EIR Accessibility Plan

Lamar State College Port Arthur (LSCPA) is committed to providing everyone equal access. We want everyone to be able to access information easily, including individuals with disabilities. This document (the Plan) outlines LSCPA’s strategy for compliance with Texas Administrative Code (TAC) requirements pertaining to accessibility of websites and other electronic and information resources (EIR) for individuals with disabilities.

The Plan is designed to assist LSCPA units and EIR owners with meeting the requirements for developing, procuring, maintaining, and using EIR in a way that meets accessibility requirements.

1. Requirements
2. EIR Accessibility Coordinator
3. EIR Accessibility Exception Requests
4. EIR Accessibility Team
5. Goals
6. Remediation
   1. Procured Products and Services
   2. Internally-Developed Applications
   3. Websites
   4. Processes for Future Development and Purchases
      1. Revise Web/Web Application Development Process
      2. Revise Software Acquisition Process
7. Training Plan
8. Compliance Monitoring and Reporting
   1. Procured Products and Services
   2. Internally-Developed Applications
   3. Websites
   4. Reporting
9. Document Control

Requirements

Accessibility requirements established by the Texas Department of Information Resources (DIR) were developed to ensure that individuals with disabilities have access to and the use of resources comparable to the access and use available to individuals without disabilities, including members of the public.

See Policies, Regulations and Standards.

EIR Accessibility Coordinator

The LSCPA EIR Accessibility Coordinator (EIRAC) is the central point of contact concerning accessibility issues and solutions for our institution's electronic and information resources. The EIRAC serves in a coordinating and facilitating role, with responsibilities that include the following:

1. Develop, support, and maintain EIR accessibility policies, standards, and procedures.
2. Process EIR accessibility exception requests and maintain records of approved exceptions.
3. Develop and support a plan by which EIR (including websites and web applications) will be brought into compliance. The plan shall include appropriate goals, a process for corrective actions to remediate non-compliant items, and progress measurements.
4. Maintain documentation of accessibility testing validation procedures and results.
5. Facilitate a response to concerns, complaints, reported issues, and Texas DIR surveys.
6. Facilitate the development or acquisition of training solutions necessary to meet EIR accessibility-related requirements.

EIR Accessibility Exception Requests

If LSCPA determines that compliance with a standard would impose a significant difficulty or expense, an exception request shall be submitted to the EIRAC using EIR Accessibility Exception Request form published on LSCPA’s IT Accessibility website. The EIRAC shall evaluate the request, formulate recommendations regarding the request, and forward it to the President who will specify an expiration date for an approved exception.

• EIR Accessibility Exception Request Form

EIR Accessibility Team

LSCPA shall form an interdepartmental team representing key areas of the organization affected by EIR accessibility requirements. This team will have the following goals:

• Facilitate progress in EIR Accessibility across the college
• Identify issues and work to resolve them as a team.

The team will be comprised of the EIRAC and representatives from the following areas:

• Academic Affairs
• Disability Services/Special Populations
• Distance Education
• Faculty
• HR
• Information Technology
• Library
• Procurement
• Public Information
• Workforce & Continuing Education

Goals

LSCPA has identified the following revised goals for bringing its EIR into compliance.

• Web Content
  • Scanning
    • Select and procure web accessibility scanning tool.
      • College website - completed 5/9/2019 (Siteimprove)
      • Blackboard - Fall 2020 (Ally)
    • Begin monthly site scans and remediation of errors.
      • College website
        • Initial scan performed 5/19/2018.
        • Automated scans performed every 5 days.
        • Remediation began 5/19/2018.
      • Blackboard
        • 6/30/2020: Goals and remediation plan under development.
  • Web Pages
    • FY 2020
      • Siteimprove Accessibility score
        • Meets or exceeds industry benchmark (74.1) - Completed in Year 1
        • Meets or exceeds 90 - Completed in Year 2
      • Percentage of A/AA Errors Remediated
        • 50% Reduction Year 1 - Completed in Year 1
        • 10% Reduction Each Subsequent Year - On Track in Year 2
      • Percentage of A/AA Warnings Remediated
        • 50% Reduction Year 1 - Completed in Year 2
        • 10% Reduction Each Subsequent Year
      • Percentage of Pages with 0 Level A/AA Errors
        • 50% Reduction Year 1 - Completed in Year 2
        • 10% Reeuction Each Subsequent Year
    • FY 2022
      • In FY 2021, Siteimprove implemented a new scanning engine (NextGen) radically changed the way it identifies issues and potential issues. This resulted in a new scoring mechanism, new industry benchmark, new performance indicators, and new reporting. 
      • Benchmarks will be identified on 8/31/2021 and new goals will be identified based on those benchmarks.
  • PDF Documents
    • 6/30/2020: Goals for accessibility of PDF documents are being revised based on an initiative to reduce the overall number of PDF documents on the website.
    • 8/23/2021: Number of PDFs requiring accessibility scanning reduced from ~900 (2018) to 516.
• Applications
  • Create form for EIR Exceptions
    • Completed November 2018
  • Implement EIR Exception Process
    • Completed November 2018
  • 6/30/2020: Additional goals for application accessibility are being revised.
• Training
  • 6/30/2020: Fundamental/Introductory: This goal is being revised based on suitability of available training products.
  • Blackboard: Under development.
  • 6/30/2020: Training for PDF accessibility will be included with web/content training.
  • 8/23/2021: Pilot department has been trained using Siteimprove Academy. Training will begin rolling out to the rest of campus beginning October 2021.

Progress Reports

Update - 8/23/2021

In February 2021, Siteimprove radically changed the way it reports on accessibility issues and the new method of reporting is incompatible with the original method of reporting. As such, a new format for progress reports will be created. Progress will be tracked by academic/fiscal year instead of project year and the new baseline will be as of 8/31/2021.

Remediation

Brining LSCPA’s EIR into compliance involves assessment and review of EIR products and EIR development and procurement processes. Remediation will be prioritized based on criticality, number of users, and audience (e.g., general public, students, or employees).

Procured Products and Services

The EIRAC will work with Procurement, IT Services, and EIR Owners to identify procured EIR in use at LSCPA. The following actions will be performed for each EIR:

• Obtain VPATs or equivalent documentation.
• Perform automated and/or manual accessibility validation testing as appropriate.

For products and services that are not accessible, LSCPA will determine an appropriate course of action, which may include one or more of the following actions:

• Request an exception as per the EIR Accessibility Exception Request process.
• Identify alternate method or formats.
• Contact the vendor and determine the vendor’s plans for making their product or service accessible.
• Identify and investigate procurement of equivalent accessible products or services.

Internally-Developed Applications

The EIRAC will work with IT Services to identify internally developed applications in use at LSCPA. Each EIR will be tested using appropriate automated and/or manual accessibility validation tools. For applications that are not accessible, LSCPA will determine an appropriate course of action, which may include one or more of the following actions:

• Request an exception as per the EIR Accessibility Exception Request process.
• Identify alternate method or formats.
• Modifying the application.
• Replacing the application with a new internally developed application.
• Replacing the application with a procured application.

Websites

The EIRAC will perform weekly scans of the following websites:

• www.lamarpa.edu

This list will be updated as necessary. The EIRAC will work with IT Services to remediate non-compliant web templates, web parts, style sheets, programming, and any other technical aspects of the website. For the purpose of remediation, web-based applications will be considered Internally Developed Applications. The EIRAC will work with content creators to facilitate remediation of content; however, it is ultimately the responsibility of those individuals to create accessible content.

Processes for Future Development and Purchases

The EIRAC will work with IT Services and Procurement on the following process revisions:

Revise Web/Web Application Development Process

• Adopt universal design principles
• Test with SiteImprove prior to publication.
• For procured web products, include accessibility requirements and validation in the scope of work.

Revise Software Acquisition Process

• Establish a New Software Acquisition Workflow with Procurement
  • Approval by EIRAC
  • Final Sign-off by IRM
• Include Accessibility criteria in ranking in RFP
• Include State of Texas Requirement for VPAT
• Include State of Texas Requirement for Indemnification

Training Plan

The EIRAC will oversee compliance monitoring and reporting.

Procured Products and Services

The EIRAC will work with Finance and Operations to develop and implement a compliance monitoring plan.

Internally-Developed Applications

The EIRAC will work with IT Services to develop and implement a compliance monitoring plan.

Websites

• Compliance validation reports will be provided to EIR Owners on a monthly basis.
• The EIRAC will work with IT Services to remediate non-compliance for technical aspects of the website beyond the control of content creators.
• The EIRAC will work with content creators to facilitate remediation of content; however, it is ultimately the responsibility of those individuals to create accessible content.

Reporting

Compliance reporting, including progress reports, will be distributed to the EIR Accessibility Team and executive management on a regular basis.