IITAA Update 2011

The Illinois Information Technology Accessibility Act (IITAA) requires that the State review and update its technical accessibility standards at least once every three years. Since the original IITAA Standards were published in February 2008, the first review of the Standards was completed in February 2011.

Between the publishing of the original IITAA Standards in 2008 and the first review in 2001, the World Wide Web Consortium released a completely revised version of its Web Content Accessibility Guidelines (WCAG) and the United States Access Board proposed substantial revisions to the Section 508 Standards. Because the IITAA Standards were based largely on the WCAG and Section 508 Standards, and because industry groups were pushing for "harmonization" of accessibility standards, the State needed to address the questions of if, when, and how to harmonize the IITAA Standards with WCAG 2.0 and the proposed Section 508 Standards.

To begin the review process, the Department of Human Services re-convened the IITAA Standards Workgroup on August 19, 2010. Forty representatives from 20 different agencies, universities, and advocacy groups participated in the kick-off meeting and teleconference. The primary question posed to the group was whether or not the IITAA Standards should be harmonized with WCAG 2.0 and the proposed Section 508 Standards.

The IITAA Standards Workgroup was convened to considering whether the IITAA Standars should be "harmonized" with the new World Wide Web Consortium Web Content Accessibility Guidelines 2.0 and proposed Section 508 Standards with a goal of making a formal recommendation by September 30, 2010. 

The following considerations were discussed:

Harmonization is the process of aligning standards so that they are identical or as similar as possible. For many years, the Federal government was attempting to harmonize Section 508 with the W3C Web Content Accessibility Guidelines 2.0, and several other countries had already done so with their own accessibility regulations. Industry groups, such as the Information Technology Industry Council, were strong proponents of harmonization.

There were arguments both for and against harmonization:

• For - Vendors who create and sell information technology would like to have a single set of standards to follow. It makes it easier for us to find compliant products and gives us access to a wider range of testing tools and resources.
• Against - Existing standards, including WCAG 2.0 and Section 508, are very general and can be difficult for developers to understand. The current IITAA standards were written specifically to be more understandable/usable by State developers.

The original IITAA Standards covered software, web sites, telecommunication products, multimedia, and computer hardware and consist of three "layers":

1. Functional Performance Criteria - high level goals indicating that IT must be usable by people with different types of disabilities.
2. Technical Requirements - more specific requirements borrowed from the original Section 508 (except for web, which is based on the original Illinois Web Accessibility Standards).
3. Implementation Guidelines - explanations of "what," "why," and "how" for the web-related Technical Requirements.

WCAG 2.0 covered only web-based information/systems but is intended to be general enough to apply to a variety of web technologies (e.g., HTML, PDF, Flash, Silverlight, etc.). It is presented in four "layers":

1. Principles - four high level concepts key to accessibility: "Perceivable," "Operable," "Understandable," and "Robust."
2. Guidelines - twelve slightly more specific guidelines on how to make information accessible (e.g., "Provide text alternatives for any non-text content.").
3. Success Criteria - the equivalent of IITAA Technical Requirements, although not technology-specifi (e.g., "All non-text content that is presented to the user has a text alternative that serves the equivalent purpose").
4. Techniques - technology-specific instructions for meeting Success Criteria in different situations (e.g., "When using the img element, specify a short text alternative with the alt attribute"). Techniques can be added and updated at any time.

Developers comply with WCAG 2.0 Success Criteria by implementing applicable Techniques.

The Section 508 draft covered software, web sites, telecommunication products, multimedia, and computer hardware, and included two levels:

1. Functional Performance Criteria - the same as IITAA Functional Performance Criteria with a few additions.
2. Technical Design Criteria - the equivalent of WCAG 2.0 Success Criteria; not technology-specific.

The Federal government was trying to harmonize Section 508 with WCAG 2.0. The Section 508 draft indicated that it would consider a WCAG 2.0 Level AA compliant website to also be Section 508 compliant.

In the draft, the Level A & AA Success Criteria were included primarily in chapters 4 & 5, with a few in 3 & 6. WCAG Techniques were not specifically included.

• The spirit of IITAA, WCAG, and 508 is the same; the differences are in how the standards are written. Harmonizing should not make Illinois' information technologies any less accessible.
• Harmonizing with WCAG and 508 may put us on firmer ground if there was ever a lawsuit regarding compliance.
• Harmonizing would allow us to use automated testing tools and similar resources that are designed for WCAG 2.0.
• There is some confusion about whether conformance would be measured against Success Criteria or Techniques. WCAG documents indicate that only the Success Criteria are "normative," but it appears that only the Techniques are specific enough to test.
• Developers need Techniques in order to know what to implement (and to be able to justify what they have implemented to management).
• Anyone can create additional Techniques; Illinois could select/create a set of Techniques for IITAA compliance.
• WCAG 2.0 has been available since December 2008, but Section 508 may not be finalized for another year. We could take steps to harmonize with WCAG now, or wait until Section 508 is comleted.
• We are already having to deal with new technologies and more changes will occur in the next three years.
• Harmonizing IITAA standards with WCAG 2.0 and Section 508 will make accessibility easier for vendors, less confusing for webmasters, and easier to enforce within organizations and statewide. (Katy Whitelaw, Northern Illinois University, August 25)
  
• I am okay with harmonization as long as we prepare the techniques and tools to ensure compliance in a way most developers can understand. Most developers want to know as specific as possible so there is no grey areas of what accessibility is. I think if we make clear techniques, harmonization is a good idea. (Kevin Price, University of Illinois at Chicago, September 3)
• Harmonizing IITAA with WCAG and 508 makes sense. It should make maintaining and teaching the standards easier. I know as a developer it will be easier to implement one set of standards as opposed to trying to make sure I cover all three. (Brandy Thatcher, Illinois Central College, September 3) 
• I think that we should harmonize with new Section 508 standards, then create our own technical guidelines based around the most common technologies like HTML. (Bill Seagle, Central Management Services, September 3)
• The general consensus of the group is to harmonize the standards at the "Success Criteria" level and then develop a set of "Sufficient Techniques" organized and written to be usable by developers, e.g., like the current IITAA Implementation Guidelines. (University of Illinois Web Best Practices Group)

Based on discussion at the IITAA Standards Update Kick-off Meeting and feedback provided via the IITAA Standards Update web site, the consensus of the Workgroup was to:

1. At a high level, harmonize the IITAA Standards with proposed Section 508 and WCAG 2.0 "Success Criteria."
2. Develop a set of "Sufficient Techniques" organized and written like the current IITAA Implementation Guidelines.

The IITAA Standards Workgroup will monitor progress made by the Federal Access Board on completing revision of Section 508 Standards. Once the proposed changes to the Section 508 Standards seem stable, and the draft of revised IITAA Standards is complete, new IITAA Standards will be drafted and published on the IITAA web site. As specified in Section 25 of the Act, State entities will then have at least six months to review and incorporate the amended standards into relevant policies and procedures.

The Workgroup will simultaneously begin investigation of recommendations to improve outreach, education, monitoring, and enforcement of the IITAA. Meeting details will be emailed to the Workgroup and posted on the IITAA web site.