Increasing Accessibility Adoption through Policy enhancements and Organizational enablement

1. Jeff Kline (@jeffkline2; jeff.kline@dir.texas.gov) Accessibility Author and Consultant / Texas Statewide EIR Accessibility Coordinator AccessU 2013 Note: Refer to speaker notes if you have problems viewing presentation slides Increasing Accessibility Adoption through Policy enhancements and Organizational enablement 1

2. We all want more accessible ICT… now… 2

3. So how are our current methods working for us? • we’ve tried technical standards – that hasn’t done it… • we’ve tried legislating around those standards – that hasn’t done it… • we’ve tried saying accessibility is cheap – it isn’t, and that hasn’t done it… • we’ve made tools to make it cheaper – but they haven’t made it easier, so that hasn’t done it… • we’ve tried to show great ROI – but examples are scant, so that hasn’t done it… • we’ve tried to show the massive spending power of disabled people – that’s debatable, so that hasn’t done it… • we’ve tried to say accessibility = usability – that isn’t always the case, so that hasn’t done it… 3

4. ICT Accessibility Adoption is Slow Recent US government reports find that current models for encouraging ICT accessibility adoption are not working • “Section 508 Report to the President and Congress: Accessibility of Federal Electronic and Information Technology” 2012 (US DoJ) • Finds that less than 50% percent of agency components incorporated specific applicable Section 508 Accessibility Standards as requirements in each procurement solicitation… • Little to no validation against Section 508 criteria performed on procured products • “US E-Government Website Quality Report” 2012 (WelchmanPierpoint) • The accessibility benchmark shows that two-thirds of federal sites achieved a moderate level of compliance federal sites • 28% of sites in the study achieved the lowest compliance band. • Automated testing only; tool(s) not defined • “National Disability Policy Progress Report August 2012” (National Council on Disability) • Rarely mentions ICT accessibility 4

5. ICT Accessibility Adoption – an International Perspective The situation in Europe isn’t any better… • European Commission research behind Proposed Directive on Accessibility of Public Sector websites Dec 2012 (European Commission) • only one-third of Europe’s 761,000 public-sector and government websites are accessible And G3ict reports indicate the same slow progress in the rest of the world… • “CRPD 2012 ICT Accessibility Progress Report” (G3ict) • Indicates significant deficits to set in place a foundation to promote ICT accessibility 5

6. Why? 6

7. The Accessibility Technology Gap “Technical enablement” challenges • Accessible technologies gap • Accessibility not considered in new, mainstream technology creation • Facilitation tools limited and lagging in development technologies 7

8. Technical Enablement is only half of the adoption problem • Lack of awareness of accessibility requirements • Awareness of accessibility but it’s deemed “unnecessary” or optional • Awareness of accessibility but unwilling to make the investment • Awareness of accessibility too late to be addressed • Lack of technical skills, tools or training programs • No knowledge transfer from previous or other projects in an organization • No organizational policies or objectives related to ICT accessibility • Lack of commitment to accessibility by top management • No one responsible or accountable for accessibility 8

9. ICT accessibility today is a governance problem more than a technical one Technical specifications / standards are not governance criteria! They’re execution criteria! • Nothing in tech specs requires organizations to do anything • The “teeth” for accessibility are in disability regulations but • Regulations not being enforced to the extent needed • Risk associated with inaccessible ICT isn’t high Where do we go from here? 9

10. Barriers are barriers. Period. • Barriers to the digital environment are no different than barriers to the built environment with respect to civil rights. • What was the “business case” for access to the built environment? Access to information technology is not a “business case” problem. It’s a civil rights problem. Governments are recognizing this and are creating new accessibility regulations which include policy requirements to facilitate adoption. 10

11. Policy Driven Adoption The integration of ICT accessibility governance into disability regulations and policies in a way that enables organizations to drive themselves to improve accessibility adoption. 11

12. Policy Driven Adoption: Benefits • Not prescriptive • Tells organizations “what” to do, not “how” to do it • Can include a technical standard component • Can be governed mostly thru non-technical methods • Makes ICT accessibility difficult to ignore • Accelerates marketplace innovation for development tools, technologies, and other resources that facilitate ICT accessibility • Passenger car emissions standards example 12

13. Policy Driven Adoption Current Examples: State of Texas State of Texas, USA: Texas Government Code 2054 Subchapter M, Texas Administrative Codes 206, 213 • Scope: Texas State agencies and state funded institutions of higher education (Approx. 175) • Uses slightly modified Section 508 technical standards • Goes beyond technical standards to include governance criteria for • Policy • Responsibility • Procurement • Exceptions • Training 13

14. Policy Driven Adoption: State of Texas How’s it working? • Over 95% of all agencies and state funded higher education institutions • Have a published ICT accessibility policy • Have an accessibility coordinator • Many agencies have very accessible public websites • Exceptions process yields improvements in accessibility of 3rd party products • State mandated information resources review conducted biannually • Includes ICT accessibility • Department of Information Resources leadership, guidance, and oversight • Establishes ICT Accessibility Rules • Provides resources in support of enabling agency accessibility • Provides a no charge accessibility web scanning program (150 pages per agency) to all state agencies agencies • Chartered the Accessibility Council of Texas to identify and implement key initiatives at the state level • Integrated ICT Accessibility criteria into state co-operative contracts program 14

15. Policy Driven Adoption Current Examples: Canada Ontario: Accessibility for Ontarians with Disabilities Act (AODA) • Scope: Public and private entities with over 20 employees operating in Ontario • Encompasses the built environment and broad range of ICT • Integrated Accessibility Standards Regulations (IASR) requires organizations to • File Customer Service Accessibility Compliance Reports online • Establish accessibility policies • Establish, implement, maintain and document a multi-year accessibility plan • Incorporate accessibility criteria and features into procurement • Includes timetables for required compliance • Includes fine schedules • WCAG 2.0 used as the technical standard for web accessibility NEW! Government of Manitoba has accepted recommendations to adopt a new Accessibility Act (Heavily influenced by AODA) 15

16. Policy Driven Adoption : Canada The effect it’s had… • Requiring organisations to create a policy has forced them to engage with the issues, to a greater extent than reproducing the usual boilerplate • While enforcement is still an issue, organisations feel more accountable once they’ve publicly published their policy • The public now has a formal mechanism for complaints, channeled through the government equality body, rather than to the organisation • And it’s likely that legal cases will take an organisation’s progress against their own policy and action plan into account • But the jury’s still out on the exact effect it will have… 16

17. Policy Driven Adoption: Possible Provisions Inclusion at Regulatory OR Organizational Levels Organizations of a certain size or business type (TBD) that use or develop ICT must: • Develop, implement, and maintain an ICT accessibility policy • Integrate ICT accessibility criteria into key phases of procurement, development, and other relevant business processes • Provide a process addressing inaccessible ICT which would include • a plan / date for compliance of the ICT • an alternate means of access until the ICT is accessible • Ensure that accessibility skills are available within (or to) the organization • Develop and maintain an organizational structure that enables and facilities accessibility progress • Demonstrate forward progress in accessibility over time through the establishment of metrics and tracking methods • Designate one or more individuals responsible for supporting the organization in implementing these provisions 17

18. No title needed “…Regardless of an agency's maturity, effective accessibility outcomes will always depend on a clearly articulated policy… Policy as a means to integrate accessibility into all aspects of the ICT environment and decision tree is fundamentally important.” Sharron Rush, Executive Director, Knowbility Inc. 18

19. Implementing Policy Driven Adoption 19

20. Scenario: Online Recruiting Corporation X had just completed the procurement and deployment of a large new web application for recruiting new employees and managing job candidates. Software Company A developed the product. Both Company A and Corporation X’s studies indicated that the new system would offer significant advantages in cost savings, productivity, and candidate quality over the previous, mostly manual processes. Then….

21. What Areas of an Organization May Be Affected by ICT Accessibility? (a non-exhaustive list) • Product development • Internet site and applications development • Intranet site and applications development • Procurement • Legal / civil rights • Executive management • Internal / external communications / PR • HR (employees) • Learning tools (hw/sw) • System admins • Student services • Business controls / compliance office • …

22. ICT Accessibility is a Complex Topic • Many moving parts = many challenges • Technical • Organizational • Legal • Cultural • Touches many areas of an organization in different ways “Organizational Enablement” is required to effectively and successfully address the complexities ICT accessibility within an organization. 22

23. An Accessibility Framework Organizational Components Assess business needs and make accessibility investments • Gain top level “buy-in” and set organization expectation levels • Ensure accessibility policies are defined • Develop strategy and implementation plans Create an organizational model Implementation Components • Measure and track progress Plan Strategically • Automate for productivity and quality • Validate thoroughly, early, and often • Grow awareness and provide education / training 23

24. Gain top level “buy-in” and set organization expectation levels Getting Started Start at the top: Obtain executive buy-in • Create an executive presentation or “sell” package • Clearly articulate the importance and need for an accessibility program • Business advantages and risk mitigation • The state of ICT accessibility within the organization if known (if not known, that can be a risk in itself) • Examples of adverse impacts • A clearly defined set of accessibility program objectives • Recommended next steps • Gain the commitment of top executives in the form of resources (human and financial) • Obtain an executive sponsor or “champion” to oversee and guide the program Set organization expectation levels • Multi-year initiative • Dynamic, with course and trajectory adjustments as needed 24

25. The Organization Policy Develop an ICT accessibility policy • Foundation on which other aspects of ICT accessibility are built • Create a team of SMEs to develop the policy • Should not be voluminous or contain technical specs • Leverage similar, existing policies • The “big stick” • Ensure accessibility policies are defined Core Team for Accessibility Policy Development Stakeholders HR Legal Procurement Development CIO Unit Execs Marketing Other Review / Concurrence 25

26. Develop strategy and implementation plans Develop a Strategy Key elements of an organization’s ICT accessibility strategy • Rationale and goals of the program • Linkage to the organization’s ICT accessibility policy, relevant standards, regulations, etc. • Definitions of high-level organizational and governance models • Funding, budget, and other financial considerations • A strategic framework for developing operational work plans • Assumptions, dependencies, and risks 26

27. Create an organizational Model Neutral Organizational Placement for Centralized Accessibility Program • Considerations • Is it positioned to reach across the enterprise? • Will it have the clout to be effective in driving transformation and policy? • Can it maintain its ability to perform without being subjected to the parochial interests of the organization in which it resides? • Will it get the care and attention needed over time? Sample Neutral Placement Analysis

28. 2nd level subunit accessibility focal point 2nd level subunit accessibility focal point Subunit accessibility focal point Centralized Accessibility Centralized Accessibility Centralized Accessibility Program 2nd level subunit accessibility focal point Subunit accessibility focal point 2nd level subunit accessibility focal point Subunit accessibility focal point 2nd level subunit accessibility focal point Create an organizational Model Organizing Accessibility • Senior manager “executive sponsor” • Centralized accessibility function • Policy and governance • Technical consulting • Business development / sales support • Project office • Other? • Sub-Unit focal points / coordinators • Loosely connected (dotted line) Centralized accessibility program 28

29. Develop strategy and implementation plans Prioritize the Work Effort Priority classification hierarchy* example External products, Internet and internet applications, etc. Internal use: Intranet and intranet applications, desktop apps, copy machines, telecommunications, etc. *Priority classification assumptions 1. New applications under development, being updated, or being procured should receive priority within the priority class 29

30. Assess business needs and make accessibility investments Program Costs Determining Factors • Funding Models • Speed and trajectory of the ICT accessibility initiative driven by • Urgency based on business or other requirements • Budget considerations • Startup and ongoing costs 30

31. Accessibility Program Framework: 2nd level • Measure and track progress Plan Strategically • Automate for productivity and quality • Validate thoroughly, early, and often • Grow awareness and provide education / training • Obtain initiative support of organization executive team • Develop long term organization goals • Integrate into or develop processes to ensure consistency over time • Select appropriate ICT technologies / suppliers • Effectively manage the ICT accessibility exception process • Maintain flexibility to adapt to criteria changes (508 refresh, WCAG 2.0, etc) • Charter a workgroup with representation from key areas of the organization

32. Accessibility Program Framework: 3rd level detail Creation of action plans, project plans, work breakdown structures, etc. • Obtain initiative support of organization executive team • Develop long term organization goals • Integrate into or develop processes to ensure consistency over time • Select appropriate ICT technologies / suppliers • Effectively manage the ICT accessibility exception process • Maintain flexibility to adapt to criteria changes (508 refresh, WCAG 2.0, etc) • Charter a workgroup with representation from key areas of the organization Organization Work Plan

33. An IT Accessibility Implementation Framework Template Organization Work Plan 33

34. Plan Strategically Internal Application Process Analysis/ Recommended Actions

35. Plan Strategically Form an Organizational Accessibility Workgroup An interdepartmental team representing stakeholder areas of the organization that require or may be affected by ICT accessibility • Facilitates progress in ICT accessibility across the organization • Identifies inhibitors and works to resolve them as a team • Sponsors or leads ICT Accessibility workgroup and subgroup efforts • Reports progress and issues to senior leadership • Solicits support of management and others as needed Application / web development • Other?? • Medical / occupational health Intranet site owners • Project management Internet site owners Internal ICT • Learning Communications • Business controls / compliance office Procurement • HR • Legal / Civil Rights

36. Grow awareness and provide education / training Identify Skill Gaps and Build “Role Based” Accessibility Training Plans * As needed based on assignment.

37. Measure and Track • Progress Set Short and Long Term Accessibility Goals: Example

38. Resources for creating an accessibility policy & programme • British standard BS-8878 Web Accessibility Code of Practice • Accessibility business process integration • Forthcoming (Autumn 2013): ‘Implementing BS 8878’ book by Jonathan Hassell • for info email: book@hassellinclusion.com • Strategic EIR Accessibility: Enabling the Organization by Jeff Kline • Organizational accessibility enablement and strategy • Other accessibility guidance documentation • W3C training • AODA documentation 38

39. Thank you