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Play 1: Establish a Section 508 Program Manager to Lead Compliance Efforts

Achieving Section 508 compliance requires a comprehensive, programmatic approach to managing compliance activities throughout an agency. The scope of an agency’s dependence upon technology is broad and continuously growing. Agencies need a well-qualified Section 508 Program Manager who has the ability, visibility, and authority to lead agency compliance activities to ensure digital services and technology solutions are accessible to users with disabilities.

Key Questions

  • Does your Section 508 Program Manager have the necessary knowledge, skills experience, and time to lead an agency-wide accessibility program?
  • Have you assigned your Section 508 Program Manager to a position of authority sufficient to manage legal compliance risk on behalf of the agency?
  • Does your Section 508 Program Manager have the support of the Chief Information Officer and the Chief Acquisition Officer, and visibility within the agency, to serve as the principal authority on Section 508 compliance matters?

Checklist

Table 1: Play 1 Checklist
Item Actions
At a minimum, an effective Agency Section 508 Program Manager:
  • Has the program management expertise to lead a complex agency-wide initiative.
  • Understands how Section 508 and related accessibility laws, regulations, and standards apply to the procurement, development, maintenance and use of information and communication technology.
  • Leads compliance management activities for all agency digital services and technology covered under Section 508.
  • Assesses the maturity of the existing Section 508 Program, develops goals and an action plan, and obtains support to improve the program's maturity.
  • Leads efforts to establish Section 508 compliance policies and processes.
  • Leads efforts to address compliance requirements in design, acquisition, development, and maintenance life cycles and processes.
  • Leads efforts to address compliance requirements and integrates into the agency's enterprise architecture.
  • Ensures Section 508 conformance claims are validated using expert review and testing.
  • Leads program governance and oversight.
  • Measures and reports on the effectiveness of program activities.
  • Coordinates training and outreach to inform and build support with program stakeholders.
Section 508 Program Managers cannot implement accessibility strategies alone. They need partners across the agency to assist them. An effective agency Section 508 Program Manager is a strategic partner who collaborates with:
  • Acquisition teams
  • Civil rights and reasonable accommodation officials
  • Communications and training groups
  • Human resources staff
  • Legal staff
  • Operations and service delivery components
  • Other federal Section 508 Program Managers
  • Technology providers and development teams
While inclusive access to federal digital services and technology is a federal law and a government-wide priority, key decision makers may not understand the business case for supporting universal access. To be effective, an agency Section 508 Program Manager also needs to be a champion who:
  • Actively promotes the benefits of accessible technology.
  • Advocates and negotiates for improving accessibility.
  • Encourages professional development and recognition of accessibility professionals.
  • Understands and can effectively communicate the needs of disabled individuals.
Section 508 compliance activities will likely affect a broad range of existing processes and work habits. To be effective at introducing activities to ensure technology is accessible, an agency Section 508 Program Manager must help individuals transition to new ways of delivering technology. Therefore, a Section 508 Program Manager must be a change agent who:
  • Understands how to manage change for an agency-wide initiative.
  • Supports agency components through the change process in order to achieve widespread adoption and effective compliance implementation.

Key Performance Indicators (KPI)

This section outlines Key Performance Indicators (KPIs) to track and measure accessibility testing, remediation, and overall Section 508 conformance across web, intranet, and enterprise ICT solutions.

Generic KPI: In FYXX, the organization's Section 508 Program Manager spends at least XX hours a pay period doing strictly ICT accessibility work. [i.e., 1/2 time or 0.5 FTE.].

Generic KPI: By QX FY2X, create a formal Section 508 Program Manager role and hire a qualified individual within X months of establishment.

Generic KPI: In FY2X, ensure that any Section 508 Program Manager vacancy within the organization lasts fewer than XX business days. The agency must designate a new Program Manager and report their name and contact information to the OMB within 30 days.

Reviewed/Updated: September 2025

Section508.gov

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