Federal agencies develop policies and directives to guide operations, governance, and compliance with laws. Failure to integrate Section 508 accessibility considerations into the policy review lifecycle increases risk for agencies. Specifically, it can unintentionally mandate inaccessible tools, systems, or practices through internal requirements, ultimately leading to higher remediation costs, greater legal exposure, and increased barriers for users.
To ensure agencies consistently and proactively address accessibility, integrate Section 508 review into the process for developing, reviewing, and approving policies and directives.
Benefits of Integrating Section 508 Into Policy Review
Section 508 of the Rehabilitation Act (29 U.S.C. § 794d) requires federal information and communication technology (ICT) to be accessible to people with disabilities. The law applies to ICT that agencies develop, use, maintain, and procure. Policies that fail to consider Section 508 requirements may:
Integration means that Section 508 review is a required and documented step within the agency’s official policy clearance workflow. This injects Section 508 expertise directly into the policy lifecycle, transforming accessibility into a fundamental design principle, rather than a late-stage consideration or afterthought. This proactive approach minimizes organizational risk.
Not every policy requires Section 508 review. Agencies should focus review efforts on policies, directives, standards, procedures, and guidance that govern, influence, authorize, procure, develop, maintain, use, or provide access to information and communication technology (ICT), electronic information, or digital services.
By integrating the Section 508 program into policy and directives review, agencies may:
Integration Best Practices
For all policies, directives, and guidance that affect ICT, agencies should establish clearly defined Section 508 review responsibilities within the official policy clearance process. Depending on agency structure, this responsibility may reside with a dedicated Section 508 program office, a designated official, the Chief Information Officer (CIO) organization, or another office responsible for accessibility compliance. This includes:
This approach embeds Section 508 expertise into decision points where policies gain authority and shape organizational behavior.
| Role | Responsibility |
|---|---|
| Policy Owner | Identifies potential accessibility impacts and engages Section 508 review when required |
| Section 508 Reviewer | Reviews policy content for accessibility implications and provides recommendations |
| CIO / Technology Leadership | Assesses technology governance implications where applicable |
| Governance Bodies | Ensure required reviews are completed before approval |
| Approving Official | Makes final policy approval decisions after considering accessibility findings |
Using the steps below, agencies can implement this integration through structured and repeatable actions within their existing policy framework.
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Identify applicable policies early
Develop and disseminate a short checklist to help policy owners recognize when Section 508 may need to be a consideration. This early identification enables proactive engagement rather than reactive review. Agencies should use a risk-based approach and focus review efforts on policies with meaningful accessibility implications. Typical categories include policies that:
- Govern ICT usage or procurement.
- Set requirements for use of digital content, communication tools, or online services.
- Influence records management, collaboration platforms, or cloud services.
- Affect how employees or the public access electronic information.
- Refer to the IT Accessibility Policy Framework for an additional list of applicable policies and how Section 508 should be integrated.
- Establish governance, oversight, approval, or management requirements for enterprise technologies, information systems, or digital services.
Tip: Develop concise job aids or short briefs to equip policy writers with the ability to identify potential accessibility implications prior to engaging the Section 508 program. -
Formalize Section 508 participation in the review workflow
Engage with the appropriate personnel to secure buy-in and update the agency's directives manual or policy clearance procedure. This ensures accessibility becomes a mandatory review step, not an optional addition. Require that, for all applicable policies:
- Policy owners submit draft language to the Section 508 program during the initial drafting stage when the policy affects ICT.
- The Section 508 reviewer provides feedback, recommendations, or an impact assessment on the proposed language.
- Clearance packages reflect Section 508 review status, including concurrence, conditional concurrence, or documented accessibility findings and recommendations. Note: Conditional concurrence indicates that the Section 508 reviewers support policy approval provided specified accessibility concerns are addressed through identified corrective actions, implementation guidance, risk acceptance, or future updates.
Tip: Position the Section 508 program as a partner and advisor during drafting rather than as a last-minute reviewer. Early collaboration improves outcomes and reduces resistance. -
Integrate 508 review criteria into existing governance bodies
Where agencies use boards or councils for policy clearance, such as executive review boards, Institutional Review Boards (IRB), Enterprise Architecture Review Boards (EARB), policy councils, or similar governance bodies, require that:
- A Section 508 representative is a standing participant.
- Accessibility review is a standing agenda item.
- Policy approval should not proceed until Section 508 review has been completed and any identified accessibility risks have been documented, addressed, accepted, or elevated through the agency’s established governance process.
Tip: Including Section 508 expertise in governance bodies elevates its visibility and ensures accountability. -
Align accessibility review with policy milestones
Embed Section 508 checkpoints into the phases of policy development:
- Concept or planning: Identify Section 508 implications and draft guidance language.
- Draft review: The designated Section 508 reviewer assesses the policy for conflicting, missing, or incomplete accessibility requirements and identifies potential accessibility risks.
- Pre-approval: Section 508 review is completed and documented. Reviewers provide concurrence, conditional concurrence, or documented concerns and recommendations. Clearance should not proceed until required Section 508 review activities have been completed and documented.
- Maintenance and Revisions: When revisions affect ICT requirements, digital communications, electronic content, technology governance, procurement practices, or public access to information, the policy owner should resubmit the directive for Section 508 review.
Tip: Cross-referencing these milestones with the agency’s policy management workflow makes accessibility review systematic and predictable. -
Document and monitor outcomes
Track results of the Section 508 review for transparency and continuous improvement. Documentation may include:
- Section 508 impact assessment records
- Recommendations and responses from the policy owner
- Final concurrence or documented feedback
- Lessons learned for future policy updates
- Metrics and trends used to improve future policy development activities
Agencies may also track operational measures such as the number of policies reviewed, recurring accessibility issues identified, percentage of recommendations adopted, and review timeliness. These measures can help demonstrate the effectiveness of integrating accessibility into policy governance processes.
Tip: Use this documentation to inform revisions to jobs aids or short briefs for policy personnel, improving consistency and accessibility outcomes over time.
