Making government accessible ? online

Federal Computer Week recently partnered with San Francisco-based SSB Technologies Inc. to evaluate the degree to which a select sampling of the Bush administration's e-government initiatives were accessible to people with disabilities, as required by Section 508 of the Rehabilitation Act. SSB Technologies used their InFocus software to automatically test 10 of the 16 paragraphs in Section 508.

FCW also worked with a representative of the National Federation of the Blind to evaluate the initiatives' Web sites. The following report is based on the results of those tests.

Making online government services available to all citizens is the law, but making the law a reality has proven to be a tough task for many agencies. As the e-government initiatives near completion and gain a broader audience, none of the Web sites evaluated in our recent review were found to be entirely accessible to citizens with disabilities, as required by Section 508. Agencies clearly are committed to the spirit of the law but are struggling with the details.

If Section 508 compliance was graded on a scale, many agencies would pass. But despite agencies' best efforts, some advocates say there is no such thing as almost compliant. Either a site is accessible or it isn't, and agency officials must boost their efforts with increased energy and resources to ensure that all citizens can access the services, experts say.

"Especially when it comes to the federal government, they need to be the example of full accessibility beyond compliance," said Ollie Cantos, general counsel and director of programs for the American Association of People with Disabilities. "This is not a matter of philanthropy. It's a matter of creating equality of access to information in the same way others who don't have disabilities get information."

Such a discussion would have gone unnoticed just a year ago. Agencies have been struggling with compliance since the law kicked in three years ago, but advocates seemed satisfied with the efforts being made then.

But the Office of Management and Budget put the issue back on the agenda. In a November 2003 memo, Karen Evans, OMB administrator for e-government and information technology, reminded chief information officers and e-government managers to consider accessibility at the beginning of a project and to use automated tools and hands-on testing to ensure compliance.

Section 508, of course, is just one of many requirements agencies face, Evans said in an interview with Federal Computer Week.

"This is a requirement just like privacy is a requirement, and all of these things need to be integrated into the overall cycle of the investment," she said, adding that the burden rests on agencies to determine how to manage the requirements. "All of these things are equally important to the IT investment. They all have to get done."

Sticking points

Agency officials clearly had accessibility compliance in mind when designing the e-government Web sites, said Chris Henderson, senior accessibility consultant at SSB Technologies, but reaching 100 percent compliance is a difficult feat, considering the intricacies of the law. The results for each of the eight evaluated initiatives varied considerably, with some sites scoring lower in certain areas.

Agency officials have reached a point where they can't dramatically improve compliance rates without a concerted effort for more dedication to the issue, Henderson said. The results indicate a need for more training or help from industry accessibility experts, he said.

"They have made an excellent first pass at 508 and have accomplished a lot, but there are problems that remain," Henderson said. "Those problems seem to be complicated enough that they need to develop some additional expertise."

For example, one difficult provision — paragraph A — requires agencies to have a text equivalent for a nontext item, such as an image or video. This allows a screen reader to identify and relay the item to a vision-impaired user. Some sites may use images in place of the words, making the site useless for those with a screen reader, Henderson said.

This item is difficult for site developers across the board, said Martin Gould, senior research specialist with the National Council on Disability. Creating text equivalents can be very expensive when it comes to labeling large tables, bar graphs and figures.

Another provision requires electronic forms to include labels that indicate what information should be entered in each field. Making forms accessible tends to be one of the most difficult tasks, Henderson said.

Web designers often forget to label tables and headers. Sites that scored low in one or two areas and higher in others were likely to have a persistent problem with one recurring form or image that was not properly labeled, Henderson said.

And almost every site had at least one provision of the law that officials seemed to be really struggling with, Henderson said.

Testing vs. experience

Section 508 tools are designed to pick up on those problems. But experts cautioned that the results of automatic testing can vary depending on the tool used. Some tools test beyond basic compliance with the law, and different testing software may present a variation of results. Furthermore, automatic testing may find inconsistencies in the site's code, rendering the site not compliant when in fact a screen reader may still be able to read the site.

This was the case in a few low-rating areas on the General Services Administration's FirstGov Web portal for the USA Services initiative, Henderson said. The test found that, of the site's 36 pages, only one-third of the forms were compliant and 66 percent of the form fields were missing labels. The problem could be as simple as a typographical error, Henderson said. Officials may have incorrectly labeled the form, but a screen reader will compensate for the error.

"They have gone to the effort, but if they are doing testing with some of the screen readers, they will try to compensate for the situation by finding text near the form field and identifying it as a label," Henderson said. "As far as following the letter of the law, they are missing that."

Martin Kwapinski, FirstGov's content manager, said the inconsistencies in the code are worth noting and fixing in later versions, but that doesn't mean people with disabilities won't be able to use the site. In short, there is such a thing as almost compliant, he suggested.

"You don't have an inaccessible page," Kwapinski said. "You have a possible inconsistency in the code you might want to look at, but it isn't something that would render your site inaccessible."

Site visitors may use different assistive technology, Henderson said, so to be accessible by all users, the site must comply with the law. "Our method of pursuing accessibility is to be as aggressive as possible, and we really feel that is our obligation," he said.

Browsing through the FirstGov site using a screen reader, Brad Hodges, technology accessibility manager at the National Federation of the Blind, found some of the inconsistencies first-hand. He stumbled on a few unlabeled buttons and noted some inaccessible areas of other unlabeled elements.

"That is something that should be caught with a tool," he said. "There's no excuse for that. We're experiencing a mixed bag."

GSA officials have dedicated significant efforts to ensuring the site is accessible, Kwapinski said. Officials use screen readers and validate software and tools for finding and fixing errors. They follow extensive testing criteria and ongoing testing procedures to ensure compliance. Officials check the site weekly and have a single person overseeing the site's compliance.

The E-Training initiative, GoLearn.gov, presented a unique challenge for managers who wanted to retain the multimedia aspects necessary for engaging online learning, said Larry Mercier, director of the Government Online Learning Center at the Office of Personnel Management.

"Interactivity is by far the most important part of online learning," Mercier said. "The idea is really that we wanted

an immersing, engaging learning experience."

To that end, OPM officials followed the guiding principle to go beyond complying with the letter of the law, Mercier said. The site scored near-perfect marks in every area automatically tested and dipped to 99 percent in the area of presenting text equivalents of nontext items. OPM officials' philosophy and process in developing the site help explain the high marks.

Initiative managers decided early on to partner with other government agencies and industry. They created a best practices paper in close collaboration with the Justice Department's accessibility officials and worked with a committee to determine the best way to evaluate the courseware on the site, Mercier said. They also were careful to work with industry in communicating their needs and only accepting fully accessible products.

"We are talking about managing the most valuable and important resource of the government, and that's the workforce," Mercier said. "We had a real need not to take the 'go/no-go' approach but to work with industry, and as a result, we far exceeded anything we dreamed."

Beyond embracing the law, OPM officials have embraced a compliance philosophy, said Jeff Pon, acting project manager for the E-Training initiative.

"We'd like to make sure the community of practice for Section 508 is championed by the initiatives such as ourselves, because we have such a wide grasp and we are effecting the change of government," he said. "There's compliance and there's principle, and the principle is what we support."

Officials at the Environmental Protection Agency, the managing partner for the E-Rulemaking initiative, took similar early steps to tackle accessibility on Regulations.gov, partnering with industry by including requirements for accessibile software in contracts, said EPA CIO Kim Nelson. EPA officials also worked closely with other agency partners involved in the initiative, bringing to the table Section 508 experts from each.

Regulations.gov generally received high marks in the review, but scored 0 percent compliance for not including text equivalents for nontext items and 84 percent for allowing users to skip repetitive links. Nelson said that Regulations.gov doesn't have the complicated multimedia aspects the main EPA site has, such as maps.

A shared priority among many of the initiative leaders

was supplementing automatic tools with human testing. Although testing with assistive technology can be useful, managers should also review the source code by hand. The managers of e-government initiatives said they include testing by people with disabilities at every stage of the project.

"You don't want to necessarily rely on the software out there, or the contractor certifying it or the agencies certifying," said Oscar Morales, E-Rulemaking program manager.

The fluid nature of Web sites and variations in testing and configuring software mean compliance is an ongoing effort for initiative leaders. Brad Westpfahl, director of government industry programs at IBM Corp., likened the process to a journey rather than a destination.

"Accessibility, particularly in a dynamic Web environment, is something that an agency or a company has to stay on top of, literally, daily," Westpfahl said. "Accessibility isn't so much something you achieve and you are there. It's more of a process and a mind-set that needs to be monitored and enforced."