Kansas Partnership for Accessible Technology April 8, 2014 Meeting

STATE ADA COORDINATOR REPORT

KPAT ANNUAL REPORT / ACCESSIBILITY STATUS OF STATE OF KANSAS WEBSITES

Accomplishments  Governance  Review of 10 IT project plans under ITEC Guideline 2400A  IT project planning for COTS items and undue burden exceptions to ITEC Policy 1210  Strategic Plan for Improving Management of Section 508 of the Rehabilitation Act  SSB BART Group Recommendations  KEES accessibility  Assistance  Support  AMP administration  Telephone captioning services

Accomplishments  Communication  ITAB  KanCare training  Website  Assessment  AMP assessments  PDF baseline assessment

Planned Initiatives  Governance  Federal updates  Assistance  Training  PDF accessibility resources

Planned Initiatives  Communication  Webmasters outreach / user group  Assessment  Continued use of AMP  More active response to results

Accessibility Status of State of Kansas Websites

AMP Usage  250 Users  53 agencies

AMP Assessment

Assessment Sample  Matches last year’s for direct comparison  63 agency home page domains, as represented in the Agency Contact Listing page of the Communication Directory on the Department of Administration website (with corrections and a few additions)  Spidered each site up to 250 pages  Automated testing

Pages  12,157 pages scanned  11,031 last year  9,845 pages had one or more violations (81.0%)  Up from 8,041 pages (72.9%) last year  ~8% increase in pages with violations

Agencies and Violations  Since last year, 32% of agencies have reduced their number of violations.  Overall violations dropped about 2%, and the average number of violations stayed essentially constant.

Numbers of Violations Δ High Severity Violations 34,470(46%) 43,058(59%) ↑ 25% Medium Severity Violations 9,994(13%) 5,116(7%) ↓ 49% Low Severity Violations 29,758(40%) 24,905(34%) ↓ 16% Total Violations 74,222 73,079 ↓ 2%

Full Assessment  For the first time, a comprehensive assessment  190 agency home page domains, as represented in the Agencies & Associations Listing page on the Kansas.gov website (with corrections and a few additions)  Spidered each site up to 50,000 pages  Automated testing

Pages  385,989 pages scanned  332,475 pages had one or more violations (86.1%)

Numbers of Violations High Severity Violations 1,768,937(55%) Medium Severity Violations 212,193(7%) Low Severity Violations 1,224,632(38%) Total Violations 3,205,762

Most Frequent Violations (by Pages Affected) Best PracticeViolations Percentage of Pages with ViolationSeverityNoticeabilityTractability 1. Ensure the language of a document is set 183,10346% Provide alternative text for images 401,02132% Provide valid labels for form fields 183,73220% Ensure heading elements are properly ordered 177,77612% Avoid unnecessary use of heading elements 700,78110%332

Most Frequent Violations (by Violation Count) Best PracticeViolations Percentage of Pages with ViolationSeverityNoticeabilityTractability 1. Ensure links do not directly target images 823,0908% Avoid unnecessary use of heading elements 700,78110% Provide alternative text for images 401,02132% Avoid the sole use of device dependent event handlers 258,2485% Provide valid labels for form fields 183,73220%1062

Most Severe Violations Best PracticeViolations Percentage of Pages with ViolationSeverityNoticeabilityTractability 1 (T). Provide alternative text for images 401,02132% (T). Provide valid labels for form fields 183,73220% (T). Ensure headers and cells are properly associated 1600% (T). Provide alternatives for server- side image maps 50%988 4 (T). Avoid utilizing sub-tables in header elements 7,0791%935

Most Tractable Violations Best PracticeViolations Percentage of Pages with ViolationSeverityNoticeabilityTractability 1 (T). Provide alternative text for images 401,02132% (T). Provide valid labels for form fields 183,73220% (T). Avoid the sole use of device dependent event handlers 258,2485%872 1 (T). Provide valid, concise, and meaningful alternative text for image buttons 38,76910%682 1 (T). Ensure frame titles are meaningful 51,2308%762 1 (T). Ensure the language of a document is set 183,10346%162 1 (T). Avoid unnecessary use of heading elements 700,78110%332 1 (T). Ensure hr elements utilize relative sizing 1950%422

Assessment of PDF Documents

CommonLook Clarity Scan  First of its kind  124 agency home page domains, as represented in the Agencies & Associations Listing page on the Kansas.gov website (with corrections and a few additions)  Spidered each site without limit  Automated testing

Results  91,814 PDF files scanned  1,032,326 pages  79,873 files failed one ore more of the accessibility checks (87.0%)  58,828 files were found to be untagged (64.1%)

PDF ACCESSIBILITY / COMMONLOOK

CommonLook Office & CommonLook PDF Recap:  PDF accessibility tools  CommonLook Office is for non-technical content creators using Microsoft Office (specifically, Word and PowerPoint)  CommonLook PDF is for more technical users who need to tag existing PDFs using Adobe Acrobat Professional  After trial evaluation, we decided to ask agencies to estimate the number of potential users to determine available pricing.

CommonLook Office & CommonLook PDF  32 agency responses amounted to 945 estimated potential users of CommonLook Office, and 215 of CommonLook PDF.  Based on this, NetCentric offered a proposal of:  $157, for 500 licenses of CommonLook Office, or $ per license  $152, for 200 licenses of CommonLook PDF, or $ per license

CommonLook Office & CommonLook PDF  Asking agencies to affirm or revise their interest in light of this pricing, I received 9 agency responses amounting to 10 licenses of CommonLook Office and 8 of CommonLook PDF.

CommonLook Office & CommonLook PDF  Standard pricing from SHI:  CommonLook Office:  1 license:$  5-pack:$1,930.00, or $ per user  10-pack:$3,607.00, or $ per user  CommonLook PDF:  1 license:$1,  5-pack:$4,864.00, or $ per user  10-pack:$9,643.00, or $ per user

CommonLook Services  An alternative NetCentric has proposed is their remediation service.  One possibility would be to identify some number of “top” documents for immediate remediation.  As an example, NetCentric looked at one entity and provided a sample quote.  1,383 PDF files; arbitrarily selected “top” 120.

CommonLook Services  Quote for 120 files totaling 826 pages: $11,264 Number of pagesPrice per pageQuote for file Range1–39$6–$125$8–$510 Mean7$21$94 Median6$10$72 Mode1$8$16

CommonLook What should we do?

Matterhorn Protocol

PDF/UA  Recap:  International standard for accessible PDF (ISO ) published August 7, 2012  Technical specifications for developers of authoring tools, readers, and assistive technology  Must be purchased from ISO

Matterhorn Protocol  PDF/UA conformance testing model  Released last summer by the PDF Association PDF/UA Competence Center  Version 1.01 released Friday  Freely available  Intended for software developers and document testers

Matterhorn Protocol  Common set of tests  31 checkpoints comprised of 136 failure conditions  Each checkpoint represents a discrete area of conformance requirements, such as “Declared natural language” or “Metadata”.  Each failure condition defines a specific test.  87 can be determined by software alone  47 usually require human judgment  2 with no specific tests  Some failure conditions pertain to the document, some to the page and most to individual objects such as tags, tables or annotations.

Examples Checkpoint 13: Graphics IndexFailure ConditionSectionTypeHowSee Figure tag alternative or replacement text missing.UA1:7.3-3ObjectMachine- Checkpoint 13: Headings IndexFailure ConditionSectionTypeHowSee Headings are not tagged.UA1:7.4-1DocHuman01-006

Matterhorn Protocol  Matterhorn Protocol 1.01   Press Release 

STATUS UPDATES

WAI-ARIA 1.0  On March 20 Accessible Rich Internet Applications (WAI-ARIA) 1.0 was published as a W3C Recommendation.  WAI-ARIA is a technical specification for making dynamic, interactive Web content accessible to people with disabilities.

WAI-ARIA 1.0  Press release   W3C blog post “WAI-ARIA Expands Web Accessibility”   WAI-ARIA Overview   WAI-ARIA 

Section 508 Refresh Federal ICT Standards and Guidelines  On February 23, the U.S. Access Board submitted a proposed rule to update the standards and guidelines to the Office of Management and Budget (OMB) for review.  OMB has 90 days to review the rule (i.e., until May 24).  Once cleared by OMB, the proposed rule will be published in the Federal Register and will be available for public comment for a specified period of time. 

Section 508 Refresh SSB BART Group speculates:  NPRM could be released this summer  There may be a 60-day comment period (instead of 90)  Final rule may be issued by the end of the year 

DOJ ANPRM Accessibility of Web Information and Services of State and Local Governments  Listing in the Fall 2013 Reginfo.gov agenda changed the date for NPRM from unspecified November to unspecified December. 

Window-Eyes for Office  In January, Microsoft and GW Micro announced an offer providing the Window-Eyes screen reader free of charge for licensed users of Microsoft Office 2010 or  Offer site   Microsoft Accessibility Blog announcement   Microsoft Office Blog announcement   GW Micro announcement 

AMP Releases  AMP was (belatedly) updated to the Fall 2013 Release last month.  Minor maintenance update  Spring 2014 Release announced last week, launches tomorrow  Features to include:  Customizable dashboards  Navigational improvements  Statistics  Overall system performance  Will preview on our staging server, instance will be updated when accepted  Announcement and info at  Recording of preview webinar at

KPAT Website  March 26, a new version of the KPAT website was launched.  Part of full OITS website refresh  New design  Now on Sitefinity CMS  Checked with AMP  Still at  Please let me know if you notice anything amiss!

SSB BART GROUP RECOMMENDATIONS

Recap  SSB BART Group process audit recommendations discussed previously:  Implement a Best Practices-Driven Approach to Meeting ITEC 1210 Compliance  Implement a Vendor Certification Process  Require Vendor Submissions of Due Diligence  While the second is not something we’re prepared to pursue at this time, more information was requested on the other two.

Best Practices-Driven Approach SSB BART Group response clarifies that recommendation is to include accessibility best practices in the WCAT, exactly as proposed last time.

Vendor Due Diligence This recommendation is to request or require the vendor to submit any accessibility test results. “The State should consider periodically requesting the results of internal accessibility testing conducted by the vendor. This allows the State to identify potentially inaccessible areas of the application in advance and prepare for the possibility of providing reasonable accommodations and mitigate any potential undue burden requests. This also allows the vendor to document due diligence towards compliance with ITEC 1210.”

2014 TOPICS AND INITIATIVES

Seeking Suggestions from the Membership  What should be the next areas of focus for the KPAT?  How can we serve the interests of your agency or organization?  What topics would you like to see addressed in future meetings?

OPEN DISCUSSION

Next Meeting Tuesday, July 8, 2014 Time: 2:30–4:30 PM Location: Landon State Office Building Room SW Jackson Street