Texas Workforce Commission Electronic and Information Resources Accessibility Compliance Plan

This plan provides information for Texas Workforce Commission (TWC) staff to aid and ensure compliance with Texas Administrative Code (TAC) web specifications and standards and electronic and information resource (EIR) requirements regarding accessibility for individuals with disabilities.

Requirements

As defined in Title 1 Texas Administrative Code Chapter 213, electronic and information resources include "information technology and any equipment or interconnected system or subsystem of equipment, that is used in the creation, conversion, duplication, or delivery of data or information." The term includes but is not limited to "telecommunications products (such as telephones), information kiosks and transaction machines, World Wide Web sites, multimedia, and office equipment such as copiers and fax machines."

In practical terms, examples of EIR at TWC include:

• Internet and Intranet pages and applications
• software applications
• voice applications such as telephone menu selections and interactive voice response systems
• video/CDROM products
• audio recordings
• electronic presentations, such as Microsoft PowerPoint
• Microsoft Office documents and PDFs
• copiers, printers, and fax machines

As of September 1, 2006, unless an exception is approved by TWC's Executive Director or a specific technology is exempted by the Texas Department of Information Resources (DIR), all new or changed web pages and web content and all other EIR goods and services, developed, procured or significantly changed by TWC, must comply with the standards and specifications of 1 TAC §206 and 1 TAC §213.

Federal standards as defined in Section 508 of the Rehabilitation Act as amended by the Workforce Investment Act of 1998 apply to EIR technology developed, procured, maintained, or used by TWC directly. These standards also can apply to EIR used by a vendor under a TWC contract that requires the use of such good or service, or requires the use to a significant extent (integral to the service) of such good or service in performing a service or furnishing a product. Employees responsible for negotiating and monitoring contracts must ensure that contractors meet the accessibility requirements that apply to them.

How We Comply

TWC is committed to achieving and improving accessibility and to fully meeting compliance requirements. Staff in all areas of the agency where EIR development and/or procurement may occur share responsibility for ensuring that accessibility-related requirements are met. The Texas Department of Information Resources (DIR) provides a central location for statewide accessibility information and TWC employees are encouraged to utilize the resources available. Division Directors are ultimately responsible for the accessibility of electronic products produced or purchased by their divisions.

TWC's three paths toward full accessibility:

1. We have built accessibility compliance into our processes for new development and procurement.
   
   

   TWC promotes and uses testing and validation tools to check and ensure that applicable web content is accessible and in compliance with 1 TAC §206 and Section 508 requirements of the Rehabilitation Act of 1973. TWC's web design standards and checklists include pertinent information and resource links to assist staff in preparations and procedures for creating accessible content and for verifying statutory compliance requirements prior to publishing.

   TWC procurement processes incorporate compliance with applicable accessibility standards. TWC uses either the Voluntary Product Accessibility Template (VPAT) or the Buy Accessible Wizard to assess the degree of accessibility of a proposed product when making an EIR procurement decision.

   It is important to note that even when an EIR purchase is made through a DIR contract, TWC is solely responsible for ensuring accessibility compliance and cannot assume that purchases made under pre-existing contracts will automatically be compliant. DIR does not evaluate the VPATs for products available through its contracts on behalf of purchasers.

   To monitor the agency's accessibility policy compliance, TWC maintains a global inventory of EIR and their accessibility status. As EIR are added or significantly altered, the business area with primary responsibility for the EIR purchase or development emails the Accessibility Coordinator with an inventory update which either self-certifies compliance with all applicable accessibility requirements or indicates the intention to pursue an exception request.

   For example, for software purchases, Purchasing provides the inventory update. For systems developed or maintained by the Information Technology (IT) Division, the appropriate IT department provides it. Program or business areas provide the inventory update for EIR they develop or maintain. (Note: Compliance monitoring for files published on the TWC Internet or Intranet sites, such as video or audio clips, PDFs, and Microsoft Office documents including PowerPoint presentations, is handled separately by TWC Web Publishing, except that agency training modules are included in the global monitoring process.)

2. We will review EIR development and procurement completed since 09/01/06 that is therefore subject to requirements of 1 TAC Chapters 206 and 213, assess compliance, and establish priorities for bringing any non-compliant resources into compliance as funds and time allow.
3. We will bring any non-compliant older web content and other EIR not currently subject to the requirements of 1 TAC Chapters 206 and 213 into compliance (a) as they become subject to the requirements because significant change or replacement is required or (b) as part of a global strategy to achieve full compliance as funds and time allow.

Exception Requests

If after careful evaluation of all available resources and options it is determined that compliance with any provision of TWC's EIR Accessibility Policy imposes a significant difficulty or expense to the agency, TWC staff may request an exception. An exception for significant difficulty or expense is not an exception to overall compliance, but rather is an exception only for the specific item or situation and requires a reasonable alternate method for access.

Completed EIR Accessibility Exception Request forms are submitted to the TWC EIR Accessibility Coordinator for processing. Requests include a description of the accessibility issue, justification for exception, and plan for alternate means of access. Exceptions require approval by the Executive Director or designee who will specify an expiration date for an approved exception.

Here is a view-only copy of the form: Electronic and Information Resource Accessibility Exception Request (PDF). The editable form for submission is available to TWC staff in the Intranet Forms Library and the LAN folder R:\Forms\Information Technology.

EIR Accessibility Coordinator

The TWC EIR Accessibility Coordinator (AC) is the central point of contact concerning accessibility issues and solutions for the agency's electronic and information resources. The AC facilitates the agency's response to concerns, complaints, reported issues, DIR surveys, and EIR Accessibility Exception Requests, and provides or arranges consulting services on matters related to accessibility. The AC works with staff in the business areas responsible for the agency's EIR. Each relevant business area designates an EIR Accessibility Liaison who collaborates with the AC and also helps appropriate staff in their area develop and maintain the knowledge and skills necessary to comply with TWC's accessibility requirements. The AC serves in a coordinating and facilitating role which excludes product selection and accessibility testing; those functions are the responsibility of the business area acquiring EIR and should involve the area's Accessibility Liaison.