15 votes
I disagreeHHS mandates tough compliance requirements in every contract that will result in products that will end up on the web (and we assume that all written documents will be posted). We augment these by posting both our standards and the applications/tools we use to test against those standards. This leaves contractors no wiggle room; deliverables must be fully compliant.
14 votes
I disagreeAffected 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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9 votes
I disagreeSection 508 requires agencies to select the product that best meets the Section 508 standards, but the FAR does not buttress the concept. A strategic plan that pledges to include “best meets” in the FAR would be welcomed. Recently case law stated that the FAR supersedes the “best meets” concept in Section 508 (an over simplification of a complicated decision but at its heart true).
7 votes
I disagreeSome commenters mentioned that software purveyors say "we will fix the 508 issues in the next release." If the whole Federal government stood firm and refused to purchase products until they were 508 compliant, the whole industry would rise to the challenge and build that requirement into the system. OMB and GSA must levy fines on agencies that buy systems that are not compliant.
3 votes
I disagreeInfrastructure Infrastructure exemplary practice: 1. Establish infrastructure that supports accessible ICT policies and practices: Four key areas-outsourcing, procurement, training and deployment Outsourcing: Provide outsourcing guidelines to suppliers and business partners, including copies of ICT accessibility guidelines; Ensure that contracts stipulate suppliers will, where relevant, apply ICT accessibility standards ...more »
Infrastructure
Infrastructure exemplary practice: 1. Establish infrastructure that supports accessible ICT policies and practices: Four key areas-outsourcing, procurement, training and deployment
Outsourcing: Provide outsourcing guidelines to suppliers and business partners, including copies of ICT accessibility guidelines; Ensure that contracts stipulate suppliers will, where relevant, apply ICT accessibility standards
Procurement: Provide clear statement that ICT accessibility standard applies to the solicitation; Indicate the applicable technical section, functional performance criteria, and documentation and support requirements for the ICT contract deliverables; Specify applicable accessibility factors as (1) evaluation criteria and (2) inspection and acceptance criteria; Ensure the solicitation and any associated documents and attachments are in an accessible format.
Do not request that the ICT accessibility standard be determined by the vendor or ask for an ICT deliverable accessibility certification of compliance
Training: Provide accessibility training opportunities for all departments, including: ADA coordinators; program managers; contracting or procurement officers; software, web and multimedia developers; and IT Help desk staff.
Possible Topics for training: ICT accessibility standards and how to evaluate software, websites and other documents for accessibility; How to buy accessible ICT; How to create accessible software, websites, electronic forms, and documents; How to caption video or multimedia. Important to provide online resources for learning about specific assistive technology products and to train all employees so that everyone understands and can use accessibility features in any technology purchased or developed.
Deployment: Establish a mechanism for centralized expertise and/or payment for assistive technology devices and services; Provide for specialized expertise to assess and evaluate an applicant’s or employee’s need for assistive technology, where necessary and appropriate; Enter into strategic partnerships with resources in the community to gain insight, information and expertise regarding accessible ICT, including assistive technology devices and services; involve persons with disabilities in the implementation of accessible ICT policy by establishing a group of employees impacted by the policy.
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