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Understanding and Leveraging the Relationship Between Sections 501, 504, and 508 of the Rehabilitation Act

Federal agencies have the mandate to uphold a range of civil rights and accessibility laws. These statutes, while distinct in their primary focus, share commonalities that present opportunities for collaboration. A Section 508 program can significantly enhance agencywide accessibility practices and foster greater cohesion by building relationships with offices such as Equal Employment Opportunity (EEO), Human Resources (HR), and Civil Rights.

A Section 508 program does not operate in isolation. Partnerships are vital for agencies to fulfill legal obligations and optimize their efforts and efficiency in delivering accessible services to both federal employees and the public. The Rehabilitation Act of 1973 contains three sections that specifically address accessible information and communication technology (ICT), each with a slightly different emphasis.

Understanding the Different Rehabilitation Act Sections

Section 508: Information and Communication Technology (ICT)

Section 508 of the Rehabilitation Act requires federal agencies to ensure that their ICT is accessible to employees and members of the public with disabilities, as defined by the Section 508 standards. This includes websites, software, electronic documents, hardware, multimedia and electronic systems used to deliver services.

Section 501: Employment Of Individuals with Disabilities

Section 501 mandates that federal agencies prevent employment discrimination against individuals with disabilities. This includes nondiscrimination in hiring and promotion and providing reasonable accommodations, often involving accessible ICT. This may require federal agencies ensure that essential software, communication tools, and employee-facing electronic systems are Section 508 conformant and provide reasonable accommodations.

Section 504: Nondiscrimination Under Federal Grants and Programs

Section 504 prohibits discrimination against qualified individuals with disabilities in programs and activities receiving federal financial assistance or conducted by executive agencies or the U.S. Postal Service. Accessible ICT is often part of meeting Section 504 obligations for accessible public services.

Why Section 508 Programs Should Build Alliances

While Section 508 is the ICT-focused requirement, its outcomes directly support Sections 504 and 501 compliance:

  • Unified Mission: Section 508, 504, and 501 all aim to promote participation, equal access and nondiscrimination. A unified ICT accessibility strategy can transform fragmented efforts into a highly effective program, maximizing the return on investment for ICT products and services.
  • Increased Efficiency: Coordinating ICT accessibility initiatives reduces redundant work and enhances consistency in accessibility approaches. This streamlines operations, lowers costs and improves outcomes for both employees and the public.
  • Enhanced Visibility: Partnerships amplify an agency's influence and recognition regarding ICT accessibility.
  • Reduced Risk: Collaboration ensures uniform standards for both internal and public-facing ICT, thereby mitigating compliance risks and administrative overhead.

Practical Tips for Building Alliances

  1. Start with Shared Goals

    Frame discussions around the common mission: ensuring people with disabilities can fully participate in federal employment, programs and services and independently access and use federal digital products and services. Emphasizing these common values fosters unity and helps overcome enterprisewide barriers.

  2. Map Overlapping Responsibilities

    Develop a straightforward matrix or diagram to illustrate how ICT accessibility contributes to Sections 501 and 504 outcomes. Visual aids are effective for demonstrating the benefits of coordination. For instance:
    • Captioning enables employees with hearing disabilities to participate in meetings, training, and internal communications and enables members of the public with hearing disabilities to access webinars, town halls, or public briefings.
    • Accessible digital forms ensure employees applying for internal opportunities or completing HR processes can do so independently. Accessible digital forms also allow members of the public to submit applications, forms, or service requests independently.
    • Interoperability with Assistive Technology ensures employees with disabilities can use HR systems, timekeeping, and internal tools necessary for their job. It also ensures applicants or users with disabilities can use agency websites and digital services.

  3. Connect with Section 504 Program Leads

    • Share information regarding ICT testing methodologies, testing tools, procurement, and remediation solutions.
    • Collaborate to ensure that digital forms, digital services, and customer-facing platforms comply with both Sections 504 and 508 requirements.

  4. Partner with EEO and Section 501 Offices

    • Establish communication channels with your agency’s Equal Employment Opportunity Office (EEO) and the office or employee that manages reasonable accommodations requests for your agency (which may be a disability program manager or your agency’s equivalent).
    • Coordinate on reasonable accommodation cases that involve ICT, such as assistive technology software, assistive technology compatibility or interoperability, and alternative formats.
    • Provide input on ICT accessibility considerations for employee-facing systems such as HR portals, timekeeping, or training platforms. Prioritize high risk ICT systems and solutions.

  5. Establish Regular Communication

    Schedule recurring check-ins with Sections 501 and 504 points of contact. Even brief quarterly meetings can create opportunities to share challenges and successes and collaborate on cases, training, or ICT accessibility reviews before issues become complaints.

  6. Share Training and Resources to Maximize Efficiencies

    • Offer joint training sessions on ICT accessibility that highlight its connection to reasonable accommodation (Section 501) and program access (Section 504).
    • Disseminate Section 508 testing methodologies and tools, along with web manager and procurement checklists, to enhance awareness and minimize redundant efforts.
    • Promote agencywide awareness campaigns emphasizing accessibility as a shared responsibility.

  7. Build or Participate in Cross-Functional Accessibility Working Groups

    • Establish or participate in agencywide councils or task forces comprising representatives from Sections 508, 501, 504, IT, and HR programs. This interdisciplinary approach cultivates collective responsibility and provides a unified platform for addressing accessibility challenges throughout the agency.
    • Develop common metrics to monitor accessibility advancements, such as tracking improvements in ICT accessibility that benefit both employees and external users.

Related Resources:

Reviewed/Updated: January 2026

Section508.gov

An official website of the General Services Administration

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