Digital Accessibility Progress Report

Because this is the city’s first progress report, this report recounts many prior efforts and city progress preceding this report. Future reports will recount only updates from the prior report.

“Digital Accessibility Law” refers to those statutory provisions adopted by HB 21-1110.

“ICT” refers to information and communications technology, as defined in the Rules.

“OIT” refers to the Governor’s Office of Information Technology, State of Colorado.

“The Rules” refers to the Rules Establishing Technology Accessibility Standards, found in the Colorado Code of Regulations at 8 CCR 1501-11.

“WCAG” refers to the most recent version of the Web Content Accessibility Guidelines, success criteria Levels A and AA.

The City believes its external-facing webpages are substantially compliant. Throughout 2023, the City engaged in a thoughtful process for evaluating its webpages and remedying accessibility issues. These efforts included retaining and utilizing third-party software designed to evaluate the City’s web pages and portals.

Furthermore, as of the date of this report, the City has provided various means for alternative and additional accommodation if persons have difficulty accessing, reading, or utilizing the City’s web pages. These include, among other things, eliminating barriers in our web pages by adding digital accessibility content to the City’s ADA webpage and adding messages, links, and phone numbers on various pages and portals that allow users to contact the City for assistance.

While the Digital Accessibility Law provided funding to OIT, it did not provide funding to local governments. Accordingly, the City is doing its best to come into full compliance without an increase in resources. While re-allocation of staff time has occurred – and while future allocation of resources through the City’s own means is planned – it is worth noting that financial constraints prevent an "all at once” conversion to full compliance of all the City’s ICT.

Identifying and addressing obstacles is an integral part of the City’s commitment to foster barrier-free built environments in its online presence.

Since the passage of HB 21-1110, the City has undertaken substantial, concrete efforts to ensure its ICT is accessible. These efforts have included, but are not limited to, the following.

Shortly after enactment, the City carefully evaluated the Digital Accessibility Law’s requirements. The City's evaluation included a review of current City ICT, such as the City's web pages and various applications. The City began planning – at its highest levels – the push needed to achieve compliance. The City also began devoting substantial staff resource time towards achieving compliance.

The following is a list of some of the City’s more significant efforts toward compliance.

Accessibility Program Steering Committee (Leadership)

Beginning in 2023, City leadership has regularly met and discussed digital accessibility compliance and issues, leading the City’s efforts to achieve and maintain compliance. These meetings have provided technical staff with broad-based support from senior leadership l in the City. The steering committee consists of the following:

• Executive Sponsors - The executive sponsors include the City Manager, Nuria Rivera-Vandermyde, and the Director of Innovation & Technology, Jennifer Douglas, ensuring high-level leadership who take accountability for communications, objectives, and City alignment.
• Steering Committee – The steering committee consists of high-level individuals of key departments that are affected by digital accessibility issues including the Finance Department (Kara Skinner and Joel Wagner), City Attorney’s Office (Teresa Taylor Tate and Andy Frohardt), Communications and Engagement (Sarah Huntley), Innovation and Technology (Jennifer Doulgas), City Manager’s Office (Carl Castillo) and Human Resources (David Bell).

Identified Workstreams and Workstream Teams

To promote technical compliance, the City formed a variety of different workstreams on digital accessibility. To date, these workstreams consist of 16 different groups that are tasked with resolving specific, discrete digital accessibility compliance issues for the City. These workstreams include, for example, vendor compliance, website accessibility, specific high-impact platforms, and training. While there is significant variability in how workstreams operate, all workstreams are comprised of specific, key personnel whose jobs touch upon the area of compliance being addressed (e.g., standards, guidelines, and regulations that ensure digital products, services and content are accessible), and include (or included) at least some regularity of meeting and communication to resolve problems.

Digital Software and Applications Accessibility Assessment Team

Since at least January 2024, the City has had a Digital Software and Applications Accessibility Assessment Team. The team is comprised of high-level resources within the city as well as subject matter experts and decision-makers. Its membership includes the following:

• Director & Deputy Finance Director, Department of Finance – Thereby ensuring digital accessibility decision-making is supported by staff with authority to make resourcing decisions.
• Director & Senior Project Managers, Department of Innovation & Technology – Thereby ensuring digital accessibility decision-making is supported by technical expertise, including project management support for evaluating vendor compliance and working with departments to manage, monitor and collaborate with vendors on compliance.
• ADA Coordinator – The City’s principal for promoting accessibility throughout the City who, along with IT resources, analyzed vendors at the time of contract renewal and initial engagement.
• Risk Manager – Thereby ensuring risk is both considered and serves as a basis for denying or not renewing vendors who are not committed to digital accessibility.
• City Attorney’s Office Personnel – Thereby ensuring legal analysis can occur on the Digital Accessibility Law and the Rules and promoting proper governance.

The team has met weekly since February 2024. The team’s principal job is to evaluate the software and applications provided by the City’s various third-party vendors for compliance with digital accessibility requirements. The team discusses vendor products’ digital accessibility in detail. The team requires that information technology vendors complete a Voluntary Product Accessibility Template (VPAT), accessibility questionnaire, or both, so that the City properly understands and can evaluate the vendor’s product. The team’s role has included requiring that the City move on from non-compliant vendors, condition the use of vendors’ technology on the vendor making changes to the technology and requiring that City staff work with vendors on enhancing compliance. This team has also supported changes to procurement processes to make accessibility a key part of procurement evaluation prior to purchase.

Digital portfolio

Existing application inventories were updated through a citywide effort to identify all digital products and content currently in use. Over 300 applications are being tracked with ongoing vendor conversations to understand their compliance and address deficiencies.

Investment in Tools

The City has procured technological resources designed to catch issues staff may miss. Specifically, the City uses Popetech and Siteimprove, which are automated tools that personnel can use to independently assess City and vendor webpage/application compliance. Furthermore, the City added enhanced licenses to certain products, such as Microsoft Office and Adobe Acrobat Pro, so that City staff can more easily produce accessible documents and other content. These were gained through participation in the Statewide Internet Portal Authority’s Accessibility Grant Program.

Educational & Community Participation

Program staff have attended various presentations and training sessions. Including sessions facilitated by:

• OIT;
• Colorado Government Association of Information Technology;
• Colorado Municipal League;
• Microsoft; and
• Adobe.

These occur regularly, and the City has ensured technical staff attend and report back on developments and best practices.

Citywide Communications/Meetings

The City has frequently discussed or mentioned digital accessibility during all employee townhall meetings. These are all-personnel meetings that City staff may attend to receive updates on the City, including information about high-level policies, such as digital accessibility. On November 14, 2023, the City held one such meeting devoted entirely to digital accessibility. During the meeting, various members of city leadership, including the City Manager, spoke to all staff about the importance of digital accessibility and the City’s goals in pursuing accessibility. Since then, the City’s Communications department has also sent periodic citywide e-mails discussing and educating staff on digital accessibility.

Digital Accessibility Champions

To promote a culture of accessibility, the City started its “Accessibility Champions” program. The program requires that all major departments to designate at least one “Accessibility Champion,” who would be trained on digital accessibility issues and promote digital accessibility within their department. The Accessibility Champions attend and participate in monthly meetings where they receive education and share perspectives and developments.

City Training Courses

The City implemented a variety of internal training courses and enrollments on digital accessibility topics. These courses were custom-created by program staff using best practices from state, university, and vendor materials. The training often combined reading, video instruction/demonstration, and knowledge testing. Course completion is tracked and enrollments are based on staff roles. These trainings have included:

• General Citywide “Awareness” Training – Program staff created and deployed an all-employee self-paced course training on digital accessibility basics. This training was designed to ensure all city personnel are familiar with the Digital Accessibility Law, receive an overview of the City’s Digital Accessibility Project (Phase I), and can take actionable steps to support accessibility in their work. More than 1,600 city staff have completed this training.
• Email and Document Training – In June, 2024, program staff enrolled city employees in Microsoft Outlook, Word, PowerPoint, Excel, and PDF accessibility courses, depending on their role. To date, XX employees have completed the pilot training and provided valuable feedback.
• Specialized Training. Additional, role-specific training courses were developed and are selectively deployed to city staff for accessible best practices for web content and Geographic Information System (GIS) content and tools.
• Contract Templates Revisions. The City’s information technology contracts were revised to include robust digital accessibility terms. The inclusion of these terms has many benefits, including that it pushes vendors to become and remain compliant, allows the City to better understand vendor compliance via the negotiation of terms, and stresses to vendors the importance of accessibility at the time of contracting. The City includes digital accessibility language in new and renewing contracts. Accessibility has also been incorporated into purchasing criteria and guidelines.

The City understands and actively pursues inclusion of all people in all aspects of the organization. The City will continually progress in its commitment to improving accessibility, addressing current and future barriers, and will ensure that its operations are accessible to everyone.