How to Build a Section 508 Technology Accessibility Program

Section 508 of the Rehabilitation Act 1973 is a federal law that requires the information and communication technology (ICT) that federal agencies use, develop, buy, and own to be accessible to people with disabilities, both as employees as well as members of the public. Websites, software, and web applications are all examples of ICT, which means that web accessibility falls under Section 508 standards.

For federal agencies to manage and deliver accessible ICT, they are required to set up an accessibility program that guides all accessibility best practices. Below is a step-by-step guide¹ on how agencies can go about creating that program.

1. Assign a qualified program manager that understands the scope of web accessibility and can lead the agency’s accessibility compliance activities. A program manager must have a comprehensive understanding of web accessibility laws, regulations, and standards, be able to assess the accessibility of web content and technology, collaborate with relevant stakeholders, report on the effectiveness of compliance program activities, provide training to relevant stakeholders, and act as an advocate for people with disabilities and assistive technology.
    
2. Assess the maturity of your compliance program. Some agencies may be well along in their compliance efforts while others might just be starting out with communicating their accessibility interest. Determine where your agency lies in terms of accessibility awareness and maturity, as this will help you determine how to move forward with your accessibility efforts.
    
3. Once you have determined the maturity of your Section 508 program, you should then develop an accessibility roadmap to identify key activities, set goals, and plan out timelines for development. This will help you stay on track and provide a framework on reaching the next stages of maturity.
    
4. Create a Section 508 policy that is aligned to the standards of Section 508 ICT accessibility standards, clarifying the responsibilities of the web team and other stakeholders, the obligations towards making ICT accessible to people with disabilities, the activities to create and maintain accessibility, as well as a feedback mechanism to respond to claims of inaccessibility. This policy can be made public in the form of an accessibility statement.
    
5. Create a program team, a task force of expert project managers, testers, developers, compliance analysts, and digital and technology specialists to help execute the program. The size and scope of your program team will depend on the size of your agency and the technology used.
    
6. Seek collaboration with external partners. Reach out to federal partners and the wider accessibility community for research and advice on best practices.
    
7. Work with usability professionals and requirements analysts to research, understand, and account for the needs and expectations of people with disabilities who use the technology.
    
8. Ensure accessibility needs are identified and addressed when conducting market research and acquiring digital services and technology solutions in accordance with Section 508 standards.
    
9. Incorporate accessibility from the beginning and have it in consideration when developing new digital services and technology. It is always easier and more cost-efficient to build in accessibility during the development stage, rather than trying to retrofit it in an existing product or solution.
    
10. Always test and validate your technology for accessibility. You can refer to Section 508 experts for a review of your site or you can use testing tools like Monsido by Acquia to automate the testing process and find issues more efficiently, but remember that you will always need to manually test using a systematic testing methodology and adjust some elements for full conformance.
     
11. Any issues found during the testing phase must be resolved. Agencies will need to develop a process to track, assess, prioritize, and troubleshoot the issues that arise. A tool like Monsido can provide recommendations on how to address specific errors, making the process easier and more intuitive. Issues can also be reported by website users, and a process for addressing, prioritizing, and escalating these issues must also be developed.
     
12. Based on the policy, remediation efforts and frequent testing according to 508 standards should be conducted to ensure that the accessibility issues on the website are resolved. Agencies are required to submit a report to the Office of Management and Budget (OMB) twice every year detailing the progress of their IT accessibility/Section 508 program and its effectiveness by providing metrics of conformance. Learn more about monitoring progress and reporting here.
     
13. Besides building a process around evaluating and addressing accessibility issues in technology, agencies should also build a culture of accessibility and Section 508 compliance into the organization. Communicating the necessity of accessibility, its legal requirements, and raising awareness of the needs of people with disabilities can not only help encourage buy-in when introducing new accessibility policies and procedures but also drives a culture of inclusivity and understanding from staff that is essential in developing a strong Section 508 program.

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¹ From the Technology Accessibility Playbook: https://www.section508.gov/tools/playbooks/technology-accessibility-playbook-intro