and information for scanning and remediation of common problems, as well recommended development practices for areas that need to self-generate web content.

The Web Accessibility Team will coordinate training for monitoring and remediation with existing campus training groups. The schedule for training will be posted in the resources web site and will also be directly communicated to the web contributor community.

Web Contributor Community

The Web Contributor Community will initially be composed of staff within Information Resources who work with web design and/or development as well as the technical leads for the sites identified in the First Year Report. As we expand the number of monitored sites, other technical leads will be added to the community.

The Web Contributor Community will facilitate professional networking and sharing of ideas related to the technical aspect of web design and development. It will use a mailing list and a web-based collaborative editing environment to give these designers and developers the resources necessary to share information. We will use this as an opportunity to share information about such topics as:

  • Web Accessibility
  • Web Standards
  • Development Best Practices
  • New Technologies

In addition to online communication, the Web Contributor Community will have physical meetings where presentations are given by members of the community. We also see the opportunity for professional networking at these meetings, which we hope will have positive implications in cross-departmental communications.

The Web Contributor Community may also serve as a forum for other departments, such as Data Warehouse and Information Security, to periodically promote their services and best practices.

Communication Plan

Communication with the content owners and web contributors will take place primarily through mailing lists that will enable the Web Accessibility Team to disseminate information as deemed necessary. Content owners will automatically be added to the mailing list, but will have the option to unsubscribe at any time. An introductory e-mail is sent to content owners and web contributors as they are phased into the plan. The mailing list will present an opportunity for content owners to ask and receive support from their peers of web content contributors and content owners. Content owners and contributors will be notified that all new and updated content will need to be in compliance with accessibility standards.

It will be primarily the responsibility of the content owners within the academic areas to communicate web accessibility information to their faculty. Additionally, the Academic Technologies staff will incorporate web accessibility awareness in their faculty training programs.

Individual communications about remediation will be communicated as indicated in the Auditing section above.

If an outside vendor is involved, they will receive the introductory communication regarding campus compliance policies and will be held to the same standards as on-campus web contributors.

Evaluating Effectiveness

Effectiveness will be measured in compliance of campus web sites as reported by AccMonitor and documented in the Second Year Web Report.

Milestones

  • May 15, 2007: Completion of the First Year Web Report. This project replaces the 20-page manual evaluation previously described in the Coded Memo AA 2006-41 dated September 28, 2006. A draft process guide incorporating both an automated and manual checking process for evaluating a sample of campus websites has been developed and placed on the ATI Blackboard site at https://fullerton.blackboard.com/. This first-year project will assist campuses in conducting a self-evaluation of the accessibility of their websites and in planning for remediation. (The Technology Access Transition Plan referenced in Coded Memo AA 2006-41 is no longer required.)
  • June 15, 2007: Submission of the Web Accessibility Implementation Plan and First Year Web Report
  • September 1, 2007: New and updated administrative websites, web applications, and web content produced by the CSU or by third-party developers should, at a minimum, conform to baseline accessibility standards as defined in Section 508, Subpart B, and where appropriate, Subpart C (http://www.access-board.gov/sec508/standards.htm). This timeline applies only to administrative sites. The deadlines applied to instructional sites are provided in the Instructional Materials section of this memo.
  • June, 2008: Submission of the Second Year Web Report
  • May 15, 2009: All administrative sites that are critical to institutional access (as established in the Web Accessibility Implementation Plan) should, at a minimum, conform to baseline accessibility standards as defined in Section 508. If remediation or replacement of the website is not possible or would constitute an undue burden, then a plan to provide an equally effective alternate form of access must be developed, documented, and communicated.
  • May 15, 2012: All websites at the CSU should fully conform to Section 508. Once again, undue burden plan requirements (as described above) apply.

Appendix A

First Year Web Report