1. Kansas Partnership for Accessible Technology July 9, 2013 Meeting

2. PDF ACCESSIBILITY / COMMONLOOK

3. CommonLook Trial  Evaluated CommonLook Office and CommonLook PDF  60-day trial  7 webinar meetings with NetCentric personnel

4. Evaluation Team  Administration, Department of  Children and Families, Kansas Department for  CivicPlus  Corrections, Department of  Deaf, Kansas School for the  Governor, Office of the  Healing Arts, Kansas Board of  Office of Information Technology Services  Optometry, Kansas State Board of Examiners in  Revenue, Department of  Treasurer, Kansas State  University of Kansas (Academic Achievement and Access Center, and Bureau of Child Research)  Washburn University  23 people on evaluation team, from 12 agencies/organizations:

5. Trial Outcome  Overall sentiment was positive  Consensus that acquisition for regular use would be desirable  All agreed any purchase should be done collectively for volume discount

6. Proposed Next Steps  Ask agencies to identify—without commitment— potential users of each product:  CommonLook Office, for non-technical content creators using Microsoft Office (specifically, Word and PowerPoint)  CommonLook PDF, for more technical users who need to tag existing PDFs using Adobe Acrobat Professional  Estimated numbers of users of each will determine available pricing  Would like to introduce this inquiry at next ITAB (and follow up by email to reach all agencies)

7. Scan Proposal  In addition to document creation/remediation tools, there is also CommonLook Clarity, the enterprise assessment tool/service.  As was brought up last meeting, we would like to run an enterprise-wide baseline scan, to be paid for from remaining INK grant funding.

8. IT PROJECT PLANNING FOR COTS ITEMS

9. IT Project Planning  Web accessibility review of IT Project Plans under ITEC Guideline 2400A  Web Content Accessibility Statement  Web Content Accessibility Template (WCAT)  Review and approval by Director of IT Accessibility prior to plan submission  Since December 2010  Has worked very well overall, though approach to one type of project might be worth revisiting…

10. COTS Defined in FAR (Federal Acquisition Regulation) 2.101 thusly: “Commercially available off-the-shelf (COTS)” item— (1) Means any item of supply (including construction material) that is— (i) A commercial item (as defined in paragraph (1) of the definition in this section); (ii) Sold in substantial quantities in the commercial marketplace; and (iii) Offered to the Government, under a contract or subcontract at any tier, without modification, in the same form in which it is sold in the commercial marketplace; and (2) Does not include bulk cargo, as defined in section 3 of the Shipping Act of 1984 (46 U.S.C. App. 1702), such as agricultural products and petroleum products.46 U.S.C. App. 1702

11. COTS Items  These are generally items that are installed “as-is”; no customization (read: accessibility remediation) is possible.  There is no ongoing relationship with vendor. Once purchase is made, that’s it.  The closed nature of the product stands in contrast to other types of items, where there is an opportunity to work through any accessibility shortcomings.

12. IT Project Planning for COTS Items  Requiring remediation that is not possible clearly does not make sense.  At the same time, we need to maintain that COTS items are subject to ITEC Policy 1210’s requirements as much as any other type of product.  COTS items cannot be an excuse for noncompliance.  FAR 12.103: “Unless indicated otherwise, all of the policies that apply to commercial items also apply to COTS.”

13. IT Project Planning for COTS Items  Suggestions?  One idea: For COTS items with compliance deficiencies, require justification of COTS choice  Agency must show research determining no customizable or other, compliant COTS product is available that could meet its requirements in order to be granted an undue burden exception.  It’s foreseeable that this will often come down to cost being the reason for choosing a COTS item over custom development. How would this be handled?  Shift narrative from “It’s unduly burdensome to remediate because customization is impossible” (with closed nature a given) to “Here’s why our only available choice is a non-customizable product.”

14. UNDUE BURDEN EXCEPTIONS TO ITEC POLICY 1210

15. STATE ADA COORDINATOR REPORT

16. SSB BART GROUP RECOMMENDATIONS

17. Process Audit  SSB BART Group conducted a process audit of vendor accessibility compliance process methodologies for the KEES project.  Among the recommendations included in the report were some for the state that were not specific to the project.  These are presented for the Partnership’s consideration.

18. Recommendations  Implement a Best Practices-Driven Approach to Meeting ITEC 1210 Compliance  Implement a Vendor Certification Process  Require Vendor Submissions of Due Diligence

19. OPEN DISCUSSION

20. Next Meeting Tuesday, October 8, 2013 Time: 2:30–4:30 PM Location: Landon State Office Building Room 509 900 SW Jackson Street