[CATO] ETAG Accessibility Follow up: Feedback requested

Monica Olsson molsson at sbctc.edu
Thu Jul 1 10:43:58 PDT 2021

Thank you, Marc. I am looping in the CATO members. Please chime in, folks!

Reflecting on your question about leverage: I think this is important for us to talk about. We have more leverage applying pressure on vendors as a system of 34 colleges, rather than individual schools trying to ask vendors for information and then verify. Perhaps as a starting point, we (SBCTC staff) can ask vendors interested in the app store to agree to a third-party evaluation of their VPAT as a requirement to make it into the store. That is not going to provide all the information and compliance verification we really need but could be a first step. We can start with the v.1 list of vendors you include below.

My thought on your second question is no, I don't believe a process has been defined that would allow us to say, for example, X vendor's product meets accessibility standards in a "verifiable way." I hope to collaborate with others to help determine what that should look like.

Regarding your third question, "I know the SBCTC staff are under some pressure to get Commons launched. For the folks who know more than me… Where do we stand on products that have any documentation, other than a vendor completed VPAT? And that have contract language requiring WCAG 2.1/AA?" -- I think Mark Carbon can speak to that since he is the primary contact for vendors.

[Title: SBCTC logo - Description: Compass]

Monica M. Olsson (she/her/hers)

Policy Associate – Accessible IT Coordinator

Washington State Board for Community and Technical Colleges

molsson at sbctc.edu<mailto:molsson at sbctc.edu> • o: 360-704-3922 • c: 206-914-7187

sbctc.edu<https://www.sbctc.edu/> • Twitter: @SBCTCWashington<https://twitter.com/SBCTCWashington> • Facebook: @WASBCTC<https://www.facebook.com/wasbctc/>

From: Lentini, Marc <mlentini at highline.edu>
Sent: Tuesday, June 29, 2021 11:52 AM
To: etag at lists.ctc.edu <etag at lists.ctc.edu>; Monica Olsson <molsson at sbctc.edu>
Cc: Abraham Rocha <arocha at sbctc.edu>; Boyoung Chae <bchae at sbctc.edu>
Subject: Re: ETAG Accessibility Follow up: Feedback requested

Hi folks, apologies for not getting back to this. End-of-quarter-plus-break had me jumping.

I guess I have a comment and then a more pragmatic concern. The comment is that I think we’re all agreeing that we need to have accessible products available to students, and operationalize that by holding vendors to account for their accessibility practices. There’s question about how best to do that, but that’s the overall goal.

The pragmatic concern has two parts:

Do we have enough leverage to do that by excluding vendors who can’t prove that they meet WCAG 2.1/AA?
From what I hear, vendors have been contacting SBCTC with interest in being incorporated into the store, so that’s a good sign. And a good time to say “are you accessible? No? Call us back when you are.” Then again, if we don’t have much content (see next point), then the Commons doesn’t have a ton of appeal to vendors. I don’t have a good sense of where that balance lies.

Do we have any products that meet standard, in a verifiable way?
If I look at the vendors we currently have listed for version 1 of the Commons (below), I think we have a few that might met WCAG 2.1/AA but don’t have documentation we’d accept (Canvas?), a few that don’t but that really care and are trying (3Play?), and a few that aren’t, and aren’t really trying (cough-proctoring-cough).

The “verifiable way” part here is the holdup, I suspect, and also that vendors haven’t fully caught up/bought off on the move to 2.1.

I know the SBCTC staff are under some pressure to get Commons launched. For the folks who know more than me… Where do we stand on products that have any documentation, other than a vendor-completed VPAT? And that have contract language requiring WCAG 2.1/AA?


v.1 list of vendors
Attribution Builder

Marc Lentini | he.him.his
Director of Educational Technology & Accessible Technology Coordinator
Highline College | mlentini at highline.edu<mailto:mlentini at highline.edu> | (206) 592-3778

On Jun 17, 2021, at 3:39 PM, Andy Duckworth <aduckworth at sbctc.edu<mailto:aduckworth at sbctc.edu>> wrote:

CAUTION: This email originated from outside Highline College. Do not click links or open attachments unless you validate the sender and know the content is safe. If you are unsure, contact the Help Desk at x4357 (206-592-4357) or email helpdesk at highline.edu<mailto:helpdesk at highline.edu>.

See my answers below:

<image004.png>Andy Duckworth
Technology Innovation Officer
Washington State Board for Community and Technical Colleges
o:360-704-4311 | c:253-318-7586
                      Book<https://outlook.office365.com/owa/calendar/AndyDuckworth@sbctcedu.onmicrosoft.com/bookings/> time with me

From: Monica Olsson <molsson at sbctc.edu<mailto:molsson at sbctc.edu>>
Sent: Thursday, June 17, 2021 2:37 PM
To: etag at lists.ctc.edu<mailto:etag at lists.ctc.edu>
Cc: Abraham Rocha <arocha at sbctc.edu<mailto:arocha at sbctc.edu>>; Andy Duckworth <aduckworth at sbctc.edu<mailto:aduckworth at sbctc.edu>>; Claver Hategekimana (Claver.Hategekimana at skagit.edu<mailto:Claver.Hategekimana at skagit.edu>) <Claver.Hategekimana at skagit.edu<mailto:Claver.Hategekimana at skagit.edu>>; Howard Fuller <hfuller at whatcom.edu<mailto:hfuller at whatcom.edu>>; Joel Gavino <jgavino at pierce.ctc.edu<mailto:jgavino at pierce.ctc.edu>>; Leslie Potter-Henderson <lhenders at shoreline.edu<mailto:lhenders at shoreline.edu>>; Lentini, Marc <mlentini at highline.edu<mailto:mlentini at highline.edu>>; Mark Carbon <MCarbon at sbctc.edu<mailto:MCarbon at sbctc.edu>>; Paul Kreemer <pkreemer at sbctc.edu<mailto:pkreemer at sbctc.edu>>; Sarah Griffith (sgriffith at lcc.ctc.edu<mailto:sgriffith at lcc.ctc.edu>) <sgriffith at lcc.ctc.edu<mailto:sgriffith at lcc.ctc.edu>>; Monique Belair <mbelair at sbctc.edu<mailto:mbelair at sbctc.edu>>; Tim Wrye (twrye at highline.edu<mailto:twrye at highline.edu>) <twrye at highline.edu<mailto:twrye at highline.edu>>; McEachern, Patrick <Patrick.McEachern at ccs.spokane.edu<mailto:Patrick.McEachern at ccs.spokane.edu>>; Boyoung Chae <bchae at sbctc.edu<mailto:bchae at sbctc.edu>>; Harbaugh, Melinda <mharbaugh at lcc.ctc.edu<mailto:mharbaugh at lcc.ctc.edu>>
Subject: ETAG Accessibility Follow up: Feedback requested

Hi everyone,

Thank you for the dynamic ETAG meeting yesterday. I want to follow up with my thoughts regarding our accessibility conversation.

I do not advise that we include apps on cards for people to "shop" unless the product meets a defined set of minimum technical accessibility standards, OR, at the very least the product has been tested for minimal compliance, and notes are available to "shoppers" explaining the degree of compliance at the time of testing. I heard your concerns about vendors sharing complaints or grievances, though I believe there is greater risk to us when our Colleges adopt software that is inaccessible to students, staff, or the public.

  *   Our WA state policy, Policy 188 <https://ocio.wa.gov/policy/accessibility> states that all "Covered Technology" meets Level AA of WCAG 2.1.<https://www.w3.org/TR/WCAG21/>This Policy reinforces regulations that already exist in Section 508 of the Rehabilitation Act and the ADA.
  *   "Undue Burden" typically refers to a high financial burden creating a barrier to ensuring access and can be tricky to prove. I do not advise we use this as an argument for not completing accessibility testing. Historically, case law has taught me that before something can be considered an "Undue Burden", the entire budget of a College or that College's system must be considered--not just a department's budget and manpower, for example.

Of course, we understand that at the end of the day, a College can make their own decision about what to purchase and implement. I believe though that we have a responsibility to provide accessibility information of products appearing within the Commons beyond that of a VPAT completed by the Vendor. Again, there may be examples when a particular product required for instruction or official business is not fully accessible, may also be considered industry standard, and an alternative cannot be identified. In that case, a College or agency may choose to move forward with a purchase knowing that they will then become responsible for providing equivalent access for disabled users. (This is why a separate different project I am working on with CATO and State Board staff is developing a Procurement Policy and Procedure.)

Now, I understand we questions to address regarding compliance testing including:

  *   Who has the technical expertise to complete compliance testing?
  *   How much time can be allotted to this work?
  *   Who ultimately is responsible for this testing within our system of Colleges and the agency?
  *   What budget, if any, do we have to pay for compliance testing.

These questions are why I look forward to talking more with Ward and others about organizing centralized Trusted Tester services for our system.

Below are three ideas I want to float to the group and kindly request your feedback.

  1.  The W3C provides a guide on how to complete "Easy Checks" for accessibility<https://www.w3.org/WAI/test-evaluate/preliminary/#title>. These checks do not require a high level of technical skill, do not replace comprehensive testing, but could be a good place for us start.

     *   My question is if we think we have the bandwidth among CATO, ETAG, and SBCTC to begin using this resource to get started in reviewing apps? I do think that if we pool all of our available resources we could develop a strategy, using the “Easy Checks” for accessibility information, to test the initial grouping of applications for the EdTech Commons. Maybe we could have levels of testing (“Easy Checks”, DHS Trusted Tester certified, 3rd party vendor certified, etc.) that are visible, but greyed out until it has been run through and passed each test?

  1.  Has the group defined a list of initial apps, say 10 or 15, that you wish to go live with? If so, perhaps we can explore the option of using Deque or Level Access to help us complete initial testing on a smaller number of products. SBCTC has worked with both companies before.

     *   Carli and I will need to have a conversation together budget feasibility, and if this is an option on the table.

  1.  A final idea we can pursue is organizing a third-party evaluation/evaluation of a product's company's VPAT as a place to start. At the very least, this will help us determine if a VPAT is making honest sense or not. 😉 Would need to discuss how we define "third party."

     *   Do people in this group think we would benefit from training on best practices for reviewing a VPAT? Yes, I think this training would be of value and sign me up! Could we develop a train the trainer model for this? If SBCTC foots the bill for someone to go through this training they need to host one local training event? This could help spread awareness and expertise.

<image003.png>Monica M. Olsson (she/her/hers)

Policy Associate – Accessible IT Coordinator

Washington State Board for Community and Technical Colleges

molsson at sbctc.edu<mailto:molsson at sbctc.edu> • o: 360-704-3922 • c: 206-914-7187

sbctc.edu<https://www.sbctc.edu/> • Twitter: @SBCTCWashington<https://twitter.com/SBCTCWashington> • Facebook: @WASBCTC<https://www.facebook.com/wasbctc/>

-------------- next part --------------
An HTML attachment was scrubbed...
URL: <http://lists.ctc.edu/pipermail/cato_lists.ctc.edu/attachments/20210701/56059ebc/attachment-0001.html>
-------------- next part --------------
A non-text attachment was scrubbed...
Name: Outlook-Title_ SBC.png
Type: image/png
Size: 22672 bytes
Desc: Outlook-Title_ SBC.png
URL: <http://lists.ctc.edu/pipermail/cato_lists.ctc.edu/attachments/20210701/56059ebc/attachment-0001.png>

More information about the CATO mailing list