Summary

Engaging the Section 508 Team early in your project plan is the best way to ensure that your project meets all federal compliance requirements while also making information more accessible

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Boost Accessibility, Avoid Surprises: Engage the Section 508 Team Early

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In competition, it is often said that the best defense is a good offense. The same goes for Section 508 compliance.

Proactively engaging OIT’s Section 508 Team early and often in your project plan – before the heavy lifting occurs – is the most efficient way to ensure that all IT products and services are accessible to people with disabilities as mandated by the federal government. The Section 508 program offers a developer series to provide technical guidance on information and communication technology (ICT) covered under Section 508 of the Rehabilitation Act of 1973.

“The sooner you think about the 508 compliance team in your project plan, the better,” says Rick Lee, OIT Chief Product Officer. “It will ensure accessibility for everyone from the start. If there are red flags, you will know about them before you invest a lot of time in developing the project and you can adjust for it. In the long run, you will spend less time chasing things down and minimizing the expenses and time that come with costly rework that has to be done because things are not Section 508-compliant from the start.”

Seeing is believing. A recent early engagement exercise with the Section 508 Team successfully took this approach from theory to practice. The Section 508 Team was brought in early to evaluate a software vendor's tool to automate objectives and key results (OKR).

“We wanted to ensure the tool was compliant before committing to it,” Lee says. “We didn’t want to repeat the issue we had with Mural, which provides critical collaboration services to CMS but isn’t 508-compliant or officially sanctioned. Mural brings a tremendous amount of value to OIT and CMS, but a certain percentage of our population can't use it because it is not fully accessible.”

As a result of testing, the Section 508 Team was able to access a demo, run their scans, do manual testing, and came back with several findings.

“Instead of halting the acquisition, it actually helped the process because we were able to go back to the vendor and say, ‘We really love this tool, it fits our market, and it will provide tremendous value to the OIT organization,’” Lee says. “But we also said to the vendor, ‘It’s not Section 508 compliant. What are your plans for making this more accessible and Section 508 compliant?’”

The lessons learned from this case study are worth noting for future reference: 

  • Being able to engage the Section 508 Team early in the process met their model of getting in front of major projects to optimize time and effort. 
  • The Section 508 Team’s analysis saved the agency a tremendous amount of pain because it flagged the compliance issue early, prior to acquisition, preventing potential access issues down the road.

“The really big news here is we don’t have to say at any point that this is not Section 508-compliant, and we can’t use it,” Lee says. “Because of the success of this initiative, we can apply this model to other projects. 

“It doesn’t mean they’re all going to work out with the same success and outcomes. We may run into other vendors who say, ‘No, we don’t have the time and money to make that happen for you. Sorry.’ In that case, we would have to move on to another tool. But instead of just assuming that’s the case, now we have an additional layer of vetting and control over how we achieve Section 508 compliance.” 

EDITOR’S NOTE: While Mural was not fully accessible at the time this article was published, Mural is actively working to fix its accessibility shortcomings.

A Brief History of Section 508 and Its Importance 

Section 508 of the Rehabilitation Act of 1973 has been with us for a long time and in various forms. It was originally drafted as an amendment to the Act in 1986 to address the workplace needs of disabled workers in the electronics and information technology fields.

Section 508 was enacted to eliminate barriers in information technology, to make new opportunities available to people with disabilities, and to encourage development of technologies that will help achieve these goals. It requires federal agencies to develop, procure, maintain, and use information and communications technology (ICT) that is accessible to people with disabilities - regardless of whether they work for the federal government.

That measure was replaced in 1998 by the Federal Electronic and Information Technology Accessibility and Compliance Act, which requires all Federal electronic content to be accessible.

The law was further updated and strengthened in 2017 with a Section 508 refresh. This update brought the US government to a level of compliance on par with standards that most other countries had established. It pushed federal agencies to redouble their efforts to work on their compliance for websites and web content.

Why is Section 508 Compliance Important?

According to the Department of Health & Human Services, 285 million people worldwide have some sort of visual impairment, 275 million people have moderate-to-profound hearing impairments, and many more have physical, speech, cognitive, and neurological disabilities or a limited understanding of English. Accessibility ensures all users can access the product or service, regardless of their capabilities.

To learn more about Section 508 compliance, go to Section508.gov.

To learn more about the CMS Section 508 Program, go to the CMS Section 508 website.

To get help from the Section 508 Team, send an email to Section508@cms.hhs.gov

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