Frequently Asked Questions
Topics
- Commonwealth of Virginia Accessibility and Web Site Standards
- Accessibility vs. Web Site Standards
- Accessibility Standard
- Timelines
- Terms Used in the Web Site Standard
- Web Site Standard
- Exemption from the Web Site Standards
- Web Site and Accessibility Compliance
- Format
- Resources
Commonwealth of Virginia Accessibility and Web Site Standards
This document is a consolidation of questions that have been posed to the Virginia Information Technologies Agency (VITA) and the Department of Rehabilitative Services (DRS) by agencies, contractors, and members of the disability community regarding the Accessibility and Web Site Standards. The responses to these questions are intended to promote a better understanding of the requirements of the Standards. This document is purely informational; it neither creates new standards nor changes the existing Standards. This document assumes the reader has a technical understanding of web site development.
ACCESSIBILITY vs. WEB SITE STANDARDS
Q: Is accessibility part of the Web Site Standard?
A: The Accessibility Standard is a distinct standard, and the Web Site
Standard is a second, separate standard; however, the two standards are closely
related. When you work on a web site, you will deal with both issues. Depending
on your method of implementation, you will most likely find that it is easier to
address the requirements of both Standards simultaneously, rather than going
through and making accessibility changes and then going back and adding all the
Web Site Standard components.
To comply with the Web Site Standard, you will be working towards the common
look and feel, which will coincidentally aid accessibility and usability. You
will also be implementing accessibility techniques for your entire web site,
but, the Accessibility Standard addresses more than just web sites.
Accessibility also applies to all other forms of information technology,
including software applications and operating systems, self-contained or closed
products such as information kiosks, printers, and copiers, also laptops and
portable computers as well as telecommunications products, and video or
multimedia products.
ACCESSIBILITY STANDARD
Q: Does accessibility include mainframe access also?
A: To the extent that a system or application is public facing; if it is
not public facing, it is not an accessibility issue. It has been pointed out
that the behind-the-scene technology that makes a system operate is not an
accessibility issue. Keep in mind, however, that “public facing” includes
employee facing.
When evaluating implementation plans related to the Rehabilitation Act of 1973,
the courts have considered each case individually and have consistently
questioned whether a plan is considered “reasonable”, given the available
resources. So, the implementation does need to state a rational date when the
systems or applications will be fully accessible compliant.
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Q: Do large applications like Pay line, lease accounting, fax, etc. have
to be accessible if they are used only by state employees?
A: If it is used by state employees, it is publicly facing, but, to a
state employee. It is important to note that state employees are part of the
public and that even though you have to have a password to get into some
applications, such as Pay line, that application must also comply with the
Standard.
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Q: What about other applications that are not web, such as FoxPro and
Access applications?
A: Those types of internal applications must comply with the Standards.
The Section 508 requirements, including procurement of accessible IT products,
have been federal law for a number of years now. Since must vendors would like
to sell to the federal government, their products most likely have accessibility
features already built in. If it is accessible to the public, or to employees,
or to other county or local groups, it definitely needs to be accessible.
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Q: Since the Accessibility Standard has a much broader scope than just
web sites, are there plans to include other people who develop non-web-page
applications in future communications and workshops?
A: Consideration is being given to holding a seminar for non-web
applications and systems. If you know of someone or a group of people in your
agency who should be included on the distribution list for information about
these non-web applications, please contact Eric Perkins (eric.perkins@vita.virginia.gov).
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Q: I have not seen pages designed that are data-entry pages with multiple
buttons such as submit, refresh, go back, go forward, skip this page, put it in
my shopping cart, etc. How do those types of pages work with the accessibility
format?
A: There are many pages that integrate those features. Learning how to
make heavy-duty applications work through these new Standards provides a great
opportunity for networking and working together. A notice can be placed in the
“What’s New” section of the WATG and people can sign up if they want to get
together and work through some of the technical issues involved in converting to
the Standard. A series of meetings could also be posted on the WATG site so
anyone interested would be aware.
TIMELINES
Q: What are the timelines for implementing the Standards?
A: The Commonwealth’s Standards echo the Rehabilitation Act of 1973 and
the Americans with Disabilities Act of 1990. Since this legislation has been in
place for a number of years, most sites are hopefully already close to
compliance.
A reasonable plan for reaching compliance required by the Accessibility Standard
is due within six months of the November 4, 2005, effective date of the Standard
– that is, May 4, 2006. Since there is no specific accessibility implementation
deadline, you will follow your plan for implementation; nevertheless,
implementation of the requirements should be a priority and your plan will
become the implementation timeline and its dates de-facto deadlines.
The Website Standard implementation is different. Your implementation plan is
due within three months of the November 4, 2005 effective date of the Standard –
that is, February 4, 2006. Compliance on look and feel is due within one year of
the November 4, 2005 effective date of the Standard – that is November 4, 2006.
TERMS USED IN THE WEB SITE STANDARD
Q: What is the definition of “public” access used in the Standard?
A: If the site is externally facing, if it is not an internal
application, if people can access the application regardless of their access
method, it falls under the Web Site Standards. Intranets are not affected by the
Web Site Standards; but, every web application of any variety must comply with
the Accessibility Standard.
WEB SITE STANDARD
Q: Does the Web Site Standard apply to public local government sites
that are not state agencies, not accessible to the general public and not
password protected?
A: No. The Web Site Standards apply only to Executive Branch agencies of
the Commonwealth.
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Q: Will you provide us with the template for the Web Site Standard?
A: The WATG site in and of itself is the template that DRS is using. All
of the source code and anything that has been developed including the actual
templates are provided. On the site, there is an example of a template page that
is available in zip format, which includes the CSS (Cascading Style Sheets),
some images, and source code. The site is being expanded to include other
applications. For instance, the form application is going to be a completely
accessible form application that fits into DRS’ template and all of the source
codes for that are provided. So as long as you have the required database
components, you can use it.
To comply with the look and feel is really not difficult. The biggest focus for
the Web Site Standard is the top 100 pixels on all your web pages. Once you get
your first page done, especially if you are using Dynamic Include, Server Side
Includes, FrontPage Includes, etc., you can make site-wide changes very quickly.
You have to look at how your left menu is handled and your footer. It is a
matter of what your header looks like, the placement of your menu on the left
and the basic footer that should be on every site. That will address specific
items outlined in the standard such as:
- the background color of your top navigation bar,
- the placement of links at the top,
- the placement of the search engine feature,
- the use of a search engine,
- the placement of your logo,
- the height of the header section,
- the height of the breadcrumb section,
- the location of your menu items,
- the number of menu items; and
- a screen resolution of 800 X 600.
That is basically the web site standard in a nutshell. Then you have
applications to consider and they will all fit in also.
The Web Site Standard can actually simplify your job in a pretty significant way
because all the content on all your pages on all your sites is set up in a
similar fashion. If you use “include” files for your menu systems, your header,
your footer, portions of your content, and your search functionality, you make
one change one place and it is all done in five seconds. The pages contain less
lines of code so they load faster. There will be circumstances with some big
applications where it will take time to figure out how to make certain pieces or
certain functionalities work under these standards. But, by and large, the
content and the sites themselves are much easier to maintain.
Because you are left with a simple text-only site, you can do certain things,
especially if you are using CSS to a large degree. There is functionality. When
somebody hits the print button, only the content prints; or they can choose to
print the whole site. The size of the text can be changed. The contrast of your
content area can be changed so it can look different for different people.
People can apply their own style sheets and can hit your sites using their cell
phones because all you are really passing is text and simple imagery. There are
a lot of really positive affects that come out of implementing these Standards.
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Q: How will the use of style sheets affect the look and feel?
A: Many users are not aware that the browser can be used to change the
size of the text, change the contrast and remove style sheets. Everything is set
up in a specific way using the default style sheet. What you cannot do is create
a style sheet that moves the menu to the other side of the page or that changes
the whole layout of the site so that it does not conform to the look and feel
policies. If you remove style sheets or you use CSS (Cascading Style Sheets),
the items are going to move to the linear format listed in your code.
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Q: Can we use our own graphics for the header?
A: You can use your own graphics. You can use different images for the
background and for the logo and you can tagline all of that material as you see
fit. As far as the look and feel is concerned, sites can have different color
schemes, and different types of menu, but, the placement is the same, which is
what is meant by “common look and feel”. The sites will be similar enough that
your average user will understand they are all Commonwealth of Virginia web
sites. For examples of some acceptable “common look and feel”, see
http://www.vadsa.org/watg,
http://www.vadrs.org, and
http://www.vaboard.org.
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Q: Can you provide some clarification on the use of tables on web sites?
A: The point of a table is to display tabular data. Tables should be used
only for data that has several columns with potentially hundreds of different
records. That data should be displayed in a specific way and needs to be set up
in a specific way. Tables should not be used for the layout and design in your
web site presentation.
The Standard also states “if the table does not make sense, provide an
alternative equivalent”. An alternative equivalent to a table would be something
like a “div” that is relatively or absolutely positioned using CSS (Cascading
Style Sheets) to display something you would have otherwise used the table to
display (for example, if there is a set number of columns, but the types of data
change from field to field). A table would not serve that purpose well, so you
would use an alternative method like a list.
There is a great resource site at
www.alistapart.com which is managed by a group of developers who use
standard base design techniques and find ways around some common problems. In
some cases, CSS is used. That format would serve as an alternative to a table
and is not quite as linear as some others.
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Q: Does the existence of certain elements (such as global search and
breadcrumb navigation) in the Web Site Standards indicate that these elements
must be present?
A: Not necessarily. If you have a certain number of pages in your site or
beyond, then global search and breadcrumb navigation really does facilitate the
site’s use. But, if that site or application is so small that there is no need
for a search function, then, it is not necessary to include one. However, if
your site offers a basic or advanced search function, it needs to be accessible.
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Q: Localized navigation is not addressed in the Web Site Standard.
Frequently, the navigation has been put into content; but, if every agency comes
up with a “solution” and puts it in the content, the primary benefit of the
common look and feel is lost.
A: The menu systems, as the primary navigational structure, must be
similar from site to site. There are different ways of performing the
navigation, but, the common look and feel must be upheld. We are looking at
multiple levels with the breadcrumbs, which can be done in a variety of ways.
This issue provides another excellent opportunity for networking. Everyone is
encouraged to participate in the solution. There is a forum application on the
WATG site where suggestions can be shared so that there is enough exposure to
start an exchange of ideas and, hopefully, arrive at solutions for this and
other common problems.
EXEMPTION FROM WEB SITE STANDARDS
Q: Would an exemption be appropriate for application types with
“accept” and “cancel” buttons, and things that are very different from just text
and verbiage?
A: One of the biggest parts of the look and feel component is to pull
some of those design elements into a more simple style for all the different
users of the site. That is why we consider the different kinds of menu options.
There are other applications very similar to the kind that you are describing
that have a lot of form elements with a lot of different options. In most
circumstances, all of those elements would fit into the content area for that
specific application. For big applications, it may take some time to figure out
how to make certain pieces or functionalities work.
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Q: Does DMV’s pin application to change a license plate have to be
compliant to the Web Site Standard?
A: The Web Site Standard makes provision for exemptions. Certain entities
such as institutes of higher education, museums, the Library of Virginia, and
the Virginia Tourism Corporation are exempt. In the case of tourism, they are in
a position where they compete with other states for tourist revenue. They need
to have flexibility in look and feel their web site to differentiate themselves
from other states. That would argue for them being exempt because of the
commercial needs. While DMV’s site has commercial needs, too, however, it is a
public-facing site that is of use to almost all Virginians and the DMV is not
competing with another entity (nobody else is distributing driving licenses in
the Commonwealth of Virginia), therefore it would most likely be required to
comply with the Standard.
WEB SITE & ACCESSIBILITY COMPLIANCE
Q: How is compliance (non-compliance) determined for large,
decentralized web sites over which the agency has no enforcement authority?
A: The Web Site Standard applies to all state agencies If your agency’s
site is linking through to a county site or a municipal site, their site can
look and feel any way they want. But, within our own organization, the Executive
Branch, the enforcement really comes through APA audit and audit findings that
may develop if you are not in compliance with the web site standard.
On the other hand, the Accessibility Standard is mandated by the Code of
Virginia and it applies throughout the Commonwealth. It applies to state
agencies as outlined in the Accessibility Standard. Code and Federal Statutes
impact the accessibility of web sites for non-state agencies. The Rehabilitation
Act of 1973 and the Americans with Disabilities Act of 1990 impact all levels of
government as well as the private sector. If a complaint is registered against a
state, municipality or local government, noncompliance goes through the
Department of Justice. The obligation to provide accessibility has existed since
1973 and exposure to liability certainly exist if a complaint is made with
Department of Justice.
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Q: Some old web sites use very old technology (i.e. frames and heavy
table structures) and include very deep structure problems. Bringing them into
compliance may take longer than a year. How firm is the compliance date?
A: Because we anticipated that certain agencies would be faced with a
really daunting challenge, there is an exemption process. The request for
exemption should explain why the exemption is needed, describe the work-around
to provide equivalent access and define the time frame for actually achieving
compliance. It would be in your best interest to indicate how you have taken
advantage of the technical assistance that has been offered, particularly if you
are citing resources. The individuals who will review your request want to work
with you and will consider any request with a reasonable explanation and
reasonable plan for compliance. You will also receive the treatment and
assistance you need.
FORMAT
Q: Which CSS elements are safe for older browsers?
A: Most agencies have a specific browser that is used agency-wide. For
DRS, that is Internet Explorer. Some of the Cascading Style Sheets elements will
not display properly in Netscape or in Firefox or in older versions of the most
common browsers, and CSS2 is not that widely supported yet. A service called
www.browsercam.com loads your site in
several computers with different operating systems and different versions of the
browsers; and, it gives you, literally, a picture in a pre-designated resolution
that shows you what your site looks like and how it operates under those
circumstances.
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Q: Are there minimum requirements and templates for the privacy policy,
the links policy, and so forth?
A: Those areas must meet the requirements of the Code of Virginia; and,
in fact, privacy statements exist because they are Code-mandated. The language
for the Virginia Assistive Technology System (VATS) site came directly from the
Code. There is information available on the WATG site in addition to policy
statements on the DRS sites that are not copyrighted and are available to anyone
who would like to use them. Daniel Ross (daniel.ross@drs.virginia.gov)
and Eric Perkins (eric.perkins@vita.virginia.gov)
can provide some assistance, and, your agencies representative in the Attorney
General’s office would have a good grasp on the language of the Code.
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Q: Has there been any discussion with regards to the use of Spanish
considering the growing Hispanic population in Virginia?
A: There are no issues related to alternate language formats that raise
an accessibility problem and alternative language versions of the site are
strongly encouraged. Some of the open source or free tools that are out there
may not be quite as efficient as something like the HiSoftware products, such as
AccVerify and AccRepair, that VITA is providing free of cost to agencies. If you
do use a tool that reports errors because some of your content is in a different
language, then, that is obviously something you can overlook. You know that is
not an actual problem; it is a flaw in the tool.
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Q: The template seems to be focused primarily on content delivery;
however, functional applications require some different paradigms and some types
of applications are data-entry intensive. Are these types of applications
addressed well in the Standards?
A: They are addressed fairly well and there are a few examples that might
provide some guidance on functional applications. One site to view is
www.vadrs.org/essp. This is a public
facing site and it is part of the Employment Services and Special Programs (ESSP)
web site, which in turn is part of the Department of Rehabilitative Services
(DRS) web site. Consequently, the template needs to exist around it. The
application has a variety of little features and is fully compliant. It also
includes its own individual search function which is facilitated because of the
number of records.
A lot of the older sites that require intensive data entry have huge forms that
can easily be split up and that allow you to pass variables from page to page.
It is not necessary to build the whole form.
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Q: Why is there a limit of twelve links in the navigation?
A: One of the primary points of discussion in the development committee’s
sessions was the number of links in the navigation. During the formation stage
of the Standard, most committee members felt the Standard was forcing their
content. Over time, however, it became evident that without restrictions on the
number of links, sites will migrate to the kind of unsynchronized chaotic, web
delivery system we have right now.
The point of the requirement is to help move sites into categorized formats that
assist people to obtain information easier. Large sites contain a lot of
information. A site map allows people to see every available section or page of
the site in one place; however, a lot of people (specifically individuals with
cognitive or other disabilities) are incredibly confused by menus with multiple
sub-items or drop lists. A recognizable, simple tab-based menu system allows
everyone to quickly get to the information. For certain sites, that may require
re-thinking how to link to your content and regrouping items into specific
categories that you can hit from those 12 main menu items.
Having a limited number of links in the navigation provides advantages for
users. Generally speaking, users are unfamiliar with our terminology, so having
a menu system with various terms on it might not make sense to them. It might
seem a very daunting task to locate needed information. Putting items into
user-friendly categories like “career center” or “find an office” can greatly
simplify the process.
Categorizing items in this fashion allows you to offer more information about
your services. For example, before transitioning to this format, DRS had “VBIC”
listed as a menu item. Even with an acronym tag attached to it, VBIC means
nothing to anyone just moving to Virginia or someone new to the world of
disability services. With the new system, detailed information is provided for
each of the 12 main menu items.
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Q: Are text-only pages required for particular web pages or for all web
pages? Is there a template for text-only pages that address navigation?
A: There was a point in time in the history of accessibility standards
where the text-only version of a web site was the end-all, be-all, and magic
bullet solution. That time is definitely past; and, having a separate text-only
site is generally not a very good idea. The W3C actively discourages the use of
text-only sites because more accessible, simpler alternatives are available.
People with visual impairments generally do not trust text-only web sites
because in the past, when web sites have been updated, the text-only sites
frequently were overlooked. So, most people rarely use text-only sites.
If you put a style sheet switcher on the site your users can have the ability to
switch the style sheet or turn the style sheets off through the browser. If your
agency has a really strict policy about placing cookies out there, there are
versions of that code that do not use a cookie. And, there are alternatives to
fix a simple java script that will allow you to change a cookie and hold it
during a session for a user. So the user can come to your site and make the text
bigger, take away all the images, change the background, and view it in a
different format. They are limited only by the number of style sheets you set
up. You can display your site in that way, but by default, it needs to display
in the template format.
On the WATG site is a page that does not have the style sheet reference in it.
It is a very simple text-based web page where the menu items are just a simple
bulleted list on the top. Information can actually be displayed in text format.
Everything can be laid out in linear fashion so technically the site is a
text-only web site. It fools your eye into thinking it has tables and images,
etc., but, that is all being managed by the style sheet. You can take what you
have and transition it so that it works better for everybody, including you.
RESOURCES
Q: Who is the person to contact about obtaining a seat license for
HiSoftware’s AccVerify and AccRepair?
A: The testing tools, AccVerify and AccRepair are available through VITA
with a site licensing agreement from HiSoftware; which means there is no cost to
your agency. Contact Daniel Ross, Department of Rehabilitative Services, at
(804) 662-9112, or at
Daniel.ross@drs.virginia.gov .
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Q: Is staffing assistance available?
A: Through the VITA/DRS partnership, limited assistance is available
through the expertise of Daniel Ross, Dianne Stottlemeyer and the other
individuals who are working with them.
We envision implementation planning as a two phase process. In the first phase
and on a first-come-first-served basis, Daniel Ross will assist you in
evaluating your web site’s accessibility and format needs. This will assist you
in the development of your implementation plans for both accessibility and the
web site. Once you draft your plans, you would move into a second phase. At this
point the individuals in your agency who are responsible for the web site’s cost
center would review your plan, the required resources, and the projected
time-frame. They would determine whether your agency will provide in-house
expertise combined with assistance from DRS; whether it makes more sense for
your agency to contract-out the implementation responsibility to a third party
vendor; or whether to contact Virginia Interactive and work out an arrangement
with them to assist your agency with implementation.

