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Comprehensive Digital Accessibility Transition Policy

Purpose & Commitment

The purpose of this Digital Accessibility Transition Policy is to formalize the commitment to fostering an inclusive digital environment that ensures equitable access to services, programs, and activities for all residents, employees, and visitors, including individuals with disabilities. Removing accessibility barriers to information and communication technology (ICT) increases the accessibility of programs and civic participation for everyone, regardless of ability.

Scope of Coverage

This policy applies to all digital assets, including web content and mobile applications (apps), that the entity provides or makes available either directly or through contractual, licensing, or other arrangements. This includes websites, web applications, mobile applications, online forms, service portals, digital documents, and other information and communication technologies.

Technical Accessibility Standards

To ensure compliance with legal mandates and provide the highest level of access, the entity’s digital assets will align with the following technical standards:

  • Web Content Accessibility Guidelines (WCAG) 2.2, Level AA: Digital content must conform to the Web Content Accessibility Guidelines (WCAG) 2.1 Level AA, as required by Title II of the Americans with Disabilities Act (28 CFR §35.200).
  • Where feasible, The City of Edinburg may adopt newer versions of WCAG that provide equal or greater accessibility.
  • Title II of the Americans with Disabilities Act: Specifically, 28 CFR 35.200, detailing requirements for web and mobile accessibility.
  • Section 508 of the Rehabilitation Act of 1973 and applicable state or local government codes.

Implementation and Remediation Strategy

To transition digital assets to full accessibility, the organization will implement the following measures:

  • Prioritized Remediation: Digital assets will be regularly audited and remediated based on a triage hierarchy determining user impact and issue severity. The order of priority is:
    1. Public-facing assets with critical and high-level severity issues.
    2. Public-facing assets with moderate severity issues and internal-facing assets with critical and high issues.
    3. Public-facing assets with low severity issues and internal-facing assets with moderate issues.
    4. Internal-facing assets with low severity issues.
    5. Accessibility reviews will be conducted periodically using automated scanning tools and manual testing methods.
  • Procurement: The procurement process will be updated to incorporate digital accessibility requirements for all new software, websites, and third-party digital services.
  • Employee Training: Digital accessibility training will be created and implemented for employees.

Exceptions and Limitations

In accordance with ADA Title II regulations, the following content is generally excepted from conforming to the WCAG 2.2 Level AA standard, unless the content is currently used to apply for, gain access to, or participate in the entity's services or programs.

The following categories are generally exempt from the technical conformance requirements of WCAG 2.1 Level AA under Title II regulations.

  • Archived Web Content: Historic content created before the compliance date that is retained exclusively for reference, research, or recordkeeping, is not altered, and is stored in a clearly identified dedicated archive area.
  • Preexisting Conventional Electronic Documents: Documents (e.g., PDFs, Word files) made available prior to the ADA compliance date.
  • Third-Party Content: Content posted by independent third parties, unless the third party is posting due to contractual or licensing arrangements with the public entity.
  • Individualized, Secured Documents: Password-protected conventional electronic documents about a specific individual, their property, or their account.
  • Preexisting Social Media: Social media posts published before the ADA compliance date.

Note on Undue Burden and Alternative Access: The entity is not required to take actions that would result in a fundamental alteration of a service or impose an undue financial and administrative burden. However, the head of the public entity must make this determination in writing, and the entity must still ensure that individuals with disabilities receive the benefits or services to the maximum extent possible. Conforming alternate versions of web content will only be used where it is not possible to make the primary web content directly accessible due to technical or legal limitations.

Requesting Accommodations and Grievance Procedure

The entity guarantees non-discrimination and provides specific avenues for the public to interact regarding digital accessibility:

  • Accommodation Requests: Anyone may submit requests for accommodations, modifications, or suggestions for digital improvements via online form, email, regular mail, or telephone. For time-sensitive events, requests should be submitted no later than 48 hours before the event.
  • Formal Grievance Procedure: For claims of discrimination or lack of accessibility, the entity follows a 5-step procedure:
    • Step 1: Attempt to resolve the issue informally with the director responsible for the service.
    • Step 2: If unresolved, submit a formal ADA Title II Grievance Form or written grievance within 60 calendar days of the alleged discrimination.
    • Step 3: The City Secretary will meet with the complainant within 14 calendar days to discuss possible resolutions.
    • Step 4: The City Secretary  will provide a written response within 28 calendar days of the meeting.
    • Step 5: If the response is unsatisfactory, the complainant may file a written appeal with the City/Entity Manager within 14 calendar days, who will issue a final agency decision within 14 days.

Compliance Timeline

The City of Edinburg will work toward full conformance with WCAG 2.1 Level AA by the compliance deadlines established by the U.S. Department of Justice for public entities under Title II.

Continuous Accessibility Monitoring and Improvement

Digital accessibility is an ongoing process. The City of Edinburg will continually evaluate, test, and improve digital accessibility as technology, standards, and user needs evolve.

To support this commitment, The City of Edinburg will implement the following practices:

  • Periodic Accessibility Reviews: Digital assets, including websites, mobile applications, and electronic documents, will be periodically reviewed using a combination of automated scanning tools and manual accessibility testing methods.
  • User Feedback and Issue Reporting: The City of Edinburg will maintain a mechanism that allows users to report accessibility barriers or request accessible formats. Reported issues will be evaluated and prioritized for remediation.
  • Monitoring of Standards and Regulations: The City of Edinburg will monitor updates to accessibility standards, including updates to the Web Content Accessibility Guidelines, and relevant legal requirements under the Americans with Disabilities Act and guidance issued by the United States Department of Justice.
  • Continuous Improvement: Accessibility improvements will be incorporated into website updates, system upgrades, and technology procurement processes to ensure long-term accessibility and usability for individuals with disabilities.

Digital accessibility is an ongoing process. The City of Edinburg will continually evaluate, test, and improve digital accessibility as technology, standards, and user needs evolve.