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Play 4: Establish a Section 508 Policy

The cornerstone of an accessibility program is an agency-wide Section 508 policy. The policy must identify how the agency will manage accessibility compliance through technology acquisition, development, authoring, configuration, deployment, and maintenance activities. The policy must define clear roles and responsibilities. The policy must clarify the authorities and shared responsibility with other agency stakeholders for implementing Section 508 across the agency.

Key Questions

  • Do you have a Section 508 policy (or policies) that establish roles, responsibilities, and expectations to support a sustainable agency-wide approach to managing Section 508 compliance risk?
  • What steps does your agency take to inform and equip agency stakeholders to follow your Section 508 policy(s)?
  • What governance mechanisms do you use to ensure conformance with your Section 508 policy(s)?
  • How often do you review and revise your Section 508 Policy(s) to keep pace with regulatory, organizational, and technology changes?

Basic Checklist

  • An effective Section 508 Policy will:
    • State the policy’s purpose and the agency’s commitments to ensuring equal access to information for people with disabilities,
    • Identify associated laws and regulations,
    • Identify how the Section 508 policy relates to other policies at the agency and department level, including technology, acquisition, and other accessibility policies related to the Rehabilitation Act,
    • Define authorities, roles, and responsibilities for all program stakeholders and participants,
    • Define how Section 508 exceptions are adjudicated and tracked through resolution,
    • Define minimum expectations for how Section 508 compliance will be addressed in acquisition, development, authoring, configuration, deployment and maintenance activities,
    • Define minimum expectations for when and how Section 508 conformance testing will be performed,
    • Define where stakeholders should go for Section 508 technical assistance,
    • Define how issues and complaints will be reported, assessed, tracked, resolved, and reported,
    • Define how governance will be used to ensure the policy is being followed (for example, independent reviews, non-compliance approvals. stage gates, and process audits),
    • Define how conformance with policy will be assessed, tracked and monitored, and
    • Define terminology to reduce misunderstanding,
  • A Section 508 Policy should make it clear that Section 508 conformance and accessibility is a responsibility for all employees. For example:
    • Program Managers must ensure that Requests for Proposals and Statements of Works call for Section 508 conformance in all digital service and technology deliverables.
    • Procurement Officials must ensure that all digital service and technology procurements are evaluated for Section 508 conformance.
    • IT Project Managers must ensure all digital services and technology solutions are designed and tested for Section 508 conformance.
    • Developers must design and develop digital services with accessible user interfaces.


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