The Road to 508 Compliance

Gaeir Dietrich Alternate Media Specialist Sean Keegan Web Accessibility Specialist High Tech Center Training Unitof the California Community Colleges

High Tech Center Training Unit

Grant Program Funded by the California Community

Colleges Chancellor’s Office Located at De Anza College in Cupertino,

California Serve 109+ California community colleges

Train staff and faculty of the CCCs to use technology to assist students with disabilities

Training Areas

Alternate Media Gaeir Dietrich

Web Accessibility Sean Keegan

Assistive Computer Technology Jayme Johnson

Resources

Trainings Listserves Manuals/Online Curricula Information/Referral

Overview

What is Section 508?

Federal lawPart of Rehabilitation Act of 1973,

as amended in 1998Section 508 standards added in

2001 Previously was a guideline;

standards carry the weight of law.Applies to federal government

The 508 Philosophy

Section 508 is about creating an open door

Section 508 uses the purchasing power of the government to induce vendors to create accessible products

The overall goal of Section 508 is a more accessible society

However…

California is not part of the federal government

California State Law

SB 105 Applied standards of Section 508 to

California Passed September 29, 2002 Effective January 1, 2003 Became part of Govt. Code 11135 CCCs accepted this as applying to them

More CA State Law

SB 302 For the CSUs

“Yes, we meant you, too.” Passed September 2, 2003 Effective January 1, 2004 Became part of Govt. Code 11135

UCs holding their breath…

Cal. Gov. Code §11135(d)(2)

"In order to improve accessibility of existing technology, and therefore increase the successful employment of individuals with disabilities, particularly blind and visually impaired and deaf and hard-of-hearing persons, state governmental entities, in developing, procuring, maintaining, or using electronic or information technology, either indirectly or through the use of state funds by other entities, shall comply with the accessibility requirements of Section 508 of the Rehabilitation Act of 1973, as amended (29 U.S.C. Sec. 794d), and regulations implementing that act as set forth in Part 1194 of Title 36 of the Federal Code of Regulations."

One Difference

California state law actually puts some responsibility for conforming to the standards on the vendor.

§11135(d)(3) states:

"Any entity that contracts with a state or local entity subject to this section for the provision of electronic or information technology or for the provision of related services shall agree to respond to, and resolve any complaint regarding accessibility of its products or services that is brought to the attention of the entity."

Law vs. Policy

Be clear Laws trump policy Users will hold you accountable under

California law Where laws are in conflict

Legal counsel should be consulted Legal counsel generally recommends

limiting liability Who is the most likely to sue?

Just FYI

Section 508 Standards currently under revision Do not expect any substantive change in

standards Updating to keep pace with technology

The Myths of 508

Debunking the Myths

Lots of confusion surrounding the Section 508 standards and why and how they apply

First we will confront the myths Then we will look at how to proceed

Myth #1

Section 508 applies to postsecondary schools because we received federal funding (TTIP).

False

Section 504 follows the money. Section 508 does not. Section 508 applies because of

California state laws that adopted the Section 508 standards. SB 105 SB 302

Myth #2

We always have to buy the most accessible product—no matter what.

False

In fact, technical requirements drive procurement.

Determine your needs first then consider accessibility.

You do not have to fundamentally alter your needs in order to comply with Section 508.

Myth #3

We cannot legally buy an inaccessible product.

False

Again, the needs of the department/entity ordering the product drive procurement.

The specific needs for the product are given first priority then accessibility is considered.

In some cases, there may be no accessible products that meet the needs.

Myth #4

Conforming to Section 508 is expensive.

False

The Social Security Administration has found that accessible products generally cost little if any more than inaccessible ones.

Buying accessible saved USPTO over $1,200,000 in one year on accommodations.

Responding to complaints is far more expensive (in both time and money).

Myth #5

Conforming to the Section 508 standards is very time consuming.

False

Retrofitting is very time consuming. Buying accessible in the first place

needn’t be that time consuming. HOWEVER, until your procedures are in

place and streamlined, you may be spending a lot of extra time training staff and trying to implement a system.

Myth #6

Section 508 applies to everything we buy.

False

Section 508 applies to electronic and information technology (E&IT) only.

If it requires electricity, has a screen or display to interact with, and transfers information it probably falls under Section 508. Microwave ovens don’t count…unless they

send e-mail.

Myth #7

Conforming to Section 508 will interfere with academic freedom.

False

Academic freedom is about the content. Conforming to Section 508 simply allows

access to that content. Conforming to Section 508 should no

more interfere with academic freedom than requiring a ramp does.

Myth #8

You only need to conform to Section 508 when making purchases for something used by students.

False

Section 508 applies to all E&IT purchases. Technically any E&IT that is “DUMPed”

falls under 508: Developed Used Maintained Procured

However, only purchases are subject to legal liability.

Myth #9

We only need to conform to Section 508 when we have a disabled student in the class.

False

Section 504 deals with specific accommodations for specific persons; Section 508 deals with general access for all persons.

The idea is to have the access already in place whenever someone who needs it shows up—even if you didn’t know the person was coming.

Myth #10

The folks in disabled student services offices (DSPS / DSS / DRC) should handle the section 508 issues.

False

Conforming to Section 508 is no more a disability services issue than conforming to the architectural standards for elevators and curb cuts is.

Disability services may function as an information resource, but Section 508 is not specifically their issue.

Disability services is concerned with accommodations under Section 504.

Myth #11

The folks in the IT department should be in charge of Section 508 conformance.

False

Although these folks can be helpful, they are not involved in the purchase of every fax machine, copier, scanner, telephone system, video, etc. on campus.

Myth #12

No one’s really going to force us to comply with Section 508.

False

Compliance with Section 508 is enforced by user complaints.

The example of Arkansas New payroll process implemented online Was not accessible and two blind employees filed

complaints Judge ordered the Web site taken down and made

accessible Cost the state $57 million to rework and took over a

year It costs far less to ensure access in the first

place.

Electronic and Information Technology

E&IT

Where Do We Begin

Only electronic and information technology (E&IT) is covered by Section 508.

First determine if the proposed purchase is E&IT.

What exactly is E&IT??

Legal Definition E&IT is defined by federal regulations as any equipment

or interconnected system of equipment that is used in the creation, conversion, or duplication of data or information, or used in the automatic acquisition, storage, manipulation, management, movement, control, display, switching, interchange, transmission, or reception of data or information.

The term does not include any equipment that contains embedded information technology that is used as an integral part of the product, but the principal function of which is *not* the creation, conversion, duplication, acquisition, storage, manipulation, management, movement, control, display, switching, interchange, transmission, or reception of data or information.

?????????

Anyone else’s brain just go TILT?

Let’s try again…

Categories of E&IT

Software applications and operating systems

Web-based information and applications Telecommunications products Video and multimedia products Self-contained, closed products (e.g.,

many office products, kiosks) Desktop and portable computers

Rule of Thumb

Is it electronic? And/or does it fit in one of the six categories (previous slide)?

Does it have a display and/or keypad that humans interact with?

Does that display have information about creating, converting, sending, receiving, or duplicating any sort of data or information?

If you answer yes to all of these, you are dealing with E&IT.

Examples of E&IT under 508

Fax Machines Scanners Printers Copiers PDAs Computers Computer software Computer operating

systems

Phones Information kiosks ATMs Multimedia Videos World Wide Web

Not E&IT under 508

Microwaves (unless it sends faxes, too) Coffee makers Heating and ventilation systems Thermostats

The Gray Area

“Back office” E&IT is exempted Must literally be somewhere that people do

not go all the time Applies to equipment that only technicians

interact with

Section 508 on Videos

(c) All training and informational video and multimedia productions which support the agency's mission, regardless of format, that contain speech or other audio information necessary for the comprehension of the content, shall be open or closed captioned.

Interpretation

Videos must be captioned before they are shown in the classroom for the first time

Uncaptioned videos may be purchased and someone (ordering department?) pays to have them captioned

Under 508, captioning required whether or not deaf students will be in the class

Be Aware

Closed captions are turned on and off with a “decoder”

Televisions (since the ‘80s) have decoders built in; not all overhead projectors do Epson and Panasonic make projectors

with decoders External decoders can be purchased

So Whose Job Is 508?

Who buys E&IT?

508 touches everyone on campus involved purchasing and using E&IT Administrators buying the campus phone

system Department secretaries buying new fax

machines IT folks choosing campuswide software Department chairs purchasing videos Faculty members creating Web sites Purchasing deciding on bids for kiosks

508 Players

Disability Services (DSPS) Information Services (IT)

Procurement

Working to Support Purchasing

DSPS and IT have supporting roles But 508 is at its heart procurement law

Whoever signs off on buying decisions must buy accessible under 508.

What Does IT Do?

Information Technology Services Focuses on functional requirements Provides information about IT needs Considers interoperability and

maintenance needs Holds the system-level viewpoint for all

E&IT purchases

What do DSPS (or DRC) Do?

Disability Services Provides information about assistive

technology Provides accommodations to students

Under Section 504

What Is Section 504??

Remember that Rehabilitation Act of 1973?

Same Act: two different laws

Section 508 is about access.

Section 504 is about accommodation. DSPS was created to deal with 504.

Section 504 vs. Section 508

Section 504 addresses individual disability needs.

Section 508 addresses the infrastructure that allows access.

A Campus Analogy

Section 504 Accommodates the student in a wheelchair

who has a classroom on the second floor by carrying the student up the stairs.

Okay, not a good accommodation, but an accommodation nonetheless.

Section 508 Provides access for all by building an

elevator.

Access Only Goes So Far

Part of buying accessible is to ensure that products work with assistive technology

Individual needs must still be accommodated

Buying accessible will reduce, not alleviate, the need for individual accommodation

Working Together

The campus buys accessible products Individual accommodations for students

with disabilities to access those products are the responsibility of DSPS

Buying accessible, however, will make such individual accommodations far less expensive.

Where Does the Buck Stop?

Someone has to have sign-off power on each E&IT purchase

Who will be responsible for complying with Section 508 on these purchases?

Buying Under 508

How to Buy under 508

Functional requirements drive the procurement, not Section 508.

First determine your business needs.

Then consider 508 accessibility.

The Process

Figure out as specifically as possible what you need.

Do market research. Decide which sections of Subpart B apply. Use VPATs and/or a checklist.

In some cases, may need to do testing (508 Standards, Subpart C).

Pick the most accessible product that meets your needs.

Step One

Determine functional requirements

Functional Requirements

Determining may be an iterative process at first

Figure out some requirements—research products—realize other requirements

What Do You Need? Be clear about your functional

requirements What are the technical specifications?

How fast? how many pages? how big/small? What features? What functions?

What are the minimum requirements? What specific need does the product meet

(i.e., what must it do)? Are there specific academic considerations

to be taken into account? Document your needs.

Requirements may include…

Campus’s ability to support the product Campus IT’s need to safeguard current

network Technician’s knowledge of maintenance

and repair

Just make sure to document the needs!

Reframe Your Thinking

It’s not, “I have this much to spend.” It’s, “This is what the machine needs to

do.”

However, you can look at machines within a given price range to see what the features are.

Step Two

Determine what’s out there

Pick Your Products

Figure out a few products that meet your needs

How many? Determine policy At least three?

All the products should meet your needs equally well

If you really hope that one will be picked, may need to go back your needs again.

Add Accessibility into the Equation

Once you have determined your needs, research the market. You already do market research for

models, prices, features, durability, etc. Just make accessibility one more item on

the list.

Getting Technical

Each of the six E&IT categories has a list of technical specifications in Subpart B of Section 508.

Determine the appropriate sections of Subpart B.

Software applications and operating systems Includes:

Operating Systems (Microsoft Windows, Apple OS X, Linux, etc.)

Server software Desktop publishing applications

(e.g, MS Office, Open Office, Corel, etc). Audio/Video software, iTunes

http://www.section508.gov/index.cfm?FuseAction=Content&ID=12#Software

Web-based information and applications Includes:

Web pages Web-based student information systems Audio/Video over the Web Podcasts Learning Management Systems, Blogs, etc.

http://www.section508.gov/index.cfm?FuseAction=Content&ID=12#Web

Telecommunications products

Includes: Telephones Microphones / TTY Connections Cell phones Voicemail / Interactive voice response

telecommunication systems

http://www.section508.gov/index.cfm?FuseAction=Content&ID=12#Telecommunications

Video and multimedia products

Includes: Digital / Analog televisions Television tuner cards (for computers) Video tapes / DVDs Multimedia productions

http://www.section508.gov/index.cfm?FuseAction=Content&ID=12#Video

Self-contained, closed products Includes:

Informational kiosks Fax machines, Copiers Calculators PDAs ATMs

http://www.section508.gov/index.cfm?FuseAction=Content&ID=12#Self

Desktop and portable computers Includes:

Keyboards, keypads Physical controls for docking stations,

switches, expansion slots, connectors, etc. Touchscreens and touch-based interfaces Mobile computers

http://www.section508.gov/index.cfm?FuseAction=Content&ID=12#Desktop

Multiple Categories

Hardware run with a software interface Hardware accessed over the Web Software application running on the Web

Make sure to look at all aspects of the product

Researching Accessibility

VPATs Voluntary Product Accessibility Templates Done by vendors Not always done well but getting better

Examples http://www.microsoft.com/industry/

government/section508.mspx#ECAA http://images.apple.com/accessibility/

Voluntary Product Accessibility Template

Criteria Supporting Features Remarks and Explanations

Section 1194.21 Software Applications and Operating Systems

Supported with exceptions. Please refer to attached VPAT.

Section 1194.22 Web-based internet information and applications

Supported. Please refer to attached VPAT.

Section 1194.23 Telecommunications Products

Microsoft Office Excel 2008 for Mac is not considered a telecommunications product according to the definition in section 1194.23.

Section 1194.24 Video and Multi-media Products

Microsoft Office Excel 2008 for Mac does not use multimedia except as covered in section 1194.21.

Section 1194.25 Self-Contained, Closed Products

Microsoft Office Excel 2008 for Mac is not considered a self-contained, closed product according to the definition in section 1194.25.

VPAT for MS Excel(Sec 1194.21—Software Apps)

Criteria Supporting Features Remarks and Explanations

(a) When software is designed to run on a system that has a keyboard, product functions shall be executable from a keyboard where the function itself or the result of performing a function can be discerned textually.

Supported with exceptionsMicrosoft Office Excel 2008 for Mac supports Mac OS 10.4 (Tiger) accessibility features including Sticky Keys, Slow Keys, and Mouse Keys.Keyboard access is provided in a number of areas throughout Microsoft Office Excel 2008 for Mac. Keyboard shortcuts, shortcut keys, and menu commands are available in Microsoft Office Excel 2008 for Mac. Documentation for the Microsoft Office 2008 for Mac system client applications, which includes Microsoft Office Excel 2008 for Mac, is provided in digital format with the product. The Microsoft Office for Mac Web site contains informational material as well.

Microsoft Office Excel 2008 for Mac does not fully meet this requirement. Functionality that is not accessible using the keyboard includes toolbar window panes such as the formula bar edit window, PivotTable layout controls, and toolbar menu buttons.

You Can Create Your Own Checklist

Use the technical standards in Subpart B as a checklist.

Some federal agencies send checklists to vendors and only consider vendors who complete the checklists.

Example http://www.uspto.gov/web/offices/cio/

s508/vendor_sw.doc

USPTO

Had problems with vendors just “checking boxes”

Wanted vendors to explain how products were compliant

Required vendors to complete their version of VPAT to be considered

USPTO Excerpt

Questions for Software and OS Accessibility

Meet Standard and How

Do Not Meet

Standard

Not Applicable and Why

(a) If software is designed to run on a system that has a keyboard, are product functions executable from a keyboard where the function itself or the result of performing a function can be discerned textually?

(b. i) Does the application avoid disrupting or disabling activated features of other products that are identified as accessibility features (where those features are developed and documented according to industry standards)?

Talk to Vendors

Ask vendors how their products are accessible, not just whether they are.

Ask them how they meet the specific standard.

If you are suspicious of anything on the VPAT, question their representative.

Don’t just accept the statement that they are fully accessible. Ask for specifics.

BEWARE!

There is no such thing as “508 Certification.”

If a vendor claims that their product has been “certified” as being “508 compliant,” they are not being truthful.

Currently, no independent agency certifies that a product conforms to the 508 standards, nor is there any sort of “508 seal.”

Organize the Information

Using the standards from Subpart B, create a table listing how each vendor did with a particular standard.

Add your columns and see who met the most standards.

Step Three

Pick the most accessible product

Organize the Information

Using the standards from Subpart B, create a table listing how each vendor did with a particular standard.

Add your columns and see who met the most standards.

Analyze the Competition

Category of Standards

Product A Product B Product C

Standard 1 Compliant Compliant

Standard 2 Compliant Compliant Compliant

Standard 3 Compliant Compliant

Standard 4 Compliant

Standard 5 Compliant Compliant

Total 3 4 3

Choose

You have already determined that all of these products meet your needs, so choose the most accessible.

If there is a tie, choose whichever you prefer.

If you choose a less accessible model, there needs to be a compelling reason (other than price!).

How much will it cost?

Typically the more accessible products cost the same as or little more than any other product in their class.

However, the only time cost is taken into account is in the case of a tie!

But remember, only buy the functionality you need.

Product Testing

On high-end products, VPATs and checklists may not be enough.

If testing is required, do you test in-house or outsource?

In-house Can work with 508 committee, but realize

that individuals may not be that skilled. CSUs have CUDA. Can use Section 508 Subpart C

Independent Testing Facilities

American Foundation for the Blind www.afb.org

Prosoft Technologies www.prosoft-tech.com

Criterion www.criterion508.com

TecAccess www.tecaccess.net

CSU Testing

CUDA CSU Long Beach

Can test under Subpart C Functional requirements

Step Four

Look at exemptions

Four Exemptions

Fundamental alteration Product does not do what is required

Technical infeasibility Not possible to make it accessible

Commercially unavailable It doesn’t exist

Undue burden Would have to prove the cost is high enough to

cause a fundamental disruption of the organization Burden of proof on defendant

Bottom Line

Focus on the functional requirements and you won’t have to worry too much about the exemptions

If no accessible products meet your functional requirements, you still buy what you need.

Summary

Determine functional requirements Determine what products are available Pick the most accessible product Consider exemptions if necessary

Replacing Current Products

Ack it’s not accessible!

Buying Cycles

Work within your standard purchasing cycles

Work within standard curriculum review cycles

Basic Questions to Ask

Is it E&IT? Is it already accessible? Is there anything that does what you

need that is accessible?

Go through the buying-accessible process

Buying Accessible Example

Hardware: Overhead Projector

Hardware Exercise

A purchase request has been made to buy new projectors for the college.

What is Step One?

Right! Start with Needs

The more complete the needs, the easier the process

Probably the most difficult step It’s okay to look at what’s out there to get

a sense of what you want Set minimum requirements

(Anything more is fine but not necessary.)

Determine Product Criteria

Gather input from all relevant staff, faculty, and administration

For high-end purchases, a committee is really helpful If you don’t think of a need, someone else

will!

Projector Criteria

For this product, we want the following product criteria: Ceiling mount 4:3 aspect ratio Closed-caption decoder built in Minimum contrast ratio 400:1

Product Survey

Determine which products are available Panasonic PT-F100 Epson PowerLite 83c Canon LV-7585

Product Analysis

Judge each product against the product criteria

You might create your own form for this List each functional requirement down the

side and the products across the top

Projector Example

Results: Panasonic PT-F100 Epson PowerLite 83c

Which Standards Apply?

Look at the six categories Which apply? If they apply to one product, then use for

all products under consideration

Categories of E&IT

Software applications and operating systems

Web-based information and applications Telecommunications products Video and multimedia products Self-contained, closed products (e.g.,

many office products, kiosks) Desktop and portable computers

Projector Example

Self-contained, closed products (e.g., many office products, kiosks) For buttons on machine and remote

Video and multimedia products For turning captions on and off

Determine Most Accessible

Review VPATs Analyze against Section 508 Standards Determine accessibility score

Checklists Make It Easy

Use the appropriate standards list Have a column for each product Check the ones that apply Count the check marks

Both Partly Compliant?

Legally the 508 Standards are all weighted equally

Do not give preference to certain standards because of greater concern about that disability group

Do not give preference based on specific employees

Possible Projectors for Purchase

Epson $900 Panasonic $1700

This is the step in which price can be used as a determining factor. Note:

The projector without the decoder built in (Canon LV-7585) was $7000.

When Compliance Is Equal…

You really can just pick whichever one you want based on whatever you like Price Individual preference Color Size It doesn’t matter…

Final Step

Have 508 Coordinator (or whoever will sign off on purchase) review and approve selection

Make the purchase

Software Examples

Software Web Distance Ed

Software and Section 508

Software Applications and Operating Systems are part of Subpart B, 1194.21

To meet these technical provisions, the product can either build-in accessibility or be compatible with assistive technology

In some situations, these provisions may be used in conjunction with another set of technical standards to assess product conformance fully

Software Example

An instructor in the math department has created a new program that the college is considering for purchase.

Is the math instructor required to make it conform to the applicable Section 508 Standards? No, the math instructor would be considered a vendor

and not required to conform to the Standards

Various accessibility components were built into the program, but it will NOT work with AT – could it be considered for purchase? Yes, provided it meets the Software Applications and

Operating Systems provisions

Buying Accessible Exercise

Web Browsers

Word Processing Applications

Accessible Web Design

In the context of Section 508, refers to 16 technical provisions (Subpart B, 1194.22)

Yes, these technical provisions include Intranet sites as well

Code samples are provided that give examples of how to meet access needs

Code Example

1194.22 Checkpoint A Provide a text description for every non-

text element Example: alt attribute <img src=“…” alt=“…” / >

Demonstration

Using assistive technology on the Web Images Form fields

Common Web Questions

I am creating the Web pages, not procuring them. Do I still need to follow the 508 Standards?

Common Web Questions

What about PDFs – those aren’t Web pages.

Subpart B, 1194.22 includes Web-based Intranet and Internet Information and Applications

For instance, a PDF could be considered a "non-text element," so you would need to provide a text equivalent

Additionally, viewing a PDF requires a separate application and the application would need to conform to Subpart B, 1194.21 (Software standards)

Common Web Questions

We need a new learning management system for the college but have been told that none of them are accessible. Can I not purchase a new system?

Distance Education & LMS Platforms

Learning Management Systems (LMS) provide a framework to post Web-based materials, media content, lecture notes, etc.

Remember, it is your “needs” that sets the threshold for which LMS are to be considered

Once potential LMS platforms have been selected, review for 508 conformance

Implementing 508

Models

Individual Oversight Committee Oversight

Roles

First we’ll look at the roles of the individual administrators and the committee

Second we’ll look at setting up the structure

Step One: Requestor

The person making the purchase Writes functional requirements for product Does market research Gets VPATs Analyzes against standards Determines most accessible Signs off and presents packet to 508

Coordinator

Step Two: 508 Overseer

Checks Packets Functional criteria VPATs Matrix of scores Accessibility assessment(s) Product choice

Step Two: Oversight (cont.)

Makes sure most accessible product was chosen

Signs a checklist and passes off to procurement

Note: ONLY 508 Coordinator can grant exemptions

Step Three: Purchasing

Procurement Responsible for ensuring that checklist has

signatures Makes the purchase

Your Campus May Need More Diffuse Structure

Don’t like sending all E&IT purchases through a 508 coordinator?

Can have each department sign off… However, the more people who can sign

off, the more training will be required. It’s a trade-off.

The 508 Committee

Stakeholders Administration Purchasing Disability services IT Faculty Staff Disabled students

Committee Involvement

When creating policy and procedures When making large-scale purchases

Phone systems, registration system, information kiosks, etc.

We suggest setting a dollar amount at which the purchases will go through the committee.

Getting 508 Buy-in

Provide context Provide training

Offer flex credit Create competitions

For best accessible Web pages For most innovative examples of access

Celebrate successes Recognize faculty achievements Advertise campus accomplishments Provide recognition by governing board

Implementation Models

508 Coordinator Distributed Partnership Committee

Coordinator Model

Model workflow if you choose to have a 508 coordinator All requests go through 508 coordinator

USPTO example

Federal Agencies

508 Coordinator should understand the campus structure have project management skills be solution-oriented be close to high-level administrators have grasp of IT & assistive tech (doesn’t need

to be a techie) understand difference between 504 and 508 be involved with budget, development, and

architecture meetings

508 Coordinator

If you choose to have a 508 coordinator…

That person should have the authority to make decisions, take action, and enforce policy.

The person will sign-off on E&IT purchases.

One or two?

Can the 504 Coordinator be the 508 Coordinator?

Yes—if that person has the skills outlined above and can do the job

No—if your DSPS director is still the 504 coordinator

There is no inherent conflict between the two positions.

Distributed Model

Assign various high-level administrators to sign off in particular product areas Videos and A/V Computers Office products Software Web site development Telecommunications

Procurement then becomes final gatekeeper

Distributed Model in Action

Mesa College: Video Purchases

Mesa College Solution

Every video purchase goes to A/V Librarian

Librarian researches what is available closed captioned

If the requested video is not captioned, offers an alternate suggestion

Requesting department can purchase alternate or pay to caption the original title

Partnership Model

Disability services, information services, and procurement work together

San José State Solution

Requestor gathers documentation Determines business needs and generates three

product suggestions—works with IT to determine functional needs

Submits packet to procurement Procurement checks for completeness

Packet goes to disability services Disability services checks accessibility scores Packet returned to procurement for final check-

off and purchase

Staffing

Procurement staff One person in charge of Section 508

purchasing Disability services

One person in charge of checking accessibility

Currently implemented for purchases≥ $50,000

Committee Model

Requestor determines functional requirements and suggests products

Committee determines accessibility score

Procurement makes purchase

De Anza Campus Model

Administrators, in consultation with requestors, are responsible for conducting market research

Unclear who is to perform product testing for accessibility

Section 508 Committee meets to: Address any exceptions Provide additional information or feedback

Implementation Problems

Lack of training Looks good on the org chart, but…

Accessibility documentation is to be submitted with Purchase Requisition…and then what?

Need a champion “508 coordinator” pushing the committee

model Committee head must be identified early and

have institutional support

Your Campus

Implementing 508 Standards on Your Campus Set up committee Develop policy Determine workflow

Piggyback on established procedures Begin training staff Hire a 508 Coordinator if needed

Remember to budget for staff for the coordinator as needed

On-going training Advertise successes!

Activity

Which model seems most workable for your campus?

Where would 508 analysis naturally fit into your current workflow?

Where are the potential bottlenecks? What are the potential challenges to

implementation? What would the roles of IT, procurement, and

DSPS be? What other entities on campus do you need to

engage with and involve?

Easing the Transition

Make sure everyone is clear on his/her role and responsibility

Make sure policies are enforceable Make 508 part of the workflow (piggy-

back on current processes) Identify possible problem areas in the

workflow Build awareness on campus Start small (purchases above $50,000?)

Final Thoughts

Access Only Goes So Far

Part of buying accessible is to ensure that products work with assistive technology

Individual needs must still be accommodated

Buying accessible will reduce, not alleviate, the need for individual accommodation

Electronic Curb Cuts

Hold the vision of access and follow the standards as best you can

Start small…but start Celebrate (and publicize!!) victories Realize that it will take time

Reference

http://www.access-board.gov/sec508/guide/index.htm

http://www.access-board.gov/sec508/refresh/report/

Questions?

Gaeir (rhymes with “fire”) Dietrich gdietrich@htctu.net 408-996-6043

Sean Keegan skeegan@htctu.net 408-996-6044

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