Best Practices for Institution-Wide Web Accessibility

The internet has become an integral facet of modern higher education. Use of the web in education has evolved well beyond the occasional online or distance course. It is estimated that by 2015, 25 million postsecondary students will take some or all of their classes online.¹ Most face-to-face courses utilize online resources and activities such as scheduling and registration are among the many institutional functions now done almost exclusively over the web. Students and teachers alike take advantage of online management systems to access records, post and check grades, submit applications for employment, and deal with financial and insurance matters. In point of fact, one cannot fully participate in higher education today without access to the web.

For many persons with disabilities, the web is a double-edged sword. While an accessibly-designed website can mitigate or remove barriers, an inaccessible one can create them. When institutional websites are not accessible, many with disabilities are unable to independently complete the tasks required of them to compete in the academic arena. Student learning outcomes are also affected by accessibility. If these students do not have timely access to educational materials and processes, their outcomes can ultimately suffer. Inaccessible materials affect the timeliness and quality of student engagement in their education and can negatively impact student independence and self-determination. Furthermore, the right of faculty members with disabilities to teach, investigate, and publish freely may depend upon the issue of access as well.

An accessible web architecture can help provide equitable access to many students, faculty, and staff members with disabilities. Ensuring that students and others have the same ability to take advantage of online materials and services not only addresses student needs but also supports the core mission of most institutions and serves society at large. It is also falls within the legal realms of Title II of the ADA and Section 504 of the Rehabilitation Act.²

It should be noted however that an institution's efforts to improve system-wide accessibility can also provide value-added benefits: Accessible materials can improve academic outcomes for students without disabilities as they can provide enhanced learning for other groups such as those who prefer multi-modal learning, or those for whom English is a second language. Furthermore, the foundation for web accessibility is present in the existing guidelines of all regional accrediting agencies and may be useful in helping make the case for compliance or serve as a component in quality improvement plans as an institution prepares for reaffirmation.

However, in order to be truly effective, web accessibility needs to be an institution-wide effort. The interconnected nature of the internet means that access to a single page is worthless if one must navigate inaccessible pages to get to them. This document provides an outline of best practices for implementing and maintaining an accessible web presence across your institution.

The institutional best practices outlined in this document are organized by the presence of four key indicators important to success. These indicators are comprised of several benchmarks. Descriptions of Indicators and benchmarks are provided along with examples and essential components for individual benchmarks.

Indicator #1: Institutional Vision and Leadership Commitment

Institution-wide web accessibility is best attained and sustained when there is leadership to support a vision and commitment toward institutional accessibility. This support should come from many levels including an institution's governing board, central administration, and key personnel. Each must actively support, participate, and take ownership in the work and outcomes of accessibility.

Two Benchmarks distinguish Institutional Vision and Leadership Commitment:

Benchmark A: The Commitment of Administrative Leadership

Administrative leadership begins with a vision and commitment toward change. Typically this vision, and its leadership support, stems from efforts made at top administrative levels within an institution. For some systems this would also include the institution's board of governors or trustees. Over time the leadership commitment results in the development and enforcement of an accessibility policy and plan, along with the necessary resources to implement them.

Examples of administrative commitment:

An institutional statement of vision or commitment to web accessibility
The creation and support of a web accessibility task force or institution-wide accessibility group
An institutional policy on web accessibility
An institution-wide accessibility action plan
The availability of resources for web accessibility efforts
Efforts to advance the visibility, promotion, and communication of web accessibility efforts

Benchmark B: Relevant Stakeholder Participation

Including relevant personnel in the planning, implementation, and maintenance of web accessibility provides vital input, fosters ownership across stakeholders, and assists in sustaining the goal of an accessible web presence. Faculty, staff, and students should be included as stakeholders as they are involved in the development, maintenance or use of institutional web content. Stakeholder's knowledge and ownership of their roles is important, as each will likely have slightly different responsibilities in planning for and achieving overall accessibility. These responsibilities encompass wide-ranging behaviors, including technical staff who design accessible web pages, faculty who identify and upload accessible materials into course management tools, staff who create accessible documents intended for the web, procurement staff who ensure that institutional purchases meet the accessibility standard chosen by the institution, and individuals with disabilities who provide feedback on accessibility outcomes. The participation of all these diverse individuals is an important key for success and underscores the vision and commitment of leadership to the end goal of institution-wide accessibility.

Examples of stakeholder participation:

Individuals representing a full range of stakeholders who are involved in institution-wide planning and continuous improvement
Institution personnel who are engaged in professional development that includes or is focused on web accessibility
Faculty, staff and students who take responsibility for web accessibility outcomes within their purview
Systems that are available for individuals to provide feedback on the implementation and outcomes of web accessibility

Indicator #2: Planning and Implementation

Web accessibility requires strategic planning. Administrators must establish policies and procedures along with a systematic plan to develop, institute, and maintain web accessibility across the organization.

Four Benchmarks distinguish Planning and Implementation of Institution-Wide Web Accessibility:

Benchmark A: The Inclusion of Key Personnel

Identifying and involving personnel who represent key constituent groups at your institution is essential during both the planning and implementation process. Key accessibility personnel may come from many departments or units and represent disability advocates as well as leaders representing technical, faculty, and staff positions. Administrators identify and include these individuals for input as the institution moves from planning to implementation and maintenance of an institution-wide accessible web presence.

The broader group of stakeholders should also be included as important feedback mechanisms to the web accessibility efforts. Stakeholders are those who are either end users of web content or those who will implement the institution-wide plan. This benchmark can be differentiated from that found in Indicator 1, as the administrative vision exerted to include a variety of stakeholders is different from the actual participation of key personnel representing different stakeholders throughout the process.

Examples of participation:

The involvement of key accessibility personnel and those they represent in policy development
The involvement of key accessibility personnel and stakeholder groups in the development of an institution-wide web accessibility plan
The involvement of key accessibility personnel and stakeholders in the implementation of an institution-wide web accessibility plan

Benchmark B: A Comprehensive Accessibility Policy

A stated policy that provides specific guidelines and standards for web accessibility is necessary in order to ensure all administrators and stakeholders understand what is required of them. The web accessibility policy should appear in the same set of governing documents as other institution-wide policies, rather than as a separate unit. Once established, the institutional policy should be promoted and enforced.

Elements of a Comprehensive Policy include:

A summary statement of the policy
Effective date(s) for compliance to the policy
The scope of the policy
A recognized technical standard for web accessibility (e.g., Section 508 or WCAG 2.0 AA)
A provision for procurement and collaborative resources
Consequences for non-conformance to the policy
Mechanisms for ongoing review

Benchmark C: A Comprehensive Written Accessibility Plan

An institution-wide effort requires a systematic plan of action. This plan includes strategies for all aspects of implementation including: goals, timelines, budgeting, materials, personnel, ongoing assessment, and, when necessary, revision of the plan. For institutions that require a business plan for use during cycles of continuous improvement, these elements can serve as the basis for a prospectus that includes concept, marketing, position and market analysis, financial planning, and implementation.

Elements of a Comprehensive Accessibility Plan include:

An executive summary of the plan or a statement of concept for institution-wide web accessibility (Business Concept)
A provision for benchmarking and market evaluation (Position and Market Analysis)
A provision to gather baseline information (Position and Market Analysis)
Identification of existing institutional challenges and risks (Position and Market Analysis)
Identification of existing institutional priorities (Position and Market Analysis)
A process to communicate and market the plan to the campus and other communities (Marketing)
A provision for budget items appropriate to accomplish the plan (Financial Planning)
Metrics, milestones, and measurable steps (Implementation)
A timeline for rollout of the milestones and measurable steps (Implementation)
The assignment of specific responsibilities (Implementation)
An education plan for staff, faculty and students (Implementation)
An institution-wide plan to obtain and use feedback (Implementation)
A plan to monitor the progress of accessibility outcomes (Implementation)
An explicit strategy to evaluate and revise the plan in an ongoing way (Implementation)

Benchmark D: The Implementation of the Written Plan

Once the accessibility policy and plan are in place, administrators and others put that plan into action, ensuring it stays on track by continually monitoring and assessing its progress.

Evidence of this implementation may include:

Meeting minutes of the accessibility team/task force
Documentation of baseline information
A budget sufficient to support institution-wide accessibility efforts
Committed efforts by administration, faculty and staff to sustain web accessibility
Communication and marketing of the accessibility plan across campus and beyond
Data on web accessibility training for personnel
Documentation of implementation progress
Documentation on the feedback from different levels of implementation
Indications of actions taken for nonconforming web content
Web accessibility outcome data

Indicator #3: Resources and Support

An institution-wide web accessibility plan requires adequate resources and support. Administrators must provide the resources necessary to implement the web accessibility plan with provisions to ensure that the system is sustainable and will remain accessible.

Five Benchmarks distinguish the Resources and Support required for Institution- Wide Web Accessibility:

Benchmark A: Focus on Personnel

An effective plan cannot be carried out without personnel who have the expertise to implement it. Make sure you focus on hiring, retaining, and supporting personnel at all levels who will help your institution attain its accessibility goals. For example you need to have technical individuals, and those with special responsibilities, to implement the web accessibility plan. Moreover, typical faculty and staff have multiple responsibilities that require their time and attention. Therefore, it is important to provide them with clear and helpful information, sufficient time and support, and the motivation or incentives to ensure that they give the accessibility work in the plan the necessary attention.

Examples of a Focus on Personnel:

Position announcements for technical individuals that include requirements for accessibility experience or knowledge
The presence of incentives and motivators for faculty and staff participation in accessibility efforts
The collection of data on retention rates for personnel key to accessibility implementation

Benchmark B: Sufficient Time and Effort Allocated to Personnel

The process to move to an accessible web presence takes time. Both the time and effort required for this work should be identified when allocating faculty and staff responsibilities.

Examples of provisions for sufficient time and effort:

The recognition of accessibility work in job descriptions and role statements
The recognition of accessibility work in personnel time and effort reports
The collection and use of feedback on the sufficiency of personnel allocation for web accessibility efforts

Benchmark C: A Budget Sufficient for Institution-Wide Efforts

Administration should take financial requirements into account when developing the written accessibility plan and design budgets accordingly. Necessary materials, licenses, equipment, personnel, and training should be considered. The funding necessary to sustain accessibility of the system should also be factored into the budget.

Methods of determining if the budget is sufficient may include:

Reports that specifically evaluate the sufficiency of available web accessibility resources
A review of reports and statements monitoring the use of accessibility resources
Feedback from key personnel and those involved in the implementation of the plan

Benchmark D: Training and Technical Support

All personnel (i.e., faculty and staff) should be provided with the knowledge, support, and materials they require to carry out their roles in implementing institution-wide web accessibility.

Examples of training and technical support:

Trainings for faculty, staff, and students which occurs in conjunction with their expected accessibility roles
Technical assistance and support that is available to, and used by, faculty, staff, and students
The presence and use of materials necessary to support training, technical assistance, and implementation

Benchmark E: The Procurement, Development, and Use of Technologies That Will Result in Accessible Web Content

To create and maintain an accessible web architecture, personnel should choose tools that possess or render accessible web content. Failing to procure or develop accessible technologies perpetuates new and existing problems. A strong procurement policy, with language included in contracts, helps ensure that personnel use the institution's resources wisely and that products are purchased in line with institution-wide web accessibility efforts. This includes programs such as open source, shareware, and freeware that don't go through the traditional procurement process.

Examples of technology procurement, development and use of that will result in web accessibility:

Accessibility procurement language that is included in contracts, is consistent with the institutional standard, and used as part of the selection process for purchasing.
The existence and enforcement of accessibility requirements for course resources that are shared but originate from other institutions or organizations.
Products that are developed by the institution meets the institution's stated accessibility standard

Indicator #4: Assessment

Ongoing assessment is necessary to ensure that your web accessibility plan is working and on track. Processes must be in place to measure progress, constituent satisfaction, and outcomes. This information is then used to help determine the sustainability of the current efforts and make improvements to the overall program.

Three Benchmarks distinguish the Assessment Necessary for Institution-Wide Web Accessibility:

Benchmark A: Evaluation of Implementation Progress

Provisions are made to ensure that the plan is implemented as intended (e.g., scope, training, and support of staff, timelines). Progress is monitored and evaluated to ascertain if implementation is occurring at predicted levels, and that alterations in planned implementation are identified and communicated.

Examples of progress evaluation:

The collection and analysis of data or information of an institution's progress within the implementation process
Formal reports on the progress of the intended implementation plan
Informal summaries or communications on the progress of the implementation plan

Benchmark B: Evaluation of Web Accessibility Outcomes

No plan or policy is useful if it does not result in the intended outcome. Those tasked by the institution to improve web accessibility must periodically monitor and evaluate its status to determine if it is meeting the institution-wide web accessibility standard. Because automated web accessibility tools don't provide a complete assessment picture, key accessibility personnel should include manual checks in their evaluation plans. As technology and standards change over time, it is also important that the institution determine if the stated outcome is sufficient or if alterations could bring it more in line with current standards and practices.

Examples of the evaluation of web accessibility outcomes:

The collection and analysis of institutional web accessibility data
The development of institutional reports containing web accessibility data or summaries
The creation of reports from external evaluations of web accessibility outcomes
The collection and use of correspondence describing accessibility outcomes

Benchmark C: Assessment Results Are Used To Improve Institutional Accessibility

Data gathered from evaluations of both the process and the outcomes of web accessibility are of little value unless they are used to improve and inform what is to happen in the future. Those tasked by the institution to improve web accessibility) should maintain ongoing oversight and review data sources continually to revise procedures to ensure the institution can create and maintain institution-wide web accessibility. These same data should also be used for future changes in institutional policy.

Methods of determining that assessment results are used for improvement:

The development and use of reports that reflect data-based recommendations for change
Documentation that describes how data sources inform institutional efforts

1. Nagel, D. (2011, January 26). Online learning set for explosive growth as traditional classrooms decline. Retrieved from http://campustechnology.com/articles/2011/01/26/online-learning-set-for-explosive-growth-as-traditional-classrooms-decline.aspx

2. DOJ (2010, April 22). Principal Deputy Assistant Attorney General for Civil Rights Samuel R. Bagenstos testifies before the House Judiciary Subcommittee on the Constitution, Civil Rights and Civil Liberties. Retrieved from http://www.justice.gov/crt/speeches/2010/crt-speech-100422.html