# Presentation: 280366

## State Review of Draft Standards

- August 17, 2007 Draft Version

## State Statutes

- At least 20 states with IT access procurement laws (more with policies - might be web only)
- Most laws reference federal IT access standards
- Some adopt in total (including Application)
- Some require, others allow for state adoption of standards (so federal can be adapted/rejected).

## State Review Questions

- Do we understand the standard?
- For Procurement
- Can we review/rate conformance to the standard based on vendor provided information?
- Will the review/rating information help us in purchasing decision making?
- For Direct Delivery by Covered State Agencies
- Can we conform to the standard?

## Overall Structure Concern

- Proposed structure exceedingly complex to implement in bids
- For telecom bids
- 10 current applicable technical standards
-  49 proposed applicable technical standards
- For web application bids
- 26 current applicable technical standards
- 48 proposed applicable technical standards
- Many N/A vendors responses; state will have little ability to verify if really NA or not.
- State will likely revise structure to meet procurement needs.

## Functional Performance Criteria - will not adopt

- Extremely subjective and variable
- Not measurable using vendor supplied information
- Heavily dependent on AT compatibility and changes
- Creates need to conduct usability testing
- Review results not defendable in bid protest or legal action.
- Defendable judgments would require
- Hands-on direct evaluation of products with range of AT products  (without reliable, valid testing protocols being available)
- Cadre of experts across disability areas (qualify as expert witness) with  statistically valid usability results
- Forces decision-making into disability type value judgments

## General Technical Requirements(Adopt-2, Adapt-3, Reject-3)

- Will not adopt (same reasons as functional performance)
- 1.2.A Closed Products and Functions
- 1.2.E  Audio Information
- 1.2.F. Visual Information
- Scope Concerns (will likely adapt and limit application)
- 1.2. D.  Pass Through
- 1.2. G.  Color (OK when limited to web/software)
- 1.2. H.  Text Size (OK when limited to web/software)

## Hardware Aspects of Products(Adopt-2, Adapt-2, Unknown-2)

- 2.1.D.  Touch Operated
- Sept version = functional performance, will not adopt (may adapt to use mechanical control standard)
- 2.1.E.  Standard Connection
- scope of application, may restrict
- clarity on “publicly available industry standards”

## Products with Speech(Adopt-3, Adapt-2, Reject-1)

- Will not adopt (not verifiable per vendor data)
- 2.2.B. Interference with Hearing Device
- Will likely adapt
- 2.2.D.  Volume
- “Maximum volume level must be at least” contradicts itself
- Unsure if 80dB is appropriate either as minimum or maximum
- Unsure if 50 dB is appropriate and what “controlled volume” is
- F.  Volume Reset
- Will likely delete exception for headsets/headphones, public use headsets must have reset for liability reasons

## User Interface and Electronic Content(Adopt-9, Adapt-11, Reject-1, Unknown-2)

- Scope concerns with this section - “These provisions apply to all electronic user interfaces and content.”
- 	- Scope of H, L, M, P, Q, R, U, V and W seems OK. All are limited by embedded standard wording to web, applications, or platforms
- 	- Scope of A, B, C, F, I, K, N, O, S, T of major concern.  Moved from web/software to broader scope.
- 	- Items D and E are new and unclear.
- 	- Item G seems to duplicate 1.2-B (Flash)
- 	- Item J will not adopt (Audio Turn-off), was partially an A/V standard but requirement was expanded and application scope was broadened.

## A/V Content or Players(Adopt-2)

-  Likely adopt both standards – might use different term than “functional equivalent” in standard to avoid confusion with the concept of equivalent facilitation in Subpart A.

## Real-time Voice(Adopt-3, Adapt-1, Reject-1, Unknown-1)

- Will not adopt A – Accessibility Configuration as technical standard (may include as state policy or in other provisions)
- Will likely adopt B (Real-time Text), C (Voice Terminal) but note complexity of B & C will eliminate ability to do internal review, will result in reliance on vendor assurance.
- Will likely adapt D (IVR) -  revise to address exclusive use of and efficiency “direct access” versus relay assisted for mixed voice/text users.
- Unsure of F (Video Support)

## A/V Content(Adopt-2, Adapt-3)

- Will adapt 6.A (Synchronized Alternatives),
- 	6.B (Captions and Transcripts), and
- 	6.C (Video Description)
- 	– covered entities in state unable to deliver 100% level required (100% of all products, 100% captioned and described.
- Will adopt  D and E.

## Info, Documentation and Support(Adopt-1, Reject-2)

- Will adopt 7.1.A (Accessible Documentation)
- Will not adopt 7.1.B (Keyboard Shortcuts) or 7.2.A (Support Services)
- 		Review verification of ALL keyboard shortcuts –
- 		not helpful in decision making
- 		Impossible to verify AT expertise of IT vendors

## Content Format and Authoring Tools(Unknown-15)

- Unsure of all 8.1 and 8.2.  Probably OK as long as scope is clearly applicable to software and authoring tools.
- If intent is to scope to all electronic content, all files, email, etc. – Will not adopt or will restrict scope.