Lost in the WCAG Woods? A Roadmap for ADA Title II Compliance

[On screen: title card, "Lost in the WCAG Woods?", with the NAGW 2026 badge. Brian speaks on the right; on the left, the deck's slides and illustrations, key lines from the talk, and under them the current section ("NAGW 2026, Milwaukee: Brian Mitchell, President, interGen" at the start) and a roadmap tracker, steps 1 to 8, with a "Step N of 8" card as each step begins. Early on, photos of the NAGW 2026 conference room.]

Welcome

Seems like an appropriate place to begin, shall we? My name is Brian Mitchell, and I thank you for coming to the session as we peer over the edge of the cliff and stare before the gates of Mordor to finish out what is a long journey many days of workshops, two or three days of workshops, but I'm sure it feels like many at this point. So I really, really appreciate you all showing up for this last session. So my hope is to provide a nice end cap experience for you. I'm going to lay out a roadmap or a journey toward WCAG compliance, and I'm going to try and do it in a way that's a little bit entertaining. And hopefully it's informative and provides a nice way to finish out. interGen's been around for 20 years, a little over 20 years, as an independent web development firm, providing websites for nonprofits, businesses, and government organizations all over the continental United States. We've got clients in Florida, California, out east, down in Atlanta, so we've been happily serving clients for 20 years. So interGen was founded in 2006, focused on website development. This is only my second time attending an NAGW conference. The first time I spoke was in 2022 down in Little Rock, Arkansas. And I'll talk about that a little bit later in the conversation. I was super compelled, one, because of the subject matter, which sounds crazy, but that'll make sense later on. Also, I'm from Milwaukee, Wisconsin. So welcome to my hometown. I'm happy to have all of you here.

Wisconsin, mapped

I want to talk a little bit about geography. interGen is a web development organization. We focus on people, places, profit, and passion. Those are our four core values. Again, we've always been a human-driven organization, even though we're a technology firm. I love context. You all serve people in a particular geographic context. And it's not just about the environments that you operate in. It's the nature and character of your community. That, of course, is true for Milwaukee as well. And I want to zero in. We're going to see what the geek factor on this room is. Does anybody know who Gary Gygax is? So, Gary Gygax is from Lake Geneva, which is a little resort community a little southwest of here. And he is the inventor of Dungeons & Dragons. So, which has had a really nice thank you, Stranger Things, for bringing it back. If I seem a little too excited, I'll try to dial it back just a little bit. So, Gary Gygax is from Lake Geneva, Wisconsin. Karen Wynn Fonstad is a cartographer from the University of Wisconsin at Oshkosh. She is known for creating the Atlas of Middle-earth. She read The Lord of the Rings no fewer than 30 times before she laid out the maps of Middle-earth. If you're a real geeky fantasy sci-fi person, she also did the Atlas for the Dragonriders of Pern series. And then, of course, Milwaukee. Marquette University, in the Raynor Memorial Libraries is the home of the original handwritten manuscripts for The Lord of the Rings trilogy. Kind of amazing. So, I am convinced that nowhere on Earth is the road to Middle-earth shorter than somewhere in the triangle that exists between Oshkosh, Lake Geneva, and Milwaukee. And if any room at this conference is better positioned to go on a journey towards WCAG compliance, it's the folks sitting in this room. So, thank you for joining me again. So, WCAG 2.1, the standard for every state and local government website . And I'm acknowledging that some of this is going to be reviewed, but I'm hoping to put it in a framework where you recognize the parts that you got and you recognize the gaps. And so, hopefully, in charting out this course from where you are now to compliance, you'll be able to figure out where you are in the journey and what you need to backfill to get there.

ADA Title II covers you

So, like Bilbo, most agencies didn't go looking for this adventure. It came to them, right? It knocked on their door unexpectedly one afternoon. April 2024, the Department of Justice published its final rule under ADA Title II. It covers all state and local governments, counties, cities, special districts. We have some clients that kind of sit in this weird in-between of schools, transit, libraries. They all fall under the ADA because they're publicly funded institutions. So, all those folks would be covered as well. What it covers? It covers web content and mobile. So, if you're presenting anything on mobile apps, WCAG matters for that as well. It also covers your vendors. Anybody using third-party software that integrates with your website, you are responsible for your vendors' WCAG compliance. Let that soak for a second. Any vendors you're using to provide payment portals, video services, you are responsible for their compliance. So, that's kind of the scary part. On the other hand, the standard itself is straightforward. It's 50 constraints, 50 rules, right? And you can work through those. 30 of them are level A. 20 of them are level AA. And they're testable success criteria. Compliance is not a feeling. It's not a widget. We played the widget. And, in fact, we still play the widget game a little bit. I'll talk about where that fits in. And I'll talk about the concerns about that. But it is a checklist that you can be measured against. So, there are very specific criteria.

The deadline moved

The deadline moved. The inventory didn't. I'm sure most of you are aware that about the time most people started thinking about this, they were already past the original deadlines. And the laws were changed to adjust to add an extra 12 months out of the conversation. If you're serving [a population of] 50,000 or more, you need to be compliant by April of 2027. If you're serving under [a population of] 50,000, you have an extra year tacked on to that. The original dates were pushed back. DOJ's interim final rule pushed back everything by one year. The extension changed the calendar, not the work. Years of agendas, PDFs, forms of pages are still on your site. One more year, not one page less. The extra year is a gift. Only if you take advantage of it.

Four buckets

I talked about those 50 criteria, where they fit. They fall into four buckets. So, it's one standard. And these are the four buckets they fall into. Perceivable. It includes things like alt text, captions, and appropriate contrast ratios. And as I get into the weeds just a little bit, if anyone's like, hey, what is that? Like, please, like, flag it down and we'll stop and talk about where those things play out. Operable addresses things like keyboard access, meaning can we navigate the web page effectively without a mouse or a trackpad. Visible focus, can I tell the elements that I'm on based on what is selected. And then time limits, do people have enough time to work through the content without running into timeouts or issues along those lines. So, keyboard access, visible focus, time limits, understandable. Are things labeled? Are there clear error messages? So, when something goes sideways, is the error messages that pop up? How do those make sense? And then this was another human element that popped into an earlier conversation is plain language. So, there's a lot of discovery about how simply and straightforward we're stating things. And that can be a tension point because sometimes language can be as technical because it's specific. Like, that is the right word for what I want to say, but is message sent, message received. And that's something we want to think about that does, that can move beyond the WCAG standards. So, all 50 of the criteria live within these four buckets. And when a criterion confuses your team, just ask which four of the buckets it falls into, which four of these things it protects. Because it's going after one of these four areas to make a website more usable.

How non-compliance bites

The black riders don't send a calendar invite. They show up at the inn at night. This is how not complying bites, right? So, it doesn't start with an audit unless you're ahead of the game. It starts with a complaint. That complaint, in the best scenario, is a resident of your community coming forward and saying, hey, I'm having a problem using your website. That allows you to remediate it in a way without quite as much pressure, but you still want to address those things in a timely and complete fashion. Demand letters are a little more pointed with a little bit more legal oomph behind them. We get into the Department of Justice and the Office of Civil Rights complaints. That certainly gets – so, you hear us ramping up the intensity of the concern. And then, of course, lawsuits can be filed. The way that you mitigate all of this is through good faith effort. And as I said earlier, good faith is not a feeling. It's a provable process. And the way you prove the process is by documenting it, knowing what's happening. So, we'll be talking about how to handle that process, what you want to work through. So, a documented plan, a current audit, a remediation log, visible progress, and I'll be itemizing those on a later slide in the deck. Agencies with that on paper are treated very differently than those that are like, we're trying real hard, right? We have a meeting every month, but there's no documentation to back that up. That's not going to stand well given any of the four things that I outlined earlier. So, we'll come back to what that looks like a little bit further down.

8 steps, 3 phases

So, here is the roadmap that we're going to lay out. These are eight steps spread across three phases. And this is a suggested roadmap for how you get from, I heard this compliance thing that matters and we should do it, to being in a really solid posture. I will frame this part of the conversation by saying, I'm not a lawyer, don't call me if you get the call or the complaint letter. Hopefully, you have good legal counsel to address those things. But this lays out a roadmap and if you put this in front of any legal counsel, they should be able to affirm in whole or in significant part, most of what I'm sharing with you today. So, the first thing you want to do is establish an audit and I'll break each one of these eight steps down a little bit further. But an audit is basically to say, what is our current state analysis? Where are we at right now? And that lays the groundwork. That's the foundation for that documentation process that I was talking about. Even if you're in a horrible spot, it lays the foundation. And in some ways, it gives you a very low bar to start making progress relatively quickly because you can establish, man, this is where we started and we're making good faith efforts to move forward. From there, we're going to look at workflows. We're going to look at templates, which might provide the only shortcut available in this journey. It's the one thing where you can get a lot of results with a modest amount of effort. Documents. I don't mean to swear one more time, but I've heard a lot of love for PDFs over the last 48 hours. People seem to appreciate the significance of looking at Word documents, whether it's PDFs or Word docs, PowerPoint presentations that are embedded in your website as downloadables. All that will fall into that bucket. And once we've sort of gone through that remediation phase, you all know the importance of establishing a permanent outpost, which means you're going to maintain a regimen of monitoring the site to make sure there's no backsliding in terms of what your processes are. Defining who owns the stewardship of the web presence moving forward. Ownership. Make sure that there's follow-through, right? Who's in charge of that piece? Reporting. And then vendors, which I alluded to earlier in the conversation. Acknowledging that they are on the hook, or you're on the hook, for their compliance as well. So eight steps over three phases. Let's take the first step on our journey.

Overlays are not a fix

I have made reference to overlays. And once upon a time, that was everybody's quick, you know, we can get there. And I will acknowledge we still maintain a partnership with UserWay. In addition to the JavaScript widgets that they provide as an overlay, there's two ways I would encourage. And I'm not, that's not a recommendation. I'm just acknowledging this is where we're at as a web development firm. So if we walk into a situation, first thing we do is come up with the plan, do the audit, walk through these steps that we're talking about. But putting an overlay on a website that is in horrible shape and that you've done zero remediation on it. It's a step. You've done something. Yay. So we do the audit. We'll do the overlay in the short term until we can get to a basic level of compliance. And then once we've gained some traction, we can get there. And then there are partners, UserWay happens to be in this list. They will also provide third-party audit. Hear that? Third-party audit. If you're checking your own homework, that's a tough argument to make. If you can point in a third-party that's been contracted outside of your services to come in and say, yes, this is where you're good, this is where you still have some work to do. And then accessiBe is everybody's favorite whipping post, maybe for good reason. They have been claiming that their widget would solve problems on any website, and it cost them a million dollars, to be wrong on that front. Back in, well, it's 2025. Yeah, April 2025. So they don't fix the underlying code. They don't address the issues. That's just sort of a bandage to cover over.

Step 1: Baseline audit

So here's each of those eight steps that I was talking about earlier. We're going to walk through them one at a time. First thing you want to do is provide an automated scan of the website. A good first blush. This doesn't cover the whole website, but if you just want to get a sense of how rough something is. And it's not, as we've acknowledged, there's going to be an ongoing monitoring piece. So you want something, one that you can run consistently the first time, but then you're going to put it on a schedule even after you've achieved remediation and compliance. So you want something you can repeat, that's the automated piece. And I think everyone in this room probably knows that simply passing the automated scan is step one. That does not equate to compliance is where you start, which gets us to step two, which is test by hand. Keyboard only, you're going to tab through your key workflows. Screen reader spot checks, whether it's NVDA on Windows or VoiceOver on a Mac, just to see how that works, how those voice tools work through your system. And then reflow deals with, a website should be able to zoom up to 400% and have the text reflow effectively to meet the standard. And then you're going to keep the report. So every time you do something, you're going to know what you did and track it. And you're just going to keep filing that away from now until forever. If you have experience with Git, it's an amazing tool. There's a technical hurdle to get over, so I don't want to pretend there's no learning curve. But if you have IT folks or your web developer, if they're well-versed in Git, Git is just a way of retaining changes in code over time. And what I'm going to say is mostly true. It's a write-only technology. So there are ways to rewind the history, but generally, Git is designed to make the change, and that change is captured forever. And you can rewind and say, oh, on this date, Chelsea did this, or James did that, based on changes in the Git repository. So Git can be a powerful tool for tracking. What's broken where? How often? If your last audit is more than a year old, it doesn't really qualify as a baseline anymore. You really sort of let the ball drop when it comes to the stewardship component.

What the scanners miss

What the scanners often miss. They'll miss alt text issues as it relates to images. And somebody was saying, they were talking about, they had a tool, they were using, I don't know if it was in the room. Somebody had deployed AI to automatically write their alt text, and they said one of the challenges they were having is that the team didn't like the suggestions that the AI was coming up with, so they would just delete the alt text. For what it's worth, I might be one of the more aggressively pro AI people here with all of the appropriate safeguards, but it's not hard to have AI look at an image. And look at the webpage that it's on to get the context for where the image sits and then have it recommend appropriate alt text. Because if you have a dog next to a fire hydrant, that image is going to, an image of a dog next to a fire hydrant, that's going to sit differently if it's on a page for the public library or the fire department. What the alt text on the image might be is going to change based on the context in which it appears. At its base, alt text is just describing what's in the image, a dog and a fire hydrant, but context does matter. AI can assist with that, of course with human review, of course. So, alt text, scanner, PDFs often fall outside of crawl, we'll talk about documents a little bit later on. Decentralized publishing, how many different ways you have to get content up on the website. Third-party vendors we've mentioned, payments, permits, agendas, video, all in someone else's domain, iframed into your website. That all falls under the umbrella that you're responsible for. Questions to ask during the audit. Who is able to publish content to the website? What do they publish? How do they publish? And which services need to go because they're never going to get compliant? A green score with a broken payment portal is still a broken payment portal.

Step 2: Resident tasks first

Check the route. Choose the road that matters to the people walking the most. So, the very first thing you want to look at are what are the pages that are getting the most traffic, and especially as it relates to user interface or user interaction. So, if you're doing a small municipality or a small village and you have a way to pay for a special garbage collection pickup, that's probably going to get some pretty regular traffic. Those are the types of processes that you want to go after first. So, look at the functionality of your website that's getting the most traffic and the most use. Those are the things that you kind of want to work through. Because those are the things that are likely to trigger that complaint that I talked about earlier in the presentation. So, pay a bill, apply for a permit, a license, or a job. Find meeting agendas and minutes. That cuts both ways, not just in terms of finding out what those are, but how the documents are managed on the back end. How to register for programs that are provided, and then contact the agency or report a problem. Rank them by the amount of traffic that that particular function or feature gets on the website. What the consequence of failure is. So, you can imagine if somebody can't pay for a parking ticket, that's going to be more serious than if they can't pay for the special garbage collection pickup, because there's legal implications for not paying for the parking ticket. So, how much traffic, consequence of failure. Is there an alternate path? Do they have another way of getting there? So, providing an alternate path can be one way to help deal with mitigation, and then, of course, the legal exposure, which I referenced earlier. A complaint almost always starts with a task someone couldn't finish. They were trying to do something. It's not just I couldn't search something. I was trying to do something. I couldn't do it. Okay?

Step 3: Fix the template

Helm's Deep. One breach of the wall endangers everyone. I talked about shortcuts. This is probably the only shortcut in the entire process. We know that if there's a problem with the contrast of the font used for your H1 headings on one page, it's probably a problem with the contrast on your H1 headings on lots of pages. The beauty is, with CSS, fix the H1 contrast issue at one time, you get it everywhere across the website. And what I'm saying is, if you're not a programmer or not geeky, it's basically just acknowledging if you can't tell the text from the background in one spot, programmers generally are going to have to fix that in one spot, and it corrects it across. And every page on your website. So a lot of, this is where a lot of ground can be gained really quickly. It's tempting to start here because you get a lot of success to point out. Look at all the green check marks we just created with one line of code, right? But if those aren't the biggest pain points for your end users, it's a vanity metric. We've got a lot of green check marks, but people still can't pay the parking ticket as a problem. Page layout, article templates, forms and form components, theme colors, typography, these are all things that a relatively small number of programming changes can have a really profound impact. A focus style fixed once in a template is fixed on a thousand pages, and it's where the remediation budget usually gets its biggest bang for the buck. Next is common breaches, this is where these types of fixes often fall short. Skip links, you don't want somebody that's using a screen reader to have to listen to your main menu on every freaking page that they browse to on your website. So you want to give screen readers an immediate opportunity to say yeah, I know the main menu structure, take me to the main content. Skip links, logical heading order, do you have six h3 tags on your page and no h1 tags, right? So make sure you're properly stacking where it's the old WYSIWYN, not WYSIWYG: what you see is what you need. Heading one is your most important, heading two is your second most important, heading three is your third most important. And ideally, if you're a web developer slash designer has done their job, the heading weight, size, and color reflects the relative importance. So there's an aesthetic incentive to choose the right heading weight based on where it sits in terms of importance for the content. So logical heading order, visible keyboard focus, we mentioned that briefly earlier. Menus that you can open by keyboard, so you don't have to click on it to be able to get to the menu to see what's going on or you can get there through tab key on your keyboard. Text contrast, you guys know the ratios from WCAG, already talked about reflow at a 400% zoom, meaning never carried by color alone. So you want to make sure that if you're communicating something to somebody in terms of status, that you get a check mark in addition to it changed to the color green to indicate success. Color cannot be the indication. These are the types of things that tend to fall short. Every form field is labeled, clear error messages, accessible names on buttons and icons. These show up on nearly every audit we run, and most are template fixes, not content fixes. So that's where you really want to be partnering with your web developer to understand how each of those things is reflected for assistive technologies.

Step 4: PDFs and documents

Into the Mines: PDFs. I'm not going to spend a ton of time on this, because I can tell everyone's had enough pain that it's easy to go after. Into the depths of Moria, dark, deep, and full of things buried long ago. Don't wake the Balrog by trying to remediate 10,000 PDFs in one sprint. Years of agenda, minutes, budgets, ordinances, forms, often untagged scans, a picture of text that a screen reader cannot read. Uploaded by everyone, owned by no one. The inventory tells you what to fix, what to convert, and what to retire. And I'm sorry I put those in the wrong order. The inventory should tell you what to retire, what to convert, and what to fix. And convert, it could be taking those items that just need to be converted into HTML, right? We hear about HTML first, right? I do have this bias, so this is sort of a, I'm always like, how do you know if something should be a PDF? Will somebody want to print it off and put it in their fridge? That's usually my bare minimum. And if you're using a platform, there's a lot of platforms that can automatically take HTML and export it as PDF and allow it to retain that context. So, always HTML first, but that's usually my bare minimum, is like, why would somebody want to print this thing off and put it on their fridge or not? So HTML first, remediate the high use service critical documents first. That ties in with, as we were talking about functionality. Archive carefully. The rule has exceptions for archived web content and some pre-existing documents. They're narrower. If residents need a document to apply for, access, or take part in a service, it's in scope. So, just know that if they need to fill out that form to do the thing, that should be at the top of your list. And then, fix upstream, accessible Word templates and export settings. Are there things that we can be doing in our workflow, and I'm going to get to workflow. Really hot and heavy in just a minute. Are there things that we can be doing in the workflow that encourage the content to be created with accessibility upfront? New PDFs are born accessible, so the archive stops growing faster than you can clean it up. The permanent outposts.

Staying compliant

So, we've already gone through the first two major phases. We've done the remediation. We've gotten to the happy place. How do we stay there? How do we build our permanent fortress? You can backslide and lose ground because of the flexibility of web. So, project compliance is about audit, fix, done. Twelve months later, you're back to where you started, unless you have a regimen for maintenance. Governance compliance. First, we're going to establish ownership over the publication of new information. Monitoring, reporting, and procurement are built into how your organization runs. Ownership, monitoring, reporting, and procurement are built into how your organization tracks information. Compliance that isn't governed slides back within a year. If these systems are not built in from the ground level, you're going to be right back to where you were.

Step 5: Recurring monitoring

Scheduled scans shows what's -- I'll confess, I almost pulled it. You might suspect that I used some AI generating the deck. Claude decided the word Palantír was appropriate for this conversation. We'll shake that off. A Palantír shows you what's happening -- if you know the Lord of the Rings, it didn't end well for Sauron and the Palantír. Shows what's happening across the realm -- the all-seeing eye, right? It shows problems, but it doesn't fix them. So to do that, we need to maintain scheduled scans on a regular scheduled basis -- automated, weekly, or monthly. Quarterly checks. Test the key workflows by hand. That goes back to those forms and processes that we were talking about, payment, whatever. Alerts -- when the new content introduces errors. How do we know? How do we catch those errors? Trends, not snapshots. So, as you're doing those scheduled scans, you're going to keep your scorecard. How are we doing over time? Are we getting better? Are we sustaining? Are we losing ground? And just the act of measuring will encourage long-term compliance. And then the goal is to catch a regression, not even the week it's published, not a month after the complaint arrives. I would say the goal is to catch the regression before you get published, right? So we'll talk about how to do that effectively.

Checks at the point of creation

This is one of my favorite topics of all time, if you've known me for more than five minutes. There's lots of fantastic vendors here. I had somebody -- how many of you are familiar with Joomla? All right. It's about half the room. I'll take it. Joomla is the world's largest community-driven content management system. It's an open source content management system. Everybody knows WordPress. Generously speaking, four in 10 websites is on WordPress, right? Joomla would be the second largest, and I know in the government space, Drupal also has a very significant -- I'm a big proponent of Drupal as well. I heard some folks grumping about it before we started the conversation, the complexity of maintaining it. Joomla, it's funny. I shared with you that the first time I spoke here was in 2022 down Little Rock, and I was super excited at the time because Joomla, four years ago, before ADA and WCAG went together in the same conversation, four years, Joomla built in WCAG compliance into Joomla 4.1, which had just released. I snuck it into my presentation four years ago because I was pretty excited about it saying, it's not law, but we should just do it because it's the right thing to do, right? In addition to WCAG compliance, Joomla also targets ATAG compliance. Anyone familiar with ATAG compliance? It turns out content authors are people, too, right? Administrators are users of your website. If we estimate that up to 20% of people use some sort of -- or have some sort of challenge dealing with traditional web technologies, that would apply to the staff in your organization that operates these websites, too. One of our team members is colorblind. She's not our designer. But one of our team members has colorblindness. So even acknowledging that, Joomla, in its administrator backend for content editors, has WCAG standards built in for how to author content. In addition, Joomla also has a WCAG checker built into the content editor. Our end-users, if they have permission, can author the content and click the button and get an instant score on the automated part of validating their content. They can check their content at the point of creation. Did I mention it's open source and free? I'm not even here selling it to you. You can go to Joomla.org and download it yourself and run it. It does require aptitude to set up, as all web-based technologies do, but it's an amazing, amazing platform. In addition to that, I'm deliberately sticking on this slide for a hot minute. In addition to all of the WCAG stuff that's been there long before anybody cared, Joomla also has built into core something called workflows. Workflows allow you to define how content moves through your organization. So I'm a big fan of letting the people that have the stuff to say, say it. They have author permission. You can establish a workflow that when they say save, it goes to an editorial phase. That can be for multilingual review, for translation, it can be for WCAG compliance. So you can have your people authoring their own content, saving it. It doesn't get published for the public yet. The next person in the workflow gets notified automatically. This is baked into the platform. This isn't some cute piece of software. It's not a new plugin for your WordPress website. It's baked into core. Joomla's multilingual, scheduled tasks, workflow, WCAG compliance built in at the point of content creation. How Joomla lost this race is a conversation you and I can have over beer later tonight. But it's an amazing platform that still runs about 1-1.5% of websites on the internet. That sounds like a small amount. The internet's a very big place. So still running millions of websites and it's second only to WordPress in terms of open source market share. So it's bigger than Drupal in terms of overall global market share. And if you really want to have fun and have things to share, I'm actually leaving tomorrow morning to go to Germany for the first Joomla World Conference since 2017 tomorrow morning. So I'll be hanging out with the folks that are making it happen. So I'm a huge, huge Joomla advocate. If you want to know more, feel free to talk to me at any point. Alright, monitoring catches problems after they shift. The good platform stops them before they even are at the point of creation. Joomla treats accessibility as a core requirement. Admin template, the default admin and site template are both WCAG 2.1 AA. And I haven't gone back to check, I know they're targeting 2.2 for the latest versions and they're maintaining their ATAG compliance as well. Decentralized publishing problem from the audit solved at the source. Again, this was first put out in February 15th of 2022. Authors check an article with a button next to preview before it's published. If it flags issues, it explains to them how to fix the issue. Careful phrasing. It's designed to target WCAG 2.1 AA. No website is automatically compliant just because it has the tools built in to do the check. I'm just telling you the tools are there.

Step 6: A log and an owner

A log and an owner for every issue. This is where we talk about ownership. Nine walkers, one quest. Everyone carries something and Frodo can't do it all alone. For every issue the log records what, where and the severity. So for every issue you define whenever you're hitting an audit. What was the problem? Where did it occur? And how serious is it? Those are the three things you want to track. The owner who's in charge of resolving the issue and then the target date and the status that you're shooting for. For what is it? What's wrong? What needs to change? And then how the fix was verified. So once you check it off and you want to retain that forever. And whether that's a git or a document, you just want a standard format or even a spreadsheet. You just want to make sure that whenever you make a change, it's captured in stone forever. Shared burden, web team, this really just comes down to culture in terms of how you handle these types of things. You all know your organization's best. But ideally, it is a shared thing, because if you make it one person's job, what a miserable job, and nobody else is learning how to actually manage the content from the word go. And that's why I love the remediation happening at the point of creation. Notice it functions as they have an opportunity to go, oh, that's wrong. What's wrong with that? It encourages questions as they're creating their own content. So it's a shared burden. The templates can help. Departments, there can be that sort of stratified piece that I was talking about with authors up to editors. We talked about procurement with vendors, and then ultimately leadership priorities. We should be reporting to where things are at with leadership, and you need to be an advocate for your leadership to know about these issues. They need to know, and it's tough. We've been working with clients for the better part of the last six months especially, just saying, I know this sounds like a geeky thing that you don't understand. And I hate that it has to be the legal liability thing that's driving the conversation, but it's like, you will get sued. And, like, I don't know what to tell you. You're going to get, we've been having a conversation for four years, nobody cared. And right now we're waving the red flag going, you've got to start caring about this, or it's going to hit you where it hurts. So whatever you have to do to get in front of leadership to help them understand the importance of this. And hopefully you've got really proactive leadership that understands that we're here to serve people, right? That's why I like the focus on usability and even over compliance. For me, compliance just sits under the umbrella of literally usability. So the log is your best evidence of good faith. And that's why I keep going back to document everything in a way that is immutable, because that's your best proof that you're making a good faith effort. How many of you guys track things in spreadsheets? Yeah. Spreadsheet is always a prototype for a database, right? And the reason that matters is because then you can control how data gets entered. You don't have to worry about, are we capitalizing our city? Are we spelling it this way or that way? Databases allow you to enforce that. So you get to do typed strings and to establish things very clearly. And again, I like them as prototypes for databases. But long term, I like to establish things that have a little bit more rigor. And along with all the beautiful things that I talked about Joomla, and this is pretty consistent for most content management systems, every edit that's made, Joomla does have version control built into its content. You can note your version. This was the last one that didn't pass the compliance on. You can just note that as a note, date and timestamp, and you can save versions. It tracks who did what, when, and where. You can literally see every piece that changes over time.

Step 7: Report to leadership

And this goes back to the leadership piece, the beacons of Gondor, the signal fire , you have to reach leadership before the crisis does, not after. So each quarter, in plain language, here are the issues that were found, this is what we fixed, this is what's still open. That stuff can be graphed pretty consistently, whether it's a spreadsheet or the database. You should have a tracking mechanism that creates visibility and intelligibility for your leaders so that they can see where things are at and they'll help them to grow an understanding for what these issues are and why they matter. Leadership funds what it can see, leadership funds what it can see, reporting turns accessibility from an IT task into an agency commitment. Governance as a system. When the remediation log feeds a dashboard, the quarterly report writes itself instead of becoming a scramble. So if you have systems in place that can track these and make the tracking visible, that's where you gain the most leverage in terms of keeping the efforts funded.

Step 8: Hold vendors to it

And then finally vendors. At the Council of Elrond, every people had a stake and everyone sent someone. Your payment processor, your agenda platform, the video host, all need a seat at the table. Under Title II, a vendor's inaccessible portal is still your service. In contracts and RFPs, somebody brought this up, in contracts and RFPs require a WCAG statement. About what standard they are providing for their services. Ask for current reports and then test it. Test it. So we talked about some of the platforms you can use to test for WCAG compliance. Define who fixes what and how fast. So when problems do pop up, how is that being addressed? And then build accessibility into the renewals. So anytime a contract comes up for renewal, treat it like you would treat zero-based budgeting efforts, right? If you're starting from zero, make sure that they still have WCAG compliance in there and use it as an opportunity to test their portals to make sure they're doing what they're supposed to be doing.

Write it all down

Bilbo and Frodo wrote it all down in the Red Book. That's why we know the story. Your documentation is how anyone else will know yours. Defensible documentation will include these nine elements. What your accessibility policy is, it should be stated on your website explicitly. Your most recent audit should be included. Your prioritization framework. So I gave you some suggestions for what to put in what order, what to go after first. Your remediation log. What have you fixed and when did you fix it and how did you fix it? Your monitoring records. How often are you monitoring? When did those things pop up? Your training records. I'm sorry, but this is a relatively short shrift in the overall presentation. But what training are you providing? That should be something that is logged as well. And not just what you're providing, who attended, what was the information that was shared. And again, what you're doing is you're building the defense before the problem is there. And if you've done your job, the problem won't be there because people are trained and you have the systems in place. So it's not just about a defensible position, but it's about being proactive to make sure that you're providing a great user experience for your content managers and for your end users. Too many sidebars. Complaint feedback process. You should proactively allow people an opportunity to let you know because you'd rather provide them that than have them find their own way to let you know, right? Vendor reviews. I talked about just a moment ago. And then your executive reports. And that's all part of that dossier. So again, accessibility policy, current audit, prioritization framework, remediation log, monitor records, training records, complaint feedback process, vendor review, executive records. This is what a demand letter, Department of Justice inquiry, or a new director will ask to see. And you can imagine if that day ever comes and you can hand them the binder that had all that information in it, it's going to be a pretty short, easy conversation for you.

There and back again

Okay? So just again, reviewing there and back again. We made it all the way to Mordor. We're headed back to that again. We started with our audit. We looked at our workflows, the things that were most necessary on our websites. We had a little bit of a shortcut with our templates, getting some quick wins, impacting a lot of stuff with some relatively modest developer effort. We looked at how we're handling documents and third-party things that are not HTML. And then once we had done that remediation, we established our permanent outposts for how to monitor, how to create ownership over compliance, how to handle reporting, and how to manage our other relationships moving forward.

Your first 30 days

Your first 30 days, what do you do next? Something you leave here. Who owns the process for your organization? First and foremost, do put somebody. They don't, that doesn't mean they get all the work. It just means they're going to be the champion of how the process is going for your organization. Second, handle the site-wide scan and keep the report. That's your baseline. And again, even if it's miserable, celebrate. You get some quick, easy wins, right? So you've got a lot of stuff you can get after, and that will show good faith effort right out of the gate. List your top five resident workflows and test each one by keyboard. Test it by keyboard. Keep your hands off the mouse and the trackpad and see what you can do. Count your PDFs. Again, you're just establishing your baseline, and then you can work through how you want to prioritize those. List every vendor that touches residents and just go through all of your contracts, make a list of your vendors, and you can start to work through those relationships. Start a remediation log, even if it's just a spreadsheet. If you want something more robust, I'd love to have that conversation with you. Put a 15-minute accessibility update on leadership's quarterly agenda, or whatever the time frame is, but you want something regular just to say it keeps it in front of people and says this matters. And then none of these need a budget line. All of them start the document trail. So notice, everything I just said up there is stuff that you can get going on. There are tools, there are vendors, there are folks that can help you out with that. But you don't have to wait to sign the big budget contract or get the budget line passed to start the process.

Resources

These are some of the things that I referenced in the context of this presentation. So the WCAG guidelines, you know about ADA. Almost everybody's hand went up for the WAVE WebAIM tool. However, actually, this was the article that kind of got me going in terms of thinking about how we handle this for our own clients and our own processes. It's just a fantastic blog post that kind of laid things out step by step for us. I love to give acknowledgments. Karen Wynn Fonstad, I kid you not, her son was in my class in high school. And I didn't learn about it until about six months ago. I was like, what? So just a really fun connection. And I know you guys got a lot of cool stuff to see in Milwaukee. But I think it's super cool that we have the Tolkien manuscripts just up the road.

Not all who wander are lost

Not all who wander are lost, especially if you have a map. Hopefully, I've done a good job outlining that for you today.

[On screen: end card. "Need a map? Let us help." intergen.org]