National Dialogue on Improving the Section 508 Program

Jim Tobias

Member since 1 year ago

Badges

• Top Contributor

11 ideas posted

69 comments 38 votes

502 points View the Leaderboard

Activity Stream

Owned Ideas

Ideas contributed by Jim Tobias

• I agree

  Voting is Disabled

  9 votes

  I disagree
  This idea is active.
  Strengthen Accountability »

  Aim for continuous improvement

  The few longitudinal studies that have been done are pessimistic -- backsliding on accessibility beginning just a few months after an intervention or campaign is the norm, not the exception. New technologies are introduced to sites, breaking their accessibility. The 508 Strategy should include an ongonig evaluation and reporting scheme. Being reviewed every 2 years by DoJ is not going to work, especially when the survey ...more »

  The few longitudinal studies that have been done are pessimistic -- backsliding on accessibility beginning just a few months after an intervention or campaign is the norm, not the exception. New technologies are introduced to sites, breaking their accessibility.

  The 508 Strategy should include an ongonig evaluation and reporting scheme. Being reviewed every 2 years by DoJ is not going to work, especially when the survey changes every time and 2 years becomes 10.

  Once reasonable metrics are agreed upon, why not have a dashboard that can be read by all, indicating where agencies are at? There may be even more value in tracking technologies -- "accessible PDFs are up 8%; captioned videos are down 5%" -- because aside from agency pride, everyone wants to know what to use and what to avoid.

  « less full details »

  4 comments for Idea: Aim for continuous improvement

  Submitted by Jim Tobias 1 year ago

• I agree

  Voting is Disabled

  6 votes

  I disagree
  This idea is active.
  Product Accessibility »

  Scan the technology horizon

  It's common to see a new kind of product emerge and upset the applecart of accessibility, usually without any warning. When the vendor is approached about accessibility, their answer may be, "We'll fix that in the next release." In the meantime, customers are stuck with an inaccessible product. To get out of this reactive mode, how about a project that identifies technologies that are 3-5 years away from the market? ...more »

  It's common to see a new kind of product emerge and upset the applecart of accessibility, usually without any warning. When the vendor is approached about accessibility, their answer may be, "We'll fix that in the next release." In the meantime, customers are stuck with an inaccessible product.

  To get out of this reactive mode, how about a project that identifies technologies that are 3-5 years away from the market? This project would approach standards bodies, R&D labs, and other fonts of innovation, bringing the message of accessibility. It could be a general message, or it could be accompanied by some statement that one or more existing accessibility regulations apply to this kind of product. Either way, the project would follow up with the innovators as the product neared market, and give some assistance to AT vendors and potential early customers as well.

  « less full details »

  3 comments for Idea: Scan the technology horizon

  Submitted by Jim Tobias 1 year ago

• I agree

  Voting is Disabled

  3 votes

  I disagree
  This idea is active.
  Improve Capabilities »

  Harmonize on 508

  Section 508 is unique among federal accessibility requirements in that it gets into a lot of technical detail. The upcoming version will do even more of that, being based on WCAG 2.0 and its interpretations for non-web. Industry correctly argues that having different standards and requirements is confusing and ultimately self-defeating. Wherever possible, federal accessibility regulations (ADA, ACAA, CVAA, 501, 503, ...more »

  Section 508 is unique among federal accessibility requirements in that it gets into a lot of technical detail. The upcoming version will do even more of that, being based on WCAG 2.0 and its interpretations for non-web.

  Industry correctly argues that having different standards and requirements is confusing and ultimately self-defeating.

  Wherever possible, federal accessibility regulations (ADA, ACAA, CVAA, 501, 503, 504, etc.) should refer back to Section 508 -- not in how it's implemented, which needs to be different in different situations and jurisdictions, but in what the technological requirements are. This will increase clarity and enforceability.

  « less full details »

  Add your comment for Idea: Harmonize on 508

  Submitted by Jim Tobias 1 year ago

• I agree

  Voting is Disabled

  7 votes

  I disagree
  This idea is active.
  Increase Transparency »

  Scary spiders

  Lots of federal sites feature videos without captions or description. Why not develop a tool that visits all federal sites, identifies these offending videos, and at least notifies the agency's 508 coordinator about the problem? Other oversight may be necessary. Of course, this should be accompanied by better availability of captioning and description tools, and by agencies purchasing only media creation tools that default ...more »

  Lots of federal sites feature videos without captions or description. Why not develop a tool that visits all federal sites, identifies these offending videos, and at least notifies the agency's 508 coordinator about the problem? Other oversight may be necessary.

  Of course, this should be accompanied by better availability of captioning and description tools, and by agencies purchasing only media creation tools that default to (and nag about) accessibility techniques.

  « less full details »

  10 comments for Idea: Scary spiders

  Submitted by Jim Tobias 1 year ago

• I agree

  Voting is Disabled

  6 votes

  I disagree
  This idea is active.
  Strengthen Accountability »

  Improve product accessibility reporting tools

  Poor VPAT, nobody loves ya. You need a makeover! The refreshed 508 provisions deserve a refreshed reporting tool, one developed by all stakeholders. It could feature: - live, online creation, indexing, and searchability - real-time training for vendors and buyers alike on the meaning of the provisions and any product-category-specific guidance - room to report testing results and workarounds - AT compatibility info, ...more »

  Poor VPAT, nobody loves ya. You need a makeover! The refreshed 508 provisions deserve a refreshed reporting tool, one developed by all stakeholders. It could feature:

  - live, online creation, indexing, and searchability

  - real-time training for vendors and buyers alike on the meaning of the provisions and any product-category-specific guidance

  - room to report testing results and workarounds

  - AT compatibility info, possibly provided by AT vendors

  - open dialogue, featuring user Q&A and even evaluative information

  - [added for the sake of extra unreality] comparative chart of compliance, against competing products

  Add your ideas for accessibility report in the comments.

  « less full details »

  1 comment for Idea: Improve product accessibility reporting tools

  Submitted by Jim Tobias 1 year ago

• I agree

  Voting is Disabled

  19 votes

  I disagree
  This idea is active.
  Strengthen Accountability »

  Build 508 into procurement processes

  As I understand it (and please correct me), including 508 in the paperwork for a given ICT procurement is not an absolute requirement, but more of an option on the part of whoever is doing the purchasing. It should go the other way -- 508 is part of the paperwork unless the purchaser can plausibly state a reason for exemption. Continuing on, every other 508 step should be documented as well, such as requesting a VPAT, ...more »

  As I understand it (and please correct me), including 508 in the paperwork for a given ICT procurement is not an absolute requirement, but more of an option on the part of whoever is doing the purchasing. It should go the other way -- 508 is part of the paperwork unless the purchaser can plausibly state a reason for exemption.

  Continuing on, every other 508 step should be documented as well, such as requesting a VPAT, receiving it, reviewing it, etc., all the way down to explaining the purchasing decision in 508 terms.

  All of this information should be subjected to oversight, leading to improvements in 508 training and other systemic actions.

  Any government-wide (or even agency-wide) initiatives on digitizing ICT procurement and management should include 508 elements as needed.

  « less full details »

  5 comments for Idea: Build 508 into procurement processes

  Submitted by Jim Tobias 1 year ago

• I agree

  Voting is Disabled

  11 votes

  I disagree
  This idea is active.
  Improve Capabilities »

  Coordinate among agencies with accessibility responsibilities

  By one count there are 22 federal entities that have some accessibility oversight role. In 508-land, the big ones are the Access Board, GSA, DoJ, CIO Council, and FAR and the Chief Acquisition Officer Council. But the FCC, Dept. of Education, Dept. of Labor, National Council on Disability, NIST, Department of Transportation and many others have parallel roles in their own domains. Why not astound the public and make a ...more »

  By one count there are 22 federal entities that have some accessibility oversight role. In 508-land, the big ones are the Access Board, GSA, DoJ, CIO Council, and FAR and the Chief Acquisition Officer Council. But the FCC, Dept. of Education, Dept. of Labor, National Council on Disability, NIST, Department of Transportation and many others have parallel roles in their own domains. Why not astound the public and make a go of working together where there are shared issues? For example, making emergency communications accessible is now subject to action by (at least) FEMA/Homeland Security, DoJ, and FCC. Hidden somewhere in the Rehab Act (Section 502?) there's mention of interagency committees. Dept. of Labor is working on new rules for federal contractors under Section 503 -- wouldn't it be better to harmonize on 508's universal design-oriented technical provisions than keep going down the "accommodation" road?

  « less full details »

  Add your comment for Idea: Coordinate among agencies with accessibility responsibilities

  Submitted by Jim Tobias 1 year ago

• I agree

  Voting is Disabled

  10 votes

  I disagree
  This idea is active.
  Increase Transparency »

  Open 508 to a Wide Community of Practice

  Right now 508 decisions are made with almost no transparency. This leads to disparities among agencies, and insufficient information about accessibility for other decisionmakers -- basically everyone who buys or uses ICT. (Remember, 508 is supposed to benefit the entire ICT market.) For example, why are VPATs treated as private communications between an agency and a vendor? All information about ICT accessibility should ...more »

  Right now 508 decisions are made with almost no transparency. This leads to disparities among agencies, and insufficient information about accessibility for other decisionmakers -- basically everyone who buys or uses ICT. (Remember, 508 is supposed to benefit the entire ICT market.) For example, why are VPATs treated as private communications between an agency and a vendor?

  All information about ICT accessibility should be public, and published in a manner most likely to see it shared usefully across the entire user base. Mainstream and AT vendors, people with disabilities, ICT implementation managers, advocacy organizations, researchers -- all have a lot of expertise to offer. Sharing our testing results and methodologies, AT compatibility notes, tips and tricks, etc. will immediately improve accessibility, and build long-term resources.

  Ironically, it's been non-federal folks, especially higher ed, who've done a great job already in this direction. But the information is still too tightly held.

  « less full details »

  Add your comment for Idea: Open 508 to a Wide Community of Practice

  Submitted by Jim Tobias 1 year ago

• I agree

  Voting is Disabled

  9 votes

  I disagree
  This idea is active.
  Improve Capabilities »

  Rolling Refresh of 508 Technical Provisions

  There's no way that regulations can keep up with the pace of technological evolution. How about identifying those Technical Provisions whose impact has most eroded, and accelerating their updates via some more agile process than the typical rulemaking? The process should be open, and could result not in new regulatory language but in authoritative guidance. For example, it could state the the current provision, especially ...more »

  There's no way that regulations can keep up with the pace of technological evolution. How about identifying those Technical Provisions whose impact has most eroded, and accelerating their updates via some more agile process than the typical rulemaking? The process should be open, and could result not in new regulatory language but in authoritative guidance. For example, it could state the the current provision, especially in the light of one or more Functional Performance Criteria, is now to be interpreted thusly for emerging technology X.

  « less full details »

  Add your comment for Idea: Rolling Refresh of 508 Technical Provisions

  Submitted by Jim Tobias 1 year ago

• I agree

  Voting is Disabled

  7 votes

  I disagree
  This idea is active.
  Increase Transparency »

  Provisional procurement

  Not all products will be fully compliant. Some sole source products are almost completely non-compliant. Yet agencies need ICT to do their jobs. How about letting agencies purchase products that are not fully compliant under the following conditions: 1. The vendor commits to a remediation plan with an enforceable timetable. 2. The vendor provides all testing results, workarounds, tips & tricks,etc. that can aid in accommodation ...more »

  Not all products will be fully compliant. Some sole source products are almost completely non-compliant. Yet agencies need ICT to do their jobs. How about letting agencies purchase products that are not fully compliant under the following conditions:

  1. The vendor commits to a remediation plan with an enforceable timetable.

  2. The vendor provides all testing results, workarounds, tips & tricks,etc. that can aid in accommodation in the meantime.

  3. The provisional status is publicized so that other agencies and other public and private sector ICT customers (and ICT competitors) know what's up.

  « less full details »

  7 comments for Idea: Provisional procurement

  Submitted by Jim Tobias 1 year ago

• I agree

  Voting is Disabled

  8 votes

  I disagree
  This idea is active.
  Roles and Responsibilities »

  Umm, federal employees and members of the public?

  I know it's a cheap shot, but these folks were left off your list of statutory roles. Take a look -- we're implied in the law, as the source of complaints. Maybe you can do a better job putting the intended beneficiaries (and those who have to live with mistakes and bad actions) at the *center* of the strategy?

  1 comment for Idea: Umm, federal employees and members of the public?

  Submitted by Jim Tobias 1 year ago

Displaying all 11 Ideas