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Voluntary Product Accessibility Template (VPAT) Review

Criteria 1194.21

Originally coding practices for software did not over reach into other forms of technology. However over time modern web coding practices have created a need for this section to be completed for web sites and applications alike.

The CSU reviews this section in relation to functionality regardless of that the product or service. The subsections below will contain the following:

  • The text of the section 508 criterion
  • Explanation of what the criterion is asking along with resource links if available
  • Cross reference information if applicable
  • Verification notes we give our campuses for reviewing VPAT's
  • Information on how this looks like it will overlay into the Section 508 Refresh
Criterion Resources

Criteria 1194.21(a)

When software is designed to run on a system that has a keyboard, product functions shall be executable from a keyboard where the function itself or the result of performing a function can be discerned textually.

Clarification:

Without using the mouse, you must be able to get to and complete all of the elements/functionality.

Section 508 Refresh

  • WCAG 2.1.1 Keyboard

Verification Notes:

  • When Supports is chosen look for the following information in Remarks and Explanation column:
    • A statement that reflects that the entire web application was tested to verify keyboard operability.
  • When Supports with Exceptions is chosen look for the following information in Remarks and Explanation column:
    • What is the impact of the user’s inability to complete any core functions of the application due to the exception or lack of support for this criterion.
  • Note that for responses that include Supports with Exceptions and Does Not Support these drive the completion of the elements of the Accessibility Road Map and information to users on the Accessibility Statement regarding any known workarounds.

Criteria 1194.21(b)

Applications shall not disrupt or disable activated features of other products that are identified as accessibility features, where those features are developed and documented according to industry standards. Applications also shall not disrupt or disable activated features of any operating system that are identified as accessibility features where the application programming interface for those accessibility features has been documented by the manufacturer of the operating system and is available to the product developer.

Clarification:

When using the program with AT, do any program commands disable the AT features?

Section 508 Refresh

  • 502.2.1 Interoperability with Assistive Technology - Documented Accessibility Features - User Control of Accessibility Feature.
  • 502.2.2 Interoperability with Assistive Technology - Documented Accessibility Features - No Disruption of Accessibility Features

Verification Notes:

  • When Supports is chosen look for the following information in Remarks and Explanation column:
    • A statement that reflects that the entire web application was tested to verify all AT features are still operable..
  • When Supports with Exceptions is chosen look for the following information in Remarks and Explanation column:
    • What is the impact of the user’s inability to complete any core functions of the application due to the exception or lack of support for this criterion.
  • Note that for responses that include Supports with Exceptions and Does Not Support these drive the completion of the elements of the Accessibility Road Map and information to users on the Accessibility Statement regarding any known workarounds.

Criteria 1194.21(c)

A well-defined on-screen indication of the current focus shall be provided that moves among interactive interface elements as the input focus changes. The focus shall be programmatically exposed so that Assistive Technology can track focus and focus changes.

Clarification:

A clear visual indication of the location of the cursor as you move through the web application must be present.

Section 508 Refresh

  • 502.3.8 Interoperability with Assistive Technology - Accessibility Services - Focus Cursor
  • WCAG 2.1.2 No Keyboard Trap
  • WCAG 2.4.7 Focus Visable

Verification Notes:

  • When Supports is chosen look for the following information in Remarks and Explanation column:
    • A statement that reflects whether/how current focus is supported while navigating through the interface (e.g. prominent color rectangle around the active control).
  • When Supports with Exceptions is chosen look for the following information in Remarks and Explanation column:
    • The impact of the user’s inability to complete any core functions of the application due to the exception or lack of support for this criterion
  • Note that for responses that include Supports with Exceptions and Does Not Support drive the completion of the elements of the Accessibility Road Map and information to users on the Accessibility Statement.

Criteria 1194.21(d)

Sufficient information about a user interface element including the identity, operation and state of the element shall be available to Assistive Technology. When an image represents a program element, the information conveyed by the image must also be available in text.

Clarification:

Does the information about each control on the interface convey the information about its name, role and state (e.g. Subscribe, checkbox, unchecked)

Section 508 Refresh

  • 502.3.1 Interoperability with Assistive Technology - Accessibility Services - Object Information
  • 502.3.3 Interoperability with Assistive Technology - Accessibility Services - Values
  • 502.3.5 Interoperability with Assistive Technology - Accessibility Services - Hierarchical Relationships
  • 502.3.9 Interoperability with Assistive Technology - Accessibility Services - Event Notification
  • WCAG 4.1.2 - Name, Role, Value

Verification Notes:

  • When Supports is chosen look for the following information in Remarks and Explanation column:
    • A statement that reflects whether/how the name role and state are coded for various AT.
  • When Supports with Exceptions is chosen look for the following information in Remarks and Explanation column:
    • The impact of the user’s inability to complete any core functions of the application due to the exception or lack of support for this criterion.
  • Note that for responses that include Supports with Exceptions and Does Not Support drive the completion of the elements of the Accessibility Road Map and information to users on the Accessibility Statement.

Criteria 1194.21(e)

When bitmap images are used to identify controls, status indicators, or other programmatic elements, the meaning assigned to those images shall be consistent throughout an application’s performance.

Clarification:

The first portion of the criteria address the status indicators and programmatic elements that are announced by Assistive Technology.  This is often missed as the vendor addresses the application of meaning consistently in the product.

Section 508 Refresh

  • WCAG 3.2.4 Consistent Identification

Verification Notes:

  • When Supports is chosen look for the following information in Remarks and Explanation column:
    • A statement that reflects that the entire application was tested to verify that images that identify as controls are labeld and used consistently..
  • When Supports with Exceptions is chosen look for the following information in Remarks and Explanation column:
    • What is the impact of the user’s inability to complete any core functions of the application due to the exception or lack of support for this criterion.
  • Note that for responses that include Supports with Exceptions and Does Not Support drive the completion of the elements of the Accessibility Road Map and information to users on the Accessibility Statement.

Criteria 1194.21(f)

Textual information shall be provided through operating system functions for displaying text. The minimum information that shall be made available is text content, text input caret location, and text attributes.

Clarification:

Does the application convey text in a manner that is available to assistive technology. Can images of text be read aloud or enlarged as needed?

Browser is not responsible for rendering text

Section 508 Refresh

  • 502.3.6 Interoperability with Assistive Technology - Accessibility Services - Text
  • WCAG 1.4.5 Images of Text

Verification Notes:

  • When Supports is chosen look for the following information in Remarks and Explanation column:
    • A statement that reflects that the entire application was tested to verify that text is conveyed in a manner that is available to assistive technology.
  • When Supports with Exceptions is chosen look for the following information in Remarks and Explanation column:
    • What is the impact of the user’s inability to complete any core functions of the application due to the exception or lack of support for this criterion.
  • Note that for responses that include Supports with Exceptions and Does Not Support drive the completion of the elements of the Accessibility Road Map and information to users on the Accessibility Statement.

Criteria 1194.21(g)

Applications shall not override user selected contrast and color selections and other individual display attributes.

Clarification:

Does the vendor indicate whether the application correctly inherits OS settings for color/contrast (e.g. font and background color).

Section 508 Refresh

  • 503.2 Applications - User Preferences

Verification Notes:

  • When Supports is chosen look for the following information in Remarks and Explanation column:
    • A statement that indicates whether the application correctly inherits OS settings for color/contrast (e.g. font and background color) or the settings of Assistive Technologies.
  • When Supports with Exceptions is chosen look for the following information in Remarks and Explanation column:
    • The impact of the user’s inability to complete any core functions of the application due to the exception or lack of support for this criterion.
  • Note that for responses that include Supports with Exceptions and Does Not Support drive the completion of the elements of the Accessibility Road Map and information to users on the Accessibility Statement.

Criteria 1194.21(h)

When animation is displayed, the information shall be displayable in at least one non-animated presentation mode at the option of the user.

Clarification

Can the user pause or stop the animation or is there a way to obtain the animation information that does not contain animation?

Section 508 Refresh

  • WCAG 2.2.2 Pause, Stop, Hide

Cross References:

  • Section 508 - 1194.21(h), 1194.21(k), and 1194.22(j)

Verification Notes:

  • When Supports is chosen look for the following information in Remarks and Explanation column:
    • A statement that reflects that the entire application was tested to verify that annimation can be paused or stopped and that the information may be obtained without annimation.
  • When Supports with Exceptions is chosen look for the following information in Remarks and Explanation column:
    • What is the impact of the user’s inability to complete any core functions of the application due to the exception or lack of support for this criterion.
  • Note that for responses that include Supports with Exceptions and Does Not Support drive the completion of the elements of the Accessibility Road Map and information to users on the Accessibility Statement.

Criteria 1194.21(i)

Color coding shall not be used as the only means of conveying information, indicating an action, prompting a response, or distinguishing a visual element.

Clarification:

More than one method must be used to convey meaning or indicating an action or distinguishing a visual element.  Color may be one means but there must be a secondary means.

For example required form fields shown in red also need an asterisk to depict requirements. Further technical explanation of color criteria

For example link text only being shown with a color does not enough the use of underline or italics will help convey the meaning.Further technical explanation of link criteria

Section 508 Refresh

  • 302.3 Functional Performance - Without Perception of Color
  • 407.7 Operable Parts - Color
  • WCAG 1.4.1 Use of Color

Cross References:

  • Section 508 - 1194.22(c)

Verification Notes:

  • When Supports is chosen look for the following information in Remarks and Explanation column:
    • A statement that reflects what method is used to conveyed information with and without color. (e.g. bold, italic, font size or style etc.).
  • When Supports with Exceptions is chosen look for the following information in Remarks and Explanation column:
    • The impact of the user’s inability to complete any core functions of the application due to the exception or lack of support for this criterion.
  • Note that for responses that include Supports with Exceptions and Not Supported drive the completion of the elements of the Accessibility Road Map and information to users on the Accessibility Statement.

Criteria 1194.21(j)

When a product permits a user to adjust color and contrast settings, a variety of color selections capable of producing a range of contrast levels shall be provided.

Clarification:

When a product provides built in color adjustment, is there enough color contrast?

Cross References:

  • Section 508 - 1194.25(g)

Verification Notes:

  • This criterion is only applicable if the product allows for color adjustment within its settings. This is not about the operating system and its ability to adjust color.
  • When Supports is chosen look for the following information in Remarks and Explanation column:
    • A statement that reflects that the entire application was tested to verify that the color setting options meet color contrast requirements.
  • When Supports with Exceptions is chosen look for the following information in Remarks and Explanation column:
    • What is the impact of the user’s inability to complete any core functions of the application due to the exception or lack of support for this criterion.
  • Note that for responses that include Supports with Exceptions and Not Supported drive the completion of the elements of the Accessibility Road Map and information to users on the Accessibility Statement.

Criteria 1194.21(k)

Software shall not use flashing or blinking text, objects, or other elements having a flash or blink frequency greater than 2 Hz and lower than 55 Hz.

Clarification:

For example a visual strobe effect.

This is not about the refresh rate of the hardware.

Section 508 Refresh

  • 405.1 Flashing - General
  • WCAG 2.3.1 Three Flashes or Below Threshold

Cross References:

  • Section 508 - 1194.21(h) and 1194.22(j)

Verification Notes:

  • When Supports is chosen look for the following information in Remarks and Explanation column:
    • A statement that reflects that the entire application was tested to verify that flashing or blinking meets the requried standards.
  • When Supports with Exceptions is chosen look for the following information in Remarks and Explanation column:
    • What is the impact of the user’s inability to complete any core functions of the application due to the exception or lack of support for this criterion.
  • Note that for responses that include Supports with Exceptions and Not Supported drive the completion of the elements of the Accessibility Road Map and information to users on the Accessibility Statement.

Criteria 1194.21(l)

When electronic forms are used, the form shall allow people using Assistive Technology to access the information, field elements, and functionality required for completion and submission of the form, including all directions and cues.

Clarification:

  • Are the fields programmatically related to the labels? For Example explicit labels, keyboard operable, ‘required’ attributes. More specific code is needed than simply the words visually around the field.
  • Labeling Controls • Forms • WAI Web Accessibility Tutorials
  • Further technical explanation of Web Forms, W3C Form Concepts
  • Section 508 Refresh
    • 502.3.4 Interoperability with Assistive Technology - Accessibility Services - Label Relationships
    • WCAG 3.2.1 On Focus
    • WCAG 3.2.2 On Input
    • WCAG 3.3.1 Error Identification
    • WCAG 3.3.2 Labels or Instructions

Cross References:

  • Section 508 - 1194.22(n)

Verification Notes:

  • When Supports is chosen look for the following information in Remarks and Explanation column:
    • A statement that reflects how the fields are coded to relate to the labels.
    • A statement that describes the methods that were used to validate that forms support assistive technology. (e.g. explicit labels, keyboard operable, ‘required’ attributes).
  • When Supports with Exceptions is chosen look for the following information in Remarks and Explanation column:
    • The impact of the user’s inability to complete any core functions of the application due to the exception or lack of support for this criterion.
  • Note that for responses that include Supports with Exceptions and Not Supported drive the completion of the elements of the Accessibility Road Map and information to users on the Accessibility Statement.