Holding the federal government accountable is an important component in ensuring consistent implementation of Section 508 standards and policies throughout the Government.
4 votes
I disagreeUse uniform Section 508 assessment criteria and score agency procurement, IT, HR, and civil rights executives on Section 508 compliance. Maintain federal website with information on what is truly 508-compliant, what is not, and how to fix noncompliant products.
8 votes
I disagreeThis 508 strategic plans seems to want to look forward, without really understanding successful or unsuccessful Section 508 implementation has been in the past. With regard to Federal Agency compliance on EIT procurements, there is over 5 years of data that indicate the government is still struggling to include appropriate and detailed Section 508 requirements into solicitations. In fact government-wide compliance rates ...more »
This 508 strategic plans seems to want to look forward, without really understanding successful or unsuccessful Section 508 implementation has been in the past. With regard to Federal Agency compliance on EIT procurements, there is over 5 years of data that indicate the government is still struggling to include appropriate and detailed Section 508 requirements into solicitations. In fact government-wide compliance rates are below 50%. GSA and OMB have this data for each agency and it should be available to all. It is eye-opening!
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3 votes
I disagreeIF it is true that the Blackberry phones are not 508 compliant, why are Federal agencies allowed to buy them? Why isn't GSA prohibiting the purchase of items that are not 508 compliant?
20 votes
I disagreeWhile attending a class on computer and network security, I stated that in addition to securing the computers and networks we needed to also ensure the networks were in compliance with Section 508 directives. With a grimace on his face, the instructor stated compliance with Section 508 was not a security issue, therefore, it was not an inspection item -- however, he added, Section 508 guidelines could be used when possible. ...more »
While attending a class on computer and network security, I stated that in addition to securing the computers and networks we needed to also ensure the networks were in compliance with Section 508 directives. With a grimace on his face, the instructor stated compliance with Section 508 was not a security issue, therefore, it was not an inspection item -- however, he added, Section 508 guidelines could be used when possible. There are no distinct penalties for non-compliance with Section 508 directives. On paper, Section 508 appears to have support from our Executive Branch of the government. "Out in the field," unless Flag Officers and SES'es in *ALL* DoD components or Federal Government Agencies become "Champions" directing Section 508 support, it will never be taken seriously by acquisition or information tecthnology personnel. As far as DoD is concerned, if a "Section 508 Inspectable Item Checklist" was developed, say for AIR FORCE INSTRUCTION (AFI) 33-393 "ELECTRONIC AND INFORMATION TECHNOLOGY ACCESSIBLE TO INDIVIDUALS WITH DISABILITIES, SECTION 508", then it most definitely will get the attention of all personnel that AFI specificly affects.
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9 votes
I disagreeMany agencies have old "grandfathered" systems that are not 508 compliant. This creates problems because assistive technologies do not work with these systems. There needs to be a time limit that requires agencies to replace/scrap these non-compliant systems by a certain date. We need to put some teeth into the 508 requirements.
11 votes
I disagreeA lot of the change necessary is not going to happen until more people file EEO complaints, law suits and any other kind of complaint applicable. Even though the EEO process hardly works, it's one of the few avenues of redress. I know that people are afraid of retaliation, which does happen. But, Federal agencies don't like EEO complaints and they don't like bad publicity. Take it to your elected officials. But, whatever ...more »
A lot of the change necessary is not going to happen until more people file EEO complaints, law suits and any other kind of complaint applicable. Even though the EEO process hardly works, it's one of the few avenues of redress.
I know that people are afraid of retaliation, which does happen. But, Federal agencies don't like EEO complaints and they don't like bad publicity. Take it to your elected officials. But, whatever you do, don't tolerate discriminatory acts such as inaccessible IT. On some level, it really is that straight-forward.
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9 votes
I disagreeThere should be oversight at least of what's available to the public electronically -- perhaps by an extended office of the Access Board -- and agreed-upon penalties for failure. Currently there is nothing to deter an agency from scoffing at 508, except fear of a lawsuit from the National Federation of the Blind. The NFB should not be the government's police force on 508.
11 votes
I disagreeIn order for Section 508 to become integrated into the culture of the Federal Government, Section 508 has to be a part of all employees performance plan. Especially Senior Management. By having Section 508 as part of their performance plan, Section 508 will get the attention it needs from upper management and everyone will be concerned or aware of 508 and how it would impact their job area.
8 votes
I disagreeContinuous Improvement Continuous Improvement Exemplary Practices: 1. Methods for ensuring continuous improvement and 2. Accountability mechanisms. Three key methods for ensuring continuous improvement: designate responsible persons/offices, encourage participation by individuals with disabilities and outside experts, and establish measurable objectives and benchmarks. Designate responsibility: Example-Chief Technology ...more »
Continuous Improvement
Continuous Improvement Exemplary Practices: 1. Methods for ensuring continuous improvement and 2. Accountability mechanisms.
Three key methods for ensuring continuous improvement: designate responsible persons/offices, encourage participation by individuals with disabilities and outside experts, and establish measurable objectives and benchmarks.
Designate responsibility: Example-Chief Technology Accessibility Officer. Provide top management support and, if appropriate, staff to manage the implementation of this strategic plan and a reasonable budget; identify the responsible individual(s) on all internal and external communications regarding the company's ICT strategic plan
Encourage Participation by Individuals with Disabilities and Outside Experts: Involve people with disabilities at each stage, particularly when testing whether the changes company has made are successful; Develop relationships with experts and learn what other companies are doing; Adopt the benchmarks and measures by teams that include users knowledgeable about accessible and usable electronic and information technology; Seek input from employees with disabilities using employee surveys and focus groups and discussions with employee diversity and advisory groups regarding the workplace environment
Establish Measurable Objectives and Benchmarks: “Conformance” evaluations or audits of company’s ICT will help in self-assessment of accessibility of existing technologies and plot course for improvement; Setting measurable objectives and benchmarks at the onset is key to evaluation and strategic planning process. Set measurable objectives by prioritizing ICT applications that need accessibility modifications and setting dates by which improvements will be implemented – then monitor achievement.
Many checklists, scorecards and grid-based tracking documents designed to help users evaluate compliance with Section 508 and other accessibility practices; Evaluate each ICT application or platform consistently, and to assign a benchmark “score” to each item at the start of self-assessment so that success can be measured.
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1 vote
I disagreeSelf-Assessment Self-Assessment Exemplary Practices: 1.Comprehensive Evaluation of Internal and External Technologies and 2. Priorities and Goals Comprehensive Evaluations: Make a list of all ICT used or offered, including all platforms, devices and applications; Evaluate the accessibility of each item; Can include formal testing of ICT applications with automated accessibility testing tools; Consider the user experience ...more »
Self-Assessment
Self-Assessment Exemplary Practices: 1.Comprehensive Evaluation of Internal and External Technologies and 2. Priorities and Goals
Comprehensive Evaluations: Make a list of all ICT used or offered, including all platforms, devices and applications; Evaluate the accessibility of each item; Can include formal testing of ICT applications with automated accessibility testing tools; Consider the user experience of applicants, employees and customers with varying disabilities (interviews, focus groups)
A variety of checklists exist. ODEP is developing an online tool that employers can use to check and then access online resources for the areas they need to address: Tech Check. Tech Check will be a starting point for companies to build their own self-assessment and improvement plan. Includes resources and tools for making needed improvements
Setting Priorities and Goals: Evaluation process generally identifies ICT that is not accessible to and/or usable by people with disabilities; Remedying all identified issues at once may not be realistic due to cost and legacy IT infrastructure constraints; Leading companies commit to making all the necessary changes, either immediately or in the longer term
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7 votes
I disagreeI understand that this is not what was wanted by the Plan committee, but regardless, after 11 years of experience in this arena, I feel that the one most effective way to attain complaince is through visible, actionable enforcement from with-in the Government, through a government-wide CIO.
8 votes
I disagreeAccountability, accessibility in procurement, developer training, etc…each is relevant and necessary for accessibility, but all of these components can be somewhat tactical if each is simply considered autonomously. What should be clearly articulated is that accessibility needs to be woven into the fabric and culture of an organization through: policy and governance, integration into key processes (procurement and development, ...more »
Accountability, accessibility in procurement, developer training, etc…each is relevant and necessary for accessibility, but all of these components can be somewhat tactical if each is simply considered autonomously.
What should be clearly articulated is that accessibility needs to be woven into the fabric and culture of an organization through: policy and governance, integration into key processes (procurement and development, as a couple of examples), accountability and management buy-in, organizational structure, skill building, establishment of goals and metrics to assess progress, and so on. Such a holistic approach, which I call “organizational enablement” (vs. “technical enablement”), is key to the accessibility journey, and plays a significant role in the speed and trajectory of accessibility initiative success.
Therefore; including language that drives organizations to establish programs, policies, processes, etc. to address accessibility in a systemic manner would be a powerful facilitator.
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34 votes
I disagreeThe suggestions received thus far are generally pretty good, but in they are nibbling at the edges rather than attacking the core of the problem. What distinguishes the very few agencies or components that have been relatively successful in implementing Section 508? It is top level executive understanding and support. Most top level executives do not understand the scale and scope of Section 508 and the need for them ...more »
The suggestions received thus far are generally pretty good, but in they are nibbling at the edges rather than attacking the core of the problem. What distinguishes the very few agencies or components that have been relatively successful in implementing Section 508? It is top level executive understanding and support. Most top level executives do not understand the scale and scope of Section 508 and the need for them to provide supportive policies, along with standardized procedures and practices. The FAR actually does a pretty good job of implementing Section 508 requirements, but it is rarely followed in practice. Further, Section 508 is often viewed as a procurement requirement for vendors, ignoring the fact that it also governs development, maintenance and use of E&IT within Federal Agencies. Until agency executives understand and get behind Section 508, implementation will continue to crawl at a snail’s pace.
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23 votes
I disagreeA 508 test plan should be part of the acceptance criteria by Procurement and should be included as part of the deliverables for contractor services for software/web development. This will force vendors performing contractor services to incorporate Section 508 in the requirements and will make them code ground up for 508 from the beginning. This is not only cost effective and efficient but will ensure the vendor tests ...more »
A 508 test plan should be part of the acceptance criteria by Procurement and should be included as part of the deliverables for contractor services for software/web development.
This will force vendors performing contractor services to incorporate Section 508 in the requirements and will make them code ground up for 508 from the beginning. This is not only cost effective and efficient but will ensure the vendor tests the application for 508 compliance. 508 will not be an afterthought.
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9 votes
I disagreeOur constant challenge with acquisitions and 508 compliance is that Section 508 is not part of requirements. The largest impediment to the implementation of Section 508 in the current requisition process is the absence of Section 508 clauses in base contracts. The most critical action required is to make sure the correct applicable Section 508 clauses are in the Contract/Requests for Proposals and Statements of work. ...more »
Our constant challenge with acquisitions and 508 compliance is that Section 508 is not part of requirements. The largest impediment to the implementation of Section 508 in the current requisition process is the absence of Section 508 clauses in base contracts. The most critical action required is to make sure the correct applicable Section 508 clauses are in the Contract/Requests for Proposals and Statements of work. This is the only way to hold the vendor to compliance. If the critical language is not in the contract, vendors charge a considerable amount of extra money to bring the product to compliance. By ensuring Section 508 clauses are in the contract the Agency can save money. According to a case study by Pressman (2005), it is expensive to retrofit software to meet accessibility standards. The cost of revision is estimated to be one to six times greater during development than during the design phase and sixty to hundred times greater after release.
So Section 508 should be part of the requirements and should not be an after thought.
The Federal Acquisition Regulation (FAR) should be used by federal agencies as guidance for developing procurement policies and procedures.
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11 votes
I disagreeIn the Metrics section of the plan, more specificity is needed for electronic content. It simply states “Agencies will review and evaluate electronic content for 508 compliance.” We need simple metrics, common across most agencies, that can be used to evaluate an agency’s commitment and effectiveness in implementing accessibility. The Section 508 refresh is increasing the scope of electronic content and the strategic ...more »
In the Metrics section of the plan, more specificity is needed for electronic content. It simply states “Agencies will review and evaluate electronic content for 508 compliance.” We need simple metrics, common across most agencies, that can be used to evaluate an agency’s commitment and effectiveness in implementing accessibility. The Section 508 refresh is increasing the scope of electronic content and the strategic plan can be used to encourage agency adoption. While measures against the majority of electronic content types in the latest ANPRM may be difficult, what can be reasonably measured should be included in the strategic plan’s metrics.
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9 votes
I disagreeThe few longitudinal studies that have been done are pessimistic -- backsliding on accessibility beginning just a few months after an intervention or campaign is the norm, not the exception. New technologies are introduced to sites, breaking their accessibility. The 508 Strategy should include an ongonig evaluation and reporting scheme. Being reviewed every 2 years by DoJ is not going to work, especially when the survey ...more »
The few longitudinal studies that have been done are pessimistic -- backsliding on accessibility beginning just a few months after an intervention or campaign is the norm, not the exception. New technologies are introduced to sites, breaking their accessibility.
The 508 Strategy should include an ongonig evaluation and reporting scheme. Being reviewed every 2 years by DoJ is not going to work, especially when the survey changes every time and 2 years becomes 10.
Once reasonable metrics are agreed upon, why not have a dashboard that can be read by all, indicating where agencies are at? There may be even more value in tracking technologies -- "accessible PDFs are up 8%; captioned videos are down 5%" -- because aside from agency pride, everyone wants to know what to use and what to avoid.
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4 votes
I disagreeI love the idea of the posting the VPAT forms, but it would be great to see the audit reports of sites that have been through a 508 audit. Not only does it show the agency responsible, but also the contractor who did the work.
Not to mention those audit reports give a wealth of information from the people doing the actual site auditing for 508.
6 votes
I disagreePoor VPAT, nobody loves ya. You need a makeover! The refreshed 508 provisions deserve a refreshed reporting tool, one developed by all stakeholders. It could feature: - live, online creation, indexing, and searchability - real-time training for vendors and buyers alike on the meaning of the provisions and any product-category-specific guidance - room to report testing results and workarounds - AT compatibility info, ...more »
Poor VPAT, nobody loves ya. You need a makeover! The refreshed 508 provisions deserve a refreshed reporting tool, one developed by all stakeholders. It could feature:
- live, online creation, indexing, and searchability
- real-time training for vendors and buyers alike on the meaning of the provisions and any product-category-specific guidance
- room to report testing results and workarounds
- AT compatibility info, possibly provided by AT vendors
- open dialogue, featuring user Q&A and even evaluative information
- [added for the sake of extra unreality] comparative chart of compliance, against competing products
Add your ideas for accessibility report in the comments.
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19 votes
I disagreeAs I understand it (and please correct me), including 508 in the paperwork for a given ICT procurement is not an absolute requirement, but more of an option on the part of whoever is doing the purchasing. It should go the other way -- 508 is part of the paperwork unless the purchaser can plausibly state a reason for exemption. Continuing on, every other 508 step should be documented as well, such as requesting a VPAT, ...more »
As I understand it (and please correct me), including 508 in the paperwork for a given ICT procurement is not an absolute requirement, but more of an option on the part of whoever is doing the purchasing. It should go the other way -- 508 is part of the paperwork unless the purchaser can plausibly state a reason for exemption.
Continuing on, every other 508 step should be documented as well, such as requesting a VPAT, receiving it, reviewing it, etc., all the way down to explaining the purchasing decision in 508 terms.
All of this information should be subjected to oversight, leading to improvements in 508 training and other systemic actions.
Any government-wide (or even agency-wide) initiatives on digitizing ICT procurement and management should include 508 elements as needed.
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2 votes
I disagreeMore metrics that emphasize sound internal accessibility requirements are needed. Today's model agencies have trained developers, trained and deployed accessibility testers, implemented project life cycle accessibility requirements, posted accessibility acceptance gates (for internal applications and contract acceptance criteria), and other important agency governance measures to ensure an improving environment. The ...more »
More metrics that emphasize sound internal accessibility requirements are needed. Today's model agencies have trained developers, trained and deployed accessibility testers, implemented project life cycle accessibility requirements, posted accessibility acceptance gates (for internal applications and contract acceptance criteria), and other important agency governance measures to ensure an improving environment. The Strategic Plan should promote these Best Practices through targeted metrics that positively benefit agencies that mature their programs in these ways.
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3 votes
I disagreeConformance to Section 508 isn't a "one and done." Technology, and user needs change over time. Just like in the InfoSec community, systems (aka EIT) change and with each change induces or reduces risk (aka Section 508 conformance). Why not look at "conformance" to Section 508 as Risk Management. Over 350 million users in the USA have the capability of accessing our ICT/EIT, 35 million are known to have disabilities, ...more »
Conformance to Section 508 isn't a "one and done." Technology, and user needs change over time. Just like in the InfoSec community, systems (aka EIT) change and with each change induces or reduces risk (aka Section 508 conformance).
Why not look at "conformance" to Section 508 as Risk Management. Over 350 million users in the USA have the capability of accessing our ICT/EIT, 35 million are known to have disabilities, and several million of are also our peers in Federal Service. Every one of these users have within their power the ability under the law to file a complaint; they are each a potential risk. Some are a higher risk than others; some work for the Federal government, and that risk is (fortunately) growing as we become a more inclusive society.
Conformance to accessibility standards, just like FISMA compliance, is a moving target but can be effectively managed if we look at differently. In FISMA they 'certify' systems Risk. In FISMA they evaluate Risk proabistically, and apply resources accordingly. In FISMA, they require the documentation of the System to security standards, and permit Risk's as long as they are managed appropriately. And when they are not (Systems sometimes get compromised, Programs sometimes run out of money, and data unfortunately gets lost)...when they are not those Systems and their Owners are held accountible.
Why can't we 'certify' our ICT/EIT upon creation, track its ownership thru revisions, assign it a Risk (ie public facing with 350 million risk points, verse internal with 5000 risk points), validate the Risk using objective data (logs, trouble tickets, support requests, etc), and apply appropriate resources to the ICT/EIT over its lifetime. Under FISMA, you can't leave a System unpatched and public facing, why do we have dormant content (files, forms, etc) still out in the .gov space?
We need to think differently. Challenge our assumptions. Collect objective data. And build a national framework to better manage conformance of our ICT/EIT. Its been over a decade what we're doing is not working.
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