Presented at InnoTech Austin on October 20, 2011. For details on InnoTech, visit www.innotechconferences.com

1. A Strategic Approach to IT Accessibility
Jeff Kline, Statewide Accessibility Coordinator
Texas Department of Information Resources
October, 2011
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2. 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. Company A Software developed the product.
Both Company A and Corporation X’s studies indicated that this system would offer significant
advantages in cost savings, productivity, and candidate quality over the previous, mostly manual
processes.
• A highly qualified applicant, Cynthia, attempts to search for and apply for jobs on their website, but she is blind
and the new website is not accessible.
• Cynthia tries to contact Corporation X by sending an email to the main Corporation X address. After a week or
so, it found its way to the recruiters. She identifies herself as blind and requests help searching and applying.
• A week or so after receiving Cynthia’s note, a representative of Corporation X contacts Cynthia and tells her
that someone would get back to her “soon” to take her application by phone.
• After several weeks, Cynthia is very frustrated and shares her issue on a popular, large internet forum for the
blind, and her discussion thread attracts a lot of attention. During that time, the jobs she was qualified for were
closed and the positions filled.
• An attorney from a well-known advocacy group active on the blind forum contacts her about her problem and
commits to contact Corporation X regarding the accessibility of their website and its impacts.
• After several months of back and forth discussions and negotiations, the attorney concludes that Corporation X
is stiff-arming him, so the advocacy group files a class-action lawsuit alleging discrimination under the Title III of
the ADA. Corporation X then sues Company A for selling them an inaccessible product.
Prior to this event, accessibility was not on the radar at Corporation X or Company A. Corporation X had
never asked about accessibility during the requirements or procurement process, and Company A never
considered accessibility when it developed the application.
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3. Approaching EIR accessibility holistically
Why is it important to my organization?
Getting started
Organizing Accessibility
Costs and Funding Models
Stakeholder areas of an organization
Developing strategies and implementation plans
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4. Accessibility is about all of us.
Disabilities are no longer confined to traditional definitions, especially
with the growing need to embrace aging workforces and citizens.
World Wide USA
Total Population 6 Billion 281 Million
Disabled 750 Million (16%) 54 Million (19%)
Nonnative language
People with Disabilities Aging speakers & low literacy Temporary disabilities
16% of world By 2025 nearly 20% of the Globalization is driving many Everyday situations
population is disabled* industrialized nations’ people to communicate in disable certain senses
population will be over 65 nonnative languages temporarily
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5. Other Demographics
Ten percent of the world’s population (more than 600M people) lives with life-altering
disabilities (vision, hearing, speech, cognition, and mobility).
Two-thirds of people with disabilities live in developing countries.
Disability is a key driver of poverty: 70 percent of blind people in the United States are
unemployed.
The U.S. Department of Labor estimates that people with disabilities have an aggregate
annual income of nearly $700 billion, including $175 billion in discretionary spending power.
Between 2011 and 2031 the phenomenon of aging baby boomers will cause the various
markets of consumers with disabilities to converge and expand dramatically. U.S. adults
older than fifty are estimated to have more than $1.7 trillion in discretionary spending power
and $17 trillion of net worth.
Source: ―The Missing Link: Financing the Industry,‖ a 2007 paper by Barry K. Fingerhut of Synconium Partners
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6. New, emerging, and evolving standards & guidelines drive
accessibility requirements around the world
United States Federal Laws
US Sections 504, 508
Section 504 of the 1973 Rehabilitation Act
ADA Amendments • Prohibits organizations and employers from
Act excluding or denying individuals with disabilities an
equal opportunity to receive program benefits and
International services.
Link to section 504 of the rehabilitation Act of 1973
Standards EU Mandate 376
Americans with Disabilities Act (ADA) of 1990
• National mandate to eliminate discrimination
against people with disabilities. Link to ADA act of
1990
WCAG 2.0 UN Convention on Rights of Section 508 of the 1973 Rehabilitation Act
ATAG 2.0 PwDs (Amended in 1998)
• Applies accessibility standards to procurement and
development of electronic and information
technologies by federal government agencies. Link
to section 508 of the rehabilitation Act of 1973
China Law on the Protection of
9241-171 Disabled People
Canada Accessibility for
Ontarians with Disabilities Act
United Kingdom Equality Act
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7. State Accessibility Laws
At least 21 states have explicit statutes or
executive orders.
At least 6 states have accessibility policies.
Most reference Section 508.
All have procurement requirements.
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8. State of Texas Accessibility Laws & Rules
Texas Administrative Code
• 1 TAC Chapter 206: State Web Sites
 Subchapters B: State Agency Web Sites
 Subchapter C: Higher Education Web Sites
• 1 TAC Chapter 213: Electronic & Information Resources
 Subchapter B: Accessibility Standards for State Agencies
 Subchapter C: Accessibility Standards for Higher Education
Texas Government Code
2054.456 Access to Electronic & Information Resources by State Employees w Disabilities
2054.457 Access to Electronic & Information Resources by Other Individuals w Disabilities
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9. Accessibility-related litigation & legal inquiries in the U.S.
Will pay up to $16 million to compensate individuals who experienced
discrimination in violation of Title III of the Americans with Disabilities Act (ADA)
Sued by NFB for inaccessible website. Settlement of $6M not including
legal expenses, site remediation, and other incidentals.
Major tech company and State of TX sued by NFB – Software is
inaccessible to blind State of TX employees.
PMI (US-based organization) sued in UK due to inaccessible training
application.
Sued by DoJ for ADA violations. Settlement terms: must provide
accommodations for deaf and hard of hearing students.
Fined by State of N.Y. for special pricing available only on inaccessible
websites.
Sued by NFB and state employees because web applications were
inaccessible to the blind. Settled.
Sued by individuals. Inaccessible online services included in ruling.
ADA settlement over inaccessible ATMs.
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10. The Case for IT Accessibility
Competitive advantage
Ability to compete and win in markets, sectors and solicitations where
accessibility is a requirement
Increased market share – Raku Phone
SEO benefits
Socially responsible messaging
Direct and indirect workforce benefits
Risk Mitigation
Bid losses
External / internal litigation - ADA violations
HR issues – Hiring and employment practices, etc.
Negative PR
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11. The Case for IT Accessibility: Example
Fujitsu Raku-Raku Cell Phone
Developed by Fujitsu for the Japanese market.
Requirements of People with disabilities included in design specifications
Features and functions benefit all users, including those with age-related and other
disabilities.
• Large screens with the ability to display large letters
• One-touch calling and programmable buttons
• A ―text-to-speech‖ function for mail and websites
• A ―speech-to-text‖ device for composing mail
• An integrated text-to-speech player for books and the like
Result: more than 80 percent of Japan’s visually impaired use the Raku-Raku phone
Over 20 million Raku-Raku phones were sold between 1999 and June 2009.
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12. A Few Reasons Why IT Accessibility Doesn’t Happen
No awareness of the requirement for accessibility or considered optional—a
bonus rather than a requirement.
Awareness of the requirement was too late to be addressed. ―The project needed
to be accessible? Well, it’s too late now—we’ll do it next time.‖
No organizational policies or objectives or related to IT accessibility. ―I’m using
our existing development process, and I don’t see anything about accessibility.‖
No awareness of previous projects having been made accessible.
No one responsible for overseeing accessibility.
No accessibility skills or training programs in accessibility.
Employees with skills in IT accessibility were reassigned, unavailable, or left the
organization.
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13. What organizational areas may be affected by IT
Accessibility? (a non-exhaustive list)
Product development
Internal IT
Web commerce and communications
Procurement
HR
Acquisitions
Legal
Advertising and marketing communications
Internal communications
Education and learning
Business controls / compliance office
Medical / occupational health
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14. Getting Started
Obtain executive buy-in Develop an IT accessibility policy
Create an executive presentation or ―sell‖ package Create a team of SME’s to develop the
• Clearly articulate the need for an accessibility program policy
The ―big stick‖
Gain the commitment of top executives in the form
Foundation on which other aspects of
of resources (human and financial) IT
Obtain an executive sponsor or ―champion‖ to accessibility are developed
oversee and guide the program Should not be voluminous or contain
technical specs
Leverage, similar existing policies
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15. Organizing Accessibility
Senior manager ―executive sponsor‖
―Neutral‖ organizational placement
• Analysis of implications based reporting organization
Centralized accessibility function
• Policy and governance
• Technical consulting
• Business development / sales support
• Project office
Sub-Unit focal points / coordinators
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16. Program Costs
Determining Factors
Speed and trajectory of the IT accessibility initiative driven by
• urgency based on business or other requirements
• Budget considerations
Startup and ongoing costs
Start-up Investment Ongoing Investment
Cost Type Element Level Level
Human resources Enterprise/organization staffing High Medium
Human resources External consulting Medium/high Low/very low
Human resources Subunit/2nd-level subunit coordinators Low Low
Human resources Overall Initiative management Medium Low
Human resources Policy and process creation integration Medium Low
Human resources Training Medium Medium
Human resources Manual testing Medium Medium/high
Human resources Accessibility development Low Medium
Human resources Management system development Medium Low
Human resources Marketing support (private sector) Medium Low
IT hardware/ software Tracking/reporting tools Medium Very Low
IT hardware/ software Enterprise scan tool(s) Medium Low
IT hardware/ software Enterprise scan tool maintenance Low Low
IT hardware/ software Developer tools Medium Low
IT hardware/ software Test tools Medium Low
IT hardware/ software Development and test tool maintenance Low Low
IT hardware/ software IT hardware (desktop computers, etc.) Low Low
IT hardware/ software IT service (database hosting, etc.) Low Low
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17. Funding Models
Centralized Accessibility
―Corporate‖ or total organizational level funding
• Relatively small when the organization is large
Sub-unit ―taxation‖
• Tax units based on size, revenue, cost of operations, etc.
• Can involve negotiations and line item detail
Centralized Accessibility as a ―Cost Center‖
• Viable after program is up and running
Hybrid Models
Unit / Subunit Accessibility
Focal point / coordinator funded at unit sub-unit level
Accessibility implementation factored into development / IT budgets as any other
resource
• in-house (preferred) or contracted
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18. Developing an accessibility strategy
Key elements of an organization’s IT accessibility strategy
Rationale for the IT accessibility program
Business objectives definition
Linkage to the organization’s IT accessibility policy and relevant
standards, regulations, and policies
A description of the role of accessibility in the organization’s primary
business or service strategies
Assumptions, dependencies, and risks
Definitions of high-level organizational and governance models
Funding, budget, and other broad financial coonsiderations
A strategic framework for developing operational work plans
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19. An IT Accessibility Framework Template
• Obtain initiative support of agency executive team
• Develop long term agency goals
• Integrate into or develop processes to ensure consistency over time
Plan Strategically
• 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
• Provide developers tools to facilitate and remediate accessibility compliance
Automate for • Integrate accessibility into content management systems / processes
productivity and • Utilize standardized accessible templates (CSS, etc)
quality Organization
• Ensure browser neutral accessibility Work Plan
• Utilize enterprise level scan tools for issue identification / resolution
• Internally developed pages and applications
• Externally hosted services
Validate thoroughly, • Published documents / information
early, and often
• VPAT analysis and testing of supplier solutions
• Corrective actions process management / tools
Grow awareness • Evangelize accessibility throughout organization / IT supplier community
and provide • Build / maintain organization’s technical capacity with SME’s
education / training • Identify skill gaps, and resolve via and training staffing plans
• Develop goal appropriate metrics, and reporting tools / methods
Measure and track • Communicate and utilize results to drive initiative trajectory
progress • Maintain processes and results for ―audit readiness‖ posture
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20. Prioritize the work effort
Priority classification hierarchy* example
1. Externally facing, mission critical, high number of external users
(includes all Internet pages)
2. Externally facing, non-mission critical, high number of external users
3. Externally facing, mission critical, low number of external users
4. Externally facing, non-mission critical, low number of external users
5. Internal use, mission critical, high number of users
Prioritized
6. Internal use, non-mission critical, high number of users Applications
Template
7. Internal use, mission critical, low number of users
8. Internal use, non-mission critical, low number of users
*Priority classification assumptions
1. New applications/application enhancements entering pilot (user acceptance) test phase (Internet or intranet) should receive priority
within the priority class (1–6)
2. New applications/application enhancements under development (Internet or intranet) will receive priority within the priority class (1–6)
3. Priority for individual applications may change based upon business needs
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21. Identify skill gaps and build
“Role Based” Accessibility Training Plans
Web Web & Web
Knowledge General State Procurement Contract Contract Project
Course Title Population Office
Content Application Application
Staff Writers Compliance Managers
Level Producers Testers Developers
Introduction to
Fundamentals Required Required Required Required Required Required Required Required Required
Accessibility (Self)
Office Documents
Fundamentals Optional Required Required Optional Optional Required Required Optional Required
(Internal)
PDF (Internal) Required /
Fundamentals Required Optional Optional
Optional*
HTML
Fundamentals Required Required Required
(Internal or External)
HTML Forms
Fundamentals Required Optional Required
(Internal or External)
Testing & Tools
Fundamentals Required Required Required
(Internal or External)
CSS
Fundamentals Optional Optional Required
(Internal or External)
Javascript
Fundamentals Optional Optional Required
(Internal or External)
Dreamweaver Required /
Advanced
(Internal or External) Optional*
ASP / ASP.Net Required /
Advanced
(Internal or External) Optional*
Java / JSP Required /
Advanced
(Internal or External) Optional*
Web 2.0 Technologies Required /
Advanced
(Internal or External) Optional*
Accessibility Law, and its
Specialized Required Required Required Required
Impacts
Accessibility in Contract
Specialized Solicitations Required Required Required Required
Understanding/validating
Specialized Vendor EIR accessibility Required Required Required Required
* As needed based on assignment.
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22. Develop short and long term accessibility goals: Example
Web Content: Public Web pages
Facing and General
Access Intranet
• Maintain less than 2.5% pages with accessibility errors
PDFs
• Reduction of inaccessible PDF Documents 25% by end of fiscal 2011
• Reduction by 10% each subsequent year
Non-PDF documents
• Reduction of inaccessible non-PDF Documents 50% by end of fiscal 2011
• Reduction by 20% each subsequent year
Validation • Select and procure accessibility web scanning tool for internet / intranet pages
• Begin monthly scans and remediation of errors
Internal / External New internally developed or purchased applications
Applications
• 75% to be accessible
Existing applications
• 10% per year increase in compliance of existing applications
Training Intro level accessibility training to staff
• 90% Agency Staff by end of fiscal 2011; Remaining 10% in following year
Accessible Office Documents training
• 50% staff trained by end of fiscal 2011; 50% balance in 2012
Web developer accessibility training
• 100% developers trained by end of fiscal 2011
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23. Putting it all together
Set organization expectation levels
• Multi-year initiative
• Dynamic, with course and trajectory adjustments as needed
Ensure accessibility policies and objectives are well defined
Business needs and make accessibility investments
Prioritize the accessibility work
Develop strategy and plans using an Accessibility Framework
Identify accessibility skill gaps and develop training plans
Develop short / long term goals and measure to them
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24. Thank you
jeff.kline@dir.texas.gov
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