By: Lois Tucke, Sign Language Interpreter Specialist and Deaf and Hard of Hearing Services, and Rosie Widell, Digital Accessibility Coordinator and Risk Management, Minnesota Department of Corrections (DOC)

The Department of Corrections (DOC) provides tablets to the people housed in Minnesota’s state correctional facilities.

These tablets aim to strengthen bonds between incarcerated populations and their friends, family, and the community. For those incarcerated, secure electronic devices provide further access to:

• rehabilitative program content,
• religious content,
• important department updates, and
• ease of access to staff communications and processes.

Additionally, these devices provide positive leisure activities, such as games, movies, and books. The DOC expects high-quality and accessible products for our users.

From the start, the DOC committed to upholding the state standard to make information accessible to all people living in state facilities. We are seeking to build a tablet system that meets the state digital accessibility standard for all incarcerated users and want to share how we are making this a reality.

Developing the baseline for the RFP

The team began discussing digital accessibility before writing the Request for Proposal (RFP) and identified some of the accessibility-related business requirements. RFP development included input from both DOC and Minnesota IT Services’ (MNIT) Office of Accessibility:

2017

• The DOC Technology Accessibility Advisory Committee met to develop the original standards for the RFP. They released the RFP in 2018.
• The RFP incorporated the Federal Americans with Disabilities Act (ADA) and /mnit/government/policies/accessibility/index.jspState of Minnesota digital accessibility requirements into the specifications. DOC and Jay Wyant, MNIT’s Chief Information Accessibility Officer vetted those requirements. They updated the document to include additional procedures and exceptions.
• Wyant updated the document to reflect federal law and cleaned up the language. Afterwards the members of the Technology Accessibility Advisory Committee met to discuss and approve draft changes.

2018

• The Technology Accessibility Advisory Committee completed the final review and approval of the RFP.

RFP language and commitment to accessibility

Emphasizing the importance of digital accessibility was a priority for the RFP’s language. To do this, we included the following statements in the RFP:

VIII. Scope of Work

“The State of Minnesota, Department of Administration is issuing a Request for Proposal (RFP) for an Offender/ Client Telephone Calling/Recording/Monitoring System, for both the Department of Corrections (DOC) and Department of Human Services (DHS). This RFP also includes Kiosk/Tablet Services for DOC and DHS, and Money Transfer/Lockbox and Debit Release Card Services for the Department of Corrections (DOC) only. Proposed solutions will have to seamlessly interface with DOC/DHS core Offender/Client/Resident demographics, Offender/Client/Resident financial and Agency intelligence systems. These systems and services will be for facilities located at: Oak Park Heights, Stillwater, Rush City, St. Cloud, Faribault, Lino Lakes, Moose Lake, Red Wing, Shakopee, St. Paul, St. Peter, Togo, and Willow River.

The purpose of this RFP is to select a Contract Vendor to provide the best combination of security, reliability, service, and commissions that is an affordable, low cost option for community members….

In 1998, Congress amended the Rehabilitation Act of 1973 to require Federal agencies to make their electronic and information technology (EIT) accessible to people with disabilities. Inaccessible technology interferes with an ability to obtain and use information quickly and easily. Section 508 was enacted to eliminate barriers in information technology, open new opportunities for people with disabilities and encourage development of technologies that will help achieve these goals. All impacted State information systems, tools and information content shall comply.”

V. IT Accessibility Standards 

“The State of Minnesota (branch state agencies) has developed IT Accessibility Standards effective September 1, 2010, which entails, in part, the Web Content Accessibility Guidelines (WCAG) 2.0 (Level AA) and Section 508 Subparts A-D which can be viewed at: http://www.mmd.admin.state.mn.us/pdf/accessibility_standard.pdf.

The Standards apply to web sites, software applications, electronic reports and output documentation, training delivered in electronic formats (including, but not limited to, documents, videos, and webinars), among others. As upgrades are made to the software/products/subscriptions available through this Contract, the Contract Vendor agrees to develop functionality which supports accessibility. If any issues arise due to nonconformance with the above-mentioned accessibility standards, the Contract Vendor agrees to provide alternative solutions upon request at no additional charge to the State.”

Appendix I

B. System Interface

“19. System interface should be ADA (Americans with Disability Act) accessible utilizing or compatible with adaptive technologies according to the Web Content Accessibility Guidelines 2.0 of the State of Minnesota's /mnit/government/policies/accessibility/index.jspIT Accessibility Standards."

Selecting a vendor

On September 24, 2019, the DOC awarded Global Tel*Link Corporation (GTL) a contract to replace the existing telephone, kiosk, and debit/credit card solutions, and to also provide tablet-based communication, entertainment, and education services to incarcerated persons. The Office of Accessibility and DOC’s digital accessibility coordinators provided counsel and feedback when selecting the vendor.

Accessibility testing

One of the most important steps we took to ensure all users have an accessible product was to ask accessibility experts to review the tablet systems early in the development process.

We included accessibility testing as part of the user acceptance testing (UAT). We coordinated with MNIT’s Office of Accessibility and developed specific test plans. This allowed experts to strategically test specific functionality and parts of the system. 

Testing has been in depth and is ongoing. It includes testing for:

• Color contrast
• Magnification
• Keyboard operability
• Switch device operability
• Visible focus
• Focus order
• Ease of use

The DOC, in cooperation with MNIT’s Office of Accessibility, collated testing results, wrote an initial report on the findings, and met with the vendor to address barriers and possible solutions. The vendor also hired a third-party expert to test and certify functionality they developed for the tablet. The DOC and MNIT’s Office of Accessibility are currently working to determine accessibility of third-party applications, such as games, the vendor has made available on the tablet.

Finalizing the tablet as an accessible product

We’ve received initial feedback from testers that suggests we have more work to do to ensure that the Android tablets are accessible for all users. The testers discovered many barriers to accessibility, especially in third party apps. Performing accessibility testing in the middle of the process provided the necessary oversight for the department to work with the contractor to correct issues as able.  

Finding inaccessible areas and doing our best to fix them are necessary parts of the process. It’s not always easy to tackle areas of opportunity and equity, such as locating games for blind users, but it is necessary to our inclusion goals.

Although the project is not yet finished, the DOC’s goal is to have tablets in the hands of our state’s incarcerated people soon.

Helpful links

/mnit/assets/Stnd_State_Accessibility_tcm38-61585.pdfState of Minnesota's Accessibility Standard (PDF)