SSB BART Group Accessibility Overview - Federal Goverment
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SSB BART Group Accessibility Overview - Federal Goverment
- 1. Accessibility Overview for US Federal Government
- 11. AMP Demonstration A brief demonstration of AMP
Notas do Editor
- SSB Background – Overview of SSB BART Group and our relevant experience. Business Case – What are the key business drivers for addressing accessibility? Standards and Guidelines – What are the relevant Standards and Guidelines for addressing accessibility? This covers the US Section 508 requirements and broader international WCAG requirements. Solution Requirements – What are the requirements for addressing accessibility in the real world? Auditing – What are the requirements for auditing a system for accessibility? Specifications – What are the requirements for development, quality assurance and training specifications? Solutions AMP – Brief overview of the Accessibility Management Platform Implementation Support – An overview of the support services we have for accessibility Point Solutions – Specific fixed scope projects including accessibility audits and training initiatives
- Founded in 1998 by engineers with disabilities - SSB BART Group has been doing accessibility since before Section 508 and WCAG existed and we've been around as long as any of our main competitors. Our organizational focus is doing this in the real world – which is in contrast to many accessibility firms that will have a grounding in academia. In practice it also means that our organization has direct experiential knowledge doing development of IT systems in a professional environment. Our staff has made enterprise-class websites, web-based applications, and software and knows what is required to make such systems compliant in the real world. This is something which is often not the case in the market where firms may have some knowledge of accessibility but no experience in real world design, development and quality assurance (QA) environments. Focus on Accessibility - SSB BART Group only does accessibility. Some other firms you have heard of in the space like HiSoftware and Deque provide products that include privacy, security, brand compliance and SEO. These solutions are “jack of all trade” solutions which ultimately means they are masters of none and do a variety of different things poorly. SSBs sole focus is on providing IT accessibility compliance solutions. Largest staff of any company of our kind - SSB BART Group has the largest staff of W-2 employees of any company of our kind. The vast majority of firms in accessibility use 1099 contractors that are hired on demand on a per project basis. That can have a significant negative impact on the quality or work delivered, the consistency and repeatability of testing results and the accuracy of contractor work. Fifty percent staffing mix of individuals with disabilities - Roughly 50 percent of SSB client services staff have disabilities and this number is often far higher than total employees at competing companies. That means two critical things. First , SSB’s has the capacity to handle the volume of business that comes from our enterprise class customers. Smaller companies or sole consultants cannot handle the volume of work of multinational IT products vendors, financial institutions or large government organizations. Second, and more pragmatically, it means that we can The more pragmatic issue is that Implementation focused solutions – Many accessibility companies focus on providing solely diagnostic information to clients – often of the form "this doesn’t work in JAWS." SSB is focused on providing specific, actionable guidance that can readily be implemented of the form "change this piece of code on this line." This includes providing code level implementation and unit test guidance for all best practices in AMP and all content delivered in audits. What you may find in the market is that a lot of accessibility consultants live in black and white worlds where only 100% accessible information technology is acceptable. SSB BART Group lives in the real world where trade-offs are required and dollars go to projects that provide the best ROI. To this end our focus is on ensuring we use your accessibility budget in an optimal fashion – ensuring every dollar you spend on accessibility has the most impact possible Developers of the first generation accessibility validation tools and second generation management infrastructure – SSB was the first company to release a commercial accessibility validation tool, InFocus, ten years ago. The first generation of accessibility software focused on validation of web sites and applications but principally worked on static content. Since then SSB has spent the last ten years investing in and developing the Accessibility Management Platform or AMP. AMP is focused at solving the broader problem that customers actually face which is how to manage all the aspects of accessibility – Auditing, Training and Standards Management – over the course of many years and development cycles.
- There are major and minor business drivers for accessibility that vary based on the industry and profile of the organization we work with. For US Federal Government agencies most organizations seek to address accessibility to: Conform to the law – Public sector electronic and information technology (EIT) must conform with Section 508 or similar standards or the agency will be out of conformance with the law. Minimize Legal Risk – Which is the cost of litigation, settlements and required retrofitting to conform to settlements relating to ADA or similar law litigation. The argument here is that online services constitute “public accommodations” which have accessibility requirements under the ADA and related state and international laws. This tends to be the a minor driver for US Federal government agencies since most EIT is more directly covered under Section 508. Eliminate Employee Discrimination – Which is the cost of resolving EEOC complaints from employees and job seekers. The argument here is that inaccessible internal systems – like portals, HR systems, development environments and the like – and external job posting and application systems are core part of people executing or getting a job. If these systems are inaccessible a reasonable argument can be made that an organization is discriminating against employees with disabilities. For most organizations this tends to be a minor driver for implementing accessibility is not something that we are going to discuss extensively today. The primary goal of an accessibility program is to optimize the tradeoff between the cost of implementing accessibility and the risk to an organization. In other words how much risk are you willing to take that you will receive a complaint regarding Section 508 compliance? The core challenge in accessibility is determining the appropriate amount of risk to eliminate and keep. That allows us to optimize the tradeoff between budget and risk achieving an optimal level of compliance within a reasonable budget and timeframe .
- US Revenues All US Federal Government agencies and funded organizations must build and procure accessible EIT Many US State Governments (42%) have Section 508 like requirements Education providers have similar accessibility requirements under ADA and IDEA Companies in highly regulated industries often require accessibility in their IT purchases Bottom line while Section 508 is applicable to the US Federal Government directly it serves as a basis for many other industries. This is inline with the original intent of Section 508 which focused on having EIT accessibility be a government lead initiative. International Interestingly enough this has also had an impact outside the US particularly in the EU. The EU i2010 guidance requires member states to pass legislation requiring the purchase of EIT –much like Section 508 - by this year – most already have Many G20 members have legislation like Section 508 in place or on track for deployment UN Convention on the Rights of Persons with Disabilities requires accessible information technology purchases by public sector organizations and has over 100 signatures to date So while you are thinking about this specifically for your organization it can be nice to know that the US has had a major impact in this areas globally over the last ten years.
- Litigation risk is the potential costs to an organization from Section 508 complaints, ADA litigation and related and retrofitting costs. The costs include lawyer fees, time lost to address the issues of the case, direct costs from damages in the case and the cost to retrofit the site into compliance. Collectively these direct and indirect costs are significant and on the order of 15M for a general high volume site. US Federal Agencies face risk roughly correlated to their transaction volume and public profile. Transaction volume would be a weighted measure of the number of discrete transactions with constituents executed on the site. The public profile relates to the focus of your public site – either general public or specific user. General public focused sites bear more risk than specific use sites. Average damages and fees awarded agreed to by a defendant to settle a class action lawsuit - $6.7M Complaints and litigation have started to rise in recent months. Cases frequency has doubled in the last year and complaint are up a similar amount. Bottom line if you haven’t received a complaint yet you will in the near future. Settlement References http://lflegal.com/category/settlements/ http://www.dralegal.org/cases/index.php http://www.dralegal.org/cases/private_business/nfb_v_target.php http://www.dralegal.org/downloads/cases/tucker/exhibits/Exhibit_S.doc http://www.dredf.org/ http://www.ag.ny.gov/media_center/2009/sep/sep1a_09.html
- WCAG ( International ) The World Wide Web Consortium (W3C) publishes the Web Content Accessibility Guidelines (WCAG) The WCAG has two versions 1.0 (1999) and 2.0 (2009) These form the basis of most Web accessibility standards including Section 508 In general it makes sense to think of the WCAG A and AA requirements as a super set of the Section 508 requirements. So think of Section 508 as the core set of accessibility requirements – generally the minimal level of compliance you would target – and the WCAG 2.0 A and AA as the maximal set of compliance. The level of compliance that makes sense for your organization will generally lie somewhere between these two extremes. Section 508 ( U.S. ) The current Section 508 standards are based on the WCAG 1.0 standards but are structured around technical, functional and support requirements The Section 508 refresh standards are due in 2010 and will maintain a relationship with WCAG Conformance to all standards requires both technical and functional compliance Application As a general rule of thumb US Public Sector organizations generally require Section 508 compliance for internal development and procurements. US private sector organization and organizations - public and private – operating in the EU require WCAG 2.0 Level A and AA conformance.
- There are three questions that you have to be able to answer in the affirmative if you are to be considered compliant? Did we write the application in a fashion that conforms to the coding requirements in the relevant standards? ( Technical Requirements ) Can people with disabilities using the application complete the core tasks of the application? Alternatively, does the application as a whole produce an accessible experience? ( Functional Requirements ) Is the deployment context of the application accessible? Does the information, documentation, support and training produce an accessible experience? ( Support Requirements ) Technical Requirements Automatic tests are requirements that can be tested for automatically with a high degree of certainty. Automatic testing can cover around 25% of applicable accessibility requirements the rest of which need to be tested manually or globally. Automatic tests generally don’t allow you to full determine compliance with the laws, f or example: Tools can test for the presence of alternative text but not if the text is a meaningful replacement Tools can test for the presence of form field labels but not if assistive technology users can fill out a form Manual testing relates to the issues that can be validate on a page-by-page (module-by-module) basis but can’t be validate across the entire application. All requirements that don’t fit the automatic profile are by nature manual requirements. Global testing relates to the issues that can be tested once or a small number of times and extrapolated across the entire application Things to think about when determining technical requirement testing coverage: What automated testing tool do you currently have in place? Do you have a checklist in place for global and manual testing? How long and detailed is the checklist? How do you store the results for your global and manual testing? Functional Requirements Functional requirements have to do with the usability of the system by individuals with disabilities. Technical requirements focus on the trees – functional requirements on the forest. Things to think about when determining technical requirement testing coverage: What individuals with disabilities do you use to test applications? Do you have individuals who are blind testing your application with JAWS 10? Window-Eyes 7? How do you capture new requirements as they are found in functional testing? AN APPLICATION MUST CONFORM TO BOTH THE TECHNICAL AND FUNCTIONAL REQUIREMENTS TO BE COMPLIANT Support Requirements Is the documentation of the application accessible? Do I have means of providing accessible support for the application? TTY / TDD? Accessible online chat? Is the training that supports the application accessible?
- Full compliance is the set of all best practices that apply to an organization based on relevant standards, technology and assistive technology requirements. Generally targeting full compliance is not cost effective and it is almost always way more cost effective to develop a specification that is a sub-set of the standards rather than the full standards. For example, if we choose Section 508 standards with the Web, Flash and PDF technology platforms we would have about 450 best practices in our specification. Generally speaking we could deploy a sub-set of these – in the example about 40% – without having a negative impact on the overall compliance of the application. This would allow us to achieve the same level of compliance but at 60% cost savings. Optimal compliance is this subset of best practices – those that provides a reasonable tradeoff between budget and risk. Conceptually by picking that sub-set appropriately we can still achieve a high degree of compliance but we can do so with a much lower cost of implementation. We can do this because the majority of accessibility requirements under any given standard set will not be applicable given our user interface design choices, technology choices, AT support requirements and generally what the market is requiring. The only cost of this approach is that the definition of optimal compliance will change over time based on litigation, legislation, technology and underlying accessibility support of the system. So we have to have infrastructure and systems in place to handle these updates. Once we have the optimal compliance specification developed we use this to development our development and quality assurance specifications as well as our training materials.
- SSB’s solution is broken down into two pieces: SSB’s Accessibility Management Platform (AMP) is a web-based platform for the implementation and management of accessibility across an enterprise. AMP provides the operating system for accessibility and gives you all the underlying infrastructure you need to address accessibility. This is primarily focused on provisioning your team to implement the three key compliance activities: Auditing – Ability to complete formal and informal accessibility audits Training – Ability to show best efforts to train team members via online, self-paced courses and certification curriculums Standards Management – Ability to manage compliance across time, standards and technology AMP is generally deployed with SSB’s Implementation Support which provides the support services needed to rapidly implement accessibility enhancements. Implementation Support provides support for your accessibility initiative and focus on four key areas of accessibility: Testing – Formal and informal testing of systems for accessibility Accessibility Help Desk – Responses to technical questions related to standards, best practices, Assistive Technology usage and other accessibility issues Training and Standards Customization – Ongoing maintenance and definition of optimal compliance across training and best practice reference manuals Production Monitoring – Accessibility monitoring for key client assets AMP provides direct access to the same system that SSB uses to deliver all are accessibility consulting services. AMP is in daily use by the largest accessibility consulting firm in the world which ensures that you will have instance ongoing updates to all content in AMP including best practices, rule sets, tests and training content in AMP. In practice this also means that everything we can do as an external accessibility consultancy you have the ability to do internally at your organization using the same infrastructure and processes that we have in place at SSB. The question that is why would we use SSB to accomplish any of these things externally if we can do everything in AMP? In general the reason most organizations choose to use a mixture of AMP and Implementation Support is that it is the most rapid way to address accessibility. While you could train internal staff on all the best practices present in AMP, on the complex assistive technology testing processes and on the interpretation of standards generally this is not cost effective to do across an organization. So SSB’s focus is on ensuring that all the items it is cost effective for client organizations to address can be addressed internally. For those items that are not cost effective for your organization to address internally – generally those items found in Implementation Support - you can utilize SSB as a low cost immediately available resource.
- This demonstration is a quick, fifteen minute demonstration of AMP.
- The testing process is broken down into three key phases – Groundwork, Testing and Reporting. The Groundwork and testing phases have two tracks – normative testing which validates the application against a set of best practices and functional testing which validates the overall use of the application. Groundwork - During the groundwork phase, the actual portions of the system that are identified and prepared for the different forms of testing that are performed by SSB. The testing scope includes two key components - the module list and the use case list. The modules that are selected are a "representative" set of interface components - pages, screens, visual components, controls, etc. - that are found in the system. These are the modules that will be tested with SSB's exhaustive automated, global and manual testing methodology which collectively defines our normative testing approach. The use cases reflect a representative set of "core tasks" that are performed by users of the system. Each use case is formally scripted to define the sequence of steps that the user performs to complete that task. These are the core tasks that users with disabilities will test with the leading assistive technologies. The lists of modules and use cases are somewhat independent of each other, but the most important or complex features of the system will be reflected in both lists. Testing - Once the lists of modules and use cases have been finalized by SSB and approved by the client, our team will test the system using SSB's proprietary methodology. The testing is broken into two broad categories. Normative testing utilizes automated testing tools where they are viable, global issue review and manual testing. The Normative testing approach general maps to the Section 508 technical standards previously discussed. Functional Testing includes testing by individuals that are blind or disabled using the leading assistive technologies. This functional testing approach generally maps to the Section 508 functional requirements previously discussed. In this fashion we can determine both the technical and functional compliance of the application in one testing process. Reporting Analysis - After the completion of the testing phase SSB's testing team will cross-validate the manual, use case, and automated testing results and synthesize them into a single compliance data set. The data set will then be analyzed for violations that occur in patterns as well as in isolation, and will map specific violation descriptions against the modules on which each was found. The analysis phase also translates the large amounts of raw data produced in the testing phase into a clear, concise, prioritized set of recommendations. This ensures that recipients of the report receive not just a list of issues but a prioritization defining what issues are most important to address first. Delivery – Finally SSB presents the report online or onsite to all relevant stakeholders across applicable functional groups. This presentation serves to raise awareness of compliance within the product groups and allow for the clarification of report findings across all affected functional groups.
- SSB will customize standard course content to optimize the amount of training material client stakeholders must be trained on. The goal of the training courses is to ensure that client organization has the knowledge in place to ensure its sites and applications are compliant with the U.S. Section 508, WCAG 2.0 A and WCAG 2.0 AA accessibility requirements. The courses will provide both a baseline level of accessibility knowledge and a framework for maintaining and updating that knowledge on an ongoing basis. This will ensure that after the training the client will be able to develop and audit against the relevant accessibility standards independent of a third party. To create the courses SSB will use current course content, published as part of the Accessibility Management Platform (AMP), as the basis for the final courses delivered to the client. These courses will be customized and extended to conform to the target set of courses provided to the client. The customization will focus on removing requirements that are not relevant to the client based on the results of (i) previously performed audits of client systems, (ii) sample testing of client systems and (iii) global violation frequency rates stored in AMP. The customizations will ensure that the training benefits from SSB’s extensive accessibility auditing experience and five million accessibility issues escrowed in AMP. In whole, these customizations allow the training to be organized around the minimal set of requirements that any given role must be trained on that - in practice - can guarantee compliance with the relevant accessibility standards. Such a minimalist approach is one of the most effective ways to ensure accessibility compliance while minimizing budget and time expenditures. Once a minimal set of requirements has been developed SSB will publish these in the form of course reference manuals and customized course content. Secondary customizations will occur in PowerPoint and Word and focus on providing code examples and best practices relevant to the client. This content is then reviewed with client stakeholders to approve primary content and prepare a candidate set of training material. Each training course is coupled with a separate certification tests that validates a basic level of trainee’s comprehension regarding the course content. These certification tests are used to validate best efforts on the part of an organization to train all stakeholders on a baseline level of accessibility knowledge appropriate to their role.
- There are two key next steps for customers after going through this accessibility overview. The first next step is to schedule some time to discuss the needs of your organization with one of our industry consultants. This will allow you some time to speak with someone in SSB that is an expert in your particular industry and has the depth of experience to determine if and what accessibility solutions may be right for you. The second next step is to schedule a more formal and in-depth look at AMP. This is a web based training session SSB provides for free to organizations that are testing and have deployed AMP.