The Rehabilitation Engineering Research Center for Wireless Technologies (Wireless RERC) is funded by the National Institute on Disability and Rehabilitation Research (NIDRR) of the U.S. Department of Education under grant number H133E110002. Our mission is to research, evaluate and develop innovative wireless technologies and products that meet the needs, enhance independence, and improve quality of life and community participation of people with disabilities. The opinions contained in the following recommendations are those of the authors and do not necessarily reflect those of the U.S. Department of Education or NIDRR.
In 2009 the Wireless RERC collaborated with the Rehabilitation Engineering Research Center on Workplace Accommodations at Georgia Tech to complete a Policy Delphi Study on the Accommodation of People with Disabilities in the Workplace. Much of the research focused on technology and its ability to both exacerbate and mitigate barriers to work for people with disabilities. Subsequent recommendations were made to the U.S. Access Board on September 30, 2010. At this time, the Wireless RERC will address the matter of what the federal government can do to influence technology accessibility via the effective management of Section 508. While accelerating the Section 508 standards and the Section 255 update remains imperative, policy Delphi participants emphasized the continued need for enforcement and outreach once the refresh is completed. The Delphi participants strongly agreed that ineffective enforcement of federal regulations is a problem in compelling manufacturers to produce accessible technologies. As such, we recommend that the Department of Justice be tasked with developing an enforcement strategy including outlining meaningful consequences, such as cancelled contracts and fines, somewhat similar to how regulatory agencies undertake their enforcement actions. Following are specific recommendations in response to the Office of Public Engagement’s request for comment on the draft strategic plan for implementation and management of Section 508 of the Rehabilitation Act:
1. Add to the section IV titled “Strengthen Accountability” the following action: Educate agency procurement officers on how to assess the accessibility of equipment and software, including providing them with a document that outlines key questions to ask vendors.
2. Delete the words “Plan to” on action number two under the section IV titled “Improve Capabilities” so that it reads “Identify and deliver workforce tools to implement the new accessibility standards.”
3. Add to the section IV titled “Improve Capabilities” the following actions:
a. Incorporate Section 508 compliance within agency IT departments and provide professional development/training on the installation and maintenance of assistive technology equipment and software.
b. Conduct quarterly webinars on Section 508 compliance with mandatory attendance for new employees.
4. Add to section IV metrics for “Increased Transparency” the following language: Agencies will place a link to the 508 complaint process in a conspicuous place on the agencies website and within employee handbooks.
5. Add to section IV metrics to “Strengthen Accountability” the following language: Agencies will recruit and hire Alternative Media Specialists to ensure the accessibility of electronic information.
6. Add to section IV “Roles and Responsibilities” the following language: The Department of Justice will make their Biennial Report on Federal Agency Section 508 Compliance publicly available in order to enhance transparency and agency accountability.