With the recent update to the Americans with Disabilities Act (ADA) Standards, state and local governments must ensure that their web content and mobile apps comply with the Web Content Accessibility Guidelines (WCAG) 2.1 Level A and AA success criteria.
This new rule presents a significant challenge for many government entities, especially when working with third-party vendors for their digital services.
This blog post will discuss practical tips for ensuring that your third-party vendors prepare for and comply with the new ADA rule.
What Do You Need to Do to Prepare?
Here's a practical roadmap:
Understanding the New ADA Rule - Make sure everyone is on the same page. The new ADA rule, published in the Federal Register on April 24, 2024, adopts WCAG 2.1 Level A and AA as the technical standard for web content and mobile app accessibility. It applies to all state and local government entities, regardless of size or funding, higher education, and third-party vendors that provide digital services to these organizations.
Proof of Conformance - If you haven't already, request an Accessibility Conformance Report (ACR) from your vendors supplying any information and communication technology (ICT) - from database software, research tools, and project management to cloud computing, CRMs, and teleconferencing software. The University of Oregon has an excellent example of contacting third-party vendors and making this request.
For a sample ACR, see Apple Accessibility Conformance Report for MacOS Sequoia, WCAG 2.0 (PDF)
Review the ACR & Conduct an Audit: Review the ACR document to determine the status of each specific criterion: supports, partially supports, does not support, or is not applicable. If needed, conduct an accessibility audit against each criterion included in the ACR. Remember, you may need to perform automated testing, like with DubBot, as well as manual testing. If you need guidance getting started, request a copy of DubBot’s "Beginner's Guide for Manual and Automated Accessibility Testing."
Establish timelines and milestones: If you discover accessibility issues that require remediation from your vendor, prioritize them and establish timelines and milestones for the work. This is essential to ensuring the project stays on track and is completed on time. The deadline for compliance is fast approaching, so don't wait.
Establish clear communication: It is essential to establish clear communication channels from the outset, which will foster transparency and help address issues quickly and effectively.
Moving Forward
To help ensure your third-party vendors are and remain accessibility-focused, build accessibility into your procurement process.
- Include the WCAG criterion your organization complies with in every RPF, Invitation to Bid, or contract for ICTs
- Require vendors to comply with the same standards and provide proof with an Accessibility Conformance Report.
- Test and validate all claims included in the ACR.
- Train your procurement team on ACR requirements.
Finally, in your accessibility statement on your website and apps, inform users that accessibility is part of your procurement process.
More than ever, investing in accessibility is not just about compliance; it's about doing what's right.
"It is critical to ensure that individuals with disabilities can access important web content and mobile apps quickly, easily, independently, privately, and equally. Accessible web content and mobile apps help to make this possible. By allowing individuals with disabilities to engage more fully with their governments, accessible web content and mobile apps also promote the equal enjoyment of fundamental constitutional rights, such as rights with respect to speech, assembly, association, petitioning, voting, and due process of law." ~ Nondiscrimination on the Basis of Disability; Accessibility of Web Information and Services of State and Local Government Entities
