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This specification provides guidelines for designing Web content authoring tools that are more accessible for people with disabilities. An authoring tool that conforms to these guidelines will promote accessibility by providing an accessible user interface to authors with disabilities as well as enabling, supporting, and promoting the production of accessible Web content by all authors.
"Authoring Tool Accessibility Guidelines 2.0" (ATAG 2.0) is part of a series of accessibility guidelines published by the W3C Web Accessibility Initiative (WAI).
This section describes the status of this document at the time of its publication. Other documents may supersede this document. A list of current W3C publications and the latest revision of this technical report can be found in the W3C technical reports index at http://www.w3.org/TR/.
This is a Working Draft intended to gather comments on a stabilized version of the Authoring Tool Accessibility Guidelines 2.0 (ATAG 2.0) prior to proceeding to a second Last Call Working Draft. The Working Draft includes an Appendix B: Comparison of ATAG 1.0 checkpoints to ATAG 2.0.
The AUWG encourages feedback about this Working Draft. Please send your comments by 11 January 2007 to w3c-wai-au@w3.org. The archives for this list are publicly available.
Publication as a Working Draft does not imply endorsement by the W3C Membership. This is a draft document and may be updated, replaced or obsoleted by other documents at any time. It is inappropriate to cite this document as other than work in progress.
The Working Group (AUWG) intends to publish ATAG 2.0 as a W3C Recommendation. Until that time Authoring Tool Accessibility Guidelines 1.0 (ATAG 1.0) [ATAG10] is the stable, referenceable version. This Working Draft does not supersede ATAG 1.0.
This document was produced by a group operating under the 5 February 2004 W3C Patent Policy. W3C maintains a public list of any patent disclosures made in connection with the deliverables of the group; that page also includes instructions for disclosing a patent. An individual who has actual knowledge of a patent which the individual believes contains Essential Claim(s) must disclose the information in accordance with section 6 of the W3C Patent Policy.
This document has been produced as part of the W3C Web Accessibility Initiative (WAI). The goals of the AUWG are discussed in the Working Group charter. The AUWG is part of the WAI Technical Activity.
This section is informative.
You are reading the Authoring Tool Accessibility Guidelines (ATAG) version 2.0. This document includes recommendations for assisting authoring tool developers to make their tools (and the Web content that the tools generate) more accessible to all people, especially people with disabilities, who may potentially be either authors or end users. These guidelines have been written to address the requirements of many different audiences, including, but not limited to:
An attempt has been made to make this document as readable and usable as possible for that diverse audience, while still retaining the accuracy and clarity needed in a technical specification.
ATAG 2.0 is part of a series of accessibility guidelines published by the Web Accessibility Initiative (WAI). The relationship between these documents is explained in "Essential Components of Web Accessibility" [COMPONENTS].
This ATAG 2.0 document itself consists of:
ATAG 2.0 defines an "authoring tool" as any software, or collection of software components, that authors use to create or modify Web content for publication.
The following categories are an informative illustration of the range of tools covered by ATAG 2.0. The categories are used primarily in the Techniques document [ATAG20-TECHS] to mark examples that may be of interest to developers of particular types of tools. Note: Many authoring tools include authoring functions from more than one category (e.g., an HTML editor with both code-level and WYSIWYG editing views):
The guiding principle of ATAG 2.0 is that:
Everyone should have the ability to create and access Web content.
Authoring tools play a crucial role in achieving this principle because the accessibility of the tool's authoring tool user interface determines who can access the tool as a Web content author (see Part A of the guidelines) and the accessibility of the resulting Web content determines who can be an end user of that Web content (see Part B of the guidelines).
The approach taken to the production of accessible content in these guidelines is one of enabling, supporting, and guiding the author. In general, the Working Group does not believe that enforcing particular author behavior through overly restrictive mechanisms is a workable solution.
As an introduction to accessible authoring tool design, consider that the authors and end users of Web content may be using the tool and its output in contexts that are very different from that which may be regarded as typical. For example, authors and end users may
For more information, see "How People with Disabilities Use the Web" [PWD-USE-WEB]. In addition, following the guidelines provides benefits for authors and end users beyond those listed in these various disability-related contexts. For example, a person may have average hearing, but still require captions for audio information due to a noisy workplace. Similarly, a person working in an eyes-busy environment may require an audio alternative to information they cannot view.
Also consider that authors may not be familiar with the specific needs of people with disabilities and will require support from the authoring tool to fill the knowledge gap.
At the time of publication, version 1.0 of WCAG is a W3C Recommendation [WCAG10], and a second version of the guidelines is under development [WCAG20]. Note that the two versions have somewhat different Conformance Models.
The Web Content Accessibility Guidelines (WCAG) is the W3C-WAI Recommendation that defines requirements for making Web content accessible to a wide range of people with disabilities. ATAG 2.0 includes a Web Content Accessibility "Benchmark" section that refers to WCAG as the guideline for judging the accessibility of Web content (see the term "Accessible Web Content") and any Web-based authoring tool user interface functionality (see the term "Accessible Authoring Tool User Interface").
Note that the references to WCAG are made without an associated version number. This has been done to allow developers to select, and record in the conformance profile, whichever version of WCAG is most appropriate for the circumstances of a given authoring tool. Consider the following when deciding which WCAG version to use:
This section is normative.
Conformance means that the authoring tool satisfies the checkpoint success criteria defined in the guidelines section. This section outlines the conformance scheme used throughout this document.
Each checkpoints is assigned one of three (3) priority levels.
(If a checkpoint success criterion is not applicable to an authoring tool, then that success criterion is treated as met for conformance purposes.)
The purpose of the Web Content Accessibility "Benchmark" is to precisely specify the evaluator's interpretation of what "accessible Web content" means with respect to the particular content type(s) that are produced by the authoring tool or are used to implement Web-based user interface functionality of the authoring tool (if applicable). This precise interpretation helps the evaluator to judge the completeness and consistency of accessibility-related authoring tool functions that must interoperate, such as accessibility prompting, evaluation, and repair functions. In addition, because the Benchmark must be made public, it allows claims to be more fully checked for accuracy.
A Benchmark document must be publicly published on the Web (the URI will appear in the conformance claim) and must include:
Note on other Accessibility Standards: ATAG 2.0 addresses how authoring tools can be designed to encourage authors to create accessible content. While the Working Group highly recommends the W3C-WAI Web Content Accessibility Guidelines due to the quality of the document and the process under which it was developed, other Recommendations, Standards, and Regulations with the same goal exist in jurisdictions and organizations around the world. @@JR: ???@@
Yes. Although it may be based on informative documents, such as WCAG Techniques, ATAG 2.0 considers that a Benchmark becomes normative for a particular conformance claim when that claim includes a reference to the URI of that Benchmark.
A Benchmark can be created by any any person, company or other organization. However, in the interest of being able to directly compare the evaluations of authoring tools that produce the same content types, the Working Group suggests checking to see if a Benchmark document has already been published, before creating a new one.
The Working Group suggests the following:
Authoring tools may claim full conformance to ATAG 2.0 at one of three conformance levels. The level achieved depends on the priority level of the checkpoints for which the authoring tool has satisfied the success criteria. The full conformance levels are:
In addition, a Partial Conformance claim option is available in cases where an authoring tool has satisfied the success criteria in one of the two Parts of the document (i.e. "Part A: Make the authoring tool user interface accessible" and "Part B: Support the production of accessible content") to a higher level than in the other. The partial conformance levels are:
Note: The Working Group remains committed to the guiding principle that: Everyone should have the ability to create and access Web content. Therefore, it is recommended that Partial Conformance be claimed as a step towards full conformance.
A conformance claim is an assertion by a claimant that an authoring tool has satisfied the requirements of a chosen ATAG 2.0 conformance profile.
Developers of authoring tools that do not yet conform fully to a particular ATAG 2.0 conformance level are encouraged to publish a statement on progress towards conformance. This statement would be the same as a conformance claim except that this statement would specify an ATAG 2.0 conformance level that is being progressed towards, rather than one already satisfied, and report the progress on success criteria not yet met. The author of a "Progress Towards Conformance" Statement is solely responsible for the accuracy of their statement. Developers are encouraged to provide expected timelines for meeting outstanding success criteria within the Statement.
This section is normative.
The guidelines are divided into two parts, each reflecting a key aspect of accessible authoring tools. Part A includes guidelines and associated checkpoints related to ensuring accessibility of the authoring tool user interface. Part B contains guidelines and checkpoints related to ensuring support for creation of accessible Web content by the tool. The guidelines in both parts include the following:
Each checkpoint listed under a guideline is intended to be specific enough to be verifiable, while still allowing developers the freedom to meet the checkpoint in a way that is suitable for their own authoring tools. Each checkpoint definition includes the following parts. Some parts are normative (i.e., relate to conformance), while others are informative only:
The checkpoints in Part A are intended to increase the accessibility of the authoring experience for authors with disabilities. For this reason, the requirements are narrowly focused on the accessibility of the user interface that authors uses to operate the tool. The accessibility of the Web content produced is addressed in Part B.
Note for tools with previews: The requirement in this section apply to all parts of the authoring tool user interface except for the content view of any built-in preview features (see Checkpoint A.2.9 for requirements on previews). In general, the configuration of the preview mode is not defined by the configuration of the editing views.
Assistive technologies (e.g., screen readers, screen magnifiers, on-screen keyboards, voice recognition systems) can only provide augmented display and control to their users if the relevant information is made available by authoring tools using common protocols.
Rationale: In addition to generally improving the accessiblity of the authoring tool user interface, implementing user interfaces using accessible Web content facilitates communication with assistive technologies via user agents. Authors must be able to have access to Web-based authoring tool user interface functionality just as they do to other Web content.
Note: For non-Web-based authoring tools, this is a relatively straightforward requirement, likely covering only a few areas of the interface (e.g., Web-based help features). However, for most Web-based authoring tools the requirement will cover the majority of functionality in the tool and overlap many of the other requirements in Part A of the guidelines. When this is the case, a note entitled "For Web-based authoring tool user interface functionality" will appear below the success criteria to provide more information.
Techniques: Implementation Techniques for Checkpoint A.0.1
Success Criteria (Web-based functionality)):
Rationale: Assistive technologies that are used by many authors with disabilities (e.g., screen readers, screen magnifiers, on-screen keyboards, voice recognition systems) rely on the authoring tool to provide data and control via prescribed communication protocols.
Techniques: Implementation Techniques for Checkpoint A.4.1
Success Criteria (non-Web-based functionality):
Rationale: When the use of accessibility architectures is fully documented, assistive technology developers are able to provide enhanced user interface access.
Techniques: Implementation Techniques for Checkpoint A.4.2
Success Criteria:
For Web-based authoring tool user interface functionality: Web-based authoring tools will rely on the accessibility platform architecture support of the user agent and therefore meeting Checkpoint A.0.1 will serve to meet this checkpoint.
In order for an authoring tool to be accessible, authors with a wide range of abilities must be able to perceive its user interface controls.
Rationale: People who have difficulty perceiving non-text objects are often able to access text alternatives of the same information, since text is more easily transformed between various display methods (e.g., magnification and enhancement, text-to-speech, Braille output)
Techniques: Implementation Techniques for Checkpoint A.1.1
Success Criteria (for the content display):
Success Criteria (for the user interface "chrome"):
For Web-based authoring tool user interface functionality: Meeting Checkpoint A.0.1 will serve to meet success criteria 1 of this checkpoint.
Rationale: People who have difficulty accessing or interpreting multimedia-supported information in the authoring tool user interface can have the information made available to them by other means. For example, people who are deaf or have a hearing loss can access auditory information through captions, and people who are blind or have low vision, as well as those with cognitive disabilities, who have difficulty interpreting visually what is happening, can receive audio descriptions of visual information.
Techniques: Implementation Techniques for Checkpoint A.1.2
Success Criteria (for the content display):
Success Criteria (for the user interface "chrome"):
For Web-based authoring tool user interface functionality: Meeting Checkpoint A.0.1 will serve to meet this checkpoint.
Rationale: Some authors require alternative display configurations to use the authoring tool user interface that may differ from the presentation the author intends to define for the published content (e.g., providing a high contrast setting to edit content that is not intended to be high contrast).
Note: The success criteria for this checkpoint are based on the capabilities of platforms (e.g., operating systems, user agents, GUI toolkits) as defined in the conformance profile, however developers are free to provide additional configuration.
Techniques: Implementation Techniques for Checkpoint A.1.3
Success Criteria (for the content display):
Success Criteria (for the user interface "chrome"):
For Web-based authoring tool user interface functionality: Meeting Checkpoint A.0.1 will serve to meet this checkpoint.
Rationale: Authors may require settings to render and control the content during editing that differ from the presentation defined for the published content (e.g., providing a high contrast setting to edit content that is not intended to be high contrast).
Techniques: Implementation Techniques for Checkpoint A.1.4
Success Criteria:
Rationale: Separating content and structure from presentation allows the user interfaces of authoring tools to be presented differently to meet the needs and constraints of different authors without losing any of the information or structure. For example, information can be presented via speech or Braille (text) that was primarily intended to be presented visually. It can also facilitate automatic emphasis of structure or more efficient navigation. All of these can benefit authors with cognitive, physical, hearing, and visual disabilities.
Techniques: Implementation Techniques for Checkpoint A.1.5
Success Criteria (general):
Success Criteria (for non-Web-based content display):
Success Criteria (for non-Web-based user interface "chrome"):
<p>
") must be available via an accessibility platform architecture available programmatically.
For Web-based authoring tool user interface functionality: Meeting Checkpoint A.0.1 will serve to meet this checkpoint.
In order for an authoring tool to be accessible, authors with a wide range of abilities must be able to operate its user interface controls.
Rationale: Some individuals have difficulty manipulating graphical input devices such as a mouse or trackball. Providing alternate means of navigating the user interface that does not rely on such devices provides an accommodation for individuals with limited mobility or those with visual disabilities who cannot rely on hand eye coordination for navigating the user interface.
Note 1: This does not preclude and should not discourage the support of other input methods (such as a mouse) in addition to keyboard operation.
Note 2: Also see Checkpoint A.3.1 when choosing keystrokes.
Techniques: Implementation Techniques for Checkpoint A.2.1
Success Criteria (general):
Success Criteria (for the content display):
Success Criteria (for the user interface "chrome"):
For Web-based authoring tool user interface functionality: Meeting Checkpoint A.0.1 will serve to meet success criteria 1 and 2 of this checkpoint. User agent functionality (e.g., for "cut/copy/paste") or access keys (e.g., for "open new content") may be relied on to achieve success criteria 3 and 4 as long as the applicable user agent(s) are specified in the conformance profile.
Rationale: Authors who have limited mobility require quick access to the items that they use frequently.
Techniques: Implementation Techniques for Checkpoint A.2.2
Success Criteria (for the user interface "chrome"):
Rationale: Authors who have difficulty typing, operating the mouse, or processing information can be prevented from using systems with short time limits.
Note: Some time limits may be imposed by external systems. This checkpoint only applies to time limits within the control of the authoring tool.
Techniques: Implementation Techniques for Checkpoint A.2.3
Success Criteria (general):
For Web-based authoring tool user interface functionality: Meeting Checkpoint A.0.1 will serve to meet this checkpoint.
Rationale: Flashing can cause seizures in people with photosensitive epilepsy.
Techniques: Implementation Techniques for Checkpoint A.2.4
Success Criteria (for the content display):
Success Criteria (for the user interface "chrome"):
For Web-based authoring tool user interface functionality: Meeting Checkpoint A.0.1 will serve to meet this checkpoint.
Rationale: It is often efficient to make use of the structure that may be inherent within certain content in order to navigate editing views and perform edits. This is particularly important for people who are using a slow interface such as a small Braille device, speech output, or a single switch input device. It is equivalent to the ability provided by a mouse interface to move rapidly around the document.
Techniques: Implementation Techniques for Checkpoint A.2.5
Success Criteria (for the content display):
Rationale: Search functions within the editing views facilitate author navigation of content as it is being authored by allowing authors to move the focus quickly to arbitrary points in the content. Including the capability to search within text equivalents of rendered non-text content increases the efficiency of the search function.
Techniques: Implementation Techniques for Checkpoint A.2.6
Success Criteria (for the content display):
For Web-based authoring tool user interface functionality: Web-based authoring tools may rely on the "find" function of the user agent to help perform the searches, as long as the applicable user agent(s) are specified in the conformance profile.
Rationale: Authors who have difficulty making fine movements may be prone to making unintended actions. All authors benefit from the ability to easily recover from mistakes.
Note: It is acceptable to collect text entry actions (e.g., typed words, a series of backspaces) into a single author action.
Techniques: Implementation Techniques for Checkpoint A.2.7
Success Criteria (for the content display):
For Web-based authoring tool user interface functionality: Web-based authoring tools may rely on the "undo" function of the user agent to perform the undo function for some editing actions that do not involve server communication (e.g., typing in a text area), as long as the applicable user agent(s) are specified in the conformance profile.
Rationale: Providing the ability to save and reload sets of keyboard and display preference settings is a benefit to authors using tools intended to be used by multiple authors as well as authors who have keyboard and display preference settings preferences that differ with fatigue, etc..
Techniques: Implementation Techniques for Checkpoint A.2.8
Success Criteria (general):
Rationale: Preview features are provided in many authoring tools because the workflow of authors often includes periodically checking how content will appear to end users in a user agent. In order to enable authors with disabilities to follow the same workflow as other authors, they must have access to any preview features that exist.
Note 1: Authors, including those with disabilities, will not be well-served if preview features diverge too much from the actual functionality of available user agents. Therefore, preview features are exempted from necessarily having to meet all of the other requirements in Part A of this guidelines document, if they meet this checkpoint.
Note 2: It is understood that the accessibility of the content display of a preview will be negatively affected if the content being rendered is inaccessible or incomplete. For example, a missing image label will result in an inaccessible image, which is useful information to the author.
Techniques: Implementation Techniques for Checkpoint A.2.9
Success Criteria (general):
In order for an authoring tool to be accessible, authors with a wide range of abilities must be able to understand the user interface controls that they can perceive and operate.
Rationale: Authors are often familiar with accessibility conventions employed by the other applications built on a platform. Departures from those conventions have the tendency to disorient authors by creating an unfamiliar environment.
Techniques: Implementation Techniques for Checkpoint A.3.1
Success Criteria (for the content display):
Success Criteria (for the user interface "chrome"):
For Web-based authoring tool user interface functionality: Meeting Checkpoint A.0.1 will serve to meet this checkpoint.
Rationale: Authors who may become disoriented easily will have less difficulty when consistent and predictable responses to author actions are provided. In general, consistent interfaces will benefit all authors to some degree.
Techniques: Implementation Techniques for Checkpoint A.3.2
Success Criteria (for the user interface "chrome"):
For Web-based authoring tool user interface functionality: Meeting Checkpoint A.0.1 will serve to meet this checkpoint.
Rationale: While intuitive user interface design is valuable to many authors, some authors may still not be able to understand or be able to operate the authoring tool user interface without proper documentation.
Techniques: Implementation Techniques for Checkpoint A.3.3
Success Criteria (for the user interface "chrome"):
The checkpoints in Part B are intended to increase the accessibility of the Web content produced by any author to end users with disabilities. While the requirements in this part do not deal with the accessibility of the authoring tool user interface, it should be noted that any of the features (e.g., checker, tutorial) added to meet Part B must also meet the user interface accessibility requirements of Part A.
The creation of accessible content is dependent on the actions of the tool and the author. This guideline delineates the responsibilities that rest exclusively with the tool.
Rationale: Content types with published content type-specific WCAG benchmark documents facilitate the creation of Web content that can be assessed for accessibility with WCAG.
Techniques: Implementation Techniques for Checkpoint B.1.1
Success Criteria:
Rationale: Accessibility information is critical to maintaining comparable levels of accessibility across transformations and conversions.
Techniques: Implementation Techniques for Checkpoint B.1.2
Success Criteria:
Rationale: Automatically removing markup can cause the unintentional loss of structural information. Even unrecognized markup may have accessibility value, since it may include recent technologies that have been added to enhance accessibility.
Techniques: Implementation Techniques for Checkpoint B.1.3
Rationale: Authoring tools that automatically generate content that does not conform to WCAG are a source of accessibility problems.
Note: If accessibility information is required from authors during the automatic generation process, Checkpoint B.2.1 applies.
Techniques: Implementation Techniques for Checkpoint B.1.4
Success Criteria:
Rationale: Pre-authored content, such as templates, images, and videos, is often included with authoring tools for use by the author. When this content conforms to WCAG, it is more convenient for authors and more easily reused.
Note: If accessibility information is required from authors during use, Checkpoint B.2.1 applies.
Techniques: Implementation Techniques for Checkpoint B.1.5
Success Criteria:
This guideline requires that authoring tools must promote accessible authoring practices within the tool as well as smoothly integrate features that support accessible authoring that have been added to meet the other requirements in this document.
Note: In addition to the normative requirements of this guideline, implementers should also consider the integration of features that support accessible authoring with the "look-and-feel" of other features of the authoring tool. This type of integration has the potential to:
However, whenever new features are introduced into an authoring tool, striking the right design balance between the similarity with existing features and the provision of new functionality is often more of an art than a science.
Rationale: Authors are most likely to use the first and easiest option for a given authoring task.
Techniques: Implementation Techniques for Checkpoint B.3.1
Success Criteria:
Rationale: Accessible design as an afterthought or separate process is much more onerous and therefore costly than when accessibility is considered from the start. If the authoring tool supports authors in considering accessibility before and/or during the authoring process it is more likely that accessible authoring practices will become a common practice. This is analogous to internationalization, which is much easier when it is considered from the beginning rather than handled last.
Techniques: Implementation Techniques for Checkpoint B.3.2
Success Criteria:
Rationale: If the features that support accessible authoring are difficult to find and activate, they are less likely to be used.
Techniques: Implementation Techniques for Checkpoint B.3.3
Success Criteria:
Rationale: The accessible content support features will be more adaptable to the work habits of authors if they can be turned on and off easily as authors need them.
Techniques: Implementation Techniques for Checkpoint B.3.4
Success Criteria:
Rationale: Without documentation of the features that support the production of accessible content (e.g., prompts for alternatives, accessibility checkers) authors may not find or use them.
Techniques: Implementation Techniques for Checkpoint B.3.5
Success Criteria:
Rationale: If accessible authoring is integrated into instructions and guidance offered by the tool (e.g., documentation, help, tutorials, examples, and workflow processes), authors are more likely to follow accessible authoring techniques if they are demonstrated as common practice. This can also facilitate a better understanding of the reasoning behind and the consequences of authoring accessible content.
Techniques: Implementation Techniques for Checkpoint B.3.6
Success Criteria:
This glossary is normative. Some definitions may differ from those in other WAI documents. The definitions here serve the goals of this Recommendation.
For the latest version of any W3C specification please consult the list of W3C Technical Reports at http://www.w3.org/TR/. Some documents listed below may have been superseded since the publication of this document.
Note: In this document, bracketed labels such as "[HTML4]" link to the corresponding entries in this section. These labels are also identified as references through markup. Normative references are highlighted and identified through markup.
There are two recommended ways to refer to the "Authoring Tool Accessibility Guidelines 2.0" (and to W3C documents in general):
In almost all cases, references (either by name or by link) should be to a specific version of the document. W3C will make every effort to make this document indefinitely available at its original address in its original form. The top of this document includes the relevant catalog metadata for specific references (including title, publication date, "this version" URI, editors' names, and copyright information).
An XHTML 1.0 paragraph including a reference to this specific document might be written:
<p>
<cite><a href="http://www.w3.org/TR/2006/REC-ATAG20-????????/">
"Authoring Tool Accessibility Guidelines 2.0,"</a></cite>
J. Treviranus, J. Richards, M. May, eds.,
W3C Recommendation, ?? ???? ????.
The <a href="http://www.w3.org/TR/ATAG20/">latest
version</a> of this document is available at
http://www.w3.org/TR/ATAG20/.</p>
For very general references to this document (where stability of content and anchors is not required), it may be appropriate to refer to the latest version of this document.
Other sections of this document explain how to build a conformance claim.
A document appears in this section if at least one reference to the document appears in a checkpoint success criteria.
Kynn Bartlett, Giorgio Brajnik, Judy Brewer, Wendy Chisholm, Daniel Dardailler, Geoff Deering, Katie Haritos-Shea, Kip Harris, Phill Jenkins, Len Kasday, Marjolein Katsma, William Loughborough, Charles McCathieNevile, Matt May, Matthias Müller-Prove, Liddy Nevile, Graham Oliver, Wendy Porch, Bob Regan, Chris Ridpath, Gregory Rosmaita, Heather Swayne, Gregg Vanderheiden, Carlos Velasco, and Jason White.
This document would not have been possible without the work of those who contributed to ATAG 1.0.
This publication has been funded in part with Federal funds from the U.S. Department of Education under contract number ED05CO0039. The content of this publication does not necessarily reflect the views or policies of the U.S. Department of Education, nor does mention of trade names, commercial products, or organizations imply endorsement by the U.S. Government.