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).
Please send comments about this document to:
Those state entities or their contractors responsible for implementing ITEC Policy 1210 must
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.
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).
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:
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.
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.
While not a complete solution, there are many software tools which can be of great assistance in performing your accessibility evaluation. The state of Kansas has a license for Level Access' Accessibility Management Platform (AMP), and it is highly recommended that you use AMP to perform your assessments.
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.
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:
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 Information and Communication Technology Standards and Guidelines (36 CFR § 1194) 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. The current Section 508 Standards are harmonized with the WCAG.
For users of AMP, this prioritization is reflected more finely in the severity rating assigned to each best practice violation, best viewed by sorting by the Severity column in the Violations by Priority report view (found on the View menu on the Violations tab). (This view also provides additional information useful for prioritizing, including frequency, noticeability, tractability, and a composite priority value.)
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.
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.
Prepare a timeline for carrying our your remediation plans. The article How much time does it take to remediate a site or application for compliance? provides information that may be useful in estimating the time that will be required.
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 was 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 effectively applied 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.
For any cases where achieving compliance would constitute an undue burden to an entity, 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).
The Kansas Partnership for Accessible Technology Guidance for Web Developers page provides helpful information for conforming to ITEC Policy 1210. As mentioned above, AMP is an essential tool for assessing and monitoring compliance. Web Accessibility First Aid: Approaches for Interim Repairs is an excellent guide from the W3C to the kind of approach to ensuring compliance that is suggested above. These and other resources can be found on the KPAT Resources page. For questions and additional support, please contact Cole Robison, Director of IT 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.