​STATE OF MARYLAND DIGITAL ACCESSIBILITY POLICY​​​

  ​​​​1.0 Purpose

​1.​​1    ​Every Marylander should have equal access to State procured and developed information technology and services, ensuring the highest degree of usability for all, regardless of disabilities.

​ 1.2   ​​The United States Census Bureau's American Community Survey states that there are over 700,000 individuals with disabilities living in Maryland, and this number is increasing over time. The State of Maryland (State) understands that procuring, developing and deploying accessible information technology across the State is paramount and has prioritized accessibility to ensure that no Marylander is left behind.

1.3   ​The State has been committed to ensuring equivalent access to our State’s information technology tools and services for many years. Maryland’s commitment dates to at least 2008 when, by law, it required the Department of Information Technology (DoIT) to develop a Non-Visual Access (NVA) Clause for use in the procurement of information technology and information technology services. The NVA clause requires all new or upgraded information technology to provide equivalent access by both visual and nonvisual means, and the State is working diligently to ensure that NVA compliance is an integral part of the information technology procurement process. Ensuring that technologies are “born accessible” eliminates the potential for costly remediation efforts and can result in cost savings for the State. The DoIT Office of Accessibility (OOA) team works closely with the Maryland Department of Disabilities and the Department of General Services to ensure that IT procurement contracts include appropriate accessibility language.​

1.4   ​​​​This policy does not specify or stipulate any particular technology or application. Rather, this policy has been authored with the aim of fostering more inclusive information technology tools and services such that all Marylanders may effectively access, interact and do business with the State with ease and equivalent access.

1.5   This policy outlines the responsibilities of Maryland's Executive Branch departments and independent agencies regarding effective implementation of the State’s non-visual access laws and regulations, including that each establish an Accessibility Officer as a champion and point of contact for the DoIT Office of Accessibility’s accessibility efforts. These officers will receive training and mentoring from the Office of Accessibility team. The policy emphasizes the use of the DoIT ticketing system to report accessibility concerns, make training requests, seek consultative support, or request accessibility testing. It further highlights the importance of departments and agencies ensuring that information technology and services are accessible to all Marylanders, in compliance with relevant State laws and accessibility policies. This includes monitoring vendor compliance with COMAR 14.33.02.01 and WCAG 2.1 AA Success Criteria requirements and establishing plans to mitigate and remediate non-compliance. Lastly, there is a provision for validation testing to ensure successful accessibility efforts by vendors working with the state. Additional details can be found in section 4.1​​

  ​​​​2.0 Definitions

2.1   Accessibility Conformance Report (ACR): A standardized reporting framework employed for the documentation of a product's or service's alignment with international accessibility standards. A widely adopted tool for generating ACRs is the Voluntary Product Accessibility Template (VPAT), which was developed by the Information and Technology Industry Council.

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2.2   ​Accessibility Officer: A state agency employee that has been designated by their respective agency leadership, trained and coached to address accessibility within their agency with the support of OOA and MDOD staff.

2.3   ​Non-Visual Access: The ability for an end user without sight to interact with information technology without restriction and with equivalent functionality.
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2.4   ​Validation Testing: The process of validating previously remediated code, content and controls to ensure the respective changes are now accessible.

2.5   ​Voluntary Product Accessibility Template (VPAT): A template document prepared by a product vendor or developer which explains how an information technology product or service conforms to accessibility standards such as Section 508 and WCAG.

2.6   ​Web Content Accessibility Guidelines (WCAG): Defined pre-determined measurable accessibility standards for all web content, including text, images, audio materials, video materials, and code for infrastructure, styles, and interactions. It should be noted that the core concepts of WCAG can be applied to non-web technologies. The guidelines include three specific conformance levels: A (lowest standard, any IT solution that does not meet this level is known as a critical accessibility blocker), AA, and AAA (highest and most difficult to achieve).
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  ​​​​3.0 Applicability

3.1   This policy is applicable to all departments and agencies within the Executive Branch of State government. It applies to internally and externally facing IT solutions and services developed, provided to, or procured by departments and agencies.

3.2   COMAR 14.33.01 and 14.33.02 (Maryland Non-Visual Standards) apply

  ​​​​4.0 Responsibility

4.1   Departments and agencies are responsible for :

4.1.1   ​​​​​​Identifying an Accessibility Officer to serve as an accessibility champion and point of contact for the accessibility efforts of the DoIT Office of Accessibility. These Accessibility Officers will be trained and mentored by the Office of Accessibility team who will also serve as consultants, as available.

​ 4.1.2   ​​​​​​Using the DoIT ticket/reporting system to report accessibility concerns, seek consultative support, or request accessibility testing by the Office of Accessibility or our strategic partner agencies.

​ 4.1.3   ​​​​​​Verifying that information technology and services developed, provided to, or procured by the respective department or agency are accessible to all Marylanders prior to deployment to production, consistent with State law and accessibility policies set by DoIT.
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4.1.3.1   ​​​​​​Ensuring that vendors deliver an IT solution or service that complies with COMAR 14.33.02.01 (Maryland Non-Visual Access Clause).

4.1.3.2   ​​​​​​Ensuring that vendors test their IT solution(s) to ensure compliance with WCAG 2.1 AA Success Criteria through manual testing and automated testing., e.g.:

​4.1.3.2.1   Vendors are required to conduct screen reading testing with JAWS, NVDA, and VoiceOver with the respective IT solution during their development cycle.

4.1.3.2.2   Vendors are required to perform mobile accessibility testing on iOS and Android during their development cycle.​

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4.1.3.3   ​Conducting validation testing in connection with remediation efforts to ensure vendors efforts to make the IT solution accessible have been successful. With the submission of a request through the ticketing system, the Office of Accessibility can conduct validation testing.

4.2   DoIT’s Office of Accessibility (OOA) is responsible for:

​​ 4.2.1   ​The development of non-visual access policy and guidelines.

​​ 4.2.2   Enforcement of COMAR 14.33.02.

​​ 4.2.3   Providing accessibility subject matter expertise and training to Executive branch departments and agencies.

​​ 4.2.4   The conduct of accessibility reviews upon request or organically as we learn about new systems being procured.

​​ 4.2.5   Collaborating with the Maryland Department of Disabilities and the Maryland Department of General Services to level up the accessibility requirements within the State’s RFPs/TORFPs and assist agencies with NVA compliance in the procurement process.

​​ 4.2.6   Consultation with members of the Executive Branch on the accessibility of current and future websites, web applications, and mobile applications.

​​ 4.2.7   Actively engaging in ongoing professional development and continuous learning to stay equipped to address emerging accessibility challenges and ensure every Marylander has access to the latest and most innovative information technology solutions.

​​ 4.2.8   Exploring, piloting, and leveraging artificial intelligence (AI) to improve the accessibility of information technology solutions and services, including, but not limited to, translation, transcription, accessibility testing, and remediation efforts.

​​ 4.2.9   Connecting state agencies with disability rights groups and the disability community of Maryland.

  5.0 Res​ources​

5.1   ​For additional guidance and information on accessibility please go to the Office of Accessibility website [coming so​on].
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Digital Accessibility Policy​