Website Accessibility Recommendations for Minnesota Cities

Start by identifying who is going to have a role in making sure your city complies with the ADA Title II rule. Designate an accessibility coordinator to lead and coordinate the city’s accessibility efforts, and put together an accessibility planning team to help develop and implement an accessibility plan.
Read more about determining who may have a role in complying with the rule.

An accessibility implementation plan can help your city outline priorities, goals, budget, and actionable steps to take to achieve accessibility. Some of the suggested steps are outlined on this webpage; your plan may include others like timelines and metrics to measure your progress.
Access the Implementation Toolkit from MNIT, including links to sample implementation planning documents.

An inventory can help your city identify the online content and apps that may need to comply with the WCAG 2.1 standards and help focus your efforts going forward. Consider including the following in your inventory:

• City website(s), including:
  • Number of webpages.
  • Types of web content (PDFs, Word files, videos, audio, images).
  • Who can post on the website, including members of the public.
• Social media and video platforms used and types of content posted on these.
• Other places on the web where the city posts content.
• Mobile apps used by the city; indicate if operated in-house or by third parties.
• Third-party vendor resources and content the city provides online.

Minnesota IT Services has an Accessibility Inventory Workbook to help you gather data, identify questions that need to be considered, and document plans for future changes.

If your city provides online resources and content from third-party vendors, review any contracts with these service providers regarding their compliance with WCAG 2.1, Levels A and AA requirements. For those that aren’t compliant, you might amend contracts or start exploring alternative vendors that can provide compliant services. The city should work with the city attorney to review any third-party vendor contracts. In addition to the city attorney, the League’s Contract Review Service may be able to help cities in reviewing their vendor contracts. Read more about the League’s Contract Review Service.

Here are some steps you may want to take regarding third-party vendors:

• Review current contracts with website and digital services vendors to determine if they include any guarantees of accessibility. Contact vendors to ensure their tools are compliant with WCAG 2.1, Levels A and AA.
• Before entering contracts with digital service vendors, ensure their services are compliant with WCAG 2.1, Levels A and AA.
• Understand the city’s role in maintaining accessibility of information hosted on a vendor’s platform. While a vendor’s platform or service may be compliant, any city-produced documents, maps, tables, or images must also be compliant. Ask vendors to outline the role of each party in the service agreement or in writing.

Read some DOJ examples of other approaches to consider regarding third-party vendors.

The ADA Title II rule provides limited compliance exceptions for certain online content. Very broadly, the exceptions include archived web content, preexisting conventional electronic documents, password-protected content, content posted by a third party, and preexisting social media posts. However, these exceptions apply only if specific criteria are met, so it’s essential to study the details of the criteria to determine if your city content qualifies for an exception.

• For more details and criteria about the exceptions including helpful examples, see the Department of Justice Summary of Exceptions.
• View examples to help understand what content may or may not qualify for an exception.

Once you’ve taken an inventory of your websites, online content, and apps and have determined which of those needs to comply with WCAG standards under the new rule, the next step is to evaluate them to see what fixes may be needed.

• Initial review: You may want to do some preliminary checks to help you get started and help figure out how to approach a more comprehensive review. The World Wide Web Consortium (W3C) offers a set of initial steps to manually check a webpage for some basic accessibility issues, which should be followed by a more robust assessment.
  Access W3C’s Easy Checks resource for a first review of web accessibility.
• Automated testing tools: Automated tools can help identify only some accessibility issues but cannot assess all aspects, especially those requiring human judgment. Therefore, automated tools should be used alongside manual assessments for a comprehensive evaluation.
  W3C offers some guidance and considerations for using automated tools and provides a list of evaluation tools that may be a helpful starting point.
  • Review W3C’s guidance for selecting web accessibility evaluation tools.
  • Access W3C’s web accessibility evaluation tools list.
• Comprehensive audit: You may want to contract with a vendor to conduct a more comprehensive accessibility assessment of your websites, online content and resources, and apps. The audit would include an automated check and a manual check by experts in web accessibility, including users with disabilities, to identify real-world accessibility barriers.

After evaluating your websites, web content and resources, it’s time to develop a plan to fix accessibility issues to comply with WCAG 2.1, Levels A and AA by the deadline. You may not be able to address all issues at once, so it’s important to prioritize what to fix now and what can be fixed over time.

The DOJ recommends considering certain factors when prioritizing content, including whether the content:

• Enables people to perform key tasks, like applying for employment opportunities; registering for programs; submitting forms, requests, or reservations; paying bills; or making purchases.
• Is frequently accessed or is important for accessing essential government programs.
• Has been flagged as inaccessible by individuals with disabilities.
• Appears across multiple web pages, like navigation menus, search features, and footers.
• Is based on a template, so that you can ensure all content using that template is accessible.

Read more from the DOJ about prioritizing which content to fix first.

View other issues to consider when prioritizing accessibility issues to fix.

Some fixes may need to be addressed by third-party vendors while others can be handled by city staff who should understand the basics of web accessibility and how to make repairs — see the ‘Train your staff’ step to learn more. Once fixes have been made, they should be checked again to ensure accessibility issues were adequately addressed.

An internal accessibility policy includes specific actions that your city will take to start complying with the ADA Title II rule and stay compliant in the future. The policy may be similar to, or part of, other ADA non-discrimination policies your city may have adopted.

A city’s accessibility policy should include accessibility goals and targets and establish the web accessibility standard you aim to conform to and by when. It can outline responsibilities, actions, processes, reporting, documentation, and deadlines for your city’s accessibility plan. The accessibility policy is a living document and should be reviewed and updated on a regular basis.

• View suggested topics from the DOJ you can include in your internal accessibility policy.
• Learn more from W3C on how to develop an internal accessibility policy and access a policy template.

Including an external accessibility statement on your city’s website:

• Shows users that you care about accessibility and about them.
• Provides users with information about the accessibility of your content.
• Demonstrates an ongoing commitment to accessibility, and to social responsibility.

Your city’s external accessibility statement should contain:

• A commitment to accessibility.
• A statement on the applied WCAG 2.1, Levels A and AA standard.
• Contact information and procedures for users to submit feedback in case they experience accessibility barriers.

Learn more from W3C on how to develop an accessibility statement and access a tool to generate an accessibility statement.

Develop a process for staff to handle requests for accessible content

City staff should be trained on how to respond to questions and requests regarding accessible online content to include the following:

• If a request comes in via phone, email, or in person, follow data practices law for the process and stress an interactive dialog.
• Document the date, time, and substance of the feedback, noting the city’s interest in working with the requester to resolve the issue.
• Document all measures taken to resolve the issue.

Consider including the handling of accessibility access requests in a specific position’s job duties and designate a back-up position to handle such requests. For example, if your city has a clerk and a deputy clerk, include this as a duty in both job descriptions.

Training your staff is an important step to help ensure your city complies with the ADA Title II rule. Those who create digital content in your organization should have a basic understanding of accessibility principles and how to implement them to comply with WCAG 2.1, Levels A and AA.

These sources are a good place to start to learn more about digital accessibility:

• World Wide Web Consortium (W3C) provides an ‘Introduction to Accessibility’ with links to additional resources.
• WebAIM provides information and resources to implement web accessibility.
• Minnesota IT Services (MNIT) provides a variety of free resources and training on creating accessible content.

If your city contracts with a third-party vendor for a website platform, check with your vendor to see if they offer digital accessibility resources or training.

Understand and apply some of the basics

City staff who develop, write, and post content online should understand the principles of accessible design. The following is a list of some of the accessibility practices that staff need to understand and implement; for more details, see WebAIM’s Principles of Accessible Design and W3C’s easy checks to start to assess accessibility. This list is not comprehensive but is a good starting point:

• Provide page titles.
• Provide image alternative text (“alt text”).
• Use headings/provide logical structure.
• Ensure hyperlink text is meaningful, descriptive, indicates the purpose or destination of the link, and avoids generic phrases like “click here” or “read more.”
• Ensure proper color contrast; do not rely on color only to convey meaning.
• Provide headers for data tables.
• Ensure users can complete and submit all forms.
• Allow users to skip repetitive elements on a page.
• Support keyboard navigation and visible keyboard focus.

Accessibility for documents

All documents your city posts online must be accessible and comply with WCAG guidelines. MNIT provides free online training and resources on how to make accessible documents.

• Learn about MNIT’s free online accessibility training modules for Microsoft Word, PDF, Powerpoint, and also maps.
• Access MNIT’s Digital Accessibility Quick Cards with tips for making documents accessible using a variety of software.

Accessibility for audio and video

All audio and video your city posts online must be accessible and comply with WCAG guidelines.

• From W3C: Learn about providing captions/subtitles and learn about providing transcripts.
• Access MNIT’s information and resources about making accessible audio and video.

Accessibility for social media

All content posted by your city on social media must be accessible and comply with WCAG guidelines.
Access MNIT’s tips for accessible social media use and outreach.