Draft rev. 8/14/2007

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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