IT Accessibility Planning Guide
Everyone should have access to state government services, employment, and the democratic process.
Colorado is committed to making that a reality. The time is now.
TAP Monthly Updates
April
OIT Accessibility Implementation Project: applications testing
OIT project update: OIT and agency partners are selecting vendors for application testing. Testing is scheduled to begin on the first group of applications at the end of April. Once testing is complete, a report with remediation recommendations will be shared with agency stakeholders.
Project Questions: Questions about accessibility testing and remediation of agency applications should be directed to your agency IT director.
Accessibility training updates
Training for vendors or contractors: Whether a vendor is providing a product or a service, the state expectation is that the vendor organization has operationalized accessibility to be able to support their government partners’ compliance requirements. TAP will keep you posted on guidance that will be added for vendors/contractors but for now, you can refer vendors and contractors to the Vendor Accessibility Checklist.
Access Academy Licenses: The TAP team is thrilled by the number of folks that are actively engaged with the course offerings in Access Academy! However, we are currently at capacity for training licenses and will not be able to enroll additional learners into Access Academy at this time. The TAP team will keep agencies posted as licenses become available and we resume our enrollment process. In addition, we need to remove users who are not actively engaged in the courses. We will be sending out an email to folks that have zero activity in the Access Academy courses since 2023 (or early 2024), giving them five business days to engage with the course content in order to keep their license. We will run another "zero activity" report on Friday, April 19 at 5 p.m. and will remove anyone on that list from Access Academy.
Accessibility announcements and resources
Overlays: After researching, reviewing and discussing the nature and issues of accessibility overlays with the disability community, accessibility community, vendor community and others, here is the current stance and guidance from the TAP team:
Accessibility overlay tools can be valuable for assisting people who have a variety of disabilities. They can also be used as a great accommodation tool when a website is not yet fully accessible and when specific issues are not yet addressed. However, overlay tools:
Should not create any accessibility issues in the website such as interference with assistive technology or limit those with visual or cognitive disabilities capabilities to access all content and functionality on the site.
Should be tested and/or a demo should be provided to show where the product meets or does not meet accessibility. It is also recommended that a compliance report be provided to indicate where the product is or is not in compliance with WCAG guidelines.
Should be combined with other means to meet compliance including manual testing, regularly monitoring, and operationalization of accessibility within the organization.
Should not be used as the sole means of meeting compliance and removing barriers for people with disabilities.
Additionally, we recommend that if a particular website uses some form of automation to address accessibility issues, it needs to enable the end user to do all of the following:
Be made aware that an automated accessibility remediation solution is operating.
Determine when an automated accessibility solution is operating and when it is not.
Activate or deactivate an automated accessibility solution as needed.
Configure the automated accessibility solution to meet specific disability requirements (e.g., screen-reader mode or contrast adjustment) using fully accessible controls.
Contact the provider of the accessibility automation remediation tool.
Local government accessibility support: For those of you getting accessibility questions from local government partners, the TAP team doesn’t have the resources to provide one-on-one support but we have put together some resources for those organizations that we encourage you to share: Accessibility Planning for Government Organizations (Google Slides)
Change management resources:
Change Management Communications Presentation (Google Slides)
Sample Change Management Communications Plan (Google Sheets)
Tyler Colorado March update:
Tyler Colorado March Accessibility Open Hours Update (PDF)
Rules Compliance Speaker Series
We’re bringing the rules to you! Now that the adopted rules are available, OIT offers multiple opportunities for you to learn about the rules and advance accessibility efforts. Don’t worry, recordings will be available if you miss a session.
For state agencies, we’re offering a weekly deep dive into different topics with the Rules Speaker Series. These sessions are open to all state agency employees and we encourage anyone interested to attend!
You may also join the “Complying with the Technology Accessibility Statutes and Rules” online session on May 10 at 10 a.m. This event is targeted to local governments and special districts. Registration on Zoom.
If you are a person with a disability who requires an accommodation to participate in any of these presentations, please send a request to oit_accessibility@state.co.us at least a week in advance of the event.
March
OIT Accessibility Implementation Project: applications testing
OIT is currently working on prioritizing the OIT supported applications that were submitted by each agency as their most critical for testing. We're on track to begin manual accessibility testing of applications by April 29, 2024.
Questions about accessibility testing and remediation of agency applications should be directed to the agency IT director.
The TAP team recommends that accessibility efforts focused on applications are coordinated with the agency product director and IT director in collaboration with the agency’s accessibility coordinator and the TAP accessibility consultant so that the entire team is working with current information and is communicating through a single channel.
Refer to the Agency Accessibility Roles Google Sheet and Accessibility Portfolios Google Doc for contact information.
New accommodations resources:
Intro to Accommodations (Google Slides)
Getting Started with Accessibility Accommodations (Google Slides)
How To: Equally Effective Alternate Access Plan (EEAAP) (Google Doc)
Support and Accommodations (Google Slides)
ADA Accommodation Fund (Google Doc)
Request Accommodation Reimbursement (Google Form)
Case Study: Assessing Products for Accessibility Compliance and Accommodation (Google Slides)
Accessibility technology rules updates:
Complying with Technology Accessibility Rules (Google Slides)
Plain Language Guide to the State Technology Accessibility Rules
Reach out to oit_rules@state.co.us with questions
Accessibility rules resources for complying
How To: Document Undue Burden, Fundamental Alteration or Direct Threat (Google Doc)
Example Evidence of an Accessibility Plan (Google Doc)
Accessibility software updates
TAP is no longer offering Commonlook, Otter.ai, and Grackle licenses. Contact your IT director if you are looking for any of these software packages.
JAWS and JAWS Inspect are still available in unlimited quantities, however, each product has a learning curve if you plan to use them for testing.
Connect with state accessibility news and resources
State of Colorado Accessibility Newsletter
Sign Up for The A11y, our monthly accessibility update (state-only content)
Sign Up for the State of Colorado Accessibility Newsletter (state and local government content)
TAP Open Office Hours (OOH)
Open Office Hours are held each Thursday between 9-10 AM
Contact the TAP team to get added to the weekly invite: oit_accessibility@state.co.us
Accessibility talking points
State agencies and accessibility law in Colorado
HB21-1110 makes it a state civil rights violation for a government agency to exclude people with disabilities from receiving services or benefits because of lack of accessibility.
Inaccessible technology potentially interferes with an individual's ability to obtain and use information quickly and easily. When our state IT systems are inaccessible, we unfairly exclude a portion of those people who need to access our information or services.
The bill states that any Colorado government entity that doesn’t comply with OIT’s Accessibility Technical Standards by July 1, 2024, could be subject to injunctive relief, meaning a court order to fix the problem; actual monetary damages; or a fine of $3,500 payable to the plaintiff, who must be someone from the disability community.
Important dates
Accountability for accessibility lies with the agency
Agencies are accountable for the compliance of both the content and platforms that they manage. Per HB21-1110, "Liability for noncompliance as to content lies with the public entity or state agency that manages the content, whereas non-compliance of the platform hosting the content lies with the public entity or state agency that manages the platform."
This technology includes but is not limited to both internal and external facing websites, applications, kiosks, digital signage, documents, video, audio and third-party tools.
OIT's role: Collaborate with agencies to review and establish implementation methodology of the accessibility standards
OIT has created a new office, the Technical Accessibility Program (TAP), to provide support and strategic planning for statewide accessibility implementation per HB21-1110. TAP and OIT are accountable for providing the following to state agencies:
Provide, maintain and promote accessibility technical standards
Provide the accessibility adoption plan template and guidance for that template which then becomes the agency plan
Collaborate with agencies to review and implement approaches to the accessibility standards
Monitor implementation of state standards
Provide compliant IT (e.g., platforms) to agencies
Provide training and enterprise-wide accessibility tools
Colorado's disability and aging demographics
As of 2023, there are 1,015,417 adults in Colorado who have a disability; that is equal to 23% or about 1 in 4. (CDC Disability Data and Statistics)
One in four of today’s 20-year-olds will become disabled during their career. (SSA Facts)
Coloradans age 65 and older are the fastest-growing age group in the state (the 3rd fastest in the nation), and forecasts show that 1 in 5 Colorado residents will be over 65 by 2050. (Colorado State Demography Office - Aging in Colorado Part 1)
Attention to technology accessibility becomes increasingly important as our population ages. Disability statistics rise significantly by age group and as people age, they will likely require more state government services and will look online to find them.
The cost and benefits of accessible services
Although you may be unfamiliar with accessibility and may view it as a new and unexpected cost, it can be a springboard for dramatic improvement of your agency and its services.
The estimated cost for testing a single application or website can average around $4,177 (40 hours of accessibility testing at OIT's FY23 rate of $104.44 per hour). That cost does not include remediation and vendor accessibility testing can vary.
The benefits of accessibility include:
Extended service reach
Compel innovation
Improve usability for all users
Increase participation in the democratic process
Improve workforce diversity
Improve workplace effectiveness
Reduce the risk of negative media exposure
Technology Accessibility is not necessarily more expensive if it is planned from the beginning. By building accessibility into the requirements of IT software and hardware, the cost of accessibility is often minor. Retrofitting those technologies once they are in place can be costly.
The Agency Accessibility Adoption Plan will create and implement standards and processes that include an upfront assessment of accessibility requirements. Those requirements will be embedded in state government contracts and purchasing standards, enterprise architecture, and web development and software development lifecycle processes.
Accessibility adoption plan: connecting standards to the people, processes, and tools that deliver technology in your agency.
Advocates and legislators behind HB21-1110 work toward the day when all state of Colorado government systems are accessible, providing equal access to information and services. Those who will ultimately implement the accessibility standards may agree with that vision, but worry about the cost, effort, and overall effect on technology delivery if they were to fully comply with technology accessibility standards.
The purpose of creating an Agency Accessibility Adoption Plan is to implement OIT’s Accessibility Technical Standards by putting in place processes, tools, and support (e.g., guidelines and training) that make accessibility the normal way we do business while addressing the approaching deadline for accessibility compliance of the accessibility bill, HB21-1110.
If you can’t make it accessible by July 1, 2024, then what’s your plan for accommodation?
Once your agency’s technology has been assessed for accessibility, there will be inaccessible technology that won’t fit into the timeline for compliance. These exceptions will need a plan for accommodation.
From a process point of view, accommodations are more costly than following a standard customer journey. Accommodations may mean that information may have to be maintained in multiple places and formats, or it may mean that a brick-and-mortar office can’t be closed because an online service cannot be accessed by all those that need it.
100% accessible is a goal that is never fully realized.
Like information security, accessibility is a moving target. As technology evolves, standards and their implementation must also evolve. The purpose of creating and implementing an agency accessibility adoption plan is to identify and put in place the processes, tools, and training that enables state employees to procure or develop IT systems and content that best meet accessibility standards.
This is a long-term process and commitment to ensure technology accessibility is built into the ways we acquire technology, so that as systems are replaced every attempt will be made to replace them with systems where accessibility was one of the basic requirements.