HHS EIR Accessibility Procedures, Chapter 1: Overview

1.1 Purpose and Scope

These procedures are intended to provide guidance for agency staff members, contractors and others involved in the creation, maintenance or procurement of electronic and information resources. Consult your agency's internal business procedures for other guidance to comply with HHS Accessibility Policy. The technical standards for accessibility in Section 508 of the Rehabilitation Act of 1973, as amended (29 U.S.C. 794d) (hereafter, Section 508) and W3C (World Wide Web Consortium) Accessibility Standards are considered an equivalent technical standard for purposes of accessibility development, procurement and testing.

1.1.1 State Employees

These procedures are intended to provide HHS Agencies with guidance in implementing the HHS Accessibility policy to ensure that employees with disabilities have reasonable access to agency Web sites and other electronic and information resources to perform their job duties.

Within an each HHS agency care should be taken to establish a common assistive technology platform to ensure that internal applications, websites, and other forms of electronic information resources are compatible with the agency's standard assistive technologies. Agencies should conduct testing of these resources using standard assistive technologies.

1.1.2 Members of the Public

Adherence to the HHS Accessibility policy, using the procedures outlined in the following chapters will provide reasonable confidence that members of the public will be able to successfully access information and services that are available through electronic information resources using assistive technologies or when accessibility is built-in to applications or information technologies. Exceptions to accessibility policies do not eliminate an agency's responsibility to provide access to information for members of the public with disabilities but instead, allows an exception to the standard means of access describe in the accompanying policies and procedures.

1.1.3 Individuals with Limited English Proficiency

This policy for access by individuals with limited English proficiency applies only to an agency's internet web site and not necessarily to intranet content or other forms of electronic and information resources. Additional guidance is provided to HHS agencies providing access for individuals with limited English proficiency. in Chapter 11: Spanish Language Translation.

1.2 Policy Application

The following table outlines the classifications of Electronic Information Resources covered by the HHS Accessibility policy. Any EIR that is incidental to the performance of a contract may not be covered by this policy. However, EIR that is used in service delivery, or in the performance of a contract that is likely to involve interaction with employees or members of the public is covered under this policy.

  Internal External
Content Applies Applies
Applications Applies Applies
Computer Hardware Applies Does Not Apply
Building Maintenance and Monitoring Equipment Does Not Apply Does Not Apply
Telecommunications Equipment Applies Applies if used to provide information or services to HHS Employees or Consumers
Office Equipment Applies Does Not Apply

1.3 Compliance

1.3.1 Exception for Significant Difficulty or Expense

If after careful evaluation of all available resources and options, an agency determines that compliance with any provision of the policy imposes a significant difficulty or expense, the agency may request an exception by completing and submitting the Accessibility Exception Request Form

Exception Request Process

  1. Determine need for exception:
    • Significant difficulty (no agency staff or contractor available qualified to complete the project in an accessible manner)
    • Cost Prohibitive (Include cost analysis of cost to achieve accessibility compared with the cost of creating or purchasing an accessible resource. This analysis should include the cost of providing and maintaining alternative access.
    • Include details of market search for an accessible product.
  2. Complete exception request form and submit to Agency EIR Accessibility Coordinator. The coordinator evaluates the request before submission to the executive commissioner indicating the recommended approval or denial of the exception.
  3. The Agency Commissioner or designee evaluates request to determine if the exception should be granted.
  4. The Commissioner grants or denies the request. Multimedia exceptions may be granted by the Commissioner's designee.
  5. If the exception is approved, an alternative method of access must be provided. Examples are provided in the next section.

1.3.2 Alternative Methods of Access

When an exception has been approved, people with disabilities must still be able to access the content or functionality of the inaccessible resource. This may be accomplished by one or more of the following means.

Alternative accessible document types (e.g., PDF, Word, Text, HTML)
Create a second version of the document in a more accessible format.
Braille
A braille version of the resource may be created to provide access for people who are visually impaired and who read braille. This method should not be used alone to provide access for people with visual impairments and should usually be accompanied by large print versions.
Teletypewriter (TTY
TTY services may be used to provide access to people with hearing impairments.
Captioning
Closed or open captions may be added to multimedia presentations for people with hearing impairments or cognitive impairments.
Transcripts
Transcripts may be used to provide access to audio and audio/visual presentations. These transcripts must include all dialog, and any meaningful information that is presented visually.
Text to speech synthesis
This method may provide access for people with visual or cognitive impairments.
Recorded Audio
Providing a recording of print based information may provide access to people with visual or cognitive impairments and can also provide access to some people with limited English proficiency

Whenever choosing to create multiple versions of documents to provide accessibility for specific groups a plan must be developed for ensuring that these alternative versions are kept current with the "main" version. Managers should consider the cost of creating and maintaining alternative versions when developing their request for an exception to the accessibility policy. Contact your agency's Accessibility Specialist to discuss other options for ensuring an effective alterntive means of access.

1.3.3 General Exceptions

This policy does not require the installation of specific accessibility-related software or the attachment of an assistive technology device at a workstation of a state employee who does not have a disability.

Captioning

For information on captioning methods, see Chapter 7: Multimedia, Audio, and Video Files.

1.4 Lack of Commercial Availability

The Buy Accessible Wizard is a good resource for beginning a search for accessible EIR products and services.