Accessibility

Gilpin County (County) is committed to providing equitable access to our services for all members of the public. With 23% of Coloradans presenting with one or more functional disabilities, according to the Centers of Disease Control (CDC), ensuring equal access to the County’s digital services is of paramount importance. In accordance with the Colorado Law for Persons with Disabilities (HB21-1110) and the Technology Accessibility Cleanup (SB 23-244), Gilpin County must provide persons with disabilities equal access to County programs, services, and activities, including those programs, services, and activities that are made available through County websites and other online technology. Gilpin County’s commitment to digital accessibility goes beyond mere compliance with the law, and we are guided by the following values:

• Equality: We strive to ensure that all our residents can access, navigate, and interact with our digital content and services with ease and dignity. Wherever possible, we seek to reduce barriers and enhance access.
• Innovation: We embrace the challenge of integrating accessibility in our digital communications, services, and programs. By leveraging technology and best practices, we continuously improve the accessibility of our digital products.
• Transparency: We prioritize the diverse needs of our residents and seek to integrate their experiences into our transition plans. We seek feedback from the community to ensure our solutions are practical, effective, and respectful. We actively communicate our efforts to the public in order to build trust and foster a collaborative relationship with the community.
• Education: We believe in the power of knowledge and strive to educate staff, partners, and the broader community about the importance of digital accessibility and how best to reach these goals. Through training and advocacy, we a promote a culture of inclusivity and awareness.
• Sustainability: Our commitment to digital accessibility is long-term and proactive. We continuously invest in sustainable practices that ensure our digital platforms remain accessible as technology evolves and resident needs change.

Digital accessibility is a multifaceted and complex issue requiring many changes to the County’s way of business including to our website, digital documents, public communications, digital applications, and other processes and assets. To that end, the County has drafted the following plan to guide our ongoing efforts to remove accessibility barriers. This document focuses on a long-term strategic approach to digital accessibility, and as such, serves as a high-level planning document and may not fully describe all the tasks, activities, or assets involved in our efforts to enhance digital accessibility. This plan will be updated according to the schedule contained in the Compliance Planning and Reporting section and is complemented by detailed reports as defined in the same section.

Maturity Measures

For each section of this plan, major tasks and target dates are delineated. For each of those major tasks, a maturity level is defined as either planned, resourced, or complete. For reference, each level is defined below:

Planned: No formal policies, processes, or procedures are defined. No staff and/or resources have yet been assigned to pursue the completion of this task in a major way.

Resourced: Policies, processes, or procedures may be formally defined. Staff and/or resources have been assigned to pursue the completion of this task in a major way.

Complete: Task has been completed. Policies, processes, or procedures are formally defined and/or staff are performing tasks in a perpetual fashion. Staff are conducting validations and/or are measuring and tracking results.

Information and Communications Technology (ICT): Information technology and other equipment, systems, technologies, or processes, for which the principal function is the creation, manipulation, storage, display, receipt, or transmission of electronic data and information, as well as any associated content. Examples of ICT include, but are not limited to, computers and peripheral equipment; information kiosks and transaction machines; telecommunications equipment; customer premises equipment; multifunction office machines; software; applications; web sites; videos; and, electronic documents. The term does not include any equipment that contains embedded information technology that is used as an integral part of the product, but the principal function of which is not the acquisition, storage, manipulation, management, movement, control, display, switching, interchange, transmission, or reception of data or information. However, if the embedded information technology has an externally available web or computer interface, that interface is considered ICT. For example, Heating, Ventilation, and Air Conditioning (HVAC) equipment such as thermostats or temperature control devices, and medical equipment where information technology is integral to its operation are not considered information technology.

Web Content Accessibility Guidelines (WCAG): A set of guidelines published by the World Wide Web Consortium (W3C) that outlines certain standards for web content accessibility. These guidelines are internationally recognized and address common accessibility barriers such as keyboard navigation, color contrast, and semantic HTML markup for use by screen readers. State and Federal law requires that all counties in Colorado adhere to the latest WCAG standards at Level AA as defined.

8 CCR 1501-11 Technology Accessibility Rules: Rules established by the Chief Information Officer in the Colorado Office of Information Technology (OIT) as per C.R.S. 24-37.5-106 (4) and C.R.S. 24-85-103. These rules govern accessibility standards for an individual with a disability for information technology systems employed by any political subdivision of the State of Colorado.

Reasonable Accommodation: As it pertains to ICT, reasonable accommodation is a modification or adjustment to a program, service, activity, job, or the work environment that will enable an individual with a disability to participate in the program, service, activity, application process, or to perform essential job functions.

Reasonable Modification: As it pertains to ICT, reasonable modification is a modification in policies, practices, or procedures when the modifications are necessary to avoid discrimination on the basis of disability.

Conforming Alternate Version: An alternate version of ICT that delivers a service, program, or activity, or information of the same, that:

1. Conforms at the designated level;
2. Provides all of the same information and functionality in the same human language;
3. Is as up-to-date as the non-conforming content;
4. For which at least one of the following is true:
   1. The conforming version can be reached from the non-conforming page via an accessibility-supported mechanism, or
   2. The non-conforming version can only be reached from the conforming version, or
   3. The non-conforming version can only be reached from a conforming page that also provides a mechanism to reach the conforming version.

The following sections provide a brief summary of the digital accessibility standards as required by State law as well as the associated duties and obligations of the County.

HB 21-1110, Colorado Law For Persons With Disabilities

As approved by the Colorado General Assembly and signed by Governor Jared Polis, HB 21-1110 makes it a civil rights violation to exclude individuals with disabilities from participation in or being denied the benefits of services, programs, or activities provided by any Colorado government entity.

SB 23-244, Technology Accessibility Cleanup

As approved by the Colorado General Assembly and signed by Governor Jared Polis, SB 23-244 expands on HB 21-1110 in order to provide greater clarity for digital accessibility standards. Under C.R.S. 23-85-101, the State Office of Information Technology (OIT) possesses the authority to establish statewide digital accessibility standards. In response, OIT released 8 CCR 1501-11 in 2024, which delineates in detail the digital accessibility standards to which the County must comply. These rules, along with a plain language guide, are available at: 8 CCR 1501-11 Technology Accessibility Rules.

The County is required to meet the standards in all ICT, internally facing and externally facing, delineated in the above rules by July 1, 2024, or otherwise provide a good-faith plan to address any digital accessibility shortcomings. However, such good-faith measures do not provide immunity to the County from any potential litigation or state-levied fines as the result of non-compliance following the grace period ending on July 1, 2025, as described below.

HB 24-1454, Grace Period Noncompliance Digital Accessibility

As approved by the Colorado General Assembly and signed by Governor Jared Polis, HB 24-1454 provides for a one-year grace period for State agencies and local governments to comply with the standards established under HB 21-1110. This grace period provides immunity from liability for the County so long as good-faith efforts towards compliance with the OIT rules can be demonstrated.

This plan, along with the reporting provided under the Compliance Planning and Reporting section of this document, provides for the primary evidence of good-faith efforts to address digital accessibility barriers by Gilpin County.

Exemptions

While Gilpin County is committed to providing equal access to all people, there may be instances where full compliance with all accessibility standards in all cases may not be met. In these cases, State law provides a number of exemptions. They include:

1. Undue Burden: Implementing certain accessibility measures may pose an unreasonable financial, technical, or administrative burden on the County’s limited resources, potentially impacting the County’s ability to deliver essential services effectively.
2. Fundamental Alteration: Strict adherence to all accessibility standards in all cases could fundamentally change the nature of some of the County’s programs, services, or activities thus rendering them infeasible or ineffective.
3. Direct Threat: In rare cases, full accessibility might pose a direct threat to the health or safety of individuals, requiring specific risk assessments and alternative solutions.

When such exemptions are made apparent, Gilpin County will:

1. Demonstrate the burden or risk: The County will transparently explain the specific reasons why full compliance is not achievable in a particular instance on the accessibility page of the County website as described in County policy.
2. Explore alternative solutions: The County will actively seek alternative accessible means, reasonable accommodations, or reasonable modifications that effectively address accessibility needs that do not result in undue burden, fundamental alteration, or direct threat. Such alternative accessible means may include providing alternate formats of information, alternative communication methods, or accessible technology solutions. Alternative accessible means should not be used as a default option and will only be pursued with the presence of the above exemptions.

28 CFR Part 35, Americans with Disabilities Act (ADA) Nondiscrimination on the Basis of Disability in State and Local Government Services

In April of 2024, the Department of Justice released its final rule to revise the regulation implementing Title II of the ADA to establish specific requirements for digital accessibility in local and state government services. As per the final rule released, Gilpin County will need to be compliant with Federal standards no later than April 26, 2027.

In order to successfully meet the digital accessibility goals outlined in this document, certain funding priorities will need to be ensured. The below priorities do not create funding obligations per se, but are intended to guide leadership as they plan, discuss, and ultimately approve a budget for the 2025 Fiscal Year.

In order to reach the highest standard of accessibility, it will be critical for the County to proactively develop feedback mechanisms for use by the public. Such mechanisms will ensure that barriers to accessibility are quickly identified and resolved. Additionally, digital accessibility standards for public communication will need to be communicated to staff and implemented into policy and planning documents.

Major Tasks and Target Dates:

• Complete | 7/1/24 – Develop and publish an accessibility statement for the Gilpin County website.
• Complete | 7/1/24 – Develop a permanent mechanism for the public to provide feedback on accessibility issues, request reasonable accommodations or reasonable modifications, and identify accessibility barriers.
• Planned | 8/15/24 – Create and distribute a survey soliciting feedback from the public at large on how the County can best meet its accessibility goals.
• Resourced | 12/31/24 – Draft and approve a Communications Plan that includes specific considerations for digital accessibility.

Accessibility Statement

As per HB 21-1110, counties in Colorado must publish an accessibility statement on their official websites. Below is Gilpin County’s website accessibility statement in its entirety:

Digital Accessibility Accommodation Form

Gilpin County is committed to providing equitable access to our services to all community members. Our ongoing accessibility effort works toward being in line with the Web Content Accessibility Guidelines (WCAG) version 2.1, level AA criteria as published by the Worldwide Web Consortium. These guidelines not only help make technology accessible to users with sensory, cognitive, and mobility disabilities, but ultimately to all users, regardless of ability.

We welcome comments on how to improve our technology’s accessibility for users with disabilities and for requests for accommodation or modifications to any of our digital services. Upon notice, the County will make all reasonable changes to policies, programs, and digital services to ensure that all residents
have an equal opportunity to enjoy the programs and services the County offers.

If you need assistance with a website function or wish to request a reasonable accommodation or reasonable modification, please complete the Digital Accessibility Accommodation Form.

Alternatively, you may email access@gilpincounty.org or call the Administrative Assistant to the Board of County Commissioners at (303) 515-4343, Monday through Thursday 7:30 a.m. to 5:30 p.m., to request assistance. As part of your request please include:

1. Name of the person initiating the request or identifying the issue
2. Address
3. Phone number
4. A complete description of the specific request or issue.
5. Program or location of the issue on the website or digital service.

Auxiliary aids and services are available at all of our locations open to the public. Anyone who requires an auxiliary aid or service for effective communication, or modification of policies or procedures to participate in a program, service, or activity of the County should call the Administrative Assistant to the Board of County Commissioners at (303) 515-4343, Monday through Thursday 7:30 a.m. to 5:30 p.m., and at least 48 hours in advance of a scheduled event, to request assistance.

An accommodation is a reasonable modification or adjustment that enables a qualified person with a disability to enjoy the same access to services, activities, and programs that are enjoyed by persons without disabilities.

Feedback Mechanisms

In addition to the above accessibility statement, the County will develop various feedback mechanisms for the public to weigh in on accessibility issues, request reasonable accommodation or reasonable modification, or to identify accessibility barriers. This effort will include a dedicated email address (access@gilpincounty.org), changes to the County’s phone-based auto-attendant, and an online form. Additionally, in 2025, the County will develop and distribute a survey requesting greater feedback on how the County can better meet its accessibility goals.

Public Communications

As a relatively small county, many members of staff are regularly engaged in public communications through social media and the Gilpin County website. In order to ensure that all public communications via digital channels remain in compliance with applicable standards, changes in policy will need to be made as described in the Governance, Roles, and Responsibilities section below, changes to various roles and their responsibilities will need to be made as described in the same section, and training and certifications will need to be conducted as described in the Skills and Training section below. In addition to these changes, the County will regularly share full accessibility reports and summaries on social media and the County website, as further described in the Compliance Planning and Reporting section below, to ensure the public remains fully apprised of the County’s good faith efforts towards improving digital accessibility.

To positively affect initial changes and ensure ongoing compliance, the County will engage in several initiatives to properly control and govern the implementation of accessibility concerns into the County’s business practices.

Major Tasks and Target Dates:

• Resourced | 8/15/24 – Form and provide initial responsibilities for a Digital Content Committee to facilitate the County’s accessibility goals.
• Resourced | 8/27/24 – Draft and implement various policy changes including a new accessibility policy and changes to extant policies.
• Planned | 3/1/25 – Develop procedures and documentation for the use of exemptions where it is impractical or infeasible to implement accessibility standards.
• Planned | 10/1/24 – Identify select positions to serve as Digital Accessibility Coordinators for the organization and make associated changes to job descriptions.
• Planned | 11/1/24 – Develop and implement tools for the tracking of digital accessibility issues to assist in remediation, planning, and reporting purposes

Digital Content Committee

In order to facilitate updates to County digital infrastructure and ensure ongoing compliance with accessibility standards, the County Manager’s Office will create and staff a Digital Content Committee. This committee will be filled by representatives from a large swath, though not necessarily all, departments. The committee will meet regularly to discuss accessibility issues and will be responsible for conducting annual audits as described in the Evaluation and Remediation section of this plan. This committee will replace and build off of the framework developed by the Website Committee under the Website Policy, P-12, with expanded responsibilities.

Policy Changes

The Digital Content Committee in conjunction with the County Manager’s Office and the County Attorney’s Office will develop a digital accessibility policy. This policy will codify many of the goals of this plan by providing guidelines, workflows, and processes for social media, published documents, video, graphic design, and the County website to ensure compliance with the latest version of the WCAG at Level AA and other standards as defined State and Federal law. This policy will also set out various roles and responsibilities for digital accessibility in and amongst the various departments.

The County website and social media accounts serve as a critical point-of-contact and point-of-service for the public seeking services, programs, and activities. As such, ongoing compliance with the latest WCAG at Level AA is critical to ensuring that County maintains the highest digital accessibility standards. To that end, the Gilpin County Website Policy, P-12, will need to be updated to include accessibility considerations. Such changes will ensure that ongoing website edits and additions remain in compliance with WCAG standards. The County will also adopt a new social media policy to ensure that certain accessibility standards are met when posting from official County social media accounts.

In addition to the above, changes will need to be made to the County’s Procurement Policy, P-1, and Contract Management Policy, P-17. These changes are described in detail in the Procurement and Vendor Management section below.

Digital Accessibility Coordinators

In order to ensure the County possesses the necessary expertise to make good on its digital accessibility promises, a select number of positions will be identified as Digital Accessibility Coordinators. These roles will serve as the primary points of contact and points of service for digital accessibility across the organization. In order to ensure that these roles are able to successfully navigate these new responsibilities, training will be made available as described in detail in the Skills and Training section of this document. In order to ensure ongoing competencies, the job descriptions of these select positions will be updated to reflect new digital accessibility responsibilities and to provide preference for appropriate certifications.

Digital Accessibility Issue Tracking

As the County continues to improve upon its digital accessibility, the tracking of accessibility issues both new and old will prove invaluable. A centralized tracker will ensure that no issues “slip through the cracks” and that they are addressed in a prompt and effective way. Such data will also greatly assist planning and reporting efforts as described in the Compliance Planning and Reporting section of this document.

All digital products utilized by members of the public to access or apply for services, by staff for internal work processes, and by staff for public communication purposes will need to be identified. This comprehensive list will serve to guide remediation efforts in a manner that ensures total compliance with State law.

Major Tasks and Target Dates:

• Complete | 7/1/24 – Procure and distribute software to staff for the remediation of PDF documents and the drafting of accessible documents.
• Complete | 4/1/24 – Arrange for a third-party audit of the County website to identify failure points as defined by the WCAG 2.1 at Level AA.
• Complete | 6/1/24 – Following the third-party audit of the County website, correct any failure points.
• Resourced | 10/1/24 – Develop a comprehensive inventory of County ICT.
• Complete | 7/1/24 – Create a comprehensive inventory of County web pages and documents to include a determination of applicable exemptions.
• Planned | 7/1/25 – Remediate or remove all web pages and documents that do not meet an exemption.
• Planned | 3/1/25 – Develop a maintenance timeline and procure an automated scanning service for ongoing audit and remediation of digital content.
• Planned | 10/1/24 – Estimate hours for remediation of web pages and web documents and determine exemptions.
• Resourced | 7/1/25 – Remediate items that do not meet an exemption.

Procure PDF Remediation Software

The Gilpin County website often links to PDF documents to provide information to the public. While the County encourages staff to display information directly on the website whenever possible, there are times where a PDF displayed in the browser is preferable. In those use cases, accessible PDFs generated via Adobe Acrobat or Microsoft Word will be required. To that end, the County has procured and distributed the CommonLook software package, which enables document remediation, to relevant staff. For 2024, these licenses were acquired via a grant provided by SIPA, but use of Commonlook or a similar software in future years will require an associated allocation of funds as described in the Funding Priorities section.

Third-Party Audit of County Website

To ensure that the Gilpin County website is able to meet accessibility standards under the WCAG at Level AA, funds were allocated under the 2024 Annual Budget for a third-party audit of the website. After the normal procurement process was conducted, AccessibleWeb Inc. of Burlington, VT was awarded a contract to conduct the audit. Through this process, AccessibleWeb examined a number of templates that utilized all the various types of web elements present on the County website, but not did not necessarily identify each specific web element itself. This audit was completed in Q2 of 2024.

Remediation of County Website

In order to remain cost-effective, staff remediated the failure points identified in the audit conducted by AccessibleWeb. Care was taken to identify each specific web element of a type that failed inspection, though until a full inventory of County pages is developed as outlined below, we cannot guarantee that the website is in full compliance. Some points were unable to be corrected by staff as they existed on the back-end and were only able to be addressed by the Statewide Internet Portal Authority (SIPA) and their website servicer, Tyler Technologies. Both SIPA and Tyler Technologies are aware of these failure points and have communicated to staff their intention to bring them under applicable standards.

ICT Inventory

In order to ensure that all ICT is meeting applicable accessibility standards under the latest WCAG at Level AA and other standards as defined by State and Federal law, the County will need to develop a comprehensive list of all ICT used both internally and externally. This list will serve to define the scope of the County’s efforts towards ICT and will serve as an invaluable asset as the County progresses towards its accessibility goals.

Web-Based Document Inventory and Remediation

In addition to all the web pages that may require remediation, the County website also contains a number of PDF documents. For these pages and documents to reach compliance, a comprehensive inventory of all web pages and web-based documents will need to be generated by staff. This inventory will serve as a guide for staff to identify and remove or remediate web pages and web-based documents on the website. Generally, staff will be encouraged to build content directly onto web pages wherever possible.

Documents include, but are not limited to: meeting agendas, public notices, forms, and applications. Additionally, to ensure ongoing compliance, any new web pages and public-facing documents will need to be created with accessibility in mind so far as they meet the latest WCAG standards, and any other standards as outlined in State and Federal law. More details on software and training to achieve this are shown in the Funding Priorities and Skills and Training section.

Maintenance Timeline

Quarterly, the Digital Content Committee will conduct an accessibility audit for all public facing websites, web-based documents, and interactive devices such as kiosks and digital information boards. This audit will include both manual efforts and automatic scanning procured from a third-party. All ICT that has been identified as failing to meet accessibility standards will be flagged and assigned to committee members for remediation. Status of items requiring remediation will be posted publicly on the County website and updated every quarter.

Once compliance with State law is achieved, regular training will be necessary to ensure that all ICT utilized by the County remains in compliance. Training of all staff that utilize ICT for communication with the public and staff will be critical to ensure ongoing compliance. Skill development will result in the implementation of accessible digital content at initial stages and reduce evaluation and remediation costs as well as limit liability risk.

Major Tasks and Target Dates:

• Planned | 3/1/25 – Procure an online training regime for all staff involved in the creation of documents or use of ICT and additional training for staff involved in the creation and distribution of public-facing documents and ICT.
• Planned | 7/1/25 – Prepare an in-house repository of resources on digital content accessibility for reference and use by staff.
• Planned | 7/1/25 – Provide for the certification of Digital Accessibility Coordinators, as identified under Governance, Roles, and Responsibilities in digital content accessibility and remediation.
• Planned | 12/31/24 – Set individual accessibility goals and track progress through annual performance reviews under select positions.

Online Learning

The County is committed to implementing an effective online training regime for staff. Online training will be made available by the Human Resources (HR) Department for staff to take through onboarding and via annual sessions. This will include training for all public-facing employees or employees engaged in public-facing communications. Additional training will be made available for software applications the County may utilize in the creation or remediation of documents, presentations, and other materials. Such online training may include:

• W3c, Digital Accessibility Foundations
• Rocky Mountain ADA Center, Accessible Social Media
• Rocky Mountain ADA Center, Document Accessibility
• Rocky Mountain ADA Center, Presentation Accessibility
• Rocky Mountain ADA Center, WCAG
• Rocky Mountain ADA Center, Introduction to Assistive Technology
• Rocky Mountain ADA Center, Digital Accessibility

Resources and Assistance

The County will develop a repository of resources for access by staff to include recordings of previous trainings, example materials, training materials, outside resources, plain language guides, checklists etc. to ensure that staff has all the resources necessary to meet full compliance with digital accessibility standards.

Certification for Select Staff

The County will provide certification for several employees as deemed necessary through policy discussions to serve as key individuals in the organization to assist in all matters of digital accessibility. Such certifications may include:

• International Association of Accessibility Professionals (IAAP), Certified Professional in Accessibility Core Competencies (CPACC)
• W3C, Front-End Web Developer Professional Certificate
• IAAP, Web Accessibility Specialist (WAS)
• IAAP, Accessible Document Specialist (ADS)
• IAAP, Certified Professional in Web Accessibility (CPWA)
• Texas Digital Learning Association (TxDLA), Digital Accessibility Certification Program
• Udemy, Web Design Accessibility Certificate
• LinkedIn, Digital Accessibility for the Modern Workplace

Integration into Performance Reviews

Given that State accessibility standards will impact many aspects of County business and in that process disrupt legacy methods utilized by staff, integrating accessibility considerations into performance reviews will be an important tool to ensure compliance. While the Digital Accessibility Coordinators, as identified in the Governance, Roles, and Responsibilities section, will serve as resident experts providing assistance to all staff, many more will be involved in the creation of accessible digital content. As such, accessibility centered goals integrated into the annual reviews of all staff involved in the creation of digital content will be a critical tool in reaching the County’s accessibility goals.

In order to monitor, document, and communicate the County’s ongoing commitment to improve digital accessibility, the County will develop and update this plan as well as provide regular reports on progress. These considerations are important for internal planning, public communication, and compliance with applicable laws.

Major Tasks and Target Dates:

• Complete | 6/11/24 – Draft and approve an accessibility plan to guide internal planning and implementation efforts for digital accessibility.
• Planned | 1/31/26 – For calendar years 2024 and 2025 and starting with Quarter 3 2024, the County will prepare quarterly accessibility reports and make them available publicly.
• Planned | 1/31/26 – For calendar years 2024 and 2025 and starting with Quarter 3, 2024, the County will update this plan quarterly and make the updated plan available publicly.
• For calendar years 2026 and onward, the County will prepare annual accessibility reports and make them available publicly.
• For calendar years 2026 and onward, the County will update this plan annually and make the updated plan available publicly.

Accessibility Plan

The County has developed this plan as the first step in its reporting and monitoring of digital accessibility issues. For the calendar years of 2024 and 2025 and starting with Quarter 3, 2024, the County will update this plan on a quarterly basis to document progress on the goals contained herein, to update or add goals or provisions, and to document any large-scale corrective actions taken not previously documented in this plan. Starting in 2026, the County will update this plan annually to remain in compliance with any updated standards or updated ICT providing services, programs, or activities. All plans will be approved by the Board of County Commissioners (BoCC) and presented at a BoCC public meeting. The County will make all good-faith efforts to stay apprised of the best accessibility requirements to ensure internal policies, procedures, and training regimes are following the most up-to-date and best practices. This will include outreach to other government agencies and organizations to share resources and best practices for improving digital accessibility as described in the Regional Collaboration and Planning section below.

Reporting

Throughout the initial ramp-up of testing and remediation and forward toward ongoing compliance, the County will provide regular reporting of its good-faith efforts to achieve the broadest possible digital accessibility. For the calendar years of 2024 and 2025 and starting with Quarter 3, 2024, the County will prepare quarterly accessibility reports. Starting in 2026, the County will prepare annual accessibility reports. All reports will be approved by the BoCC and presented at a BoCC public meeting. These reports will include all corrective actions taken, all reasonable accommodations provided, all reasonable modifications provided, all requests for reasonable accommodations or modifications, all public feedback received via official channels, all staff feedback received, and any other details, documents, or other information as deemed relevant and necessary.

Gilpin County staff purchasing ICT services via third-party contractors are responsible for ensuring that vendors are both aware of the accessibility requirements under State and Federal Law and that vendors provide affirmation of their ability to meet these standards both through any proposals received by the County and through any contractual agreement between the vendor and the County. The implementation procedures published under this plan will identify resources, strategies, and guidelines for securing the greatest level of conformance to the standards provided under State and Federal law by third-party vendors. Where possible, the County will adopt policies and negotiating tactics to ensure third-party vendors providing ICT to the County are meeting all accessibility standards.

Major Tasks and Target Dates:

• Resourced | 9/1/24 – Reach out to third-party contractors to inquire about compliance with State accessibility standards, negotiate contract addendums if necessary, and/or give notice of intent to terminate following the contract period if necessary.
• Planned | 11/1/24 – Update the Procurement Policy, P-1, to include considerations for accessible ICT.
• Planned | 11/1/24 – Update the Contract Management Policy, P-17, to include considerations for accessible ICT.

Policy Changes

To ensure ongoing compliance with accessibility standards, the County will update the Procurement Policy, P-1, and the Contract Management Policy, P-17, as appropriate, to include the following considerations.

• All Request-for-Proposals (RFP) must include requirements for vendors offering ICT through a web-based platform to be compliant with the most recent WCAG standards at Level AA and all other standards as defined in State and Federal law.
• Evaluation criteria for proposals received from vendors offering ICT via an RFP process must include considerations for accessibility standards.
• All third-party vendors contracting with the County to provide ICT will be required to conduct accessibility testing on their digital services to ensure they meet the most recent WCAG standards at Level AA and all other standards as defined in State and Federal law.
• All contracts with third-party vendors providing ICT to the County will be required to include provisions for addressing accessibility issues that may arise during the contract term including steps for remediation.
• Gilpin County will ensure that third-party vendors remain in compliance with the appropriate accessibility standards on an on-going basis by taking such actions as withholding payment or terminating contracts in the event of non-compliance.
• All contracts with third-party vendors providing ICT to the County will be required to include an accessibility statement on any webpage hosted for provision of county services, programs, or activities. Such statement will provide a method by which members of the public may request reasonable accommodation or reasonable modification and report digital accessibility issues.

Compliance for Outside Consultants

From time to time, the County may contract with outside consultants to provide planning or policy documents. The County often wishes to share these documents widely with the public, and as such, will need to ensure that such documents are compliant with accessibility standards.

• All outside consultants preparing and providing documents to the County will need to ensure they meet the latest WCAG standards at Level AA and all other standards as defined in State and Federal law.
• All outside consultants preparing and providing documents to the County will need to ensure they meet other standards as determined by State and Federal law. This includes, but is not limited to, appropriately tagged content, lists, and alternative text for non-text content.
• All outside consultants will provide for an accessibility review of their documents by a third-party. A copy of the review will be provided to the County upon delivery of the work product.
• Gilpin County will ensure that third-party consultants providing documents as part of a work product are compliant as verified by a third-party by taking such actions as withholding payment or terminating contracts in the event of non-compliance.

In order to share resources, insights, and enhance collaboration, Gilpin County will strive to work closely with regional partners to enhance digital accessibility. While the County welcomes cooperation with entities across the State, our efforts focus on those located in the Peak-to-Peak region and the State agencies focused on digital accessibility such as OIT and the Statewide Internet Portal Authority (SIPA).

Major Tasks and Target Dates:

• Planned | X/X/XX – Reach out to regional partners for interest in forming a digital accessibility working group.
• Planned | 7/1/25 – Work with partners at the State on accessibility issues, seek out available resources, and attend accessibility related conferences and webinars.

Regional Digital Accessibility Working Group

As a small county with limited resources, leveraging regional partnerships will be vital to our ongoing efforts toward improving digital accessibility. Regional cooperation will enable the County to be more efficient with our limited capacity by sharing resources, information, and strategies. For this reason, a regional working group will enable Gilpin County to better reach all the various goals outlined in this plan. Potential partners include:

• The City of Black Hawk
• The City of Central
• The Town of Nederland
• Clear Creek County
• Jefferson County
• Gilpin County School District (GCSD)
• Boulder Valley School District (BVSD)
• The Denver Regional Council of Governments (DRCOG)
• Colorado Counties Incorporated (CCI)
• Counties & Commissioners Acting Together (CCAT)
• Rocky Mountain ADA Center

State Resources Engagement

The State of Colorado offers a number of resources for local governments to utilize as they work towards making their digital assets more accessible. In particular, staff will utilize those resources made available by the State OIT and SIPA offices. Such resources available include:

• OIT
  • Regular Website Updates
  • Accessibility Newsletter
  • Accessibility Website Toolkit
• SIPA
  • Newsletter
  • Micro-Grant Program

Gilpin County's commitment to digital accessibility is not just about compliance with the law but is a reflection of our dedication to serving all residents equitably. Recognizing that 23% of Coloradans live with one or more functional disabilities, we are resolved to ensure our digital services are accessible to everyone. This strategic plan outlines our approach to removing barriers and enhancing accessibility across our website, digital documents, public communications, and applications.

This plan is necessarily dynamic and will evolve as we continue to learn and adapt to new accessibility standards and technologies. We will regularly update this document as detailed in the Compliance Planning and Reporting section, ensuring that our efforts remain relevant and effective. Through continuous evaluation, remediation, skills training, and collaboration with regional partners, we aim to foster an inclusive digital environment that empowers all our residents.

Regular reporting will ensure the public may stay apprised of our ongoing efforts toward enhancing digital accessibility. Gilpin County invites all stakeholders, including residents, employees, and vendors, to join us in sharing their thoughts on how the County can proceed on this important endeavor.

Gilpin County Accessibility Compliance Progress as of July 1, 2024

Gilpin County is committed to providing equitable access to all Coloradans. Our ongoing accessibility effort works towards the day when all county services, programs, and activities are accessible, providing equal access to information and services to all Coloradans.

To that end, Gilpin County has a plan to prioritize, evaluate, remediate, and continuously improve every digital touchpoint within our services, programs, and activities.

Below is Gilpin County’s quarterly update on progress toward digital accessibility.

Accessibility Maturity

Gilpin County is at the following accessibility maturity level as of July 1, 2024. 

Why we are at this stage 

We’ve made great progress since HB21-1110 has passed considering substantial challenges to Gilpin County:

• Limited budget for our program: $50,000
• Two administrative FTEs, one of whom was hired in January 2024, manage the website, documentation, procurement, contract and vendor management, communications, and other duties

Organizational measures completed:

• Complete | 4/1/24 – Arrange for a third-party audit of the County website to identify failure points as defined by the WCAG 2.1 at Level AA. 
• Complete | 6/1/24 – Following the third-party audit of the County website, correct any failure points.  
• Complete | 6/11/24 – Draft and approve an accessibility plan to guide internal planning and implementation efforts for digital accessibility.  
• Complete | 7/1/24 – Procure and distribute software to staff for the remediation of PDF documents and the drafting of accessible documents.  
• Complete| 7/1/24 – Develop and publish an accessibility statement for the Gilpin County website. 
• Complete | 7/1/24 – Develop a permanent mechanism for the public to provide feedback on accessibility issues, request reasonable accommodations or reasonable modifications, and identify accessibility barriers. 
• Complete | 7/1/24 – Create a comprehensive inventory of County web pages and documents to include a determination of applicable exemptions.  
• Complete | 7/1/24 – Create a comprehensive inventory of County web pages and documents.
• Complete and in Progress | 7/1/24 - Publish quarterly accessibility report

Remediation and Compliance Status

Website, GilpinCounty.Colorado.gov - In Progress

The county has identified approximately 152 public-facing web pages as of 6/30/2024.

# of pages remediated to reach the WCAG 2.1 Level AA Rating: 3

# of pages remaining: 149

Documents on GilpinCounty.Colorado.gov – In Progress

The county has identified approximately 3,481 public-facing documents as of 5/17/2024.

# of documents remediated: 25

# of documents remaining that need remediation: 3,456

Formal approval

Melanie Bleyler, Community Engagement Officer, July 1, 2024