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Accessible Technology Initiative

FAQs

Draft rev. 8/14/2007

Q1. The coded memorandum indicates that new or updated administrative websites, web applications, and web content produced by, or on behalf of, the CSU must be conformant with Section 508 accessibility standards no later than September 1, 2007. What is meant by ‘updated’?

A. While the CSU is responsible for ensuring that its entire web presence is conformant with Section 508 accessibility standards, the scope and complexity of this task will require a staged implementation in order to fulfill this responsibility. The specific intent of the September 1, 2007 milestone is to ensure that campuses are not creating new accessibility barriers as their information infrastructure continues to expand and evolve.

The ATI Web Community of Practice has engaged in extensive discussion regarding the impact of this milestone on web development activities. The circumstances and manner in which this milestone applies to web development activities for administrative websites and web applications are summarized below:

Action (After September 1, 2007) Response

When new web pages are added or existing pages are modified in a manner that alters the functionality of the pages (e.g. new or revised forms, tables, or multimedia), or alters the underlying structure of the pages (e.g. incorporation of XML feeds, changes to overall layout or reading order) …

These pages must, at a minimum, conform, to Section 508 guidelines and should meet Web CoP Best Practices standards. Any other (unaltered) pages on the web site should be targeted for evaluation and remediation to Section 508 standards by the May 15, 2009 deadline if they are deemed ‘critical’. Non-critical sites should be conformant by May 15, 2012.

When existing web pages are modified in a manner that does not alter the functionality or underlying structure of the pages (e.g. a revised color scheme, an added story on a news portal, updating office hours for a new term)…

These pages should be targeted for evaluation and remediation to Section 508 standards by the May 15, 2009 deadline if they are deemed ‘critical’. Non-critical sites should be conformant by May 15, 2012.

When new web applications are added, or when either existing web applications or the overall web architecture are modified in a manner that alters the functionality or underlying structure of web pages that are generated (e.g. migration to a Content Management System, adoption of a blog module, changes to campus web page templates)…

These pages must, at a minimum, conform, to Section 508 guidelines and should meet Web CoP Best Practices standards. Any other (unaltered) pages on the web site should be targeted for evaluation and remediation to Section 508 standards by the May 15, 2009 deadline if they are deemed ‘critical’. Non-critical sites should be conformant by May 15, 2012.

When existing web applications or the overall web architecture are modified in a manner that does not alter the functionality or underlying structure of web pages that are generated (e.g. updates that resolve bugs or implement cosmetic changes)…

These pages should be targeted for evaluation and remediation to Section 508 standards by the May 15, 2009 deadline if they are deemed ‘critical’. Non-critical sites should be conformant by May 15, 2012.

Q2. Given the large volume of web content and educational materials already in use across the CSU, what priorities should campuses incorporate into the evaluation and remediation process?

A.The evaluation and remediation processes are likely to vary to some degree across the system based upon campus-specific factors (organizational structure, technical resources, financial priorities). Campuses are encouraged to first evaluate whether there are materials that are no longer in active use or that no longer meet academic objectives. This is an opportunity to identify areas whose infrastructure would benefit from being updated or streamlined.

For the remaining materials, the following list identifies the types of materials that should generally be given higher priority in the remediation process:

High Priority Materials Examples

Materials used by large audiences

Admissions, Registrar, Financial Aid, and Student Affairs web sites; student orientation videos

Materials that are public-facing

Public Relations, Communications, and Campus Directory web sites; Visitor Center promotional videos

Materials that enable important administrative or academic functions (or electronic paths of travel to such materials)

Student portal web sites; lecture recordings; mandatory staff training videos

Materials for which no alternative method of providing the information is (readily) available

Course registration web sites (on campuses that lack backup systems); electronic library reserves

Materials that are likely to be utilized by persons with disabilities

Disability Resource Center, Diversity/Compliance web sites;

Transportation maps and schedules

Materials used frequently (even if by smaller groups)

Academic department sites; Help Desk tutorials

Q3. What happens if particular web content or instructional materials cannot be made accessible due to limitations inherent in the technology on which the material is based?

A. In situations where web content or instructional materials cannot be remediated to achieve conformance with Section 508 guidelines, the campus will still need to provide an equally-effective means of accessing this information based on Section 504 and American Disability Act (ADA) civil rights legislation. In addition, campuses should work with vendors (where appropriate) to identify potential workaround or solutions to this accessibility gap as well as proactively establish a plan by which these workarounds will be implemented as needed.

One example of this is the use of molecular visualization software that provides interactive, 3-dimensional views of molecular structures. Given the absence of accessibility ‘hooks’ within the (often proprietary) file formats utilized by this type of software, accommodating persons with some types of disabilities will likely require transformation of this material into other formats (e.g. tactile graphics, molecular model kits, etc.) for the foreseeable future. This type of transformation will generally be best accomplished through a collaboration with the faculty member, the Disability Services office, and the student.

Q4. If there are no identified students with disabilities that are enrolled in a particular course, do the web pages and instructional materials used in that course still need to be accessible?

A. There are basically two types of accessibility requirements that apply to instructional materials and web content for CSU courses:

  1. The Americans with Disabilities Act (ADA) requires that public entities provide reasonable accommodations to otherwise qualified persons with disabilities who access their programs and services.
  2. California Government Code 11135 specifically applies the technical and functional accessibility standards of Section 508 to electronic and information technology (EIT) including but not limited to web content, electronic documents, and multimedia.

Based on ADA, the CSU is expected to ensure that information is provided to persons with disabilities in an equally-effective manner. This specifically includes ensuring a timely response, quality translation, and delivery in a manner or medium that is appropriate for the information being conveyed. While ADA does not specifically require that EIT infrastructures be fully accessible in anticipation of usage by persons with disabilities, both Office for Civil Rights investigations and case law consistently emphasize the importance of proactive institutional planning and the difficulties associated with timely delivery when the institutional infrastructure has not been designed with accessibility in mind.

Based on CA Code 11135, the CSU is responsible for maintaining an EIT infrastructure that meets the Section 508 technical and functional standards. The standards are designed to ensure that EIT products are readily usable by persons with disabilities without requiring significant modification. This ‘universal design’ approach therefore emphasizes that accessibility must be supported in the EIT product whether a person with a disability is using that product or service at any given moment in time.

Taken together, these two sets of requirements constitute strong guidance to the CSU on the importance of incorporating accessibility into the EIT infrastructure. Campuses should therefore work to ensure that their web and instructional materials are conformant with Section 508 to the fullest extent possible—whether an identified student is enrolled in a course or not.

In situations where Section 508 conformance cannot yet be readily achieved, campus efforts should first center on ensuring ADA compliance by identifying equally-effective ways in which to provide access to the information contained in these instructional materials. Additional attention should also focus on evaluating the various methods by which instructional materials are delivered on campus and then establishing a process by which these materials will be remediated.

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Last Update: 08/8/2013