Roadmap to Digital Equity

Last Updated: 11/20/2024

Introduction

The Colorado Department of Personnel & Administration (DPA) recognizes that technology plays an increasingly critical role in all aspects of life including, but not limited to, the abilities of individuals to participate in the workforce, seek and understand information, and meaningfully interact with government agencies. Digital equity is vital to our values and a fundamental component of our mission: to create a Colorado for all by enabling the consistent and seamless delivery of quality government services.

• DPA is committed to providing inclusive and equitable information, services, and programs to all individuals regardless of disability or difference.
• DPA is committed to ensuring that all information and communication technology (ICT) used by the department meets, at a minimum, all applicable Levels A and AA success criteria of Web Content Accessibility Guidelines (WCAG) specified by the Governor's Office of Information Technology (OIT). 
• DPA recognizes that the process of achieving digital equity must be ongoing, iterative, and evolving. 

This resource is divided into 3 main sections to help you learn about:

• Why Is This Roadmap Important (Legal Requirements) - In addition to our mission, vision, and values necessitating our pursuit of digital equity, we are obliged through a variety of laws to ensure that our services, programs, and activities meet internationally recognized accessibility standards.
• What We Are Doing (ICT Accessibility Goals & Strategies) - We have 3 primary goals supported by a wide variety of activities. We have included milestones, barriers, and next steps for each of our goals.
• Where Is Our Timing (Accessibility Findings & Improvement Schedule) -  We are committed to transparency by sharing our progress, plans, and anticipated timeframes with stakeholders. 

Legal Requirements

Colorado Laws

HB21-1110

On June 30, 2021, Colorado HB21-1110 strengthened Colorado’s laws protecting individuals with disabilities from discrimination. HB21-1110 requires that public entities make their information and communication technology (ICT) accessible. The Governor’s Office of Information Technology (OIT) established Technology Accessibility Rules that define compliance and identify obligations for public entities. 

Federal Laws

Title II of the Americans with Disabilities Act (ADA)

Title II of the ADA mandates that governments ensure that people with disabilities have equal opportunities to benefit from their programs, services, and activities. In practice, this means that governments must engage in effective communication, provide reasonable modifications and/or accommodations, facilitate access, and adhere to applicable standards. These steps help to ensure that individuals with disabilities can fully participate in all aspects of civic life. In April 2024, the Department of Justice published updated rules under Title II of the ADA regarding Nondiscrimination on the Basis of Disability: Accessibility of Web Information and Services of State and Local Government Entities. The rule establishes clear accessibility standards for digital resources, including websites and mobile applications. The requirements of 89 FR 31320 are very similar to HB21-1110 and are based on WCAG conformance.

Section 508 of the Rehabilitation Act 

The Rehabilitation Act of 1973 was amended in 1998 to include accessibility requirements for electronic and information technology (EIT). While Section 508 is generally applicable to federal agencies, many governmental entities (including DPA) have incorporated Section 508 compliance into their own accessibility processes. In addition, recipients of federal funds may have Section 508 specific requirements. In practice, efforts to comply with Title II and HB21-1110 typically result in compliance with Section 508 requirements.

ICT Accessibility Goals and Strategies 

DPA’s goals, and strategies for achieving them, are designed to meet the evolving needs of members of the public, employees, and stakeholders while ensuring that we meet or exceed all applicable state and federal legal requirements. Key components of our strategy, which are discussed in detail below, include:

• Accessibility Policy, Procedure, and Practice Development - This includes establishing standards, guidelines, procedures, and policies that support and strengthen our commitment to accessibility.
• Staff Training, Awareness, and Empowerment - This includes developing and disseminating resources, training, and software designed to help staff be successful in their accessibility efforts. Areas of focus include best practices, legal requirements, procurement, and content authoring. 
• Procurement Guidelines, Vendor Engagement, and Accessibility Compliance - Communication, documentation, and engagement are key to ensuring that vendors and partners can meet or exceed our standards. 
• User Feedback and Continuous Improvement - Our user-centric approach requires inviting, encouraging, and acting on user feedback (from both internal and external stakeholders).
• Monitoring and Reporting - DPA is committed to ensuring that all efforts related to digital equity are meaningfully monitored. Monitoring enables us to share statuses transparently, report on success metrics, and make data-driven decisions. 

Establish ICT Priorities 

DPA will, on a recurring basis, inventory all of DPA’s websites, applications, and other ICT and will: 

• Prioritize accessibility auditing and remediation efforts. This effort will be based, where applicable, on: 
  • OIT recommendations for prioritization
  • Data regarding the number of users (internal and external) 
  • Considerations such as continuing operations, delivering the best service, and safety
  • Stakeholder feedback
  • Legal requirements
  • Organizational capacity
  • Strategic alignment to leverage existing initiatives and resources
• Track accessibility compliance, where applicable, based on:
  • Auditing 
  • Testing
  • Vendor-supplied documentation (such as VPATs)
  • The availability of alternative formats and processes
• Maintain, where possible and applicable, contact information for key stakeholders in order to facilitate communication.

Employee participation, leadership support, and vendor relationships will greatly influence DPA's success in these efforts.  

Milestones

• June 2023 - DPA resolved more than 2,500 accessibility issues and achieved full WCAG 2.1 compliance on 51% of its primary public websites.
• September 2023
  • DPA achieved full WCAG 2.1 compliance on its primary public websites.
  • DPA achieved the highest average accessibility compliance score among monitored State agencies.
• November 2023 - DPA completed initial inventories of all internal and public websites and applications.
• December 2023 - DPA began reaching out to key vendors for accessibility information.
• February 2024 
  • DPA completed accessibility audits on 40% of its applications.
  • DPA launched its internal accessibility tracking dashboard to share progress in real time with stakeholders about websites, applications, and documents.
• March 2024
  • DPA notified 34% of vendors about accessibility requirements.
  • DPA published a public notice to all vendors and contractors regarding accessibility compliance requirements. 
• May 2024 - DPA’s cumulative application accessibility audit total reached 65%.
• June 2024
  • DPA authored multiple independent patches (or bug fixes) to address accessibility issues on vendor-supported platforms, resulting in the resolution of more than 100 accessibility issue occurrences. 
  • DPA resolved more than 5,000 accessibility issue occurrences in vendor-hosted web-based applications.
  • DPA’s cumulative application accessibility audit total reached 84.2% including 100% of high-priority applications and 82% of medium-priority applications.
  • DPA’s cumulative vendor notification total reached 98.5% including 100% of high-priority applications and 82% of medium-priority applications.
• July 2024 - DPA began converting more than 340 inaccessible employment-related documents to public web content to improve the availability, accessibility, and accuracy of information. 
• September 2024
  • DPA’s cumulative application accessibility audit total reached 93%.
  • DPA successfully reengaged with 50% of previously non-responsive vendors.
  • DPA identified initial internal inaccessible ICT applications for decommissioning and replacement. 
• November 2024
  • DPA authored multiple independent patches (or bug fixes) to address accessibility issues on vendor-supported platforms resulting in the resolution of more than 61,632 accessibility issue occurrences. 
  • DPA’s employment-related document conversion project was 69% complete, benefiting at least 5,163 website visitors since it began. In total, converted material has been viewed more than 15,350 times. 

Barriers

• External Tools: Some vendors of third-party created and hosted applications, including subscription-based services, are not currently contractually obligated to ensure accessibility. 
• Inventorying: Some secure employee-created resources cannot be inventoried or monitored due to security requirements and similar constraints.   
• Data Availability & Accuracy: Occasionally, data about digital solutions are missing or inaccurate. In these scenarios, DPA faces unique challenges in notifying stakeholders, testing solutions, and resolving accessibility issues.

Next Steps

• External Tools: DPA will continue to engage with vendors and, if needed, identify alternative resources or processes to replace inaccessible solutions. 
• Inventorying: DPA will continue to encourage its employees to contribute to relevant inventories through communications, policies, and procedures. If necessary, DPA will explore additional options with the Governor’s Office of Information Technology.
• Data Availability & Accuracy: DPA will continue to engage with other state entities, internal stakeholders, and third parties to assess ICT ownership, use status, accessibility compliance status, and remediation options.

Establish Expectations & Compliance Processes

DPA will ensure that all employees are aware, through training, policies and procedures, and communications, of their responsibilities in ensuring that their work products meet or exceed accessibility standards. In service to this effort, DPA will: 

• Establish policies, procedures, and practices to enumerate expectations clearly and consistently across the department.
• Monitor and acquire, when possible, accessibility tools (including specialized software) to help employees be successful. 
• Provide and make available training related to digital accessibility.
• Provide internal auditing services, one-on-one support, and documentation related to digital accessibility.
• Develop a robust communications plan to support employee education and attain goals. 
• Promote accessibility culture through a variety of mechanisms.
• Implement rigorous accessibility testing and evaluation processes for all ICT solutions. Processes include automated tools, manual testing, and user feedback to identify and address accessibility barriers.
• Establish mechanisms for users to provide feedback on the accessibility of ICT solutions.

Milestones

• July 2023 - DPA began creating accessibility resources on its Intranet. Note: This effort is continuous; additional accessibility tools, training, and guides are added regularly.
• September 2023
  • DPA developed a training plan for all internal stakeholder audiences, including 7 courses. 
  • DPA developed and began testing an introductory digital accessibility course intended for all employees.
• October 2023 - DPA finalized its initial Accessibility Testing & Remediation Process by Product processes and standards documentation.
• December 2023 - DPA obtained licenses for accessibility remediation tools for approximately 5.6% of its workforce through an OIT TAP program. 
• January 2023 - DPA launched a feedback form on its website to report issues or request assistance.
• February 2024 - DPA drafted procedures and a policy related to website and document accessibility. 
• March 2024
  • DPA drafted procedures and a policy related to accessibility in ICT acquisition.
  • DPA revised and completed its Digital Accessibility Communications Plan.
• April 2024
  • DPA, through interagency cooperation and a grant program, increased its total license volume for accessibility remediation solutions by 434%. Additional resources may enable up to 36% of employees to access and use these tools.
  • DPA launched new streamlined processes for document auditing and remediation assistance.
  • DPA launched new feedback mechanisms for ADA-related accessibility issues.
• May 2024
  • DPA launched a new version of its Accessibility 101 course. 
  • DPA began its Do Your Part Challenge Series in order to educate and reward employees for engaging in accessibility work.
• June 2024
  • DPA, through continued cooperation with SIPA and its vendors, obtained an additional distribution of licenses for document accessibility solutions. To date, grant-supported acquisitions have resulted in an estimated $42,210 savings. 
• September 2024
  • DPA continued course development for internal disability awareness and digital accessibility training. 
  • DPA acquired a collaborative web-based PDF remediation utility now available to all DPA staff. In addition to supporting remediation efforts, the tool facilitates document conversion (PDF to HTML or plain text) which enables staff to create more accessible and searchable content.
• November 2024
  • DPA’s new and improved Accessibility 101: Accessibility Fundamentals course, available to all employees and required for supervisors and those involved in web content management and communications, was completed by more than 35% of mandatory students within 2 weeks of launching.  
  • DPA’s Document Fundamentals training course was updated to include draft AG 3.0 standards and other best practices. 
  • DPA’s IT Accessibility Program, in partnership with Integrated Document Solutions (IDS), developed and published a digital accessibility best practices guide, Inclusive Branding, for all State agencies. 
     

Barriers

• Provisioning Accessibility Solutions: Cost is a significant barrier to securing and deploying accessibility solutions for productivity tools. 

Next Steps

• Providing Accessibility Solutions: DPA will continue to use an internal application process to ensure that individuals in need of solutions are provided access to them, explore purchasing options where appropriate, and engage in associated funding request processes.
• User Training: DPA will continue developing audience-specific training on digital accessibility topics. 

Expand Accessibility Expertise

The IT Accessibility Program team will, depending on budget and organizational needs, be expanded to help meet DPA’s needs. Additionally, existing staff in other work units whose duties include accessibility compliance activities will:

• Receive additional advanced training.
• Receive additional productivity support to enable accessibility auditing, testing, and remediation.
• Be empowered to advocate for and educate others on accessibility.

Milestones

• November 2023 - DPA engaged in the successful recruitment of an IT Accessibility Program Manager to oversee its digital equity efforts.
• February 2024 - DPA engaged in the successful recruitment of a Web Content & Communication Specialist to support accessibility initiatives across its web portfolio. 
• April 2024 - DPA successfully recruited a Remediation Support Specialist to support document auditing, remediation, training, and advocacy.
• May 2024 - DPA trained two existing staff on advanced document remediation techniques.
• September 2024
  • DPA provided access to vendor-led training to at least 32 staff.
• October 2024 
  • DPA joined the International Association of Accessibility Professionals (IAAP).
  • DPA launched an internal application process for IAAP participation and certification sponsorship. 

Barriers

• Additional Staff: Budgetary limitations create challenges to expanding the IT Accessibility Program team. Formalizing professional duties related to accessibility for existing employees, while a future goal, is not a reasonable objective at this time.

Next Steps

• Additional Staff: Existing staff who are identified by their supervisors, or who otherwise volunteer to engage in accessibility tasks, will continue to receive all available support. IT Accessibility Program team expansion will be considered as fiscal realities allow.

Accessibility Findings & Improvement Schedule

DPA is currently auditing, testing, and remediating a wide variety of ICT. The following addresses trends identified during these processes, resolution plans, and the status of individual products.  

• DPA has approximately 100 websites including external (public-facing) and internal (secured) resources. At least 49 websites are expected to be in active use on or after July 1, 2024.
• DPA owns, operates, or is otherwise responsible for various applications including web-based and installed solutions. Around 70 applications are expected to be in use on or after July 1, 2024. Of these: 
  • At least 35% are wholly vendor-managed. DPA has no ability to alter the accessibility of the solutions directly. DPA actively engages with vendors to help identify and resolve issues where possible.
  • Around 32% are subscription-based products. DPA has no contractual ability to require or request accessibility improvements and is actively investigating alternative solutions for inaccessible products. 

Issues and Timelines

The goals described below do not, in any way, preclude or prevent available on-demand resolution options, including ADA Accommodations. Any individual impacted by inaccessible technology is strongly encouraged to participate in any applicable process.  

DPA’s approach to issue resolution is based on a variety of factors, including:

• Functional Accessibility: Technical accessibility issues have different impacts depending on context. DPA will continue to prioritize issues that may result in undermining, preventing, or making inequitable the use of any ICT solution. 
• Criticality of Solutions to Operations: Issues with solutions that are necessary for (1) official programs, services, and activities, (2) employee work duties, and (3) general operations will be prioritized over issues in non-essential solutions. 
• Responsibility: The DPA IT Accessibility Program provides guidance to individual work units and sets department-level objectives. Individual work units (including offices and departments) are responsible for ensuring they create, maintain, and act on accessibility transition plans for ICT that they purchase or are otherwise responsible for. Their plans may include variable timelines and address barriers to achieving compliance such as undue burden, fundamental alteration, or direct threat. 

Websites

DPA uses two platforms for websites: Drupal, managed by Tyler Colorado and SIPA, and Google Sites. DPA contributes content to these resources but cannot independently resolve issues that exist on the platforms.

Potentially Significant Issues

• None identified.

Disability Categories Impacted

• Not applicable.

Resolution Plan

• In Progress: Continue to monitor user-contributed content and platforms for potential accessibility and seek resolution with appropriate vendors as applicable.

Multimedia Content 

DPA has a moderate volume of multimedia content including training videos, employee orientation videos, and recorded meetings with audiovisual content. 

Potentially Significant Issues

• Lack of consistent human-verified captions
• Lack of consistent audio descriptions

Disability Categories Impacted

• Auditory
• Visual
• Cognitive, learning, & neurological

Resolution Plan

• In Progress: Provide critical data in alternative formats by July 1, 2024.
• In Progress: Add captions and audio descriptions by July 1, 2025.

Web Applications

DPA has a variety of web applications in use including subscription-based services, custom vendor-developed solutions, and OIT-developed solutions. DPA’s web applications are diverse and have significant variability in accessibility compliance and accessibility support (where applicable).  In situations in which full compliance is not feasible, DPA has implemented a robust accommodation process to ensure users who need access have an equally effective alternative.

Potentially Significant Issues

• Inconsistent keyboard support
• Insufficient color contrast
• Poor quality or missing alternative text
• Poor quality or missing labels
• Poor quality or misleading links

Disability Categories Impacted

• Auditory
• Visual
• Cognitive, learning, & neurological
• Physical
• Speech

Resolution Plan

• In Progress: Notify all vendors of accessibility requirements before July 1, 2024.
• In Progress: Resolve or seek resolution of high-priority accessibility issues in vendor products by July 1, 2024.
• In Progress: Begin replacing inaccessible solutions and remediating low to medium-priority accessibility issues by July 1, 2025.

Documents

DPA has more than 7,000 publicly available electronic documents and thousands of documents for internal use. Documents include PDFs, Microsoft Office documents, Google Workspace documents, and other document types.  

Potentially Significant Issues

• Missing or improper structural elements
• Missing or incorrect tags
• Poor quality or missing alternative text
• Poor quality or missing labels
• Poor quality or misleading links

Disability Categories Impacted

• Auditory
• Visual
• Cognitive, learning, & neurological
• Physical
• Speech

Resolution Plan

• In Progress: Audit and remediate impactful issues on all critical and high-priority documents, using internal and external solutions, by July 1, 2024.
• In Progress: Convert documents to accessible formats where practical by July 1, 2025.
• Not Yet Started: Audit and remediate non-archival low and medium priority documents by April 20, 2026.

Technology Solutions and Statuses

Applications & Websites

The following solutions snapshot excludes resources that are used exclusively for internal purposes. Secured information about internal resources is available to all DPA employees on MyDPA, the department’s Intranet. Only publicly-available ICT owned and managed by DPA are shown below.  

Status Summary by ICT Resource

Documents

DPA publishes a wide variety of documents, including Google Docs, PDFs, and Microsoft Office documents. DPA employees create and share, for internal work purposes, a significant volume of documents. 

Document Remediation Efforts by Actor

Remediation totals below do not include remediation efforts by DPA staff that have not been reported to DPA’s IT Accessibility Program. The number of remediated document pages is likely to be moderately to significantly higher than the figures below. 

The cumulative total shown below includes remediations completed between December 2023 and June 2024. 

Total Document Pages Remediated by Month and Actor 

Documents on Colorado.gov 

Data below include only documents published through Colorado.gov. Documents hosted on other sources (such as Google Drive) are not included. Known accessibility issues are included only for documents that have been audited or tested; a significant number of documents have not yet been evaluated. A large volume of publicly available documents are no longer in active use. 

Colorado.gov Document Totals & Known Issues: Fiscal Year 2024-25, Second Quarter