In my last post in the Digital Accessibility Maturity Model (DAMM) Series I detailed the Policies and Standards Dimension of DAMM. In this post I’ll discuss the Regulatory Dimension, the aspects and artifacts associated with this dimension, and what each of the five maturity levels looks like for the Regulatory Dimension. (DAMM Definitions and Acronyms)
The Regulatory Dimension encompasses all non-HR filings, remediation plans, or other documentation that are required by statute, regulation, or are part of a settlement agreement, consent decree, or other legal proceeding.
- Regulatory Process – The maturity of the organization in communicating with regulatory authorities regarding accessibility policy and standards implementation activities. This includes the process associated with filing relevant certifications and reporting documents with regulatory organizations, involvement in the creation of accessibility policies and standards, and participation in the accessibility complaint and dispute resolution process.
- Regulatory Calendar – a formal method of tracking deadlines for accessibility filings.
- Regulatory Filings – including but not limited to responses to the Department of Justice or Equal Opportunity Employment Commission pertaining to formal ADA complaints, Section 504 plans, etc.
Level 1 – Initial
- Interacting with federal, state, or local agencies related to regulatory filings or communications is done on a reactive, ad-hoc basis.
Level 2 – Managed
- Basic regulatory structure is in place, such as an assigned legal representative or a regulatory calendar.
- Basic regulatory communications process is in place to inform all stakeholders when regulations have been added, updated, or deleted.
Level 3 – Defined
- Inaccessible ICT components are reviewed by legal prior to deployment.
- Specific regulatory filings or communications with approval process can be cited.
- Legal staff participates in the development of all remediation plans or Corrective Action Plans.
- Legal staff continuously monitors disability-related federal, state and local regulations.
Level 4 – Quantitatively Managed
- Enterprise level metrics are available on regulatory efforts.
- Regulatory filings and communications efficacy and metrics can be tracked.
Level 5 – Optimizing
- Legal has the right to stop a product launch process if they view the risk of inaccessible components to be too high to the organization.
In my next post I’ll discuss Dimension #5 of DAMM – the Fiscal Management Dimension – which defines the core maturity an organization has in analyzing and implementing accessibility investments.