QA ABOUT THE REVISED SECTION 508 STANDARDS WITH

Q&A ABOUT THE REVISED SECTION 508 STANDARDS WITH THE ACCESS BOARD AND GSA CSUN Assistive Technology Conference March 11, 2020

What is “Section 508”? Law Versus Standards ■ Section 508 of the Rehabilitation Act (29 U. S. C. § 794 d), as amended by the Workforce Investment Act of 1998 (P. L. 105 -220) [THE LAW] – Requires federal agencies to develop, procure, maintain and use information and communication technology (ICT) that is accessible to people with disabilities (PWD) who are members of the public or federal employees ■ The Access Board developed and published the Section 508 standards that implement the statute and provide the requirements for accessibility [THE STANDARDS] 2

Agenda Topics Brief overview of how the U. S. Access Board (USAB) and the General Services Administration (GSA) work together to develop and provide technical assistance on accessibility. Review common questions and responses; focus on how the 508 Standards are implemented across government. Discuss the technical assistance and online resources available. ■ ■ Buy – Acquisition Create – Development and Testing Use – Operate (e. g. , no-cost tools, shared services) Maintain 3

Introductions 4

Introductions ■ The U. S. Access Board and the General Services Administration – Federal agencies that have a responsibility to provide technical assistance on and respond to questions about the Section 508 standards and guidelines. ■ Both the Access Board and GSA – Maintain help desks where we respond to emails and phone calls about Section 508 of the Rehabilitation Act (29 U. S. C. § 794 d, as amended). – Provide training and technical assistance about ICT to individuals and federal agencies. ■ The Access Board only enforces Section 508 accessibility requirements against itself. ■ All agencies enforce the Section 508 Standards against themselves. 5

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Do I Have to Comply with Section 508? (1/3) ■ Section 508 (Rehabilitation Act) only applies to federal agencies in the Executive Branch – 508 imposes mandatory accessibility requirements only on Federal agencies ■ Many non-executive branch agencies also comply voluntarily – Applies to Federal contracts, but up to agencies to enforce ■ Some Federal grant or other funding programs make compliance with Section 508 Standards a condition of program participation ■ Section 508 does not directly apply to private sector websites or businesses, unless they are creating websites for a federal agency – For most private sector business websites, see ADA 7

Do I Have to Comply with Section 508? (2/3) ■ General Exceptions (E 202) may be granted by an approving authority, for – Legacy ICT (ICT conformant with prior standards and unaltered prior to 18 Jan 2018) – – – National security systems Incidental to a contract ICT functions located in maintenance or monitoring spaces Undue burden or fundamental alteration Commercial non-availability (Best Meets) ■ Alternative means required – Undue Burden, Fundamental Alteration, Best Meets (Commercial non- availability) 8

Do I Have to Comply with Section 508? (3/3) ■ Some State governments and other non-federal entities incorporate, adopt, or reference the Section 508 Standards as their benchmark for ICT accessibility – The Access Board does not make this determination – We are unable to tell you whether our Section 508 Standards apply to your ICT through some other law or policy ■ Please consult your authoritative source for specific program information, requirements, or exceptions: – Funding source – Relevant statutes – State or federal agency 9

CREATE (DEVELOP) 10

What is required when making ICT Accessible? Who is asking: Federal or state entity? ■ Title II of ADA covers state and local governments – State and local governments must “effectively communicate” about their programs and services – Consult DOJ if a definitive answer is needed ■ How does an organization such as a state government integrate the provisions of § 508 as it applies to access by employees with disabilities to internal information? – For Federal agencies, 508 covers “Agency Official Communication” (E 205. 3) – If your state government “follows 508” then those categories are the minimum for “internal information” – Remember that 508 is proactive for all ICT, it is not an accommodation 11

Can I Wait and Provide an Accessible Version of Electronic Content Upon Request? ■ No – Section 508 requires proactive accessibility, without being asked – Providing special assistance or assistive technology upon request is a reasonable accommodation (Section 504 of the Rehabilitation Act) ■ What about exceptions like Best Meets and Undue Burden and Fundamental Alteration Exceptions? – Those exceptions all mention Alternative Means – What is the difference between an accommodation and Alternative Means? – Can I use an accommodation as Equivalent Facilitation? 12

Can I Assert Cost as an Undue Burden? ■ Yes, but -- As a general rule, an agency is taking a risk by asserting cost as a reason for not providing accessible content ■ Historically, assertions of Undue Burden (see E 202. 6) have a high bar to meet ■ In addition, the agency must still provide access to and use of information and data by an alternative means that meets identified needs 13

How Does Section 508 Address Documents and Files? (1/2) ■ It depends! Look to E 205 Electronic Content ■ All electronic content is required to be accessible when either: – Public facing – e. g. posted on the web or otherwise shared with the general public (E 205. 2) – Agency Official Communications –Nine different covered categories (A-I) (E 205. 3) ■ Electronic content includes document types such as Microsoft Word, Power. Point and Excel and PDF 14

How Does Section 508 Address Documents and Files? (2/2) ■ Some covered categories are common uses of electronic documents (e. g. Training Materials) – Some are hard to imagine (e. g. using PDF as an emergency notification rather than HTML or TXT) ■ However, file formats like Auto. CAD and Photoshop: – Requirements for Electronic Content (E 205) are different than the requirements for Software (E 207) – Files from software like Auto. CAD and Photoshop, when converted to other formats (i. e. , PDF or HTML) would need to be made conformant to 508, before sharing with the general public, – It would be a Fundamental Alteration to require something other than the native file format needed by the software 15

How Can We Improve the Quality of Captions? ■ The requirement is that “captions are provided for all … content in synchronized media” (i. e. video with audio) ■ If content is essential for the comprehension of content, it needs to be captioned. – If sounds in context are less important, captions use musical notes symbols ♪ ♫ or short text in brackets, e. g. [music] – Song lyrics need not be captioned unless they are important to action or dialog; e. g. , a character on-screen comments on the song – Often, the title of background music is displayed in the captions ■ The name of each speaker should be identified when they talk - this is especially important when speaker is off-screen ■ As a best practice, pre-recorded broadcast TV usually has good examples of quality captioning 16

CREATE (TEST) 17

Automated Versus Manual Checkers Pros/Cons Automated checkers Manual Checking ■ Most software content products on the market include built-in accessibility checkers! – E. g. Word, Power. Point, PDF ■ Human review is still necessary ■ Check accuracy of alt tags – WHAT information is the image intending to convey? The accessibility checkers are excellent, but may report false negatives/positives, . e. g. , – Alt tags are frequently missed or incorrect – Color Contrast is often not checked – Interactive elements on a page (label associated with a question) missed ■ Color contrast requirement for text and background: 4. 5 : 1 [SC 1. 4. 3 Contrast] – E. g. Use a Color Contrast Analyzer (CCA) tool for contrast ■ Use Adobe Reader application to interactively test PDFs for accessibility. – “Read Out Loud Text-to-Speech” tool mimics the experience of Assistive Technology ■ 18

Automated vs. Manual Testing of ALT Tags ■ There is no automated testing tool that can assure full conformance with WCAG 2. 0 SC 1. 1. 1 Non-text Context ■ Use the requirements as a checklist (i. e. , WCAG 2. 0 Level A and AA success criteria) ■ Majority of requirements need a human to perform the evaluation, for example: – An automated tool can flag images that are missing an <ALT> attribute, but no automated tool can say if the supplied ALT value is providing a text equivalent or not – ALT=“cat meme” vs. ALT=“A cat with a coat hanger around it’s neck with the words “Human I request your assistance“” 19

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Does Section 508 Apply to Free/Shared Services? ■ Yes, even though your agency doesn’t pay for it Section 508 does apply! ■ ICT products and applications used by federal agencies at no-cost must be accessible. ■ Examples of “free” applications and services commonly used by federal agencies: – Social Media: Facebook, Linked. In, Twitter, You. Tube, and Instagram – Project Management: Asana, Jira, Monday and Trello – Shared Services: Payroll Services, Assisted Acquisition, GSA Smart. Pay, and Travel 21

Is It OK to Link to Third-party Content? ■ Yes, but choose wisely - You are responsible for linking to accessible content ■ The regulations generally apply to content agencies have control over ■ Pro Tip: Let users know when they are leaving your site 22

What About User-generated Content? ■ Citizens comment on: – Regulations – Blog posts – Crowd-sourced suggestions ■ Federal agencies are responsible to ensure accessibility ■ Ask commenters to submit with text descriptions and not just images ■ If you have a contest, contest rules explain that videos must be captioned ■ Agency staff must create and maintain a conforming alternate version 23

MAINTAIN 24

How Can I Make Maps Accessible? (1/2) ■ Maps and geospatial information systems (GIS) are a challenge to make accessible, but are also important for distributing information ■ Meet the accessibility requirements that you can! – – – ■ At least provide descriptive identification for visuals Provide good keyboard accessibility Provide as much visual contrast as possible, and pay attention to color blindness Referencing the base requirement? From WCAG 2. 0 SC 1. 1. 1: – If non-text content is primarily intended to create a specific sensory experience, then text alternatives at least provide descriptive identification of the non-text content – Providing descriptive identification is not that difficult! 25

How Can I Make Maps Accessible? (2/2) ■ Some examples of providing an alternate source of information for maps and GIS include: – Make the raw data available ■ Someone else might figure out an innovative way to make the information accessible ■ Example formats: Spreadsheet (CSV, XML), JSON – Provide contact information ■ It won’t just be people with visual impairments that have trouble using your maps! ■ Section 508 does not prevent the government from using these sort of applications! – Meeting the standards is subject to being “consistent with the agency’s business needs” 26

Under Revised 508, Do Web Applications Have to Meet Requirements Besides Those in WCAG? ■ Yes, possibly, depending on the nature of the web application ■ If the web application plays videos: – 503. 4 User Controls for Captions and Audio Description ■ This provision reflects common practices ■ No real-world examples of web videos (with CC or AD) without prominent controls ■ If the web application lets you create content: – 504 Authoring Tools ■ Chapter 6 – Support Documentation and Services – is also applicable 27

Questions from the Audience? 28

RESOURCES, TRAINING AND CONTACT INFORMATION 29

Where Can I Find Section 508 Resources? ■ Revised 508 Standards: – access-board. gov » ICT Refresh » Final Rule » Single File Version ■ Section 508. gov - A one-stop for Section 508 information and resource for agencies: – Create: section 508. gov/create – Test: section 508. gov/test – Tools: section 508. gov/tools – Manage: section 508. gov/manage – Buy: section 508. gov/buy – Sell: section 508. gov/sell ■ Making the Web Accessible: w 3. org/WAI 30

How You Can Contact Us U. S. Access Board ■ 800 -872 -2253 (voice), 800 -993 -2822 (TTY) ■ 508@acess-board. gov|access-board. gov GSA IT Accessibility Program ■ Office of Government-wide Policy ■ section. 508@gsa. gov | section 508. gov | gsa. gov 31

Thank You for Participating in Today's Session! This presentation is available at: https: //www. section 508. gov/training/presentationsworkshops 32