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Colorado Rulemaking on Digital Accessibility is Evolving – Are You Ready?

On Friday, December 15th, the State of Colorado Governor’s Office of Information Technology (OIT) submitted rulemaking changes relating to HB21-1110, also known as the Colorado Anti-Discrimination Act (CADA). There’s a lot going on here, and we won’t summarize everything but instead will focus on one or two elements that relate directly to content. Here’s a link to the update: Technology Accessibility Rules Summary of Changes 2023-12-15 – Google Docs

First, unlike the initial rule, this update specifically stipulates that archived content is in scope but subject to the entity’s accessibility transition plan that each entity establishes based on prioritization of that entity’s various Information Communication Technology (ICT). In fact, according to our reading of the update, the entire Exceptions section (11.6) is replaced by the requirement for an accessibility transition plan.

What does this mean for you as a City compliance or technology leader? Our interpretation of this is that city, county and state entities cannot simply exclude repositories of information because they would be difficult or time-consuming to make them accessible. Instead, according to our interpretation, the entity must assess the importance and impact of the content and create a prioritized schedule for addressing these various content types. For example, it might be highly important to make constituents’ tax or utility billing information 100% accessible, and much less important to make meeting minutes from 20 years ago accessible.

Prioritization may depend upon transparency and what content is retrieved most often. We at Crawford Technologies would recommend a combination of subjective judgement about what content should be accessible, but also hard retrieval metrics that can be gleaned from Google Analytics or other repository-specific algorithms. Our solutions can help you automate all of this. It looks like this:

  • Establish a priority schedule, don’t worry, there are already good examples to use as a template!
  • Set up workflows to extract and route content;
  • If the content is image-based, apply optical character recognition and validate that the OCR’d; content is valid at the end. Again, don’t worry, there are best practices here!
  • Apply AI to majority-tag the content;
  • Run a final QA step and ensure that read-order, tables, alternate text for images are properly applied;
  • Validate that resulting documents are accessible and unchanged from original input;
  • Load back into original repository or website.

We would recommend an approach that takes prioritized content through a workflow that categorizes your content and uses AI to significantly reduce the time to accessibility for those files that your city/county or state agency deems to be highly prioritized for accessibility. To see how this might work in an environment similar to yours, watch our recent Colorado-specific webinar.

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December 27, 2023


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