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 »
Holding the federal government accountable is an important component in ensuring consistent implementation of Section 508 standards and policies throughout the Government.
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... 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.... 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,... 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... more »
In 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.
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... 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... 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.... more »
There 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.
Many 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.
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,... 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... 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... more »
I 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.