Section 508: NIH Meeting (July 30, 2008)

Prudence Goforth
Dick Stapleton

Web Communications and New Media Division

Agenda

NIH Web Presence

Section 508: Why Comply?

It’s the right thing to do:

• 28,000,000 people in the United States—approximately 10% of the population—are deaf or hearing impaired.
• 11,400,000 people have visual conditions not correctible by glasses.
• 6,400,000 new cases of eye disease occur each year.
• 2,800,000 people are visually handicapped from color blindness.
• 1,100,000 people are legally blind.
• Add those with dexterity issues and we’re talking 20% of the U.S. population.

And it’s the law.

Letters of Non-Compliance

• WHO:
  • Accessing Digital America (ADA)
  • A non-profit Section 508 advocacy organization
  
  
• WHAT:
  • Determine U.S. government compliance with relevant accessibility standards and statutes
  
  
• WHEN:
  • Survey of federal Web sites began October 1, 2007
  • HHS/OGC received first Letters of Notice in November
  
  

Scope of the Problem

• Initial HHS Web site inventory
  • 1.6 million Web pages
  • 22.4 million 508 issues
    • Average of 14 accessibility issues/page
  • 1 million broken links
    • Average of almost 1 broken link/page
  
  

• May grow significantly as OpDivs submit inventories

• Does not cover attached files (DOC, PDF, PPT, etc.)

NIH Broken Links & 508 Issues

Other NIH Document Types not Scanned: PDFs, WORD docs, ZIP file, PPTs

*Last Scan Date: 5/30/08

Word Myths & Facts

• Myth:
  • Word DOCs are easier for people to use.
  
  
• Fact:
  • Word DOCs require the user have MS Word. (Proprietary software)
  
  
• The Better Choice: Straight HTML
  • Word DOCs should be the choice only when the file needs to be modified by the end user.

PDF Myths & Facts: Signed Documents

• Myth:
  • PDF files necessary to show signature.
  
  
• Fact:
  • U.S. Code proscribes handling signature as text.
    
  
  
• The Better Choice: Straight HTML

PDF Myths & Facts: “Etched in Stone”

• Myth:
  • If I post the file as a PDF, no one can change it.
  
  
• Fact:
  • There are any number of freeware and software apps that alter PDF was easily as HTML.
  
  
• The Better Choice: Straight HTML
  • Use PDF when a formatted document needs to be reproduced by the end user.

Guidance: Making Accessible PDFs

www.hhs.gov/web/policies/pdfaccessibility/index.html

Tools: Adobe Acrobat Pro
Essential for making compliant PDFs

• Department standard for creating and/or verifying 508-compliant PDF documents

v9 released June 26

Tools: Adobe Acrobat Pro v9
Who needs it; How to buy it

• Single licenses are available through NIH
  (www.cdwg.com/dhg).
• Both v8 and v9 being shipped until v9 is onto approved software list
• Upgrade vouchers for v8 copies bought after 5/ 1)
• Not required on every desk top
• But needed by everyone who regularly creates PDF files for Web (or email sharing)
• Some offices may consolidate 508 PDF function

Tools: CommonLook

Supplement to Adobe Acrobat Pro (advanced tool)

• Valuable for tagging complex tables and other non-textual content
• Steep learning curve
• Limited need

Tools: JAWS / Window Eyes / ZoomText Screen Reader (Testing PDFs)

Window Eyes Easy to use ($895 retail) Inexpensive Best for forms
ZoomText 2 Magnifier/Reader ($595 retail) Less expensive Easier to use Will catch all errors
JAWS ($1,095 retail) Not the easiest to use Too smart! (corrects some errors w/o reporting) Available on GSA Schedule, contract number GS-35F-0330J ($866.15)

Tools: HHS 508 Lab

• Available to offices/programs lacking access to 508 remediation or testing tools
• Available for training
• Equipped with all major tools
  • Adobe Acrobat Pro
  • CommonLook
  • Window Eyes (soon)
  • JAWS
  • ZoomText
  • Policy Tester (soon)

All Videos Must Be Captioned

Quick: What’s the Most Visited Page on HHS Web Sites?

Broken Links: What To Do

• Try to fix it
  • Check the URL for typos (rare)
  • Try to find the appropriate page or file being linked
  
  
• Delete it or comment it out
  • Record the link
  • Notify the page owner
  • Reinstate if replacement link is found
    • >10% ever get replaced

508 Compliance: Clean Out the Basement

Archive Outdated Content
508 Exempt!

Header:

Footer:

508 Compliance: Clean Out the Basement

This is your very best friend.
Use it wisely.
Use it a lot.

• Eliminate old PDFs and DOCs
• Eliminate PowerPoints
• Eliminate old videos, Webinars & podcasts
• Ask yourself, “Is retaining this content worth the cost of making it 508 compliant?”

Unapproved Domain Names

Web Inventory

508: Contracting Language

• Acquisition policy provides language applicable to Statements of Work (SOW) or Performance Work Statements (PWS)
• Covers all Web sites & content for Web sites
• Covers communications materials including reports, documents, charts, posters, and audio or video materials
  • Placed on a department-owned or department-funded Web site
  • Intended for public or internal use

508: Grants Language

• Working with Grants Administration

• Develop language applicable to all grantee products

• Section 504 currently applies
  • Ambiguous
  
  
• We will require Section 508 compliance
  • Definable, measurable standards
  
  

508: HHS Guidance & Standards

http://www.hhs.gov/web/508/index.html

508: “Accommodations”

• Provide on-demand access
  • Braille
  • Large type
  • Someone reads the content
• Web Council Committee to determine guidance
  • Document size
  • Document Complexity
  • Potential demand for content
• On-demand accommodations has its own cost
  • Contract service

508: “Accommodations”

• Provide access to help on file-by-file basis
  • Approval required from WCD before doing this

508 Compliance & Remediation (C&R) Plan

Five-year Phased Approach

• C&R Framework developed collaboratively
  • Issued 04/08/08 to all OPDIVs/Staff DIVs
  
  

• All new sites & files must be compliant when posted

• Remediation addressed over 5-year period
  • Recognizes budget and workload constraints
  • Established priorities
  • WCD believes this is defensible

508 Compliance & Remediation

Plan Implementation Priorities

• Web infrastructure (html code)
• Demand (most viewed or downloaded)
• Interactivity (forms and training)
• Agency/OPDIV mission critical
• Disabled audience specific

What’s Next?

• Stay focused when dealing with 508 issues
  • 508 is the law; we must comply
  • 508 is the right thing to do
    • Serving the disabled is integral to HHS mission!
• Review your business processes – build in compliance and maintenance [all contracts]
• Prepare to be brutal with your Web
  • 20% of your pages do 90% of your work
  • 25% of your pages do nothing
  • Delete or archive non-compliant legacy content!

508 Compliance & Remediation
Site Cleanup

• One major cornerstone of remediation is the removal of expendable Web sites and legacy files
  • Deleting obsolete sites and content
  • Archiving dated sites and content
  • Eliminating orphan sites
  • Removing duplicate content or pages
  • Consolidating disorganized content
• Is this page/site/file worth the cost of remediation?

508 Standards/Guidance

The following standards are planned or in development:

• Alternative Text/Long Description
• Audio *
• Excel Files
• File Formats and When to Use Them
• HTML Tables
• Converting Scanned PDFs to OCR **
• How to Use Watchfire Policy Tester *
• Image Maps *
• Interim Approval for Non-Compliant Documents
• Making PowerPoint 508 Compliant
• Plug-ins
• Regulation and Federal Register Notices
• Skip Navigation – Standards and Policy
• Compressed Files *
• Managing Old Content *

* Out for comment
** Not started

508 Training Course Development

• Testing Document Accessibility
• Creating Accessible Word Processing Documents (and email!) I & II
• Creating Accessible PDF Documents I & II
• Creating Accessible Power Point files
• Creating Accessible HTML I & II
• Creating Accessible Excel Files
• Creating Accessible Multimedia
• 508 and Contracting
• Developer Certification

508: Checking Compliance

IBM Policy Tester Formerly Watchfire Has been rolled out to all OPDIVs Training schedule and call-in information at www.hhs.gov/web/508/index.html Not living up to expectations May be replaced Questions: Kristen Kayatta Baldwin kristen.kayatta@hhs.gov

WCD Enterprise-wide Support

• Compliance and remediation management
• Inventory and progress reports: monthly
• Tools: analysis, selection and instruction
• Guidance: step-by-step instructions
• Standards
• Training: 12 modules planned
• Acquisition language/verification assistance
• We are the 508 “Help Desk”

WCD Enterprise Support

www.hhs.gov/web/508

WCD 508 Contacts

• Prudence.Goforth@hhs.gov
  • Director, WCD 202-690-7264
• Richard.Stapleton@hhs.gov
  • Deputy Director, WCD 202-690-7856
• Marsha.Carey@hhs.gov 202-205-0734
• Kathryn.Hambleton@hhs.gov 202-260-1326
  • WCD’s NIH liaisons
• Kristen.KayattaBaldwin@hhs.gov
  • 508 Team Leader 202-690-6713