Implementation and Roadmap

The April 24, 2024, Rule issued by the Department of Justice to update its regulations for Title II of the ADA applies to all state and local governments. This means all State of Vermont agencies, departments, divisions, offices and entities must follow the updated Rule. Each State entity producing digital content is responsible for adopting and maintaining the WCAG 2.1 AA standards, and self-certification of compliance will be required. 

The State of Vermont Digital Accessibility Steering Committee is responsible for providing agencies and departments with guidance and tools to meet the Federal accessibility standard, incorporate accessibility into standard communications procedures, and maintain – and exceed – standards over time. 

• Entity Responsibilities
• Implementation and Roadmap Phases

Entity Responsibilities 

To support the Digital Accessibility Steering Committee, each State agency and department has identified an Internal Digital Accessibility Team. This team includes:

• One Project Point, who will be responsible for their agency’s compliance efforts, tracking and reporting. The Digital Accessibility Steering Committee recommended that Cabinet members encourage the agency/department’s web manager or communications director to serve as the Project Point.
• One or more Digital Accessibility Support Staff to be trained in digital accessibility criteria and best practices who can support remediation and ongoing digital accessibility practices.

Each Internal Digital Accessibility Team will be responsible for their agency and/or department’s remediation and maintenance of digital accessibility standards. The Digital Accessibility Steering Committee maintains a list of the Internal Digital Accessibility Teams and will provide regular updates with specific action items, guidance, tools, and internal messaging to help with this compliance effort. Regular check-ins with Project Point personnel will be scheduled as we progress through the steps outlined in the Implementation and Roadmap.

Implementation and Roadmap Phases 

• Phase 1: Preparation
• Phase 2: Launch
• Phase 3: Review and Assessment
• Phase 4: Remediation
• Phase 5: Maintenance and Continuous Improvement

Phase 1: Preparation 

Timeline: January 2025 – March 2025

Core Focus Areas of Preparation

• Assemble a Digital Accessibility Steering Committee.
  Assigned to: Digital Accessibility Steering Committee. Completed.
• Develop a plan to support enterprise-wide compliance.
  Assigned to: Digital Accessibility Steering Committee. Completed.
• Identify vendors available to support auditing and remediation.
  Assigned to: Digital Accessibility Steering Committee. Completed.
• Establish a training curriculum.
  Assigned to: Digital Accessibility Steering Committee. In Progress.

Phase 2: Launch 

Timeline: January 2025 – April 2025

Core Focus Areas of Launch

• Inform agency and department leadership, web editors, digital content, application and platform developers, procurement specialists; and communications teams are aware of the new Rule requirements and need for an Enterprise effort to meet it.
  Assigned to: Digital Accessibility Steering Committee. Completed.
• Establish an Internal Digital Accessibility Team for each agency and/or departments.
  Assigned to: Appointing authorities. Completed.
• Inform and engage Internal Digital Accessibility Teams to advance the Universal Digital Accessibility project.
  Assigned to: Digital Accessibility Steering Committee. Ongoing.
• Establish a resource page for the Universal Digital Accessibility project.
  Assigned to: Digital Accessibility Steering Committee. Completed.
• Complete training as assigned by the Digital Accessibility Steering Committee.
  Assigned to: Internal Digital Accessibility Teams.
• Create and distribute guidance and tools to support agencies throughout the Universal Digital Accessibility project.
  Assigned to: Digital Accessibility Steering Committee. Ongoing.

Phase 3: Review and Assessment 

Timeline: Spring/Summer 2025

Core Focus Areas of Review and Assessment

• Conduct automated audits for all websites and webpages hosted by the State’s contractor Tyler Technologies.
  Assigned to: Agency of Digital Services. 
• Remediate issues in Tyler templates based on audit results. 
  Assigned to: Agency of Digital Services.
• Provide guidance and referrals to help agencies and departments pursue manual audits and establish remediation plans.
  Assigned to: Digital Accessibility Steering Committee.
• Conduct manual audits to problem areas.
  Assigned to: Internal Digital Accessibility Teams.
• Update State's digital accessibility policy and build a system for reporting issues and feedback.
  Assigned to: Agency of Digital Services.

Phase 4: Remediation 

Timeline: Spring 2025 – April 2026

Core Focus Areas of Remediation

• Issue guidance and toolkits to support agencies and departments with remediation.
  Assigned to: Digital Accessibility Steering Committee.
• Fix and update existing digital content to meet WCAG 2.1 AA criteria.
  Assigned to: Internal Digital Accessibility Teams.
• Adopt recommended digital accessibility review processes to ensure WCAG 2.1 AA criteria are met for digital platforms and content posted or issued electronically by their agency or department.
  Assigned to: Internal Digital Accessibility Teams.

Phase 5: Maintenance and Continuous Improvement 

Timeline: Ongoing

Core Focus Areas of Maintenance and Continuous Improvement

• Follow established digital accessibility protocols and processes for all digital content.
  Assigned to: Internal Digital Accessibility Teams.
• Monitor and adopt new digital accessibility standards as required, or able.
  Assigned to: Internal Digital Accessibility Teams.
• Ensure training of new employees, and adopt new trainings as needed.
  Assigned to: Internal Digital Accessibility Teams.
• Develop long-term maintenance goals and accountability measures.
  Assigned to: Digital Accessibility Steering Committee