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Policy & Management
Integrating Section 508 into Federal Capital Planning and Investment Control
Section 508 of the Rehabilitation Act ensures all information and communication technology (ICT) used by federal agencies is accessible to people with disabilities. Despite this, ICT accessibility is often only considered after the product is ready for deployment or publication. Integrating Section 508 considerations into the Capital Planning and Investment Control (CPIC) process ensures that ICT accessibility is accounted for from the outset and reduces risk, cost, and potential compliance issues.
What is CPIC?
The goal of the Capital Planning and Investment Control (CPIC) process is to achieve the best balance in IT investments at the lowest cost with the least risk while ensuring the mission and business goals are met. It provides agencies with a structured approach to:
Select — Determine the best IT Investments based on current and future business needs as they relate to the mission.
Control — An ongoing process for tracking each initiative’s progress against planned cost, schedule, performance, and mission benefits to ensure proper management.
Evaluate — After implementation, compare actual results to expectations to: (1) assess the initiative’s impact on strategic performance, (2) determine needed changes or improvements, and (3) update investment management processes based on lessons learned, self-assessments, and benchmarking.
Mandated by OMB Circular A-130, CPIC forms the backbone of federal IT governance.
Why Integrate Section 508?
Section 508 compliance is a legal requirement that also improves the quality of user experiences when accessing government electronic information and digital services. Agencies that ignore accessibility during the CPIC process risk:
Increased remediation costs for inaccessible systems
Delays in deployment or procurement
Legal or reputational consequences
By integrating Section 508 into CPIC, agencies can:
Ensure accessibility is evaluated during investment selection
Incorporate accessibility into risk management and performance monitoring
Foster a digital environment accessible to everyone from the start, rather than incurring the costs of retrofitting solutions later
Key Points for Integration
Agencies can embed Section 508 into the CPIC lifecycle using the following strategies:
1. Strategic Planning & Investment Justification
Include ICT accessibility as a critical criterion in the business case.
Align investments with Section 508 goals to support mission delivery.
Identify users and preliminary Section 508 requirements during concept development.
2. Selection & Approval
Evaluate vendor solutions for Section 508 compliance during procurement.
Use the Accessibility Requirements Tool (ART) and Solicitation Review Tool (SRT)—or equivalents—for ICT procurements to identify applicable accessibility requirements from Section 508 standards and incorporate them into procurement and contracting documentation.
Assign a Section 508 point of contact to guide the review process.
3. Implementation & Execution
Conduct ICT accessibility testing at key milestones.
Ensure project management plans include Section 508 checkpoints.
Train staff on accessibility standards and tools for continuous compliance.
4. Performance & Evaluation
Track accessibility performance indicators alongside traditional cost, schedule, and performance metrics.
Use remediation planning as part of risk management for identified accessibility gaps.
Report accessibility achievements in IT investment performance reviews.
5. Continuous Improvement
Collect lessons learned on accessibility for future investments.
Update CPIC guidance and templates to reflect emerging Section 508 standards.
Encourage cross-agency collaboration to share accessibility best practices.
Next Steps for Agencies
Assign accountability
Designate a Section 508 lead for CPIC integration.
Review current investments
Identify where accessibility gaps exist and incorporate corrective actions.
Embed in policy
Update CPIC governance documents to formalize Section 508 requirements.
Train teams
Ensure acquisition, IT, and program staff understand accessibility requirements and evaluation methods.
