[Etag] ETAG Accessibility Follow up: Feedback requested

[Monica Olsson]

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?

  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.
  2.  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?




[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/>

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