IITAA Update 2017

On January 9, 2017, the U.S. Access Board released the final rule updating the Section 508 Standards and harmonizing them with the World Wide Web Consortium's Web Content Accessibility Guidelines (WCAG) 2.0, with an effective date of January 18, 2018. In accordance with the IITAA Standards Update Workgroup recommendation, the State immediately began the process of updating the IITAA Standards to match.

As outlined in the Act, the State convened a working group of State entity representatives, stakeholders, and other appropriate individuals and officials to advise and assist in the process of reviewing and amending the IITAA Standards: 

• Matt Allen, Department of Innovation & Technology
• Nate Argo, Southern Illinois University/Illinois workNet
• Shirisha Balusani, University of Illinois
• Diana Baranzelli, Department of Transportation
• Christy Blew, University of Illinois
• Ray Campbell, United Airlines
• Craig Carpentier, Department of Innovation & Technology
• Krystal Connolly, Illinois Assistive Technology Program
• Jason Crotchett, Illinois School for the Visually Impaired
• Pawel Czarnota, University of Illinois as Chicago
• Michelle DeYoung, Microsoft
• Vance Dhooge, Illinois Assistive Technology Program
• Andrea Finn, Department of Innovation & Technology
• Elena Forster, Department of Human Services/Blind Services
• Todd Goetz, Department of Innovation & Technology
• John Gordon, Department of Human Services/Blind Services
• Corey-Anne Gulkewicz, Department of Human Services
• Jon Gunderson, University of Illinois
• Willie Gunther, Illinois Assistive Technology Program
• Keith Hays, University of Illinois
• Art Hermes, Department of Innovation & Technology
• Ed Holt, Department of Innovation & Technology
• Matt Housewright, Western Illinois University
• Rita Howells,
• Nicholas Hoyt, University of Illinois
• Teri Karpman, University of Illinois
• Jeanne Kitchens, Southern Illinois University/Illinois workNet
• Mike Kramer, University of Illinois
• Lori Lane, University of Illinois
• Nick Langley, Illinois School for the Deaf
• Dan Lorenc, Department of Innovation & Technology
• Patricia Malik, University of Illinois
• Mike McIntyre, Department of Innovation & Technology
• Marla McKinney, University of Illinois
• Jeremy Merritt, Western Illinois University
• Daniel Miller, Department of Innovation & Technology
• BJ Moore, Department of Innovation & Technology
• Lisa Morgan, Human Kinetics
• Dawn Moushon, Department of Human Services/Blind Services
• Tim Offenstein, University of Illinois
• Edwin Ostos, Illinois Assistive Technology Program
• Tim Payne, Illinois Commerce Commission
• Janet Peters, Great Lakes ADA Center
• Nate Porter, Department of Innovation & Technology
• Serena Preston, Illinois School for the Visually Impaired
• Kevin Price, University of Illinois as Chicago
• Ganapathi Ramaswamy, Department of Human Services
• Melissa Romanotto, MSF&W
• Chris Scheufele, Southern Illinois University/Illinois workNet
• TJ Schlouski, Illinois Assistive Technology Program
• Suellen Scoby, University of Illinois
• Mike Scott, Department of Human Services/Rehabilitation Technology
• Bill Seagle, Department of Innovation & Technology
• Vickie Simpson, Department of Innovation & Technology
• Brad Smith, Illinois Commerce Commission
• Daniel Szajna, University of Illinois
• Kim Tarkowski, Blind Services Planning Council/LIFE CIL
• Dan Thompson, Blind Services Planning Council
• Joel Turner, Department of Innovation & Technology
• Andrew Webb, Blind Services Planning Council/Equip fo Equality
• Barry Wiser, Illinois School for the Visually Impaired
• Reuel Wright, Illinois School for the Visually Impaired
• Nathan Zak, MSF&W

• Jon Gunderson, University of Illinois 7/12/2017 12:56 PM -- I would like to reaffirm the other comments related to training. Training will be critical to making real changes to accessibility and helping people get the knowledge and experience they need to be confident in the accessibility of the products and services their company or organization provides. I think we should explore some type of certification of people with skills in accessible design, development and quality assurance. This would give employers the ability to evaluate and advertise for people with accessibility skills.    
• Jon Gunderson, University of Illinois 7/12/2017 12:51 PM -- I would like to see some type of ongoing working group to discuss and update the techniques for implementation of IITAA. This working group ideally should consist of representatives of industry, government and education. This group could maybe also work on providing guidelines on processes and procedures to assess accessibility of products and services.            
• Ed Holt, DoIT Web Services 6/22/2017 10:47 AM -- After reading the new draft version of the Standards how would social media be impacted? As agencies move more and more toward social media for communication how would the proposed standards impact social media? Do we need to clarify using social media tools and posting on non-government sites? I would assume it would since it is public facing and used by agencies. There are many social networking sites that the public uses, and while those sites may not be accessible, agencies may want to use them to provide information and engage with the public. [Editor's note: The Access Board does intend and believe that social media falls under "public facing."]
• Reuel Wright, Illinois School for the Visually Impaired 6/9/2017 8:53 AM -- I think we are on the right track. There seems to be a consensus of agreement on most of the above questions. I feel, as many others do, that there should be a position or person at each institution (department, agency or location) charged with the responsibility of promoting and monitoring progress on accessibility. Without accountability and timelines, the accessibility concerns at many locations will not improve significantly. One thought I have would be for the IITAA committee to establish a reporting page, such as this one, and require each entity to enter periodic (perhaps quarterly) reports on accessibility improvements at their location. This would help insure that someone examines this on a periodic basis, and even if there is no movement at a location, it would be posted for all to see.      
• Diana Baranzelli, IDOT 6/2/2017 11:45 AM -- I am very interested in the U of I Information Accessibility Design & Policy Certification as a training tool readily available. However, the Admission Requirements require individuals to hold at least a bachelor's degree. This will severely limit the potential SOI candidates - any thought to eliminating this admission requirement?             
• Nate Argo, SIUC Center for Workforce Development 6/1/2017 12:45 PM -- Firstly, it would be very useful as a developer to know exactly what is required (and under what circumstances it is required), and then what can be done in addition to that to enhance the "bare minimum" experience (i.e., a "required", "recommended", "optional" scale of implementation guidelines). Secondly, methods for testing the implementations are important. Automated testing can only cover so much, and tends to give faulty results in edge cases. Some form of training or guidance (even something as simple as a "how-to" guide) meant for non- or semi-technical testers who may not necessarily be developers will be great for knowing whether or not the standards have been truly met. Thirdly, if possible, it would be very useful (especially for the testers) to have a reasonable idea of what tools to expect people to use and be familiar with. For example, are there well-known browser tools (built-in or as extensions) that are commonly used to assist blind users, or does additional software installed alongside the browser tend to be the norm? It's not useful to make uninformed guesses as to what tools people with disabilities may or may not already be accustomed to using. This can also benefit the users themselves, as such tools can be recommended to them in cases where they are not already in use.
• Shirisha Balusani, University of Illinois 6/1/2017 9:02 AM -- Yes, IITAA should be harmonized with WCAG 2.0 and WCAG 2.1. As Section 508 is harmonized with WCAG 2.0, referring to WCAG 2.0 standards is preferred. It should be a more understandable way by including success criteria, techniques, and some working example. The content should be brief and simple language. we can improve compliance through enforcement and training.     
• Ray Campbell, Illinois Council of the Blind 6/1/2017 10:10 AM -- Some thoughts on education, monitoring and enforcement of IITAA compliance. Each state agency should have someone on staff responsible for IITAA compliance, an IITAA coordinator. That person's job should be to make sure that the agency is developing web content, procuring equipment, and taking other steps to be IITAA compliant. Not only will this help the public better access state services, but it will also result in more state employment opportunities for individuals with disabilities. State agencies updating web content should be required to use tools that at least encourage and perhaps force creating content that is accessible. For example, if content management systems are used, they should force the user to enter some kind of alt text when they put up an image, either a description of the image if needed or a null alt tag. Periodically, agencies should run automated tests on website content utilizing tools such as those developed by the University of Illinois to make sure they remain in compliance. Finally, the Department of Innovation and Technology should be the agency responsible for evaluating IITAA compliance across digital channels. This needs to be seen as an essential part of quality assurance. They can employ individuals with expertise in analyzing and documenting accessibility issues, or contract with consulting companies which provide audits of digital accessibility with expertise in evaluating accessibility and usability for individuals with various types of disabilities. Several companies including the Paciello Group, www.paciellogroup.com, SSB BART Group, www.ssbbartgroup.com, Tech for All, www.tfaconsulting.com and SPR Technology Consulting, www.spr.com can provide expert auditing of digital content as well as recommendations on how to improve its accessibility. In the interest of full disclosure, I worked for SPR and assisted in evaluating the website of a large transportation entity for accessibility. Perhaps, this could be a project for our own esteemed university system to take on, providing educational opportunities around accessibility.    
• Keith Hays, University of Illinois 6/1/2017 9:30 AM -- We should harmonize IITAA with Section 508 and WCAG 2.0. This will accomplish two things: - By keeping us in sync with federal law, it will be less confusing for accessibility professionals Illinois to meet legal accessibility requirements. - Entities in Illinois can work with those in other states to leverage collective pressure on vendors to include accessibility support in their products. For the most part, it would be good to simply refer to Section 508; however, there may be points where further delineation would be helpful. In the end, the IITAA standards should remain streamlined and read as a complement to Section 508. We should make available techniques and other reference guidelines to assist in compliance; however, they should be non-normative (like the techniques for WCAG 2.0). As with the WCAG 2.0 sufficient techniques, the techniques and guidelines should explain why a certain technique should be used as well as how to implement it. Code examples should be included where appropriate and necessary. Reference guidelines should approach accessibility from varying skill levels and roles. For example, what does leadership and management need to know at an organization to be successful? What do developers need to know? Someone new to IT accessibility? Etc. Accessibility compliance could be considered from a public health model, with both preventive and corrective approaches. Preventive approaches should include multiple modes of outreach for awareness raising and training. Corrective approaches would include monitoring and enforcement, but it should also include training and approach--at first--from a standpoint of lack of awareness rather than willful non-compliance. More stress should be placed on preventive approaches until it is clear that awareness is sufficient to expect compliance. Use surveys and other data gathering techniques to determine if the balance is right and adjust accordingly.
• Tim Offenstein, University of Illinois 6/1/2017 9:24 AM -- In retrospect from our meeting this morning and in addition to Jon Gunderson's comment about Training, I wanted to add two extra bullet points. Jon has authored a "badging" program that is available to anyone. And, the U of I offers a course through Applied Health Sciences, titled Information Accessibility Design and Policy (AHS-494). It is an extensive set of three 8-week courses that provide a comprehensive overview of accessibility. Both of these certificate programs have a cost but they are excellent opportunities for training.
• Dan S, University of Illinois 6/1/2017 9:17 AM -- Should we harmonize IITAA standards with the new Section 508 standards, WCAG 2.0, WCAG 2.1, something else? From a procurement perspective we will be much more successful if we harmonize with Section 508 and WCAG 2.0 standards which are commonly known in the industry. If we have unique requirements beyond these common standards then we will be at a disadvantage trying to leverage the collective needs to meet IT accessibility requirements. How would you envision harmonized standards being written? Simply refer to Section 508, copy the language of 508, another way? Keep it as simple as possible, refer to Section 508 but we can also provide examples to help vendors and developers understand the 508 requirements. Do we need techniques or something similar that explain how to implement the standards in a more understandable way? I'll defer to our technical folks to address. Do you have ideas on what techniques should look like? IITAA Implementation Guidelines, WCAG 2.0 Techniques, code examples, etc.? Again, I'll defer to our technical representatives. What are your thoughts how we can improve compliance through outreach, education, monitoring and/or enforcement? By using an industry standard it should help us achieve compliance. Training, education and monitoring are definitely required. To reach vendors for this training, I'd recommend using the various Procurement Bulletins to communicate out training opportunities so potential vendors can participate. (https://www.illinois.gov/ppb/Pages/links.aspx) Also, Jon Gunderson's comment about a certification for individuals responsible for IITAA compliance would be beneficial.
• Ray Campbell, Illinois Council of the Blind 5/31/2017 11:15 PM -- 1. I believe we should copy relevant language both from the new Section 508 document as well as the WCAG 2.0 guidelines, with proper citing. Having the copied language in the IITAA will make it much more efficient for those who need to implement the standard to follow it. 2. We need to provide techniques, code samples and other tools to help developers of content implement the IITAA standards. For those agencies and organizations using content management systems like Drupal or WordPress, we need to have themes or modules created that implement IITAA in any new or revised content. Finally, we need someone in procurement or other agencies dealing with purchasing of services to make sure that if any contracted services to revised websites and/or mobile apps are procured, those bidding on such services have working knowledge on how to implement IITAA.
• Tim Offenstein, University of Illinois 5/31/2017 4:07 PM -- Should we harmonize IITAA standards with the new Section 508 standards, WCAG 2.0, WCAG 2.1, something else? - Harmonization with WCAG 2.0 and the new Section 508 seems the most practical since WCAG 2.1 is still too new. The harmonization will require in depth study of what Section 508's new rules look like. How would you envision harmonized standards being written? Simply refer to Section 508, copy the language of 508, another way? - I like the way IITAA 1.0 did it. Effort was made to explain Section 508 in more functional, plain language with practical application. Mapping to Section 508 and WCAG 2.0 without copying the guidelines should suffice. Do we need techniques or something similar that explain how to implement the standards in a more understandable way? - Pointing to code examples and work that's already been done, such as the W3C pages mentioned by Pawel, would be an efficient method. Do you have ideas on what techniques should look like? IITAA Implementation Guidelines, WCAG 2.0 Techniques, code examples, etc.? - Avoiding jargon and geek speak, while focusing on practical application. As mentioned in #2 above, IITAA 1.0 did a good job of this. What are your thoughts how we can improve compliance through outreach, education, monitoring and/or enforcement? - Training modules for specific techniques through a web application or video - 20-30 minutes - would take some effort to produce but could be useful for educating and training wide audiences.
• Andrew Webb, Equip for Equality 5/31/2017 3:31 PM -- With regard to enforcement, I agree with prior comments regarding establishing an agency or enforcement body that is expressly tasked with receiving, reviewing and acting upon accessibility complaints. The more specific the information that is provided to the public about where to deliver their complaints, the better. Of course agency personnel changes over time so I would not necessarily expect a specific person to be named, but I think that it would be highly appropriate to provide information regarding an office name, website, email address, phone number, etc. Perhaps this information could be posted or linked to all websites and state IT resources going forward. Not only would this give people a clear path to follow in voicing concerns regarding accessibility and compliance, it would hopefully give them leads on which to follow up after a complaint has been submitted, to help ensure that proper action is taken by the responsible administrators in order to resolve issues. 
• Dan Lorenc, DoIT/HFS 5/31/2017 11:32 AM -- re: centralized compliance... Once upon a time? Agency Internal Audit was the 'central' point of contact to mitigate risk.. such a being the 'gatekeeper' for application go-live? I think we even built-in a checklist into the 'old' CMS/BCCS EPM system for the CMS auditor(s)? here's an example: The Internal Audit Division is an independent administrative unit operating internally within the Illinois State Board of Education organization. The Division's mission and purpose is to independently and objectively provide assurance and advisory services directed toward evaluating the effectiveness of internal risk management, control, and governance. These services are designed to add value and improve ISBE's operations, delivery of state educational services, and ensure ISBE's compliance with rules and regulations. Checklist item for ITG gate 5 release might look like what we hold our vendors to ?mm? "4.1. Vendor certifies that information technology, including electronic information, software, systems and equipment, developed or provided under this contract comply with the applicable requirements of the Illinois Information Technology Accessibility Act Standards as published at (www.dhs.state.il.us/iitaa) 30 ILCS 587."               
• TJ Schlouski, Illinois Assistive Technology Program 5/25/2017 10:52 PM -- Thoughts how we can improve compliance through outreach, education, monitoring and/or enforcement? I would like to see if possible a centralized entity be established at some upper management level of a technical services agency that would monitor and enforce IITAA standards. To be the point for reporting, monitoring, and enforcement. I would also like to see if possible with the IITAA update that some type of language be introduced that if compliance is not meet then a set of actions will happen. For example if IITAA compliance is not met then the application/site/document is taken down until it does become complaint.
• Pawel Czarnota, University of Illinois at Chicago 5/19/2017 12:43 PM -- Based on the discussion we had on the last Standards Update meeting, I think we should standardize with both Section 508 and WCAG 2.0 standards since WCAG 2.1 is not yet finalized. I think copying the language would make the document easier to read (we should make it clear if the language comes from Section 508 or WCAG 2.1, or both) and we should have an example on how to implement the standard - maybe placed a link to the example after the standard's text). I am a web developer and for me the most important part (other than understanding the standard) is how to implement it. With limited time and resources, examples speed things up a lot and also learning from examples increases understanding. I think the techniques should look similar to examples on this website: https://www.w3.org/WAI/tutorials/carousels/. To improve compliance, Accessibility offices at each university (agency) could use Webmaster lists to distribute new requirements and hold meetings (maybe quarterly or twice a year) for developers to attend (in person or online) to provide examples, statistics, etc.
• Dan Lorenc, DoIT/HFS 5/18/2017 11:37 AM -- Should we harmonize IITAA standards with the new Section 508 standards, WCAG 2.0, WCAG 2.1, something else? Harmonize with one or several international standards? This should establish the SOI IITAA Policy. How would you envision harmonized standards being written? Simply refer to Section 508, copy the language of 508, another way? Policy - Standard(s) - Procedures (all auditable) - Guideline or Handbook (the meat and potatoes of 'How To') Refer to the section(s) from the policy and/or standard(s).. hyperlink.. that way 'maintenance' is more keeping an eye on the changing international standards, not copy and paste to the State standard? high value, methinks? Do we need techniques or something similar that explain how to implement the standards in a more understandable way? Yes. The implementation 'guides' or 'handbooks' should be written by the ops/dev group based on the maturity of the staff and their toolset and dev process/framework. You might consider hooking into the DoIT Competency Groups: .Net; Web/Mobile; GIS/Spatial; User Interface/Design; Process Re-engineering; Mainframe/Legacy Modernization. Let them integrate the IITAA Policy to the process/operations guides. Do you have ideas on what techniques should look like? IITAA Implementation Guidelines, WCAG 2.0 Techniques, code examples, etc.? No. What are your thoughts how we can improve compliance through outreach, education, monitoring and/or enforcement? Collaboration with development teams? Agency CIO's.. Cluster CIO's? State CIO? no magic, hard work to overlay IITAA on top of changing technologies/dev methods?
• Bill Seagle, CMS 9/3/2010 12:14 PM -- 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.   
• Brandy Thatcher 9/3/2010 9:22 AM -- 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.     
• Kevin Price, University of Illinois at Chicago 9/2/2010 2:35 PM -- 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.    
• Katy Whitelaw, Northern Illinois University 8/25/2010 10:34 AM -- 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.     
• Michael Murphy, DCFS 8/25/2010 9:53 AM -- As a developer, I would like to see a site with code sample & example on what is a harmonized site. Information would then be needed to say/discuss how this can vary based on applications so that whatever systems can be built. How is enforcement for the various department going to happen? I am from/with DCFS but do not represent DCFS in any way. If you want department enforcement, I would assume that more departments would be represented at these meetings. I can tell my DCFS management all day long about your harmonization initiatives, but it will not happen till you travel with this information to Executive management within DCFS and I am sure other departments.

On July 18, 2017, the IITAA Standards Update Workgroup completed and published updated standards that harmonized Illinois' requirements with the revised Federal Section 508 Standards and the World Wide Web Consortium's Web Content Accessibility Guidelines (WCAG) 2.0. Following the 2011 recommendation, the Workgroup also developed a set of "Techniques" to provide easy-to-understand instructions on how to meet IITAA Standards. The updated IITAA Standards and Techniques are available at:

• IITAA 2.0 Standards
• IITAA 2.0 Techniques

In accordance with the Act, and in alignment with the revised Section 508 Standards, the updated IITAA Standards apply to information technology developed, procured, or substantially modified by the State effective January 18, 2018.