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From: Andrea Miralia
Date: Mon, Jun 26 2017 6:09AM
Subject: "marked" as compliant?
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We remediated a document for CMS, and then got this comment back. I've never seen this before. Anyone know what they want here? Lol

"If the materials are not marked as 508 compliant, CMS will still proceed with the established meeting but be unable to share provided materials electronically throughout the agency."

In the past, we've just included the accessibility report.

From: Ryan E. Benson
Date: Mon, Jun 26 2017 7:01AM
Subject: Re: "marked" as compliant?
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Cms is part of HHS, so you should be making the files meet the checklists
on http://508.hhs.gov. The link is near the bottom of the page.

Ryan E. Benson

On Jun 26, 2017 08:09, "Andrea Miralia" < = EMAIL ADDRESS REMOVED = >
wrote:


We remediated a document for CMS, and then got this comment back. I've
never seen this before. Anyone know what they want here? Lol

"If the materials are not marked as 508 compliant, CMS will still proceed
with the established meeting but be unable to share provided materials
electronically throughout the agency."

In the past, we've just included the accessibility report.

From: Andrea Miralia
Date: Mon, Jun 26 2017 7:26AM
Subject: Re: "marked" as compliant?
← Previous message | Next message →

Ryan,
Yes... We're familiar with remediating documents for CMS. What we have not seen before is a file actually marked, in some way, as "compliant." Usually, we just remediate the file in Word and PDF and attach the accessibility report. CMS has never asked for a file to be "marked" otherwise; we did not get clarification on what they mean by this. We use the HHS and CMS checklists frequently. But those do not mention "marking" anything or having any sort of addition to a file.



 

 

From: Ryan E. Benson
Date: Mon, Jun 26 2017 8:44AM
Subject: Re: "marked" as compliant?
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I am not familiar with CMS' checklists, but I thought they just used the
ones I mentioned. There's not a way to mark it as compliant. Normally the
appropriate checklist is completed, and maybe another party will double
check, but that is it. You might to check the file properties window, if
this is a pdf, and make sure it thinks that it is tagged. Other than that,
I would ask for clarification from the person or the 508 coordinator.

Your 508 coordinator knows me, tell him to email me at my work address if
he wants to.

Ryan E. Benson

On Jun 26, 2017 09:26, "Andrea Miralia" < = EMAIL ADDRESS REMOVED = >
wrote:

>
> Ryan,
> Yes... We're familiar with remediating documents for CMS. What we have not
> seen before is a file actually marked, in some way, as "compliant."
> Usually, we just remediate the file in Word and PDF and attach the
> accessibility report. CMS has never asked for a file to be "marked"
> otherwise; we did not get clarification on what they mean by this. We use
> the HHS and CMS checklists frequently. But those do not mention "marking"
> anything or having any sort of addition to a file.
>
>
>
>
>
>
>
>
>

From: Jonathan Cohn
Date: Mon, Jun 26 2017 9:11AM
Subject: Re: "marked" as compliant?
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It sounds to me like they just want a statement in the document indicating
that it meets Section 508 requirements. Much like the accessibility link at
the footer of most federal web sites.

Best Wishes,

Jonathan Cohn

On Mon, Jun 26, 2017 at 10:44 AM Ryan E. Benson < = EMAIL ADDRESS REMOVED = >
wrote:

> I am not familiar with CMS' checklists, but I thought they just used the
> ones I mentioned. There's not a way to mark it as compliant. Normally the
> appropriate checklist is completed, and maybe another party will double
> check, but that is it. You might to check the file properties window, if
> this is a pdf, and make sure it thinks that it is tagged. Other than that,
> I would ask for clarification from the person or the 508 coordinator.
>
> Your 508 coordinator knows me, tell him to email me at my work address if
> he wants to.
>
> Ryan E. Benson
>
> On Jun 26, 2017 09:26, "Andrea Miralia" < = EMAIL ADDRESS REMOVED = >
> wrote:
>
> >
> > Ryan,
> > Yes... We're familiar with remediating documents for CMS. What we have
> not
> > seen before is a file actually marked, in some way, as "compliant."
> > Usually, we just remediate the file in Word and PDF and attach the
> > accessibility report. CMS has never asked for a file to be "marked"
> > otherwise; we did not get clarification on what they mean by this. We use
> > the HHS and CMS checklists frequently. But those do not mention "marking"
> > anything or having any sort of addition to a file.
> >
> >
> >
> >
> >
> >
> >
> >
> >

From: Ryan E. Benson
Date: Mon, Jun 26 2017 10:03AM
Subject: Re: "marked" as compliant?
← Previous message | Next message →

The checklist serves that purpose for hhs

Ryan E. Benson

On Jun 26, 2017 11:11, "Jonathan Cohn" < = EMAIL ADDRESS REMOVED = > wrote:

> It sounds to me like they just want a statement in the document indicating
> that it meets Section 508 requirements. Much like the accessibility link at
> the footer of most federal web sites.
>
> Best Wishes,
>
> Jonathan Cohn
>
> On Mon, Jun 26, 2017 at 10:44 AM Ryan E. Benson < = EMAIL ADDRESS REMOVED = >
> wrote:
>
> > I am not familiar with CMS' checklists, but I thought they just used the
> > ones I mentioned. There's not a way to mark it as compliant. Normally the
> > appropriate checklist is completed, and maybe another party will double
> > check, but that is it. You might to check the file properties window, if
> > this is a pdf, and make sure it thinks that it is tagged. Other than
> that,
> > I would ask for clarification from the person or the 508 coordinator.
> >
> > Your 508 coordinator knows me, tell him to email me at my work address if
> > he wants to.
> >
> > Ryan E. Benson
> >
> > On Jun 26, 2017 09:26, "Andrea Miralia" < = EMAIL ADDRESS REMOVED = >
> > wrote:
> >
> > >
> > > Ryan,
> > > Yes... We're familiar with remediating documents for CMS. What we have
> > not
> > > seen before is a file actually marked, in some way, as "compliant."
> > > Usually, we just remediate the file in Word and PDF and attach the
> > > accessibility report. CMS has never asked for a file to be "marked"
> > > otherwise; we did not get clarification on what they mean by this. We
> use
> > > the HHS and CMS checklists frequently. But those do not mention
> "marking"
> > > anything or having any sort of addition to a file.
> > >
> > >
> > >
> > >
> > >
> > >
> > >
> > >
> > >

From: Chagnon | PubCom
Date: Mon, Jun 26 2017 6:16PM
Subject: Re: "marked" as compliant?
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We do work for CMS and I think they're looking for the little certification icon (or medallion) in the left hand panel that states that it's PDF/UA accessible.

You can force the certificate/medallion into the panel (see long instructions below) with Acrobat Pro, but there's a caution:

It really doesn't preflight the file for accessibility or check it or verify it in any way.

It's just a medallion.

Hopefully you will do the checking to validate the PDF before adding the medallion. To prove this point, my firm demonstrated adding the medallion on an untagged PDF that was totally inaccessible.

But the medallion was there!

Email me off list if you'd like a copy of our short instructions on how to do this.
= EMAIL ADDRESS REMOVED =

FWIW, I'd don't recommend putting the accessibility report into the PDF because 1) it adds extraneous code to the file, and 2) I think it just confuses the average user. The report really isn't intended for the public user.

--Bevi Chagnon

- - -
Bevi Chagnon | www.PubCom.com
Technologists, Consultants, Trainers, Designers, and Developers
for publishing & communication
| Acrobat PDF | Print | EPUBS | Sec. 508 Accessibility |
- - -

From: Ryan E. Benson
Date: Mon, Jun 26 2017 6:52PM
Subject: Re: "marked" as compliant?
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With all due respect, what Bevi says *does not* need to be done for HHS
OPDIVS. How HHS and its OPDIVs determine a file is compliant, is through
our approved checklists. The PDF one is located at
https://www.hhs.gov/web/section-508/making-files-accessible/checklist/pdf/index.html.
Some people just give a "yes this meets the checklist" via e-mail, but the
preferred method to copy/paste the checklist into a word doc, and complete
it. Some people add a digital signature to the doc, but that's not needed.

I say this as a lead technical SME for a HHS OPDIV, and a recognized SME
for the department. The only person who can change the above requirement is
the Agency 508 coordinator. I spoke to CMS'' 508 Coordinator this
afternoon, and he agreed that a completed checklist just needs to be
submitted with the PDF. If CMS staff have issues with this, i recommend
referring the CMS staff to him, if they have issues.


Thanks

--
Ryan E. Benson

On Mon, Jun 26, 2017 at 8:16 PM, Chagnon | PubCom < = EMAIL ADDRESS REMOVED = >
wrote:

> We do work for CMS and I think they're looking for the little
> certification icon (or medallion) in the left hand panel that states that
> it's PDF/UA accessible.
>
> You can force the certificate/medallion into the panel (see long
> instructions below) with Acrobat Pro, but there's a caution:
>
> It really doesn't preflight the file for accessibility or check it or
> verify it in any way.
>
> It's just a medallion.
>
> Hopefully you will do the checking to validate the PDF before adding the
> medallion. To prove this point, my firm demonstrated adding the medallion
> on an untagged PDF that was totally inaccessible.
>
> But the medallion was there!
>
> Email me off list if you'd like a copy of our short instructions on how to
> do this.
> = EMAIL ADDRESS REMOVED =
>
> FWIW, I'd don't recommend putting the accessibility report into the PDF
> because 1) it adds extraneous code to the file, and 2) I think it just
> confuses the average user. The report really isn't intended for the public
> user.
>
> --Bevi Chagnon
>
> - - -
> Bevi Chagnon | www.PubCom.com
> Technologists, Consultants, Trainers, Designers, and Developers
> for publishing & communication
> | Acrobat PDF | Print | EPUBS | Sec. 508 Accessibility |
> - - -
>
>

From: Duff Johnson
Date: Tue, Jun 27 2017 9:42AM
Subject: Re: "marked" as compliant?
← Previous message | Next message →

Hi Bevi,

> We do work for CMS and I think they're looking for the little certification icon (or medallion) in the left hand panel that states that it's PDF/UA accessible.

Hmm. In addition to some little image pasted on the page, do such files also include the PDF/UA metadata flag (required for conformance with PDF/UA)?

Thanks,

All the best,

Duff Johnson

Independent Consultant
ISO 32000 (PDF) Intl. Project Co-Leader & US Chair
ISO 14289 (PDF/UA) Intl. Project Leader & US Chair

p +1.617.283.4226
e = EMAIL ADDRESS REMOVED =
w http://duff-johnson.com
l http://www.linkedin.com/in/duffjohnson/

From: Chagnon | PubCom
Date: Tue, Jun 27 2017 9:21PM
Subject: Re: "marked" as compliant?
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Hi Duff,
Ha! Such a trick question from you <grin>.
Of course our PDFs have the PDF/UA metadata.

--Bevi Chagnon

From: Andrea Miralia
Date: Wed, Jun 28 2017 8:20AM
Subject: Re: "marked" as compliant?
← Previous message | Next message →

I've been the 508 person at my company (a contractor for CMS) for 2 1/2 years now, and we've never been asked nor trained to attach nor complete the HHS checklist, a footer, or add a medallion. We *do* follow the checklists as part of our procedures to make documents compliant, but not as a formal part of submission. (We treat the checklists as just internal reminders, not as deliverables.) We've never been asked to submit anything additional. When we deliver our documents, we deliver accessibility reports (separately, not attached) for each document. With that said, we've never received any communication from a 508 person at CMS!


Andréa Miralia

From: Duff Johnson
Date: Wed, Jun 28 2017 10:33AM
Subject: Re: "marked" as compliant?
← Previous message | Next message →

Hi Bevi,

No trick intended!

I was not referring to your PDFs, but to the specifics of what I understood to be the CMS requirement based on the conversation.

I was hoping to hear that if CMS requires some PDF/UA 'medallion- that they also require the PDF/UA metadata.

Part of the point of PDF/UA is to improve the economics of accessibility, and enhance the availability of accessibility information to users. That's why we included *machine-readable* metadata as part of the specification. Software can use this feature to scan websites for PDF files that include the promise (PDF/UA) of accessible content vs. those that need work (for example).

Duff.

> On Jun 27, 2017, at 23:21, Chagnon | PubCom < = EMAIL ADDRESS REMOVED = > wrote:
>
> Hi Duff,
> Ha! Such a trick question from you <grin>.
> Of course our PDFs have the PDF/UA metadata.
>
> --Bevi Chagnon
>
>

From: Ryan E. Benson
Date: Wed, Jun 28 2017 6:47PM
Subject: Re: "marked" as compliant?
← Previous message | No next message

Andrea,
I recommend reaching out to CMS' 508 Coordinator for official guidance. The
checklist is how the Department judges if a file is compliant or not. This
is outlined in HHS Section 508 Policy, section 5.13.f (
https://www.hhs.gov/ocio/policy/508_policy.html#513AllHHSStaff)
Will ensure that contractors and vendors provide complete and accurate
HHS Section 508 Acceptance Checklists for all ICT being developed,
procured, maintained or used by HHS employees and by the public sites,
websites and applications.

--
Ryan E. Benson

On Wed, Jun 28, 2017 at 10:20 AM, Andrea Miralia <
= EMAIL ADDRESS REMOVED = > wrote:

>
>
> I've been the 508 person at my company (a contractor for CMS) for 2 1/2
> years now, and we've never been asked nor trained to attach nor complete
> the HHS checklist, a footer, or add a medallion. We *do* follow the
> checklists as part of our procedures to make documents compliant, but not
> as a formal part of submission. (We treat the checklists as just internal
> reminders, not as deliverables.) We've never been asked to submit anything
> additional. When we deliver our documents, we deliver accessibility reports
> (separately, not attached) for each document. With that said, we've never
> received any communication from a 508 person at CMS!
>
>
> Andréa Miralia
>
>
>