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Assistive Technology – Compliance Procedures

1. Overview

1.1. The District is obligated under Federal law, State administrative code, and Board of Trustees policy to make its information technology resources accessible to persons with disabilities.

1.1.1. Section 508 of the Rehabilitation Act of 1973 defines its obligations under Federal law.

1.1.2. Sections 206 and 213 of the Texas Administrative Code define its obligations at the State level.

1.1.3. Board of Trustees Policy – Information Resources CS (Legal) defines the specific provisions by which its compliance with Federal and State requirements are met.

1.2. This document outlines the specific procedures by which the District’s compliance efforts are executed.

2. Scope

2.1. These procedures apply to all information technologies, services, and content provided directly by the District, its colleges and offices, faculty and staff, or indirectly through third parties contracted or authorized by them.

2.2. Compliance with these procedures is required for information technologies, services, and content both administrative and educational.  Examples include:

2.2.1. Informational websites of the District, its colleges, and programs such as www.dcccd.edu or www.northlakecollege.edu.

2.2.2. Online services in support of instruction or student services such as ecampus.dcccd.edu or econnect.dcccd.edu.

2.2.3. Classroom technologies and online content.

3. Organization

3.1. Approval of these procedures and their subsequent revision lies with the Chancellor’s Staff.

3.1.1. Revision to these procedures will occur on an ad hoc basis as changes occur in disability law, regulation, and policy.

3.2. Per Board of Trustees Policy, Access To Programs, Services, and Activities, GL (Legal), the District’s compliance efforts are coordinated by the college ADA Compliance Coordinators.

3.2.1. The role of these coordinators includes:

-  Organizing and supporting the implementation of Section 508 of the Federal Rehabilitation Act of 1973 within their respective colleges.

-  Serving as the central point of contact for information concerning accessibility issues and solutions.

-  Development, support and maintenance of the college’s internal accessibility policy as required by TAC Rule §213.41c.

4. Design Requirements

4.1. Rule §206.70a requires that new or revised web pages on all websites comply with the following specific standards and specifications:

4.1.1. Section 508 of the United States Rehabilitation Act, Subpart B §1194.22, paragraphs (a) through (p), excluding paragraphs (b) and (k).

4.1.2. Chapter 213 of the Texas Administrative Code, Subchapter C, Accessibility Standards for Institutions of Higher Education.

4.2. Revisions to these specifications will occur in response to changes in law, regulation, or code as part of the ad hoc revision process.

4.3. As such, these may not reflect the most current specifications in force; consult the websites listed in the External Resources section of this document for the latest versions of these specifications.

5. Compliance Plan

5.1. The plan for achieving compliance with the District’s legal and regulatory environment must address reduction and remediation of compliance issues in new and existing web content and services.

5.2. The compliance assessment tools identified by the Department of Information Resources will be used for automated testing of content (see http://www.dir.texas.gov/management/accessibility/tools/Pages/TestingTools.aspx).

5.3. Manual assessment of content will be performed at the point of creation in the case of new content; assessment of existing content will be performed as operational contingencies allow.

5.4. To best reduce the growth of noncompliant new web content and services, all staff involved in its development should be trained in compliance measures.

5.5. To best remediate existing web content and services, prioritization criteria are necessary to focus available resources in the directions that serve the greatest number of impacted people.  The order in which these criteria are applied are:

5.5.1. Pages containing information concerning services to persons with disabilities.

5.5.2. Pages directly leading to the pages concerning services to persons with disabilities.

5.5.3. Pages providing self-service to the student or direct instruction.

5.5.4. Pages experiencing high levels of network traffic.

5.5.5. All remaining pages experiencing low levels of network traffic.

6. Compliance Management

6.1. By establishing and following the compliance management protocol outlined below, compliance with accessibility standards can be achieved in a manner most consistent with our commitments to our students and the public we serve.

6.2. Testing

6.2.1. Faculty and staff responsible for selection or generation of online content will receive training in the use of accessibility testing tools and manual compliance checking techniques.

- The Texas Department of Information Resources recommends a number of tools for automated testing of web pages for accessibility.  This list can be found at http://www.dir.texas.gov/management/accessibility/tools/Pages/TestingTools.aspx ..

- As automated testing is not 100% reliable in identifying noncompliant content, its use should be augmented by manual checking of content.

6.2.2. New content should be tested for compliance just prior to publishing, with remediation of noncompliant content prior to publishing

6.2.3. Existing content should be initially tested in order to identify that requiring remediation.  Remediation can then be prioritized according to the criteria outlined in 5.5 and scheduled as operations and resources permit.

6.3. Monitoring

6.3.1. To best ensure compliance and monitor progress towards remediation, annual testing of content should be placed on an audit schedule by the college compliance coordinators to best integrate with existing academic and production calendars.

6.3.2. Results should be acted upon to ensure:

- That training efforts have been successful in stemming the increase in new, noncompliant content.

- That progress is occurring in remediation of existing content.

- Noncompliant content identified via monitoring should be reprioritized and scheduled for remediation.

6.4. Reporting

6.4.1. Results of testing and monitoring should be reported to the campus compliance officer and the location’s executive leadership.

The report should include the following data from the current and previous years’ compliance audit.

- Total number of content pages

- Total number of noncompliant pages

- Total number of new pages

- Total number of noncompliant new pages

- Total number of existing pages

- Total number of noncompliant existing pages

6.4.2. The compliance officer should work with the executive leadership to ensure that adequate resources are provided to the remediation effort within the constraints fiscal and operational feasibility.

7. Exception Protocol

7.1. The request for compliance exceptions is initiated by the department sponsoring the information resource.

7.2. The documentation for the exception request should include:

7.2.1. The number of impacted students currently servable by the resource

7.2.2. The cost of implementing the resource

7.2.3. The amount of labor needed to implement the resource absent an exception

7.2.4. Other initiatives delayed or cancelled to realize the resource.

7.3. This documentation is to be attached to a memorandum addressed to the campus chief executive officer making the formal request for exception.

7.4. The chief executive office will respond to the request via answering memorandum.

7.5. The resulting documentation will be filed with the campus compliance officer.

8. External Resources

8.1. United States Rehabilitation Act - Subpart B §1194.22 http://www.section508.gov/Section-508-Of-The-Rehabilitation-Act – the federal technical standards for compliance referred to by the Texas Administrative Code.

8.2. Texas Administrative Code Chapter 206 http://info.sos.state.tx.us/pls/pub/readtac$ext.ViewTAC?tac_view=5&ti=1&pt=10&ch=206&sch=C&rl=Y – State of Texas rules for institution of higher education websites

8.3. Texas Administrative Code Chapter 213 http://info.sos.state.tx.us/pls/pub/readtac$ext.ViewTAC?tac_view=5&ti=1&pt=10&ch=213&sch=C&rl=Y – State of Texas accessibility standards.

8.4. W3C Web Accessibility Guidelines http://www.w3.org/TR/WCAG10/ – guidelines for making web pages accessible to persons with disabilities.