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 »
The problem with the language of the rules and regulations is that they are open for interpretation and each company implementing a new application or site can interpret differently. I think an official site that contains a running archive of compliant vs. non compliant examples of actual implementations for each rule/regulation (and why they have that status) would be helpful. That way, you could check your implementation/idea... more »
Do people in HR or in areas that might handle Section 508 get trained in how to handle Section 508
complaints? It seems that the whole issue of how to make a Section 508 complaint for those of us that might want to is very confusing because
all the agencies are supposed to come up with their own plans for how to handle them.
Comment from Accessibility Committee virtual Listening Session, Sept 8, 2011
People with disabilities; rely on accessible technology to do their jobs. When Federal agencies follow through on their commitment to recruit, retain, and advance individuals with disabilities while embracing strategies that ensure accessible technology people with disabilities are assured equal access to government programs and equal employment opportunity. Simply put, equal access to technology is essential to equal... more »
After reviewing many of the topics as well as the memos on 508, I noticed that many agencies' civil rights organizations are not involved in this process or at least do not appear to be. Section 508 requires a complaint process that generally mirrors an agency's 504 process unless it involves a Federal employee where it could be a Section 501 complaint. In both cases, an agency's civil rights organization is responsible... more »
Add Functional Performance Criteria (FPC) for people with cognitive disabilities. Currently, there are no standards or provisions in Section 508 related to individuals with cognitive disabilities. Additionally, consider functional performance criteria for persons with multiple disabilities such as a person who is deaf or blind who has cerebral palsy or a speech impairment with possible limited manual dexterity.
Projects should use native users of screen readers, magnifiers, voice command software to test their applications. The functional performance criteria (1194.31)is a very important Section 508 provision in the current standards -and the questions asked under FPC are simply whether some one who is blind can use the system, some one who has low vision can use the system, someone who is deaf , and some one with mobility... more »
By one count there are 22 federal entities that have some accessibility oversight role. In 508-land, the big ones are the Access Board, GSA, DoJ, CIO Council, and FAR and the Chief Acquisition Officer Council. But the FCC, Dept. of Education, Dept. of Labor, National Council on Disability, NIST, Department of Transportation and many others have parallel roles in their own domains. Why not astound the public and make a... 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 »
Right now 508 decisions are made with almost no transparency. This leads to disparities among agencies, and insufficient information about accessibility for other decisionmakers -- basically everyone who buys or uses ICT. (Remember, 508 is supposed to benefit the entire ICT market.) For example, why are VPATs treated as private communications between an agency and a vendor? All information about ICT accessibility should... more »
If regulation is the "stick", then perhaps awards are the "carrot." It would not be right to give awards for mere compliance, but what about awards for innovative solutions, program excellence, fewest complaints, most improvement...?
Do not support the broad use of alternate conforming websites. Support the narrow use of alternate conforming websites only as a last resort and preferably as a temporary measure on the way to full accessibility of the non-conforming version. It is the Rehabilitation Act’s stated policy that “all programs, projects, and activities receiving assistance under this Act shall be carried out in a manner consistent with the... more »
OMB is currently updating its Federal Enterprise Architecture reference models. Now is a great time to ensure the new models, most importantly the new IRM and ARM reference Section 508. The 508 standards should be integral to the IRM and ARM technologies. The BRM references Section 504, individual accommodation, but not Section 508. Ensure OMB's CIO supports this integration.