Tapping Technology - The Change Process- Meeting Compliance Standards

February, 2003

Tapping Technology

The Change Process- Meeting Compliance Standards

This article is compiled with information provided by AccessIT, Technical Assistance Project, University of Washington.

It has been over a year since the Access Board finalized the Section 508 standards, which mandates that all federal IT, and any institutions that receive any sort of federal funds, be accessible. For many education institutions, the effort to understand the needs of students and the need to comply with the 508 standards has been a year-long effort. And much of that effort has gone into determining what exactly Section 508 is and how it applies to them.

The first and most important rule to making an institution compliant to accessibility standards is determining what those standards are:

The following functional performance criteria are included in Section 508 of the Rehabilitation Act

a) At least one mode of operation and information retrieval that does not require user vision shall be provided, or support for assistive technology used by people who are blind or visually impaired shall be provided.
b) At least one mode of operation and information retrieval that does not require visual acuity greater than 20/70 shall be provided in audio and enlarged print output working together or independently, or support for assistive technology used by people who are visually impaired shall be provided.
c) At least one mode of operation and information retrieval that does not require user hearing shall be provided, or support for assistive technology used by people who are deaf or hard of hearing shall be provided.
d) Where audio information is important for the use of a product, at least one mode of operation and information retrieval shall be provided in an enhanced auditory fashion, or support for assistive hearing devices shall be provided.
e) At least one mode of operation and information retrieval that does not require user speech shall be provided, or support for assistive technology used by people with disabilities shall be provided.
f) At least one mode of operation and information retrieval that does not require fine motor control or simultaneous actions and that is operable with limited reach and strength shall be provided.

In order to institute these standards into a school's functioning curriculum and system, the education institution must first create a policy that addresses the issues and clearly defines what needs to be done in order to ensure accessibility.

Policies and procedures can be developed to assure that electronic and information technology procured and used in schools is accessible to all employees and students, including individuals with disabilities and their family members. How can an organization begin this process? Considerations for K-12 and postsecondary educational entities should include the following:

Make sure that all stakeholders, including potential students, instructors, and other staff with disabilities, are represented as policies, procedures, and standards are being developed.
Review what policies and procedures currently exist for the procurement, use, and development of electronic and information technology and consider how accessibility issues might be incorporated within existing policies and procedures.
Consider at what level the policy should reside--for example, at the school level, district level, state level--and be sure to involve decision-makers at the appropriate levels in the policy development process.
Consult with the school's or district's legal counsel to determine what legal issues apply in this policy area.
Review policies and guidelines that have been created by other organizations, including those for distance learning courses developed by the California Community Colleges, the software procurement guidelines (http://www.washington.edu/accessit/articles?169) developed by Oregon State University, and the web accessibility policy (http://www.washington.edu/accessit/articles?140) developed by the University of Wisconsin. Incorporate good ideas into the school's or district's policies and procedures.
Develop a broad policy statement that commits the school to making all programs, services, and resources accessible to students and employees with disabilities.
List potential access challenges that may face students and employees with disabilities within the programs, services, and resources offered using electronic and information technology at the school.
Consider Section 508 Standards (http://www.washington.edu/accessit/http://www.access-board.gov/508.htm) used by the federal government as a model for the school's or district's standards.
Assign a person or a department within the school or district to be responsible for updating disability-related program access policies and guidelines and assuring compliance.
Develop a plan to phase in compliance with program accessibility guidelines for previously developed courses and resources, with a date by which all electronic products will be compliant.
Disseminate accessibility policy, guidelines, and procedures throughout the school or district. Make it clear that the policy has high-level endorsement.
Provide regular training and support regarding accessibility issues, policies, and guidelines to educators, students, and other stakeholders.
Regularly evaluate progress made toward the use of accessible electronic and information technology in the school or district.
Develop procedures for responding quickly to requests for disability-related accommodations when electronic and information technology that is used in the school or district is not accessible to a student or employee. Applying accessibility policies, procedures, and standards will assure that such requests are kept to a minimum.

Once the institutions policy is clearly determined and enacted, with language that is clear and effective for all reviewing the policy, the institution needs to determine how to go about procuring all accessible software. To do this, the school needs to be ensured that the software is accessible.

To determine whether a software application is accessible, the application should be evaluated according to a set of guidelines or standards that defines software accessibility.

The only legal standard is Section 1194.21 ("Software applications and operating systems") of The Electronic and Information Technology Accessibility Standards
http://www.access-board.gov/sec508/508standards.htm. These standards were developed by the Access Board as required by Section 508 of the Rehabilitation Act Amendments of 1998. There are twelve standards, and the Access Board provides a detailed explanation of each in its Guide to the Standards (http://www.access-board.gov/sec508/guide/1194.21.htm).

Following publication of the Access Board standards, the Information Technology Industry Council (ITIC) partnered with the U.S. General Services Administration (GSA) to create a Section 508 compliance checklist called the Voluntary Product Accessibility Template (http://www.itic.org/policy/508/vpat.html) (VPAT). Many software companies have completed VPATs, and have made them available on their company web sites. GSA has also created a central database called Buy Accessible (http://www.section508.gov), where many vendors have posted their VPATs. The database serves to assist purchasers in making informed decisions about products' accessibility. To date, there is no comprehensive third party evaluation of software, so purchasers must rely on vendor self-representation in the VPATs, coupled with their own understanding of product features and accessibility issues.

IBM separately maintains the IBM Software Accessibility Checklist
(http://www-3.ibm.com/able/accesssoftware.html). This checklist includes twenty checkpoints in seven categories, and each of the checkpoints links to specific techniques documents for software developers.

A few postsecondary educational entities have developed their own checklists, guidelines and policies for ensuring that accessibility is considered when purchasing software. Examples include
MIT (http://web.mit.edu/atic/www/sw/purchaseapp.html),
Oregon State University (http://tap.orst.edu/Policy/soft.html), and
the University of Minnesota (http://cap.umn.edu/ait/Software/index.html).

The U.S. Architectural Transportation Barriers Compliance Board (Access Board), as mandated by 1998 Section 508 amendments to the Rehabilitation Act of 1973, developed standards for electronic and information technology developed, maintained, procured, or used by the federal government. They became effective in 2001. They are being mandated or voluntarily used as accessibility standards by other organizations as well. For more information you can read the Access Board's article on standards for software applications and operating systems (http://www.access-board.gov/sec508/guide/1194.21.htm).

Once a school has developed its accessibility policies and determined how to go about procuring accessible software, it will inevitably reach a group of students that have been unfairly left behind. By creating an accessible field for all people to learn in, each institution can be proud of the fact that it is enabling minds to move forward in a world where they are often bound by barriers.