- [Kari] Hello. Good morning, good afternoon. We will get started here shortly, just while we let people finish getting registered and enrolled into the room. So just give us a minute. Again, just wanna thank everyone for joining us today. I'm gonna give it one more minute so attendees can finish joining the room. All right, it looks like we're slowing down a little bit, so just wanna say good morning, good afternoon to everyone. My name is Kari Kernen, and I am the Senior Manager of Sales Development here at TPGi. While we wait, just gonna go through a few housekeeping items for everyone. This session is being recorded and we will email everyone the recording after the event. We have captions available, so feel free to use those as needed. We will have time for live Q&A at the end of the session. Please use the Q&A box to input any of your questions, and we'll get to as many as we can. If you insert questions into the chat, they sometimes get missed. So again, please try to use that Q&A box for questions. Lastly, I'd like to mention if anyone is needing any accessibility support, training, usability testing, et cetera, an email will be sent out after the event with a link to schedule a time to meet with one of our experts. And with that, I'm gonna pass things off to David Sloan and let him provide an introduction of himself and get started.

- Thanks, Kari. And hi everyone. Hoping those of you experiencing the heat wave at the minute are able to use this as a reason to stay indoors right now. And also, apologies for rescheduling this webinar due to my unavailability two weeks ago, the original date this was planned to happen. So thank you everyone for joining. So my name's David Sloan, I'm Chief Accessibility Officer at Vispero and TPGi's User Experience Practice manager. And I'm talking today about the ADA Title II rule on web content and mobile app accessibility, managing risk, and improving UX, how to prioritize Title II, Digital Accessibility Efforts. And on today's webinar, we're gonna provide an overview of the new ADA Title II rule. I say new, it's been around since more than a year now. Who and what does the rule apply to? What requirements does it place on organizations subject to the rule and maybe other organizations who would benefit from being heed to what the rule requires? And then I'll outline an organizational strategy for responding to the rules requirements, firstly, evaluating and addressing current state. And secondly, on building capacity to be able to continue to meet the rule requirements over time. But before I start, I want to say a few things. Firstly, this webinar does not offer legal advice. I am not an attorney. So any reference to applicability of the law is just a lay opinion and certainly recommend you seek legal advice if you need to know the details of how the law might apply to your particular situation. Secondly, decisions made by the new administration in the US have created some uncertainty over the future direction of disability rights, legislation and regulation in the country. And I don't intend to speculate on quite what might happen in future months and years. I wanna focus on the current published rule, which is in place and is there to be observed by covered entities. But regardless, people with disabilities need accessible and usable digital resources. And the rule is a tool, a mechanism, a way to encourage efforts to meet ADA requirements while providing more inclusive online experiences for people with disabilities. So let's start with setting a bit of common ground in terms of an overview of the ADA Title II rule. But first of all, we'll kind of step back and look at what Title II of the ADA itself says. So the original text of Title II of the ADA, as passed in 1990 says, subject to the provisions of this sub-chapter, no qualified individual with a disability shall by reason of such disability be excluded from participation in or be denied the benefits of the services, programs or activities of a public entity, or be subjected to discrimination by any such entity and public entities covered by Title II, mean state and local governments and organizations and agencies funded by state and local governments. I'll give a couple of examples shortly, but just this kind of sets the scene that Title II is essentially prohibiting discrimination on account of a disability by state and local governments when providing services, programs or activities. So what are those examples of public entities? Well, that includes public schools, community colleges and public universities, public hospitals and public healthcare clinics, state and local elections offices, public transit agencies, state and local police departments, state and local courts and public libraries. And there are other examples as well. I took this list from a fact sheet that the Department of Justice provided on the new rule, and the link to that sheet is available in the copy of this slide deck that you should all have received as attendees of the webinar. So if you represent one of these public entities, then the ADA Title II rule applies to you. If you supply digital products to any of these entities, you should also pay attention to those requirements even if they don't directly apply to you. So the Department of Justice always maintained that ADA Title II applies to services and programs provided through websites and mobile apps, as well as on physical premises of public entities. And yet people with disabilities continue to encounter online barriers trying to access and use websites and apps provided by public entities. So the 2024 web content and mobile app accessibility rule really reinforced the position that the Department of Justice has held for a long time. And it also adds language to the ADA Title II regulation to provide clarity on how the broader ADA Title II can apply to websites and mobile apps. What do covered organizations, public entities need to do in order to meet their ADA responsibilities when looking at services, programs and activities that are provided online? So technically the rule adds a new subpart to the official Title II ADA regulation. So it's like adding more detail to something that already exists rather than something that is brand new and completely separate to what's already out there. And one thing that's clear and it really is clear with the ADA overall, that the rule's intention isn't to reduce protection for people with disabilities where other applicable laws or regulations may provide a higher level of protection. So an applicable state law with more stringent accessibility requirements would take precedence over the ADA rule, and that's kind of important when the ADA rule as we'll find out references a specific technical accessibility standard. If a state or local government passed a law that set a higher level of technical accessibility, then that's the one that would take precedence over the ADA that said, as we'll hear, the ADA sets a very helpful baseline for digital accessibility. So what technologies are covered by the rule? Well, specifically the rule focuses on web content and mobile apps. It talks about web content in terms of HTML webpages, including embedded audio and video content provided in those webpages. And also digital documents. So Microsoft Word, Microsoft PowerPoint, Adobe PDF format documents that are made available through the web. The list doesn't include technologies like desktop software or hardware. That doesn't mean that they don't need to be made accessible, just that the requirements of this particular rule don't apply. So it's very focused on web content and mobile apps. There are also some exceptions, which we'll talk about in a few minutes. So what's the technical accessibility requirement? Well covered web content and mobile apps must meet the W3C Web Content Accessibility Guidelines or WCAG version 2.1 to level A standard. Now, this is a potentially contentious decision because this is one version older than the latest version of WCAG, but that is to say there's nothing in the rule to stop a public entity adopting WCAG 2.2 as their standard. And in fact, I would encourage organizations to adopt WCAG 2.2, but the rule specifically references WCAG 2.1 and the Department of Justice explained their decision in choosing that particular version of WCAG. One of the challenges when writing the rule was that they can't issue a rule that refers to the latest or the current version of a standard. They have to be very specific in referencing a particular version rather than having something that could be open to interpretation and, you know, potentially other challenges there when they're not specifically referencing something that currently exists at the time of writing. WCAG 2.1 AA is helpful because it aligns with current standards in the European Union, in particular, the European standard EN 301549, which is companion to the European Accessibility Act. That situation will change when an updated version of EN 301549 is implemented probably early next year, but still at present, it's a helpful harmonized baseline between the Title II and efforts elsewhere in the world. It also provides a higher level of protection for people with disabilities than is currently required for federal entities in the US which are covered by the revised Section 508 standards. So if you're a provider of web content or tools that help create web content and you supply to federal agencies, you have a higher accessibility bar to reach for state and local government entities. So deadlines for compliance, well, we have less than 10 months to go for the deadline for larger public entities. The deadline or compliance are based on the size of the covered organization. So April 24th, 2026 is the deadline for compliance for state and local government entities with populations of 50,000 people or more. Smaller state and local government entities and also special district governments have an extra year to comply that the deadline there is April 26th, 2027. And the Department of Justice set those different deadlines based on the perceived capacity of a covered organization to meet the rules requirements and the likely effort that would be required based on the amount of content that needed to be addressed. So the assumption is a larger entity might have more content, but also has more resources and capability to address that content. So there's less time to achieve it. We can debate that logic. But essentially that's where we are. We have two deadlines. The earlier one is for larger public entities. There are some exceptions, as I mentioned on the rules applicability. And then, you know, again, the Department of Justice when they set these exceptions, and they initially set some exceptions that were then adjusted based on public feedback to an initial draft of the rule. But this was driven by efforts to help covered organizations prioritize efforts on the highest impact areas, recognizing that in some cases, entities may not have unlimited resources to address accessibility. So the exceptions were driven by the Department of Justice's best intentions to help focus efforts and where they had highest positive impact. And the exceptions are specific to the web content and mobile app accessibility rule, not to the ADA overall. So the exceptions relate to the specific technical requirements I just talked about and covered organizations would still need to be ready to address accessibility to meet those broader ADA requirements to ensure effective communication and provide reasonable accommodations for people with disabilities. So just because exceptions exist doesn't mean that you can say, I don't need to worry about accessibility at all. It's just in terms of applying the technical requirements in the rule, that's where the exception applies. The exceptions apply to certain types of content based on the content's age, format and purpose, and also who provided that content. And the rule has very specific definitions of content that can be included in exception. If a piece of content doesn't meet that definition, then the exception doesn't apply and the requirements have to be met. So what are those exceptions? You know, each, as I say, each exception is very clearly defined in the rule. And a digital resource must meet all parts of the definition to meet the exception criteria. So it's harder to use these exceptions as a kinda more general excuse not to do anything or to delay efforts. So the listed exceptions include archived web content where archived content is something that's kept in a clearly recognizable archived area online kept only for reference, research or record keeping and isn't updated. 'Cause as soon as it's updated, it's current. It's not archived. The existing conventional electronic documents, mean documents created before the date the state or local government must comply with the rule. And content hasn't been changed since that point. Again, it's been changed, it's not preexisting, it's current and it has to comply with the requirements. Content posted by a third party that isn't engaged by a covered organization to provide content. So for example, content that might be a comment on a public news item, content that was unsolicited and provided by a third party, not under any kind of contractual basis. That would be exempted. Individualized password protected content is included in the exception. And also preexisting social media content hosted by a covered organization. So again, that preexisting definition, if it's already out there, then it doesn't need to be remediated, but anything hosted from the deadline moving forward will have to meet Accessibility requirements. There are other potential exceptions listed in the rule in particular dealing with situations where it might not be feasible to meet technical accessibility requirements. And one is a general longstanding provision of the ADA relating to undue burden or requiring fundamental alteration. Paraphrasing that means if it would cost too much or if it would change the resource too much, then an exemption can be claimed from meeting the technical accessibility requirements. And to meet either of those exception criteria would require detailed documentation to demonstrate that making a change would cause undue burden or fundamental alteration. So again, it's not a process to be entered lightly. It does require careful documentation and decision making. Second exception, where not meeting technical Accessibility requirements can be mitigated by providing a conforming alternative version instead of a single version that meets WCAG 2.1 level AA. This situation is likely to be very rare and may be a solution for very specific edge case situations where a technology used to provide web content cannot be made fully accessible. But again, typically, it's something that's very rare as a justifiable approach to not remediating a website or mobile app to meet those technical accessibility requirements. And the third exception case is where not meeting technical accessibility requirements does not materially affect access to content functionality or participation for people with disabilities. And that is defined in the rule. You know, where participation means that people with disabilities can access the same information as individuals without disabilities, engage in the same interactions as individuals without disabilities, conduct the same transactions as individuals without disabilities or otherwise participate in or benefit from the same services, programs and activities as individuals without disabilities. So this would be a situation where an accessibility barrier exists in a part of a website or app that is so incidental and peripheral to the services, programs or activities the app or website supports that nobody is in practice affected by that barrier. So again, it's part of that focus, that intention of the Department of Justice to encourage organizations to focus efforts where they have most positive impact. So there's a concern expressed that the rule as it's written encourages focus on the sort of defaulting to a minimum baseline of technical accessibility compliance. But I like to see the rule as encouraging organizations, public entities and their technology suppliers to focus on improving accessibility and the online user experience of programs, services and activities provided through web content and mobile apps. And really the rule provides a baseline set of accessibility requirements and even following those technical accessibility standards specified in the rule will help on the journey towards improving usability of services, programs and activities for people with disabilities. And may make those services, programs and activities accessible and available to people who couldn't otherwise access alternatives provided through physical means by, for example, having to travel to an office or other location to receive those services or programs or activities. So already just by following those standards, you're helping make things more available and accessible to people who might not otherwise have been able to access them. While the rule requires WCAG 2.1 level AA conformance, that doesn't mean that you can't go further to include other accessibility requirements such as WCAG 2.2 as I mentioned, or following the advice provided in the W3C document making content usable. This is additional guidance provided by W3C to support people with a range of cognitive and learning disabilities. And that's a another way to build on top of the technical accessibility standards. Or you might want to look at the software accessibility requirements provided in Section 508 or the European standard EN 301549 to provide additional guidance where a native app or a web application might behave more like software and additional guidance on on effective use is provided in other standards. So while the rule helps you focus on a specific standard, it doesn't stop you from going a bit further to providing more accessibility enhancements based on the type of resource that you're building. The rule also encourages focus on user experience for people with disabilities. So one example is the exception that allowing resources not to meet WCAG 2.1 AA in a minor way, if there's no impact on people with disabilities. How would you verify that a conformance issue has no impact on users by testing with users? So including people with disabilities is an important aspect of any strategy towards meeting their requirements of the rule. Ultimately, the ADA is about reducing and/or eliminating discrimination on account of disability. And the best way to ensure that you've done that is by involving people with disabilities, firstly in the evaluation of existing resources to identify the nature and impact of barriers. And secondly, in the design, development and testing of new resources to help you build things that really work well for people with diverse accessibility needs. So let's switch now to focusing on strategies for responding to the rule. And this section of the webinar applies whether you're a public entity that's covered under Title II or a supplier to public entities. There are opportunities to respond intentionally and effectively to the rules, requirements and risks if you don't pay appropriate heed to what the rule requires. And before I go into more detail to the strategic guidance, I wanna mention that public entities already have obligations under Title II of the ADA to firstly conduct a self-evaluation of programs, activities and services, whether provided online or in physical premises to identify barriers to access by people with disabilities. And secondly, to create and implement a transition plan that identifies how the barriers identified in the self-evaluation will be addressed, who will address them, when will they be addressed by, how will we know that they've been successfully addressed. So public entities already likely have processes in place to address other aspects of ADA Title II, and taking advantage of that existing infrastructure, existing staff, maybe your public entity has one or more ADA coordinators who are already active in figuring out what's needed to meet the rules. There's infrastructure expertise, frameworks, processes already in place that can be extended to address website and mobile app accessibility in more detail. So essentially, public entities should not be starting from zero, there should already be some level of infrastructure in place. Secondly, we can look at those two components of ADA Title II compliance and kind of build on them for looking at the digital estate that is subject to this rules requirements. Firstly, a strategy should look at assessing and addressing current state. So essentially, the self-evaluation phase. And secondly, building capacity to ensure that future digital resources meet the core requirements, but also improve the user experience for people with disabilities. And that's kind of the transition planning, the moving into a desired future where an organization has capacity to maintain and exceed core accessibility requirements. So let's talk about the assessment and addressing current state aspect of strategy. And there's a very logical, intentional approach that you can take regardless of the size and current available resources that you might have to address digital accessibility. The first thing to do is to inventory existing resources. As a public entity, your goal is to find out what web content and mobile apps you have that are subject to the ADA Title rule. And that starts by documenting all the digital resources that your public entity owns or operates or provides to members of the public to access services, programs and activities. And then to, once you have a list of those covered resources, considering the exception criteria, which might mean that a certain resource is not subject to the ADA Title II rule requirements, then it's a case of prioritizing these resources based on factors such as their resource purpose, the frequency and criticality of use, how often is it used and based on the purpose, how critical is it that citizens are able to access and use the resource, what are the consequences of not being able to use the resource? What is the planned lifetime of the resource? Is there an intention to replace the website or retire it? That might impact on the prioritization rank of that resource and also the ownership. Is it a resource that's built and managed internally or is it provided by a vendor, in which case there's a vendor relationship to handle in terms of fixing any issues that you might find. Secondly, based on that prioritized list of resources, conduct an evaluation of those existing resources. And the goal is to find out where accessibility barriers are in those resources. So in priority order, evaluate resources for conformance with the rule's requirements, and you should use a mix of methods to do this. You can use automated tools to test against the technical standards specified WCAG 2.1 AA. You can use manual testing methods to test for those issues that cannot currently be identified through automated testing tools. Conducting usability testing with people with disabilities helps you learn more about the impact of existing barriers. What tasks do existing barriers either impede or stop people from being able to complete successfully? And again, that's important information when considering the next step of remediation. And you should also be looking at any sources of research or knowledge into already reported issues. Maybe there's bug lists or sort of people that have called in and reported issues with websites. You know, looking at information that's already been provided about a resource that reports on issues that have been encountered. So based on that evaluation, your goal is then to remediate existing resources to fix the barriers identified. And again, given the reality that there may be a lot of resources to fix and limited resources to address those barriers. Taking a prioritized approach to remediation is a sensible approach. And prioritization should take into account factors such as the severity of a barrier on affected user groups. You know, what is it that people have difficulty or are unable to do because of the existence of this barrier, the effort to fix how much expertise and time will it take to fix the barrier? And then also the availability of workarounds given that are related to the severity of a barrier. Is there another way that somebody can be supported? How adequate or effective is that way to support somebody in getting around that barrier? And ideally, you know, a high severity barrier that's easy to fix is something that you would address first, that would be at the top of the prioritization list and some things that are more complex or have less impact on people may be assigned a lower priority. And whenever you take steps to fix something, then you need to validate that remediation effort through further testing. Again, whether it's manual accessibility testing or further usability testing. And the final part of the assess and address phase of the strategy is to document your remediation efforts. Your goal here is to provide evidence of remediation to anyone who might want to know what you've done to address issues and move towards compliance. And that might be, you know, somebody who just wants to know what progress are you making towards meeting your legal obligations. It may be you know, that somebody decides to file a lawsuit. Having evidence of progress is important and valuable information to help you defend your efforts and demonstrate your commitment to progress. So documentation of remediation efforts might be, you know, in addition to the looking, you know, looking at each item on the inventory of resources that are covered, the methodology that you've used for evaluation and remediation, the progress that you've made in remediation efforts, the support that you are providing for people affected by barriers not yet fixed. And this is particularly important to people who are affected by the accessibility barriers that you've not yet been able to fix. Documenting a way to allow people to access the programs, services and activities that are affected by the barriers helps manage that situation while you make that remediation effort effective. And then where appropriate, justification for non-remediation, for example, invoking those exemptions may be related to disproportionate burden or fundamental alteration. So in each case, documenting what you've done for remediation or why you have decided not to implement remediation helps you present your position to anybody who might need to know. So that's focused on the assessing and addressing current state. In parallel, it's essential to focus on building organizational capacity so that you are set up as an organization to provide accessible digital resources going forward. That you're meeting the ADA Title II requirements and also anticipating any changes that might mean higher accessibility requirements as well as taking advantage of websites and mobile apps to be more efficient in providing public services to citizens. So there's a real opportunity here to use the ADA Title rule to improve the quality of the online services that you offer to the widest range of people possible. So part of the strategy is to establish a level of shared ownership across a public entity, firstly by securing leadership support. So that accessibility is an organizational priority and has top level support, which might include financial and resourcing support rather than something that's considered a grassroots effort that's led from the bottom up. Sure, it's important to have passionate people working at the coalface, but leadership support is essential to communicating that there is shared ownership across an organization for accessibility, defining accessibility, accountability and responsibility for every role that's involved in creating or managing or procuring or maintaining or editing digital resources helps make sure that everybody knows how accessibility expectations fit into their job duties. So this is really this overall strategy of communicating that accessibility is something that everybody is responsible for, and then when everybody knows that they have a role to play and that others do, then there is more of a sense of this team commitment to accessibility. Rather than it being considered a specialist activity that one or two enthusiasts or subject matter experts are responsible for without any authority to make changes and progress, then you need to ensure a shared understanding of what accessibility means and when it is considered in activities and in decision making. So an organizational accessibility policy communicates accessibility as a core value of an organization and how it's going to commit to that value. Supporting that is an organizational accessibility standard, which communicates in more detail what's meant by accessible or accessibility in the context of ADA Title II, then that accessibility standard could be WCAG 2.1 level AA but again, there's no reason why you can't move that to WCAG 2.2 AA as a higher level of accessibility with more, you know, that addresses more accessibility needs than is currently required as a baseline and helps you demonstrate that you are meeting the broader goal ADA Title II which is ensuring accessible public services. A governance framework helps communicate how the accessibility efforts will be monitored across the organization. So that there's some level of accountability and support for helping the organization as a whole understand the progress that it's making and to support course correction where progress isn't as positive and as significant as would be desired. And then more specifically, when we look at new digital resource specifications, including accessibility requirements in any new resource specification helps communicate accessibility is a priority right from the start. So a shared understanding when an organization decides to build or procure a new website or mobile app, making sure that accessibility is part of that initial specification. And ideally, the goal from a user's perspective has taken into account the perspectives and needs of people with disabilities. So their accessibility becomes a requirement, but it's also a catalyst for innovation in improving provision of public services. And that again, helps accessibility be perceived as something that encourages creativity and innovation as well as something that's required for compliance reasons. Training and resources is an important part of any effort to build accessibility capacity. Providing role-based training helps staff understand how they can meet their accessibility responsibilities as well as support the organization's accessibility goals. When training on accessibility is role-based, it allows you to provide the knowledge that people need to have and not the knowledge that people don't need to have. There is a tendency in accessibility, and I'll hold my hands up in giving people too much information too soon that can sometimes overwhelm them, especially when you're telling people about things that they don't need to know that are not relevant to their job. But what is also important with role-based training is helping staff understand where to go for specialist help. Who else is doing accessibility work as if I am performing a particular role, where can I get help and who else is responsible for other parts of the accessibility picture? So knowing your place, in terms of the broader organization strategy helps, helps people meet their roles and supports others in meeting theirs. Resources, tools and services can help staff meet their accessibility responsibilities, whether it's support in creating accessible content, whether you're a website developer or you're producing digital documents. You know, even pointing people to the accessibility checker for Microsoft PowerPoint to make sure that a slide deck is optimally accessible is a way to point somebody to an easy to use and very, you know, a tool that's available at someone's fingertips instead of having to go and download it or purchase it. Testing digital content for accessibility. There are lots of tools and resources available to help somebody make use of automated testing tools or provide or following quick checklists to test content for accessibility. And then services that might be more specialist in nature, for example, live captioning for events or needing more advanced accessibility support from an accessibility knowledge or connecting with people with disabilities in order to perform usability testing. The services that an organization provide may be more specific. It's not something that everybody would necessarily be able to do on their own, but knowing where to go to get access to those services and when to ask for that support is an important part of building knowledge and skills and providing support and implementing that knowledge and those skills across the organization. Another part of digital accessibility strategies, looking at recruitment and staff development, looking at job descriptions, making sure that they include accessibility requirements. We've talked already about responsibilities for existing employees, but ensuring that job descriptions have accessibility duties that will help communicating expectations and also support hiring of accessibility aware staff when you're hiring into positions. Somebody who has a working knowledge of accessibility has applied to the role that they're going to be working in is a great asset to helping an organization build capacity and helping achieve and maintain accessibility standards over time. Likewise, including accessibility in professional development and performance assessment frameworks just helps underline how accessibility skills are valued by an organization and hiring people with lived experience of disability and using assistive technology helps bring that expertise into the overall accessibility efforts helps build connections, brings that personal perspective that can support building more accessible and more usable digital resources as well as providing a broader visibility of disability within the organization. One criticism of the Title II rule is that public entities are on the hook for compliance, but products available on the market that entities might use to help them provide services, programs and activities don't meet those accessibility requirements. And the providers of those products are not subject to the rule. The Title II rule doesn't have the sort of best meets clause of Section 508 where federal agencies can choose the best solution, even if it doesn't fully conform to accessibility requirements. So I see this as an opportunity for public entities to reinforce expectations of third party suppliers and for third party suppliers who provide products and services to public entities covered by Title II, to take an opportunity to raise their accessibility game and be more attractive as options in the market. The Title II rule and other related legislation that is intended to focus on influencing the marketplace, like the European Accessibility Act, may help technology service and product providers to raise accessibility levels so that accessibility in third party provided resources becomes higher that it maybe has been up to now. So an effective third party accessibility policy helps a public entity manage accessibility risk throughout relationships with third party suppliers. Firstly, by ensuring that accessibility requirements are outlined in any request for proposals or any specification of a product or a service that the public entity is looking to procure from a third party, including accessibility characteristics when assessing candidate solutions, you know, products, how accessible is the product and vendor capability, how capable is this vendor of delivering accessible products and services in situations where a decision to select a particular product or service is made and the accessibility of that product or service is not as good as it could be. What is the process for dealing with any accessibility shortcomings, again, dealing with the reality that what's the best solution for the public entity might not be the most accessible. How does the entity deal with any accessibility shortcomings? How does it manage accessibility risk over the lifetime of using that third party product or service? And then embedding accessibility in contracts so that the vendor, the third party supplier where a contractual agreement is in place has some understanding of its obligations and the consequences of not meeting those accessibility obligations under contract. And then the last phase of strategy I want to talk about is communication. It's really important to set up and monitor communication channels where accessibility issues or concerns can be reported on and acted upon. And this all helps ensure that any barrier is identified and addressed in the most efficient and effective way possible. And that could be through an accessibility page on a public entity's website. It could be through a dedicated email address to report issues and supporting those channels. It should be a process in place for triaging those requests and issues, which might include escalating to the most appropriate responsible staff and also supporting the person who made the request or reported the issue, including helping them access whatever it was that they weren't able to access because of the barrier. And communication also relates to ongoing reporting, demonstrating progress internally across the organization and identifying where adjustments might need to be made to accessibility strategy where ongoing efforts are not making the progress that one would expect. And if you are a provider of digital products to public entities, then providing evidence of your accessibility efforts through, for example, Voluntary Product Accessibility Template, VPAT, Accessibility Conformance Report for the products you provide. And providing that in the WCAG format rather than only in the Section 508 format, which was kind of designed for federal agencies. Then that helps you communicate accessibility to prospective customers. It helps you tell prospective customers that you have been thinking about accessibility, you've taken steps and it helps reassure them that when they buy or use your product, then they're well on their way to meeting their obligations. So I'm just gonna finish up with a few full resources and the Department of Justice has provided a lot of really helpful resources to support implementation in meeting this ADA Title II rule for web content and mobile accessibility. The slide I'm sharing just now has links to the official text of the final rule that was published in the Federal Register. And while this is a long document, it's also very helpful to read through commentary from the Department of Justice on how they responded to public feedback, including the rationale that they presented for either changing the initial draft of the rule or where they didn't change the rule. So it provides a very transparent way of the rulemaking process, including the public feedback that was received and how it influenced the final rule. Then there's some useful supporting resources from the Department of Justice. There's a facts sheet on the rule and a small entity compliance guide, which provides specific guidance, for those smaller entities who may have an extra year but may also be feeling particular pressure to respond to the requirements of the rule. And I want to also give a shout out to the ADA coordinator training program that has been in place for many years, predates the rule, but has always made reference to the applicability of the ADA to digital means of providing services, programs and activities. This is a formal training process where members of a public entity or anyone else for that matter, can get training and certification, which covers a sort of whole broad spectrum of knowledge related to how the ADA applies and how an organization subject to the ADA can respond to meeting its requirements. And I'll just finish with a reminder that TPGi can help you with questions or services to support your ADA Title II efforts. We have a whole range of service offerings ranging from digital accessibility audits to creating VPAT ACRs, UX and accessibility strategy consultancy, automated testing with our ARC platform, accessibility training, and also self-service kiosk and testing solutions. So at this point, I'm gonna stop and look and see if we have questions and I will read them in order. First one question from Carla Blanco. Hello. I wanted to know if the regulations also cover books in ePub formats and when these same requirements will be applied to private sales channels and sites like Amazon, et cetera. The ADA Title II regulations don't specifically cover books. Again, because the ADA Title II applies to state and local government services, programs and activities, it's harder to look at that, you know, unless you could see a book being a way that a public entity provided access to a service, program or activity, it's unlikely that it would be explicitly covered under the ADA. That said, that's an example of a regulation that is covered by the European Accessibility Act. So any organization providing eBooks to consumers in the European Union, even if that organization is based in the United States, they would be subject to the requirements of the European Accessibility Act. So that's an example of where a law in another part of the world could potentially influence a provider based in the United States. Second question from Anthony Vasquez. Does this rule cover point of sale systems on campus, say a coffee shop? You know, it's a good question. I think it would depend if a service was, or a service, activity or program was included as, you know, whether a retail outlet would be considered part of that. I mean, I think there's a reasonable argument to make, and this is, you know, I, again, I'm not a lawyer, so I would recommend legal advice here, but it seems like an argument that a point of sale system could be considered subject to the rule. I think, I mean, it kind of depends what's being sold, what's the service being sold? If it's a coffee, then it's probably peripheral to the provision of a public entity. But if it's something like a means to pay tuition fees, then that might be something that's more applicable. But either way, making sure that point of sale systems on a campus are accessible is, you know, there's a broader requirement under the ADA to ensure that that services accessible to people with disabilities, whether it's considered a Title II thing or a Title III thing, a place of public accommodation. So I think more broadly, yes, the ADA applies specifically, I think that would be, you know, I would look to legal guidance on whether the Title II rule would cover point of sale systems. Then next question from anonymous attendee, how do these laws apply to internal websites and apps, those accessed by employees in the tight and in the government sector? Well, employee accessibility is governed by another part of the ADA. So again, technically, my reading of the rule is that it applies to websites, web content and mobile apps that provide services available to the public services, activities and programs. But that again, does not mean that internal websites and apps that are used in the purpose of somebody doing their job, they still need to be made accessible. It's the specific technical accessibility requirements in this rule probably would not apply if the internal websites and apps were only used by employees rather than to a public audience. But again, as I say, none of this is to say you don't have to make them accessible or you can ignore the requirements. Those requirements are very solid baseline and meeting those requirements would help you demonstrate your commitments and obligations under the ADA, whether as an employer or as a provider of service, programs and activities as a public entity or as a place of public accommodation or any other applicability of the ADA. And last question from Erin Vicker, just to confirm, digital documents created prior to the date the ruling goes into effect, don't have to be remediated, obviously, it's probably better to remediate everything, but those aren't held to standard, just anything created post April, 2026, that preexisting digital document clause. Yes, you know, that relates to anything that existed when the rule or the deadline was applied. So if somebody asks for access to that document, then you still have an obligation to provide an accommodation equivalent communication. But the specific applicability of this rule that, you know, that exemption would apply. So I'm now looking at the general webinar chats. So there's a question around religious organizations. Where do religious organizations fit into the guidelines to ensure accessibility? Or are they exempt? That is the one area that seems to not have any accountability. My understanding, and again, I'm not a lawyer, is that yes, religious organizations are exempt from many or most or possibly all of the ADA requirements. You know, again, I would encourage, regardless of whether you are obliged to or not, making digital environments accessible to everyone just makes good sense. It's a more inclusive way to provide access to the services or goods or whatever your organization offers, for whatever purpose your organization exists. So the absence of an organization from the specific applicability of the requirements doesn't mean that you don't have to do anything. You know, I still highly encourage an organization, whether it's a religious organization or not, to take steps to make its digital properties as accessible as possible to everyone, you know, it just really makes good sense to do that. And the ADA Title II rule is a very helpful way to give you a baseline on what you need to do. So one more question came in, another anonymous attendee. The preexisting clause works in isolation, doesn't require the other four criteria you listed to also be true. I think yes, each of those five exemption clauses exist independently of each other. So they all stand alone rather than kind of relate to each other. But again, I would highly encourage reading the rule to be absolutely clear of the exemption criteria. And even if we go, I'm gonna just move the slides back a couple of notes to the facts sheet on the rule. So go to the www.ADA.gov website and search for the facts sheet on the ADA Title II rule. That will set out the text of the exception. So always look to the canonical location of exemptions and exceptions before making a decision not to address accessibility of those resources. So given that we're just over time, I want to thank everybody for attending. I hope you found this useful. We'll be sending the slides out shortly if we haven't done so already. And again, any further questions or comments, I would be happy to address them offline. My email address is dsloan D-S-L-O-A-N @TPGi.com. So thank you everyone for your attendance and best of luck with your ADA Title II efforts. Thank you.