To ensure that updates to its website are tested for accessibility, by July 31, 2015, Covered California should develop and follow a written test approach that describes how and when changes to its website will be reviewed. This plan should describe how the department will include both automated and manual forms of accessibility testing.
Covered California has developed a 508 compliance test approach, which provides for manual and automated testing. Prior to product deployment, testing activities are performed and validated as part of the product testing cycles. Testing is also conducted post implementation to validate compliance. Covered California is continuing to enhance the test approach to reflect lessons learned.
The CalHEERS project recently began transitioning the ADA compliance activities to one of our newly hired state resources - with onlylimited transition occuring to date (Dec. 2015). Covered California will need additional time to continue identifying deficiencies and develop an appropriate corrective action plan and timeline for full implementation.
A draft written test plan, which describes the testing required when changes to our website are planned, has been created. It has been reviewed and approved and the testing approaches will be implemented before a change to the website is made. It includes both automated and manual forms of accessibility testing.
The draft plan has been submitted hard copy by US Mail.
Covered California submitted a test plan that is still in draft form. Accordingly, we assess this recommendation as only partially implemented. Further, Covered California's draft plan does not specify that manual testing will be used to determine compliance with Section 508. Instead, the draft plan states that manual testing is designed to identify aspects of its user-interface that might be technically accessible but still awkward or difficult for users with disabilities. Also, Covered California's draft plan does not include manual testing of every update to its website, but rather implements annual manual testing. To fully meet this recommendation, Covered California's test plan must incorporate manual testing as a means of determining compliance with Section 508 and also test updates to its website manually.
Agency responses received are posted verbatim.