National Dialogue on Improving the Section 508 Program

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  Roles and Responsibilities »

  Effective enforcement of federal regulations

  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 ...more »

  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.

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  Submitted by Section508 1 year ago

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  Strengthen Accountability »

  Metrics exist for Agency Procurement Compliance

  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 ...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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  2 comments for Idea: Metrics exist for Agency Procurement Compliance

  Submitted by Community Member 1 year ago

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  Strengthen Accountability »

  Non-Compliance with Section 508 has no "TEETH"

  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. ...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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  1 comment for Idea: Non-Compliance with Section 508 has no "TEETH"

  Submitted by patrick.moran 1 year ago

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  Increase Transparency »

  Agency Web Application Metric

  Collect and post data for external web applications on an agency and/or OMG/GSA web site and post a similar data set on an agency’s intranet. Present it as a quarterly or yearly report by Providing a table which lists: 1) the agencies web applications (link to splash screen), 2) has/when accessibility testing occurred, 3) a compliance determination, 4) known accessibility defects (link), 5) work around or accommodation ...more »

  Collect and post data for external web applications on an agency and/or OMG/GSA web site and post a similar data set on an agency’s intranet. Present it as a quarterly or yearly report by Providing a table which lists: 1) the agencies web applications (link to splash screen), 2) has/when accessibility testing occurred, 3) a compliance determination, 4) known accessibility defects (link), 5) work around or accommodation available (link), and 6) a method for providing accessibility feedback for each application.

  This is a good way to evaluate an agencies performance, it addresses the Transparency objectives of the plan, and it also encourages agencies to mature their accessibility programs with a feedback tool to help the process.

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  4 comments for Idea: Agency Web Application Metric

  Submitted by 508 Govt Professional 1 year ago

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  Roles and Responsibilities »

  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 ...more »

  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.

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  6 comments for Idea: Stress 508 Compliance to Support 501/503 and 504 Obligations

  Submitted by 508 Govt Professional 1 year ago

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  Strengthen Accountability »

  Executive Support Needed for 508 to Succeed

  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 ...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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  17 comments for Idea: Executive Support Needed for 508 to Succeed

  Submitted by Community Member 1 year ago

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  Action Plan »

  Standardized government-wide testing methodology

  Related to a few ideas already posted, the government needs to create a standardized testing methodology that federal and contracted staff can use for compliance testing. Such a methodology needs to include both automated testing tools and functional, usability testing. Once the government standardizes on a testing approach, the market will react and can provide clearer results as to what is compliant and what is not. ...more »

  Related to a few ideas already posted, the government needs to create a standardized testing methodology that federal and contracted staff can use for compliance testing. Such a methodology needs to include both automated testing tools and functional, usability testing. Once the government standardizes on a testing approach, the market will react and can provide clearer results as to what is compliant and what is not. Even with the Section 508 refresh coming, the need for standardized testing methodology will be present.

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  4 comments for Idea: Standardized government-wide testing methodology

  Submitted by dalbert 1 year ago

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  Strengthen Accountability »

  A Metric with No Measure

  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 ...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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  5 comments for Idea: A Metric with No Measure

  Submitted by 508 Govt Professional 1 year ago

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  Improve Capabilities »

  Bad Purchases Made Better Through Implementation

  Agencies must purchase E&IT, the market is not doing a great job of supplying compliant products and solutions, and so often agencies must purchase inaccessible products. The job does not end there though. An agency is still charged with implementing that E&IT in the most accessible manner give its ‘other than procurement’ obligations (develop, use, maintain). It is also still under Section 504 obligations. Agencies ...more »

  Agencies must purchase E&IT, the market is not doing a great job of supplying compliant products and solutions, and so often agencies must purchase inaccessible products. The job does not end there though. An agency is still charged with implementing that E&IT in the most accessible manner give its ‘other than procurement’ obligations (develop, use, maintain). It is also still under Section 504 obligations. Agencies must improve their capabilities in developing, configuring, and implementing accessible solutions after they purchase E&IT irrespective of any "out of the box" Section 508 limitations. Metrics that promote accessible implementation post procurement are needed (contract acceptance criteria, project planning, life cycle management, accessibility governance, and accommodation planning).

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  2 comments for Idea: Bad Purchases Made Better Through Implementation

  Submitted by 508 Govt Professional 1 year ago

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  More Emphasis on Agency Implementation and Less on Procurement

  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 ...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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  2 comments for Idea: More Emphasis on Agency Implementation and Less on Procurement

  Submitted by 508 Govt Professional 1 year ago

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