Section508 Management Strategy Ideas

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 »

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 »

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,... 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 »

Section 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).

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...?

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 »

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 »

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 »

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 »

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.

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 »

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 »

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 »