EIR Accessibility

Fr​equently Asked Questions

Electronic Information Resources (EIR) Accessibility​

What are the specific job duties of a state agency EIR Accessibility Coordinator?

DIR administrative rule does not specify mandatory requirements for the position, as functions will vary based on the size of the agency. DIR has posted examples of agency accessibility coordinators' roles and responsibilities we have received from other agencies. It is the responsibility of each agency to identify the specific job duties of their EIR Accessibility Coordinator.

Does DIR provide compliance reviews for state institutions and agencies that go beyond the IRDR questionnaire?

The Information Resources Deployment Review (IRDR) is the formal tool that DIR uses as a compliance review for state agencies and institutions of higher education. Occasionally, and depending on the scope of an agency’s request, DIR may review policies and specific targeted web pages and provide feedback on compliance items that go beyond the IRDR questionnaire.

Are there any websites that DIR can recommend to track federal laws?

Note that Section 508 of the ADA Rehabilitation Act is the only federal accessibility law that DIR monitors. However, your agency may fall under other federal laws/statutes and requirements because of your funding source, the lines of business and/or the services you provide.

DIR tracks updates related to the federal Section 508 accessibility standards, as well as the World Wide Web Consortium (W3C) and Web Content Accessibility Guidelines (WCAG) from their websites. WCAG and W3C are international organizations that develop standards for making websites accessible. WCAG has published version 2.0 of their guidelines. These revised guidelines may have a future impact on the Section 508 standards because the current law was last amended in 1998.

What external EIR accessibility resources are available to state agencies?

EIR accessibility services are available through Comprehensive Web Development and Management Services offered through DIR's Cooperative Contracts program. State agencies should review vendor information to ensure that the EIR accessibility services needed are offered through the contract.

Do webcast and/or real-time files posted to the web need to be in an accessible format?

An agency’s accessibility policy should address its plan for either posting accessible recordings and/or accommodating requests from the public for alternate formats of those recordings. When an agency posts audio or video recordings on its website, it should seek to ensure that those files are also available in an accessible format. 1 TAC 213​.12 and 1 TAC 206.50 (b) requires that upon receiving a request for accommodation of a web cast, the agency is then obliged to provide an alternative form of accommodation, such as a transcript.

The following is an example of language that may be included on an agency’s website to advise the public on how they can request an accessible version:

"If you use assistive technology and the format of any material on our website interferes with your ability to access the information, please contact (your agency’s information). To enable us to respond in a manner most helpful to you, please indicate the nature of your accessibility problem, the preferred format in which to receive the material, the Web address of the requested material, and your contact information."

We post audio files of our board meetings on our site. In order to make the files accessible, would we also have to include a text file of the meeting or would the minutes from the meeting suffice?

If an agency chooses to provide an audio recording of its board meeting, a transcript is generally considered to be an alternate format for the recording. Unless the agency’s board meeting minutes include essentially everything that was said in the meeting, it is not considered the same as a transcript. That said, minutes can certainly be posted in connection with the recording, however, should the agency receive a request for alternate accommodation, the agency is then obliged to provide an alternative form of accommodation, such as a transcript (see 1 TAC 213.12 and 1 TAC 206.50).

Do you have examples of agency EIR accessibility policies that address some or all of the requirements of 1 TAC 206 and 1 TAC 213?

Policies from selected state agencies include:

Information about file formats

Does the agency's EIR accessibility plan need to be published on the agency's website?

Agencies are required to develop a written plan for their internal use, which may be referenced by policy, but it is not necessary to post that plan on their website. However, 1 TAC 213.12 requires that an agency's EIR accessibility policy be published on its website.

Are there accessibility standards that state agencies are required to follow?

State agencies and institutions of higher education are required to follow the 1 TAC 206 and 1 TAC 213.12 rules.

You may additionally choose to adopt specific standards or provisions within Web Content Accessibility Guidelines (WCAG) 2.0 or Section 508. For information about conformance requirements for WCAG 2.0, see Understanding Conformance.

Should you choose to adopt provisions of WCAG or Section 508 standards in your policy, you will need to specify the detail regarding how you will implement these standards in your accessibility plan.

Does DIR evaluate vendor VPATs to verify they are compliant with TAC accessibility rules?

A VPAT (Voluntary Product Accessibility Guide) is a vendor-produced document used by state agencies to assist in making preliminary assessments regarding the levels of accessibility of EIR products and services.

DIR’s administrative rule, 1 TAC 213.18, requires vendors to have VPATs or an equivalent for their products, but it is each agency’s responsibility to evaluate the VPAT(s) for themselves and determine if the product meets their accessibility requirements. Each state agency or higher education institution is responsible for writing all requirements, including accessibility, for the products and services sought for their organizations. Agencies make their own purchasing decisions based on their needs, and evaluate requirements against availability of product functionality, conformance with statewide standards, and other factors.

Each agency is responsible for verifying that a VPAT is compliant with TAC accessibility rules. VPAT information should be validated by the procuring agency through accessibility testing before contract execution.

Lack of conformance to accessibility standards does not exclude an agency from purchasing that product. It is up to the agency to evaluate the vendor’s responses to determine if a product meets their requirements.