Archived 508 Coordinators Reference Manual - Section 3
Section 3: Roles and Responsibilities
Under Section 508, agencies must give disabled employees and members of the public access to electronic and information technology that is comparable to the access available to others. The law applies to all Federal agencies when they develop, procure, maintain, or use electronic and information technology. Section 508 was enacted to eliminate barriers in electronic and information technology, to make available new opportunities for people with disabilities, and to encourage development of technologies that will help achieve these goals.
Agency responsibilities include:
- incorporating the new requirements into policy and practice, especially related to procurement and acquisitions;
- managing administrative complaints; and
- responding to reporting requirements.
Most of these responsibilities usually fall within the offices of the agency's Chief Information Officer (CIO) (the responsibility for managing administrative complaints may reside elsewhere, as discussed below.) The CIO usually designates a Section 508 EIT Accessibility Coordinator to take the lead role in implementing Section 508. In addition, it is recommended that each agency establish a Section 508 EIT Accessibility Team to involve all the important stakeholders required for an effective and efficient implementation strategy for Section 508.
The following sections provide the suggested roles and responsibilities for the CIO, Section 508 EIT Accessibility Coordinator, and members of the Section 508 EIT Accessibility Team. These recommendations are provided as guidelines. Each agency will need to evaluate how to tailor these roles and responsibilities to meet its unique operational environment.
The Department of Justice will shortly provide guidance regarding how agencies should tailor their complaint processing procedures and policies for the Section 508 context. These responsibilities may be shared among several offices.
The CIO manages an agency's IT resources and, therefore, is usually responsible for appropriately managing the implementation of Section 508 within the agency . On May 10, 2000, G. Martin Wagner, the Associate Administrator for Government Wide Policy, General Services Administration, issued a memorandum for the Chief Information Officers of all Federal agencies. The CIOs were each asked to establish an EIT Accessibility Coordinator and Team to ensure successful implementation of Section 508 within their agencies. (See Memorandum in Appendix A.)
3.2 Section 508 EIT Accessibility Coordinator
3.2.1 Section 508 Coordinator Role
Each Section 508 Coordinator will lead the agency's efforts to assemble a Section 508 EIT Accessibility Team and develop and execute a Section 508 Implementation Plan. It is not necessary for the Coordinator to be an expert in all areas of EIT. The Section 508 Coordinators should establish intra-agency teams according to the structure of their respective agencies and the resources that are available. Team members will be responsible for understanding, implementing, and disseminating information regarding Section 508 to their respective components. The roles and responsibilities of each Team member should be defined in accordance with agency policy. Under the leadership of the Coordinator, the team will determine the contents of a Section 508 Implementation Plan and a strategy for evaluating the success of that plan's implementation. A sample plan has been provided in Appendix B.
3.2.2 Section 508 Coordinator Responsibilities
The Section 508 Coordinator should hold regular meetings with the EIT Accessibility Team and provide updates to the CIO office on what the team is accomplishing. The Coordinator can monitor other agency activities and identify methods to share information about 508 compliance. Some of the activities the 508 Coordinator could manage include:
- Establish a Section 508 EIT Accessibility Team.
- Assign responsibilities to the team according to members' areas of expertise.
- Conduct regular meetings of the Section 508 EIT Accessibility Team.
- Coordinate and assure education and awareness of all employees within the agency.
- Monitor the Access Board (www.access-board.gov) and the General Services Administration (GSA) (www.section508.gov) web sites for new guidance and training opportunities.
- Prepare procedures for the development of requirements for promulgation by the CIO.
- Develop and implement methods for monitoring adherence to Section 508 policies and procedures.
- Develop market research procedures and methods to monitor adherence to these procedures.
- Coordinate with personnel and training to add disability awareness and accessibility training into agency training programs.
- Develop an intranet page off the agency's web site to share Section 508 information and establish links to the Access Board's Section 508 provisions, internal guidelines, points of contact, and available training opportunities.
- Provide progress and ad hoc reports to the CIO.
- Contribute to the CIO's biennial self-evaluation report under guidance provided by the Department of Justice.
3.2.3 Section 508 Coordinator Resources
Through meetings and forums sponsored by GSA, the coordinators have been focusing on agency approaches to implementing Section 508. These forums and training sessions are to help the Section 508 Coordinator develop a thorough understanding of the 508 provisions.
It is highly recommended that Section 508 Coordinators share information with each other. GSA has established a chat room that is password protected for use by Section 508 Coordinators. A list of Section 508 Coordinators, their email addresses and their phone numbers are available on-line at http://www.section508.gov/coord.html. This web address is also the entry point to that chat room. For more information on obtaining a password, contact Helen.Chamberlain@gsa.gov.
Providing training is an important responsibility of the Section 508 Coordinator. Both the EIT Accessibility Team itself and other agency personnel will need current information on Section 508. The Coordinator should monitor upcoming events and conferences that involve Section 508 related activities and disseminate the information to the EIT Accessibility Team. A complete list of conferences that address Section 508 related issues can be found at http://www.section508.gov/events.html .
The Section 508 Coordinator should disseminate information about training classes that are offered through GSA and other organizations. Up-to-date information about training classes can be found at http://www.section508.gov/classes.html. Technical assistance materials can be found on the Access Board's web site (www.access- board.gov.)
3.3 Section 508 EIT Accessibility Team
3.3.1 Section 508 Accessibility Team Role
As part of the memo issued on May 10, 1999, the General Services Administration provided guidelines for establishing the EIT Accessibility Team. (See Appendix A.) The memorandum established the basic guidelines for the EIT Accessibility Coordinator/Team as follows:
- Develop a charter to further define roles and responsibilities of the EIT Accessibility Coordinators in their respective departments/agencies.
- Respond to future Department of Justice Section 508 surveys.
- Integrate Section 508 accessibility needs into agency budget plans, strategic plans, and EIT capital plans.
- Utilize major systems inventory (from Y2K effort) and agency website inventory to provide a roadmap for required remediation efforts and training requirements.
- Identify current needs for accessible systems and adaptive technology (hardware/software) and identify EIT deficiencies that impact the performance of persons with disabilities in both current and prospective EIT systems.
- Work with software vendors/developers on accessibility issues relating to EIT systems.
- Participate in monitoring, measurement, and disclosure activities including usability testing and priority setting.
- Support validation of accessible EIT systems performance prior to deployment.
- Provide status reports to agency CIO.
- Provide sources of education and training to key personnel within the department/agency on: how Section 508 will affect their organizations, what services and support are available, and procurement changes (FAR) that will affect the purchase of any new equipment or software.
The Section 508 Coordinator and/or EIT Accessibility Team members should be familiar with the committees or workgroups that exist within an Agency that may need to add accessibility into their policies or plans. For example, there may be groups that are responsible for implementing the Government Paperwork Elimination Act (GPEA), the Government Performance and Results Act (GPRA), the Agency's Enterprise Architecture, Security Policies, Change Control Boards, Tools Selection Committees, Provisions Workgroups, Electronic Service Delivery Committees, etc. You may want to consider giving presentations and/or educating these groups on Section 508 to make sure that they are considering the Section 508 provisions when developing, procuring, or maintaining EIT.
3.3.2 Section 508 Accessibility Team Responsibilities
In addition to the roles outlined in the memorandum, responsibilities include:
- Provide recommendations and expertise to the Section 508 Coordinator regarding Section 508 implementation issues and solutions.
- Support the development of policies and procedures to ensure Section 508 compliance.
- Assist in the education and training of agency personnel regarding Section 508 compliance requirements, policies, and procedures.
- Develop methods to ensure that requiring officials (purchase requestors) are fully informed about 508 requirements and have tools to determine if their requirement is subject to Section 508.
- Develop language that incorporates Section 508 requirements for use in Statements of Work.
- Monitor web sites for information regarding vendor products' accessibility and recommend links to vendor sites, as appropriate.
- Develop evaluation factors to ensure that products purchased provide the greatest degree of compliance.
3.4 Section 508 Accessibility Team Membership
Listed below are areas of expertise that should be represented on each agency's EIT Accessibility Team, along with guidance regarding appropriate responsibilities of each team member. Employees who have disabilities should be included as team members, whenever possible. In many agencies, employees with disabilities have established associations. Collaborating with such a group if one exists in your agency, provides an excellent opportunity to tap into the knowledge, perspective, and experience of users while implementing 508.
3.4.1 Information Technology Membership Roles and Responsibilities
Members of the Team with expertise in EIT will include Information Technology Specialists, Webmasters, EIT Accessibility Experts, and EIT Security Specialists.
EIT members of the team should participate in the following activities:
- Review and comment on updates/revisions Section 508 provisions.
- Attend training sessions on accessibility and, in turn, train others.
- Utilize major systems inventory (from Y2K effort) and agency web site inventory to provide a roadmap for required remediation efforts and training requirements.
- Identify current needs for accessible systems and adaptive technology (hardware/ software) and identify EIT deficiencies that impact the performance of persons with disabilities in both current and prospective EIT systems.
- Work with software vendors/developers on accessibility issues relating to EIT systems.
- Support validation of accessible EIT systems performance prior to deployment.
- Participate in monitoring, measurement, and disclosure activities including usability testing and priority setting.
GSA sponsors the Accessibility Forum, which is an industry-led partnership among people with disabilities, EIT vendors, and assistive technology vendors. For more information on the Accessibility Forum, see Appendix F and www.section508.gov.
A number of agencies have established assistive technology centers and other resources that may be helpful in meeting the software development and EIT requirements of Section 508. A list of the centers and their contact information can be found in Appendix G.
3.4.2 Procurement Membership Roles and Responsibilities
Contracting offices should be relied upon to employ acquisition strategies to comply with Section 508. Representatives from procurement offices should be key members of an agency's Section 508 Implementation Team.
The procurement members of the EIT Accessibility Team should:
- Help the contracting officer if he/she wishes help in drafting technical specifications and minimum requirements, or drafting a solicitation.
- Review and comment on updates/revisions to the FAR language and the Access Board.
- Refer agency personnel involved in EIT procurements to appropriate agency and external resources to ensure Section 508 requirements are incorporated in requirements as applicable.
- Ensure that undue burden documentation, when appropriate, is prepared and maintained within that contract file.
- Ensure that all procurements apply the agency's market research and requirements development procedures to contracting actions. In accordance with the FAR, the requiring official (not the contracting official) must:
- Identify which provisions apply to the procurement.
- Perform market research to determine the availability of compliant products and services (using vendor web sites and the Section 508 web site, which will link to vendors who describe their accessibility).
- Identify which provisions, if any, would not apply in a procurement because of non-availability or undue burden and provide written documentation to the contracting officer for inclusion in the contract file.
- Draft technical specifications and minimum requirements to be submitted with the purchase request.
3.4.2.1 Resources-BuyAccessible Template
BuyAccessible represents a partnership between government and industry to provide a service to federal procurement staff. It will assist government personnel in completing market research necessary to ensure that they are buying the most accessible EIT products and services available in order to comply with Section 508.
The Information Technology Industry Council (ITI) is hosting a template on their site (www.itic.org) which will allow vendors who choose to participate the ability to download the document and complete it to describe how a particular product or service they offer complies with Section 508 Access Board provisions. They will then link this document with the specified product or service and provide the link information to GSA.
Government procurement staff will be able to search the site by specific product or service type and see all vendors who have provided links. They can then use the links to reach the template information and product or service descriptions necessary to complete their market research.
Vendor participation is voluntary. Since the vendors will be maintaining their own information on their site, they are solely responsible for its content and GSA can make no warranty of its accuracy or thoroughness.
3.4.3 Human Resources Membership Roles and Responsibilities
Human Resources team members may include human resources specialists, Section 501 and 504 coordinators, union representatives, Equal Employment Opportunity (EEO) specialists, and trainers. Their responsibilities relevant to Section 508 include the following:
- Develop and include Section 508 awareness into existing training programs.
- Provide expertise on accessibility gained through Section 504 accommodations to ensure web sites are accessible, to identify assistive technology solutions and to identify EIT deficiencies impacting the performance of people with disabilities.
- Establish and implement a complaint process to handle Section 508 issues. This process will follow Section 504 processes already in place.
Since training departments are often found in the Human Resources department, they should pay particular attention to the telecommunications and video technical provisions.
3.4.4 Policy and Planning Membership Roles and Responsibilities
Policy and Planning team members may include program managers or officers, legal experts, budget specialists, and other staff responsible for policy and planning. The Policy and Planning team members can help develop your overall 508 plan and evaluation mechanism. They can further define the roles and responsibilities outlined in this document to better meet your agency's needs. Section 508 responsibilities for policy and planning personnel include the following:
- Ensuring accessibility is included in 2003 budget.
- Leveraging Section 508 budget needs with E-FOIA, E-GOV, GPEA, and Security
- Working with CIO and CFO to meet Section 508 compliance
- Briefing Senior Managers and inform them of the need to include Section 508 requirements in their operating plans for FY 01 and FY 02.
Budget issues cut across a number of planning and implementation activities and must be addressed comprehensively. This is an important responsibility of the policy and planning team. The Team members from this area can help estimate the costs of purchasing Section 508 compliant EIT within their respective agencies and add those costs to their IT Capitol Planning process. To assist in determining the costs, the coordinator should review the "Economic Assessment" report that was developed by the Access Board. The report can be found at http://www.access- board.gov/sec508/assessment.htm.
