Managing Accessibility Governance Structure, Roles and Responsibilities

1
Managing AccessibilityGovernance Structure,
Roles and Responsibilities

• Susan CozadAccessibility CoordinatorDepartment
  of Information Resources
• Rebecca Rychlik-AdamsWeb AdministratorTexas
  Department of Banking

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Overview

• The position of accessibility coordinator, as
  specified in Texas Administrative Codes (TAC)
  206 and 213, is to develop, support, and
  maintain an agencys internal policies for
  providing access to electronic and information
  resources (EIR) to individuals with disabilities,
  as required by TEX GOVT CODE 2054, Subchapter M.
• Accessibility coordinator may not be your only
  duty.
• Agency size and staffing resources may determine
  if you need more than one coordinator.
• Large agencies may need to have several
  accessibility coordinators responsible for
  specific lines of business, but only one of them
  should be designated as the contact person
  representing your agency.

3
What does Texas statute require of DIR?

• TEX GOVT CODE 2054, Subchapter M directs DIR to
  develop accessibility-related rules, guidelines,
  and processes covering
• Training and technical assistance
• Compliance with state and federal standards and
  laws
• Public awareness
• Websites
• Emerging technologies, products
• Agency exceptions for significant difficulty or
  expense, alternate methods
• Statewide exceptions
• Surveying and results reporting

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What do Texas state rules require of agencies?

• Amendments to TAC 206 and 213 went into effect
  September 16, 2008.
• Followed standards set by Section 508.
• Required that agencies have an accessibility
  coordinator.
• Gave agencies the flexibility to define the
  positions qualifications, roles, and
  responsibilities.

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What is executive leaderships role?

• Executive leaderships involvement is fundamental
  to implementing EIR accessibility within an
  agency.
• Executive leadership
• Identify expectations for implementing EIR
  accessibility
• Establish the accessibility coordinators
  function within the agency organizational
  structure
• Working within this structure, direct the effort
  to
• Identify the accessibility coordinators roles
  and responsibilities
• Identify the accessibility coordinators required
  skill set
• Select an accessibility coordinator

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What is managements role?

• Management may refer to either the agencys IRM
  or the coordinators supervisor, or both.
• Management defines key strategies that will guide
  a successful accessibility program.
• Management should
• Be familiar with federal and state accessibility
  requirements
• Identify where accessibility fits into an
  agencys line of business and strategic plan
• Identify agency stakeholders who will work with
  the accessibility coordinator

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Sample accessibility org chart
DARS Accessibility Organization
Policy Technical Assistance (PTA)
Accessibility Users Group (AUG)
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What makes an effective accessibility coordinator?

• Awareness and sensitivity to people with
  disabilities
• Awareness and knowledge of state and federal
  accessibility laws, regulations/standards, and
  policies
• Ability to conduct an accessibility assessment
  and evaluation of products and website content
• Ability to implement strategies
• Ability to develop and implement a process to
  bring an agency into compliance with
  accessibility requirements

Source California Arts Council
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You are the accessibility coordinator. Now what?

• Familiarize yourself with federal and state
  accessibility rules, guidelines, standards, and
  best practices.
• Meet with management to discuss the agencys
  strategic direction and identify expectations for
  a successful accessibility program.
• Join mailing lists and users groups to identify
  the technical tools and techniques at your
  disposal.
• Gain exposure to the inner workings of
  accessibility.
• Enroll in accessibility training.
• Learn to use authoring and testing tools.
• Work with best practices.

Adapted from California Arts Council
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Where can you go for help?

• Leverage all resources and maximize reuse.
• Good starting points are
• California Arts Council
• Texas Department of Information Resources
• Texas Department of Assistive and Rehabilitative
  Services
• Texas Health and Human Services
• Public Electronic Services on the Internet
  Working Group (PESO)
• Additional resources to be provided.

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With whom do I collaborate?

• Your agencys internal teams
• Goal Integrate accessibility principles into
  your organizations technology, operations, and
  products
• Other agencies and institutions of higher
  education
• User groups and electronic mailing lists
• See resource list.

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In what key areas will I be involved?

• EIR accessibility promotion
• Your agencys accessibility policy
• Your agencys project development lifecycle
• Agency EIR testing and validation
• Agency EIR compliance reporting
• Agency EIR non-compliance remediation
• Consulting with agency stakeholders
• Requests for EIR exceptions

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EIR accessibility promotion

• Provide formal and informal opportunities to
  educate your agency staff about the requirements
  to support implementing and monitoring
  accessibility standards.
• Provide technical assistance to your agency and
  the public regarding accessibility issues.

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Your agencys accessibility policy

• Engage internal and external stakeholders in
  developing your accessibility policies.
• Verify that overall agency policies and business
  practices are consistent with the agencys
  accessibility policy and meet the accessibility
  requirements in TAC 206 and 213.
• Publish by June 30, 2009.

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Your agencys project development lifecycle

• Coordinate with agency software development teams
  to ensure that accessibility functionality and
  testing is built into the development life cycle
  of new and enhanced products.
• Help developers write the specifications for
• Software, whether developed in-house or purchased
  off the shelf
• Solicitations from vendors

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Agency EIR testing and validation

• Develop a process to regularly test and validate
  agencys websites, electronic and information
  resources, applications, or products for
  compliance with EIR accessibility standards.
• Identify the necessary components of a
  comprehensive accessibility evaluation.
• Identify and involve participants/consumers with
  disabilities.
• Identify non-compliance with Texas state laws and
  TAC rules.
• Develop a comprehensive action plan to correct
  deficiencies.

17
Agency EIR compliance reporting

• Develop, implement, and maintain a process for
  the public and staff to report non-compliant
  websites, electronic and information resources,
  applications, or products to the accessibility
  coordinator.
• Coordinate with your agencys legal counsel and
  management to develop the process.
• Collaborate with staff to investigate and resolve
  formal complaints as directed.
• Generate reports on the results of the
  investigation and resolution as directed.

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Agency EIR compliance reporting The IRDR

• State statute requires agencies to
• Conduct a biennial Information Resources
  Deployment Review (IRDR), including a review of
  agency compliance with IR-related rules and
  standards, including TAC 206 and 213
• Submit the results of their review
• DIR distributes instructions for completing the
  IRDR, as well as the reporting tool, to the IRMs.
  
• DIR generates reports from the results and
  submits them to LBB and SAO.

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Agency EIR compliance reporting The IRDR

• An agency that is out of compliance with one or
  more rules or standards must submit an IR
  Corrective Action Plan (IRCAP) for approval by
  DIR.
• DIR works collaboratively with agencies to
  develop their IRCAPs.
• The 2009 IRDR cycle will begin this summer with
  the release of instructions and reporting tool.
• This cycles IRDR submission deadline is December
  1, 2009.

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Agency EIR compliance reporting The IRDR

• IRDR data is used by DIR to
• Identify trends of statewide non-compliance
• Develop outreach and educational opportunities to
  help agencies remediate non-compliant issues
  identified on their corrective action plans
  (IRCAPs)
• Track agency progress toward compliance
• Evaluate the responses to questions to determine
  if the data collected meets its intended purpose
• Refine the survey instrument to improve accuracy
  in agency compliance levels

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Agency EIR non-compliance remediation

• Develop a plan for how your agency will remediate
  non-compliant websites, electronic and
  information resources, applications, or products.
• Provide status reports on compliance and
  corrective action plans to agency management as
  directed.
• Coordinate with your agencys IRM or designee to
  complete the Accessibility section of the IRDR as
  required in TAC 213.20.

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Consulting with agency stakeholders

• Consult with agency staff on accessibility
  issues.
• Evaluate new software and hardware (e.g.,
  validating the VPAT).
• Suggest effective methods of access as
  alternatives to inaccessible EIR.

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Requests for EIR exceptions

• As the accessibility coordinator, you may serve
  as a consultant to the agencys head for
  reviewing requests for exceptions from within the
  agency.
• TAC 213.17 (agencies) and 213.37 (higher
  education) contain the exception request
  requirements.
• Your accessibility policy should include
  standards and processes for handling exception
  requests.
• A separate request is required for each EIR
  development or procurement, including outsourced
  development, which does not comply with the
  standards and specifications described in TAC
  206 and/or TAC 213.

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Managing AccessibilityGovernance Structure,
Roles and Responsibilities

• Susan CozadAccessibility CoordinatorDepartment
  of Information Resources
• Rebecca Rychlik-AdamsWeb AdministratorTexas
  Department of Banking

25
Managing AccessibilityGovernance Structure,
Roles and Responsibilities

• Susan CozadAccessibility CoordinatorDepartment
  of Information Resources
• Rebecca Rychlik-AdamsWeb AdministratorTexas
  Department of Banking

26
Is being an accessibility coordinator your only
duty?

• It may not be!
• Remember
• Start today.
• Starting small is still a starting place.
• Get buy in from others and work from there.
• Not only is it the right thing to do, it is the
  law!

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Resources

• California Arts Council www.cac.ca.gov/artsaccess
  ibility/guide/2.php
• Texas Department of Information
  Resourceswww1.dir.state.tx.us/accessibility
• Texas Department of Assistive and Rehabilitative
  Services (DARS)www.dars.state.tx.us
• Texas Health and Human Serviceswww.hhs.state.tx.
  us
• Public Electronic Services on the Internet
  (PESO)www.dir.state.tx.us/peso/

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Thank you