I agreeto Idea Stress 508 Compliance to Support 501/503 and 504 Obligations
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Stress 508 Compliance to Support 501/503 and 504 Obligations

Affected individuals have difficulty lodging complaints against Section 508 because the enforcement model is based on procurement remedies. The result is that most unresolved E&IT complaints devolve into Section 501/503 (anti-discrimination), or more predominantly, Section 504 (reasonable accommodation for qualified individuals) issues. The Strategic plan should emphasize the importance of Section 508 compliance in aiding Section 501/503 and Section 504, and more importantly, in minimizing the cost of meeting these other Sections of the Federal Rehabilitation Act of 1973. After all, they are all parts of the same law and federal agencies (and many organizations receiving Federal funds) are obligated to all of these Sections.

Submitted by 508 Govt Professional 2 years ago

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  1. The idea was posted
    2 years ago

Comments (6)

  1. Have there been any 508 complaints from members of the public? I'm only aware of a few employee actions and even fewer vendor protests.

    2 years ago
    1 Agreed
    0 Disagreed
  2. 508 Govt Professional Idea Submitter

    Section 508, 501, and 504, like many other civil right provisions that open the Federal government to law suits, require the exhaustion of administrative complaint processes before a case can go to court. So, by design there are more formal and informal complaints than have been discussed publically. The Metrics suggested by the CIO Council’s Accessibility Committee do recommend: 1) Agencies report whether they have a formal complaint process in place (I’d like to see some qualifiers associated with this metric), 2) Agencies report the number of formal complaints received and the percentage of unresolved complaints, and 3) Agencies develop and maintain a process for collecting and responding to problem reports, feedback and suggestions (more qualifiers please). The last one is important because it can distinguish an agency that may be overwhelmingly exposed to risk and has responded appropriately with informal feedback processes. Consider that some agencies get more complaints despite having excellent programs. Complaints can be a product of their mission and not a reflection on the agency’s effectiveness, so the program maturity (how well it can respond to change and feedback) is important when evaluating an agency. See the suggested metrics here: http://section508.ideascale.com/a/pages/metrics

    2 years ago
    1 Agreed
    0 Disagreed
  3. An additional metric that should be collected is the number of employees filing union grievances or other administrative complaints which are not clearly a pure Section 508 concern. For example, employees with disabilities who complain that the inaccessibility of their agencies systems effectively great a "glass ceiling" that prohibits them from progressing in their career is an excellent indicator of the environment within the agency

    2 years ago
    2 Agreed
    0 Disagreed
  4. I will agree with this idea, but a real problem is that a Section 508 complaint that doesn't refer to something procured, say, a complaint referring to an application developed in-house, becomes a 504 complaint, thus allowing an agency to provide a person-centered solution as opposed to a technology-centered one. The federal employee may get a solution of sorts, but usually, the Section 508 violation remains. Even for EIT procured, the procedures for filing a Section 508 complaint are so vague that many agencies and many employees simply don't know what they are. This gets back to a point that has sort of been made on other ideas here, but that is probably beyond the scope of this strategic plan, namely, that Section 508 should have a centralized enforcement mechanism, including a centralized place and policy for filing the complaints and a way for those complaints to be filed anonymously.

    2 years ago
    0 Agreed
    0 Disagreed
    1. 508 Govt Professional Idea Submitter

      If the agency is not invested in solving accessibility issues through technology, the business case for Section 508 is relegated to a procurement exercise. Technology investments are more productive and meaningful for people with disabilities, but who is making the case that it has a better ROI. Since lawsuits for 508 are narrow in scope and limited in reach, agency executives need to understand the risk/return relationship to the other sections of the Rehab Act before many will make the necessary investments. Who cares if you haven't been sued for Section 508, how many 504/501 complaints do you get and what does it cost. Are you neglecting 508 in such a way that the risks and costs are much higher than technological solutions can remedy?

      2 years ago
      0 Agreed
      0 Disagreed
  5. It is difficult for anyone needing alternative access because of different abilities than the mainstream and what is more difficult is the disheartening task of jumping through hoops to have accessibility. The systemic challenges make it even more costly and at the other end is someone with a different story. No two situations are alike, and if you are not able to fit into the mainstream system for whatever reason, we are delegated as inferior and disabled and most often are not offered the same privilege and opportunity. Intern, we don't even end up being seen as people and end up fighting and justifying being capable. We are not provided the same kindness nor consideration and because we have ignorance, I have seen more resistance, underlying prejudice, judgment and inequity. Until one can truly understand the repercussions, I find it ludicrous when mainstream elite make these provisions and don't know what it is like for those of us that have to utilize these systems that continually cause more grief.

    2 years ago
    2 Agreed
    0 Disagreed