Including Section 508 in Quality Assurance Surveillance Plans

A Quality Assurance Surveillance Plan (QASP) is a tool the federal government uses to monitor and evaluate contractor performance against contract objectives. It outlines the methodology for surveillance activities, detailing the “what,” “when,” and “who.” The QASP also helps the Contracting Officer or Contracting Officer’s Representative (COR) monitor vendor performance and verify that deliverables meet contractual requirements. For information and communication technology (ICT) deliverables, the QASP should include verification of conformance with the Section 508 standards to ensure vendors consistently deliver digital products and services that meet federal ICT accessibility requirements. It should also specify how compliance with Section 508 standards will be verified. This ensures ICT accessibility is treated as a measurable, enforceable contract requirement.

Accessibility testing described in a QASP should be risk-based and appropriate to the type of ICT deliverable. While agencies may not test every individual element of a product, they should test representative workflows, templates, and components that reflect typical and critical user interactions to ensure accessibility issues are identified across the system.

Including Section 508 conformance requirements in QASPs:

• Reduces risk of rework by verifying accessibility throughout the project rather than only at final acceptance.
• Provides enforceable criteria for deliverable acceptance.
• Strengthens vendor accountability by making Section 508 conformance part of performance measurement.

The QASP is created during the solicitation phase. Include language in each solicitation to notify vendors that Section 508 conformance will be monitored through the QASP. For example:

In the QASP, agencies should:

• Explicitly identify the applicable ICT accessibility standards used to evaluate performance, such as the Section 508 standards and Web Content Accessibility Guidelines (WCAG) 2.0 Level AA.
• Define testing checkpoints for Section 508 conformance, such as during design, development, and user acceptance testing (UAT).
• Specify testing methodologies used to verify conformance. These may include automated scanning, manual inspection, assistive technology testing, representative sampling, or comprehensive testing.
• Detail corrective actions such as documenting a process for remediation and retesting.

Where to Include Section 508 in a QASP

At minimum, include Section 508 requirements in the following sections of a QASP:

• Performance Objectives and Standards: Defines the expected level of quality. Example langauge:

  All ICT deliverables must conform to Section 508 of the Rehabilitation Act, as implemented by the Section 508 Standards (36 C.F.R. Part 1194).

  Note: Add any additional ICT accessibility requirements for your agency beyond Section 508.
• Performance Indicators and Acceptable Quality Levels (AQLs): Defines how much deviation is acceptable before it counts as a defect. Example langauge:

  All information and communication technology (ICT) deliverables shall meet Section 508 requirements with no accessibility defects that prevent users with disabilities from completing required tasks. Examples of minor defects may include cosmetic or low-impact issues that do not prevent users with disabilities from being able to perceive, operate, or understand the content. Major Section 508 conformance defects or repeated minor defects will result in the agency rejecting the deliverable until remediation is complete. The Government will determine the severity of accessibility defects and whether remediation is required before acceptance.

  Note: Agencies may choose to require fully conformant deliverables without leeway for minor defects. Add any additional ICT accessibility requirements for your agency beyond Section 508.
• Surveillance Methods: Specifies how your agency will verify accessibility compliance. Example langauge:

  The agency will evaluate Section 508 conformance using a combination of automated testing tools, manual code inspection, and assistive technology testing, where applicable. The agency will test representative samples of web pages, software screens, or documents to confirm Section 508 conformance. The Government may also perform additional testing or require the contractor to provide supporting accessibility test results at no additional cost.

  Note: Specify testing methodologies and tools and modify the scope of testing by ICT type, where applicable.
• Frequency of Surveillance: Describes when Section 508 compliance reviews will occur. Example langauge:

  The agency will conduct Section 508 conformance reviews at major project milestones, including design reviews, development milestones, sprint reviews (for agile projects), user acceptance testing (UAT), and prior to final acceptance of deliverables. The agency reserves the right to also perform ad hoc Section 508 conformance testing and review deliverable progress at intervals not noted.
• Remediation and Corrective Action: Ensures defects must be fixed and re-tested. Example langauge:

  The Contractor must remediate Section 508 defects identified by the agency within [10ß] business days of notification, unless otherwise approved by the Contracting Officer or COR. The agency will re-test to confirm that corrective action meets Section 508 requirements. The agency may reject the deliverable until the Contractor completes remediation and meets all Section 508 standards. Remediation will occur at no additional cost to the agency.

  Note: Modify the timeframe of remediation as needed. Use cure notices when applicable.
• Roles and Responsibilities: Clarifies who checks Section 508 conformance and who fixes issues. Example langauge:

  The Contractor is responsible for ensuring deliverables conform to Section 508 requirements. The agency will perform surveillance and may engage third-party testers. Contractors must provide supporting documentation, such as a completed Accessibility Conformance Report (ACR) or test report, to demonstrate conformance. At a minimum, the documentation must include results for all applicable Section 508 standards, cover all major features, functions, and product workflows, and clearly describe the testing methodologies and tools used.

  Note: Modify the supporting documentation requirements as needed.

Sample QASPs by Project Type

Related Resources

• 37.604 Quality assurance surveillance plans Federal Acquisition Regulation (FAR)
• Accessibility In Procurement II: Solicitation and Post-Solicitation
• Buy Accessible Products and Services
• ICT Accessibility and Risk Management
• Technology Accessibility Playbook - Play 8: Integrate Accessibility Needs into Market Research and Acquisition Processes
• Quality Assurance Surveillance Plan (WARU.edu)
• Quality Assurance Surveillance Plan (FAA)