DARS Web Remediation Plan by lefttoleave

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									DARS Web Accessibility Implementation
       and Remediation Plan




               June 30, 2009




              Table of Contents
Introduction ..................................................................................................................... 3
1. How do we find out if a web site is accessible? ........................................................... 4
   1.1 Internet (public Web sites) ..................................................................................... 5
   1.2 Intranet (employee pages) ..................................................................................... 5
   1.3 Extranet (for a shared group of users, a password-protected public Web site) ..... 5
2. How do we find out if a Web application is accessible? .............................................. 5
3. How do we repair a Web site if it is not accessible? .................................................... 6
   3.1 Internet (public Web site) repairs ........................................................................... 6
   3.2 Intranet (employee page) repairs ........................................................................... 6
4. Who is responsible for ensuring that the Web sites are accessible? ........................... 6
   4.1 IRM accountability ................................................................................................. 7
   4.2 Accessibility coordinator’s accountability ............................................................... 7
   4.3 Web application and web developers’ accountability ............................................. 8
   4.4 Program or contract managers’ accountability ....................................................... 8
   4.5 Web publishers’ and content developers’ accountability ........................................ 8
5. What are the risks of not making DARS Web sites accessible? .................................. 8
6. How do employees and members of the public report accessibility failures? .............. 9
7. How do we ensure that new Web designs and documents are accessible? ............... 9
8. How does dars ensure that Web-delivered multimedia content is accessible? ......... 10
9. How does DARS teach staff members to make Web-delivered content accessible? 10
10. What kind of training is being offered at the HHS enterprise level? ........................ 11
11. How does DARS share resources and coordinate accessibility testing and
consulting? .................................................................................................................... 11
   11.1 Shared resources .............................................................................................. 12
   11.2 Coordinated accessibility testing, consulting, and training ................................. 12
12. How do HHS agencies share best practices in web accessibility remediation? ...... 12
13. How does DARS decide what to do first? ................................................................ 12
14. How does each agency handle exceptions for inaccessible Web pages and
applications? ................................................................................................................. 12
15. How does each agency tell its staff members what they need to do to make
everything accessible and how accessibility affects their job? ...................................... 13
                               Introduction
Health and Human Services System (HHS) policy dictates that all HHS agency Web
sites and Web applications must be accessible to staff members and members of the
public with disabilities. Texas Health and Human Services agencies are committed to
providing equal access to Web-based information in accordance with Section 508 of the
Rehabilitation Act of 1973, as amended; the Americans with Disabilities Act; and Texas
Government Code, Chapter 2054, Subchapter M. The resulting rules in 1 TAC Part 10,
§206.51 require each state agency to develop and publish an accessibility policy by
June 30, 2009. The HHS Electronic and Information Resources (EIR) Accessibility
Policy (HHS Circular C-024) and the HHS Electronic and Information Resources (EIR)
Accessibility Policy Manual satisfies this requirement. The Department of Information
Resources rule at 1 TAC §206.51(b) also requires each state agency's accessibility
policy to include a plan by which all Web pages, Web sites, and Web applications that
are subject to the Web accessibility standards will be brought into compliance with the
specifications and standards of 1 TAC Chapter 206, State Web Sites. This DARS Web
Accessibility Implementation and Remediation Plan is presented to fulfill the
requirements of this rule section, describing DARS’ detailed approach to testing and
remediating inaccessible Web sites, documents, and Web applications. Other electronic
and information resources (such as, telecommunications systems, office equipment,
and non-Web applications) are not covered by the scope of this plan.


HHS uniform policies, guidelines, resources, and testing methods are governed through
the Health and Human Services EIR Accessibility Steering Committee. Each agency is
represented on the EIR Steering Committee by the agency’s chief operating officer. The
EIR Steering Committee considers recommendations from the staff-level EIR
Accessibility Work Group consisting of each agency’s designated accessibility
coordinator and voting alternate. The HHS Remediation Plan template is evaluated by
the EIR Accessibility Work Group annually. Progress on plan implementation is
monitored, documented, and reported quarterly by each accessibility coordinator to the
HHS EIR Steering Committee and to his or her agency’s internal governance.


The DARS accessibility team is staffed within the Center for Policy and Innovation
(CPI). The team includes the PTA manager, online manual specialist, accessibility
coordinator, and one accessibility specialist, with plans to add three additional
specialists in the 2010–2011 biennium. DARS also has a dedicated Media Services unit
with a Captioning Center to provide captioning to video and multimedia presentations.
The DARS Information Resources Department has a lead accessibility Web developer
for Web applications.

This DARS accessibility team serves as an agency resource for
    accessibility testing,
      consulting,
      training, and
      Web page and document accessibility remediation.

The DARS accessibility coordinator works with internal stakeholders to implement the
HHS EIR accessibility policy throughout the agency. The accessibility coordinator chairs
the DARS Accessibility Users Group (AUG). The DARS AUG manages the governance
of accessibility in coordination with the DARS Technical Architectural Review Board,
Business Review Board, and Internet-Intranet Users Group. These DARS IT
governance groups coordinate approval of accessibility recommendations to the DARS
Guiding Team. DARS Enterprise-level accessibility issues are governed and
coordinated through the HHS EIR Accessibility Work Group.

DARS CPI promotes accessibility implementation by delivering accessibility training to
all DARS staff. The DARS New Employee Orientation includes a basic introduction to
accessibility of electronic and information resources. Tool-specific accessibility training
is provided to DARS content contributors and developers as needed.


1. How do we find out if a Web site is
accessible?
HHS agencies began testing portions of their public Web sites using IBM’s Rational
Policy Tester in December 2008. The strategy for all HHS agencies is to test a limited
number of pages monthly and identify the most frequent errors, and then each agency
assigns those issues to the responsible staff members for remediation. As issues are
resolved, the next most frequent problems are addressed. All HHS agencies have
prioritized the testing and remediation of their public-facing Web sites. Testing of
internal Web pages is pending the resolution of information security issues with the IBM
Rational Policy Tester access to internal servers through the IBM Team for Texas
contract.


After each agency’s Web pages are scanned by the automated testing software (IBM
Rational Policy Tester), many pages will be inspected manually as part of an ongoing
auditing process. The cross sections of pages that are being monitored as part of a first
year report sample are representative of the diverse agency Web environments. Any
applicable sites not currently monitored are added in a timely manner. Monitoring is
administered or supervised by the accessibility coordinators or their designees, who
report directly through the EIR Accessibility Work Group and the EIR Accessibility
Steering Committee. If a Web page does not conform to the Section 508 guidelines, a
report communicating results of the Web site's Section 508 compliance evaluation is
sent to the Web publisher and/or owner, requesting a correction and notification of the
correction.
1.1 Internet (public Web sites)
The DARS public Web site (www.dars.state.tx.us) is scanned monthly using the IBM
Rational Policy Tester. The monthly reports are reviewed by the DARS accessibility
coordinator, the DARS webmaster, and the DARS accessibility specialist. This team
prioritizes problems that have been identified by the tool, and remediation is completed
on a monthly schedule. Over 90 percent of the issues identified by the initial scans of
the DARS Internet site have been cleared to date.
New Internet content is reviewed by the Center for Consumer and External Affairs and
tested for accessibility by the CPI accessibility team using automated and manual
testing procedures before publication.

1.2 Intranet (employee pages)
Intranet content is tested for accessibility by the DARS accessibility team and by trained
content developers using automated desktop and manual testing methods. Policy for
intranet content is developed and maintained by the Internet-Intranet Users Group. The
DARS network security officer is currently working with IBM Team for Texas to open the
DARS Intranet for scanning using the IBM Rational Policy Tester. After the Rational
Policy Tester scans are implemented, review and remediation procedures similar to
those for the DARS Internet will be used.

1.3 Extranet (for a shared group of users, a password-
protected public Web site)
Extranet content is tested for accessibility by the DARS accessibility team and by
trained content developers using automated desktop and manual testing methods. This
testing is initiated by the owners of the extranet content.


2. How do we find out if a Web application is
accessible?
Agency web applications are tested for accessibility by the application development
team, the DARS accessibility team, and, in the case of mission-critical applications, by
assistive technology users within the agency. All testing occurs before deployment of
the application and after upgrades or modifications to the application, and testing is built
into the lifecycle of new and enhanced applications.
3. How do we repair a Web site if it is not
accessible?
The persons who test and repair inaccessible Web sites vary from agency to agency.
When web content is determined to fail to meet accessibility standards at DARS, either
through automated testing or user reporting, the content owner, accessibility
coordinator, and in the case of internet content, the DARS webmaster are notified. The
accessibility coordinator works with the content owner and/or the webmaster to
determine the severity and impact of the failure and establish a priority and timeline for
repair. In cases where the impact is severe, and the repair cannot be accomplished
within 30 days, an exception may be requested from the commissioner, or if the content
is not critical to DARS mission it may be temporarily removed. In cases where the
impact is not severe, for example when the failure does not prevent access but only
makes access more difficult, repair of the content may be delayed to allow the
remediation of more severe problems.

3.1 Internet (public Web site) repairs
Accessibility repairs to the DARS Internet site are made by the content owners with
consultation and assistance from the DARS accessibility team and DARS webmaster.

3.2 Intranet (employee page) repairs
Accessibility repairs to the DARS Intranet site are made by the content owners with
consultation and assistance from the DARS Accessibility team and DARS webmaster.


4. Who is responsible for ensuring that the
Web sites are accessible?
Under HHS policy, all HHS agencies must comply with all provisions of Chapter 2054
Subchapter M, Texas Government Code, and Section 508 of the Rehabilitation Act of
1973, as amended (29 U.S.C. §794d). According to HHS policy, the enterprise
consolidated plan for accessibility of electronic and information resources places
accountability for accessibility with each agency's commissioner and requires that he or
she hold his or her agency’s management accountable for accessibility compliance.
Each agency must develop its own plan to ensure that employees with disabilities have
access to and the use of those resources comparable to the access and use available
to state employees without disabilities, unless compliance with this requirement
imposes a significant difficulty or expense. Under the plan, agencies must also provide
members of the public who have disabilities with access to and use of information that is
comparable to that provided to members of the public without disabilities, unless this
requirement imposes a significant difficulty or expense.
The implementation of accessibility and remediation of noncompliant Web pages is a
shared responsibility within each agency. This responsibility includes participation from
each agency's chief operating officer; accessibility coordinator; webmasters and Web
developers; staff members contracting or purchasing Web applications and services
delivered on the Web; and anyone who creates, distributes, modifies, or maintains any
electronic communication delivered on the Web, including documents, forms, and
multimedia content.



4.1 IRM accountability
The DARS Information Resources manager (IRM) works under the supervision of the
chief operating officer. The IRM guides DARS’ overall strategic vision for information
technology applications and Web resources. The DARS IRM collaborates with all DARS
business units to ensure that IT solutions align with business needs. Under the DARS
IRM’s leadership, accessibility is implemented through coordination with the DARS
accessibility team, and AUG; and with accountability to the DARS Guiding Team and
the Texas Department of Information resources.

4.2 Accessibility coordinator’s accountability
The DARS EIR accessibility coordinator does the following:
         ensures that agency policies and business practices are consistent with HHS
          EIR accessibility policy and meet the accessibility requirements in 1 Texas
          Administrative Code, Chapters 206 and 213;
         works with the EIR Accessibility Work Group to maintain the HHS
          accessibility policy and content for the EIR accessibility Web site;
         develops, implements, and maintains a process for the public and staff
          members to report noncompliant Web sites, electronic and information
          resources, applications, or products to the EIR accessibility coordinator;
         recommends a process to regularly test and validate agency Web sites,
          electronic and information resources, applications, or products for compliance
          with HHS EIR accessibility standards;
         develops corrective action plans to remediate noncompliant Web sites,
          electronic and information resources, applications, or products;
         promotes EIR accessibility requirements to agency staff members by
          coordinating or providing training, technical support, and presentations to
          support implementing and monitoring effective accessibility standards;
         provides regular status reports on compliance and corrective action plans to
          the HHS EIR accessibility steering committee;
         coordinates the completion of the annual DIR Accessibility Survey as required
          in 1 TAC §213.20;
         coordinates with agency software development teams to ensure that
          accessibility functionality and testing is built into the development lifecycle of
          new and enhanced products;
          provides consulting services to agency executive staff members on
           accessibility issues such as
              o evaluating new software and hardware (for example, validates the
                  Voluntary Product Accessibility Template - VPAT),
              o suggesting effective methods of access as alternatives to inaccessible
                  EIR; and
              o serving as a consultant to the commissioner for reviewing requests for
                  exceptions from within the agency.


4.3 Web application and Web developers’
accountability
DARS Web application and content developers are responsible for understanding
accessibility standards, obtaining necessary training, and applying applicable standards
to their content. Web contributors may request accessibility testing of content and/or
consulting from the CPI accessibility testing team using a DARS1597. Training may be
obtained through the CPI accessibility team or through third parties with approval of the
contributor’s supervisor.

4.4 Program or contract managers’ accountability
DARS program and contract managers have a shared responsibility for ensuring the
accessibility of their internal and external Web content. Program and contract managers
may request accessibility testing of their content by the CPI accessibility testing team
using a DARS1597.

4.5 Web publishers’ and content developers’
accountability
Program Web contributors are responsible for understanding accessibility standards,
obtaining necessary training, and applying applicable standards to their content. Web
contributors may request accessibility testing of content, training, and/or consulting from
the CPI accessibility testing team using a DARS1597.


5. What are the risks of not making DARS
Web sites accessible?
The legislature holds the commissioner accountable. The commissioner holds the chief
operating officer, the accessibility coordinator, and the IRM accountable. If DARS failed
to make its Web sites accessible inaccessible content may be removed, DARS staff
members with disabilities would not be able to perform their duties efficiently and DARS
stakeholders and consumers could be denied important information or access to
services.
6. How do employees and members of the
public report accessibility failures?
The content and approach to public reporting are unique to each agency. The HHSC
Civil Rights office handles formal accessibility complaints about civil rights violations for
employees and the public. Other accessibility issues are addressed separately by each
agency.


Internal problems are reported by employees, while external problems are reported by
members of the public. Such problems may be technical issues or accessibility issues
more broadly understood. All reports go to the designated agency staff members such
as Webmasters or the designated EIR accessibility coordinator. The content and
approach to reporting and responding to technical issues are unique to each agency.


If a staff member receives a formal accessibility complaint from an employee or the
public, the staff member refers the complaint to the HHSC Civil Rights Office within 10
calendar days. These complaints are related to receipt of services and access to
electronic and information resources.


Within DARS, complaints received from the public regarding the accessibility of DARS
external Web content are forwarded to the accessibility coordinator by the Inquiries Unit.
Internal complaints from staff are received directly by the accessibility coordinator via
email, telephone, or in person. The accessibility coordinator evaluates the complaint to
determine if the content in question fails to meet HHS accessibility policy and works with
content owners to ensure that problems are corrected.


7. How do we ensure that new Web designs
and documents are accessible?
DARS follows technical coding guidance already published in the HHS EIR Accessibility
Procedures Manual. In addition, DARS ensures that new Web designs and documents
are accessible by
      using a style guide; testing all forms for accessibility before publication in the
       DARS forms catalog; developing and testing pages and applications to Section
       508 standards before they are published; and
      putting accessibility specifications in all contracts that directly or indirectly include
       the development or provision of Web pages or Web applications.
8. How does DARS ensure that Web-
delivered multimedia content is accessible?
DARS ensures that Web-delivered multimedia content is accessible through manual
testing, compliance communication, and training for media staff. Health and Human
Services System (HHS) policy dictates that training and informational video and
multimedia productions that support the agency's mission and contain speech or other
audio information necessary for comprehension of the content must be captioned,
regardless of format. Audio-only media presentations that are not live, such as
streaming audio webcasts, must include a posted text transcript. HHS agencies
evaluate the target audience of training and informational video or multimedia
production when considering a reasonable exception to this policy for significant
difficulty or expense. Multimedia content intended for the general public or all agency
staff members may have a greater need for captioning than multimedia content
intended for a discreet target audience, as the latter is often used for a short duration
and is unlikely to need captioning.
Testing and compliance methods include
      using manual testing or inspection,
      putting accessibility specifications in all contracts that directly or indirectly include
       the development or provision of multimedia Web content, and
      providing captioning and audio description through DARS Media Services.


9. How does DARS teach staff members to
make Web-delivered content accessible?
DARS management ensures that staff members receive EIR accessibility training
appropriate for their job function. HHS provides a Web-based training introductory
course to fulfill a requirement for basic training of all HHS staff members.
At DARS
          accessibility awareness training is included in new employee orientation
           training;
          IRMs and managers commit funding for training their developers;
          HHS training subcommittees organize online resources on the HHS EIR
           Accessibility Center for making Web-delivered content available; and
          the DARS CPI accessibility team provides training to DARS and other HHS
           agencies on accessibility policy, testing, and techniques.
10. What kind of training is being offered at
the HHS enterprise level?
HHS policy mandates introductory and basic accessibility training for all staff members,
plus, intermediate, advanced, and specialized training to meet specific needs for the
production of different types of EIR content.. The following training courses are being
developed at the HHS enterprise level:
       Introductory. Introductory training is being developed at the HHS enterprise
        level and will entail high-level online training for all HHS staff members. HHS will
        add accessibility awareness information in the computer-based civil rights
        training that all HHS employees receive at hiring and every two years thereafter.
        HHS will develop additional introductory training to guide staff members through
        the following electronic and information resource accessibility information:
                o overview,
               o policy and procedures,
               o assistive technologies, and
               o examples of accessible electronic and information resources.
       Basic. Basic training guides staff members through developing accessible
        electronic information using standard desktop applications.
       Intermediate. Intermediate training teaches staff members to write, maintain,
        and review Web-based electronic information. This includes accessible Web
        pages, forms, and tables. This training applies to a relatively small number of
        staff members.
       Advanced. This is technical training for Web and applications developers and
        other Information Technology (IT) staff members. DARS accessibility staff will
        provide advanced technical training to other HHS agencies’ personnel.
       Specialized. This training is for a variety of specialized staff members, ranging
        from IT purchasers, to procurement and contracting staff members, to
        communications staff members, etc. The accessibility coordinator and applicable
        management evaluate the need for specialized training on a case-by-case basis.
        The accessibility coordinator will continue to identify specialized training
        resources, such as the free online courses available at www.section508.gov by
        registering for “508 Universe.”

11. How does DARS share resources and
coordinate accessibility testing and
consulting?
DARS expands its existing shared services contracts with enterprise agencies to
provide accessibility testing, training, and consultation. Agencies have the flexibility to
use state-approved accessibility contractors if DARS is unable to meet an individual
agency’s request for services. Each agency retains its individual accountability and
responsibility for planning, prioritizing, and implementing accessibility compliance.

11.1 Shared resources
The existing HHS Electronic and Information Resources (EIR) Accessibility Work
Group, under the direction of the HHS EIR Steering Committee, serves as the strategic
coordination and planning effort for enterprise accessibility compliance.

11.2 Coordinated accessibility testing, consulting, and
training
The HHS EIR Accessibility Work Group coordinates common approaches for
accessibility testing, compliance, and use of the shared IBM Rational Policy Tester
resource. DARS delivers consulting, testing, and training resources through the LAR-
approved shared services contract between DARS and the HHS agencies.


12. How do HHS agencies share best
practices in Web accessibility remediation?
Agencies share best practices through the EIR Accessibility Center Web site and EIR
Accessibility Work Group meetings.


13. How does DARS decide what to do first?
Priorities are established based upon the solution’s impact on the overall accessibility of
the Internet or intranet content, and upon the severity of the accessibility barrier. For
example, global changes are made to agency Web templates to address site-wide 508
failures, or corrections are made to Web forms used to provide access to agency
programs.


14. How does each agency handle
exceptions for inaccessible Web pages and
applications?
HHS agencies may find a compliance issue that proves to be too costly or difficult to
resolve. For compliance exceptions for inaccessible Web pages and applications, the
agency must submit a request to the agency’s commissioner and complete an
Accessibility Exception Request Form. For more information about exceptions, see HHS
EIR Accessibility Policy Manual, Chapter 1
15. How does each agency tell its staff
members what they need to do to make
everything accessible and how accessibility
affects their job?
In addition to directing staff members to the basic accessibility awareness training, HHS
policy dictates that each agency do the following:
       send out general communications to all staff members explaining what
        accessibility of EIR means, why it is important, and why addressing it is
        mandatory and pointing them to training and resources to help them acquire the
        skills they need to incorporate accessibility into their daily work;
       publish a link from the agency’s intranet or Extranet Web site to the HHS EIR
        Accessibility Web site; and
       use its primary communications tools (newsletters, intranet, email, etc.) to
        promote new accessibility training and resources as they become available.

								
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