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Policy & Management
Sample Position Descriptions with Section 508 Responsibilities
Some duties and responsibilities reflected in this content were informed by an interagency working group convened in response to Immediate Governmentwide Actions in OMB Memorandum M-24-08. The working group brought together federal employees from multiple agencies to collect and analyze position descriptions and identify common accessibility-related competencies for Section 508 Program Managers and digital accessibility specialists. This content expands on the working group efforts.
How to Use this Content
This resource provides a practical reference for federal agencies working to define, strengthen, or formalize accessibility-related roles and responsibilities across their workforce. The content is not prescriptive. Treat it as a starting point and adapt it to fit your agency’s structure, existing position descriptions, and governance model.
For each role, you will find:
Key duties and responsibilities drawn from OMB M-24-08 requirements and federal best practices.
Sample position description language you can incorporate into new or existing position descriptions.
Alliance building and engagement strategies to help role-holders collaborate effectively across the enterprise.
Sample performance metrics to help agencies measure and report on accessibility outcomes for each role.
RACI charts showing how each role intersects with other stakeholders on key accessibility activities.
How to Apply This Content
For HR professionals and hiring managers: Use the sample position description language as a starting point. Incorporate the duties and responsibilities that reflect your agency’s mission, organizational structure, and existing classification standards. You do not need to include every item; select what is relevant and tailor the language to align with your agency’s approved position descriptions and Office of Personnel Management (OPM) classification guidance.
For Section 508 Program Managers: Use the best practices, alliance building strategies, and RACI charts to identify gaps in your agency’s current accessibility governance, clarify role boundaries, and build the cross-functional relationships needed to sustain an effective program.
For agency leadership and executives: Use the metrics and engagement strategies to establish accountability, set expectations with key partners, and integrate accessibility into existing governance and performance management structures.
For IT Project Managers and Contracting Officers: Use the duties, responsibilities, and RACI charts to understand your role in the broader accessibility ecosystem and identify where coordination with other stakeholders is required.
A Few Important Notes
This content does not replace OPM classification standards. All position description language must align with applicable OPM classification guidance and your agency’s HR policies before use.
Tailor, do not copy wholesale. Every agency has a different structure. Take what is relevant, leave what is not, and adjust the language to reflect how your agency actually operates.
Use the RACI charts as a conversation starter. The charts reflect recommended role boundaries but your agency may assign responsibilities differently. Use them to facilitate conversations about ownership, coordination, and accountability.
Metrics are a starting point. The sample metrics reflect common measures of accessibility performance. Select the metrics that align with your agency’s existing reporting structures and data collection capabilities.
Reviews and complies with FAR section 11.002(f) and subpart 39.2 by ensuring Section 508 standards are considered in acquisition planning documents and procurement requirements for ICT and that deliverables meet accessibility standards.
Includes applicable Section 508 accessibility standards in requirements and acquisition planning documents and agreement, per FAR section 7.105(b)(5)(iv).
Best Practices
Coordinates with program offices, the Section 508 Program Manager, and technical staff to determine applicable accessibility requirements and identify any exceptions.
Ensures solicitations clearly define accessibility requirements, deliverables, and acceptance criteria, including requirements for Accessibility Conformance Reports (ACRs) or equivalent documentation.
Evaluates vendor-submitted accessibility documentation such as ACRs or test reports as part of the acquisition process, in coordination with subject matter experts.
Ensures accessibility considerations are included in source selection criteria and technical evaluations, as appropriate, and documented in evaluation records.
Incorporates accessibility requirements into contract terms and conditions, including provisions for testing, validation, and remediation of nonconforming ICT.
Documents accessibility decisions, including applicability, exceptions, and evaluation outcomes, in the official contract file.
Monitors contractor compliance with accessibility requirements throughout contract performance, in coordination with the Contracting Officer’s Representative (COR).
Enforces contractual accessibility requirements, including requiring remediation of defects, withholding acceptance when requirements are not met, and taking corrective action as appropriate.
Ensures accessibility requirements are addressed in contract modifications, renewals, and option exercises.
Sample Text to Include in a Position Description
Is responsible for ensuring that acquisitions of information and communication technology (ICT) comply with applicable accessibility requirements. The CO incorporates Section 508 standards into acquisition planning, solicitations, and contracts, and ensures that accessibility requirements are clearly defined and enforceable.
Collaborates with program offices, the Chief Information Officer (CIO), and the Section 508 program manager to determine applicable accessibility requirements and to evaluate vendor-submitted accessibility documentation.
Ensures that accessibility considerations are included in source selection and that all decisions related to accessibility are appropriately documented. The CO administers contracts to ensure contractor compliance with accessibility requirements and takes appropriate action when deliverables do not meet established standards.
Strategies For Engagement & Alliance Building
Program Office Partnership
Require requirements packages that include:
Sufficient accessibility requirements.
Acceptance criteria tied to testing.
Push back on incomplete submissions.
Section 508 Program Manager Collaboration
Use subject matter experts to:
Interpret ACRs and review test results.
Identify accessibility risk in vendor claims.
Establish a standard review workflow.
CIO and Technical Team Coordination
Align on:
Accessibility risk acceptance.
When independent testing is required pre-award.
COR Relationship
Ensure contracting officer representatives (COR):
Understand ICT accessibility requirements.
Are prepared to validate deliverables and enforce requirements.
Tip: Accessibility enforcement often fails here if expectations aren’t understood.
Vendor Communication
Set expectations early regarding how:
ICT accessibility will be evaluated.
Documentation will be validated.
Noncompliance will require remediation.
Sample Performance Metrics
Pre-Award Compliance
Percentage of ICT solicitations that include appropriate Section 508 requirements.
Percentage of acquisitions that included accessibility criteria in contract documents during the selection or technical evaluation process.
Evaluation Quality
Percentage of awards supported by reviewed and validated ACRs or similar documentation.
Reduction in awards with incomplete or insufficient accessibility documentation.
Documentation and File Integrity
Percentage of contract files with complete accessibility documentation, such as requirements, evaluations, and exceptions.
Post-Award Enforcement
Percentage of contracts where accessibility requirements are enforced at acceptance.
Number of accessibility-related issues identified post-award due to insufficient pre-award evaluation or lack of accessibility criteria used in the evaluation process.
Risk Reduction
Reduction in contract modifications related to accessibility gaps.
Percentage of high-risk ICT procurements escalated for additional review.
Includes applicable Section 508 accessibility standards in acquisition planning and requirement documents.
Verifies that products or services delivered under an agreement meet the accessibility terms and conditions included in a contract prior to accepting deliverables.
Best Practices
Supports the development of acquisition requirements by ensuring applicable Section 508 standards are identified and included in requirements and acquisition planning documents.
Collaborates with the contracting officer (CO), Section 508 program manager, and technical staff to define accessibility requirements, deliverables, and acceptance criteria.
Reviews contractor deliverables to verify conformance with contractual accessibility requirements prior to acceptance.
Coordinates accessibility testing and validation activities, including working with subject matter experts to assess conformance of ICT products and services.
Documents accessibility evaluation results, including identified defects, and provides recommendations to the CO regarding acceptance or rejection of deliverables.
Tracks and manages accessibility defects identified during testing, ensuring issues are communicated to the contractor and remediated within established timelines.
Monitors contractor performance related to accessibility requirements throughout the period of performance and escalates issues to the CO as needed.
Ensures accessibility requirements are maintained and enforced in contract modifications, task orders, and iterative deliverables such as agile releases.
Validates that required accessibility documentation, such as Accessibility Conformance Reports, are delivered, current, and reflect the actual product being provided.
Maintains complete and accurate records of ICT accessibility-related activities, including testing results, communications, and acceptance decisions.
Coordinates with program offices, developers, and content owners to ensure accessibility is addressed throughout implementation — not just at final delivery.
Sample Text to Include in a Position Description
Ensures that contractor deliverables comply with applicable ICT accessibility requirements. The COR collaborates with the CO, program officials, and the Section 508 program manager to define, evaluate, and enforce accessibility requirements throughout contract performance.
Reviews and validates contractor deliverables against established accessibility standards and provides recommendations to the CO regarding acceptance. The COR monitors contractor performance, tracks accessibility-related issues, and ensures that identified defects are remediated in accordance with contract requirements.
Maintains documentation of accessibility evaluations and supports the CO in ensuring that all contractual obligations related to accessibility are fulfilled.
Strategies For Engagement & Alliance Building
CO Partnership
Establish joint-accountability early on:
Accessibility risk determination.
What documentation is required for ICT acceptance.
Keep the CO informed.
Section 508 Program Manager Collaboration
Use SMEs for:
Test planning.
Interpreting results.
Risk-based decisions.
Avoid “self-certification” by vendors without validation.
Technical and Program Team Integration
Work closely with:
Developers.
Product owners.
Content teams.
Ensure accessibility is tested iteratively, not just at final delivery.
Monitor, track and reduce the number and severity of defects introduced during updates.
Vendor Relationship Management
Set clear expectations:
Accessibility defects must be fixed.
Acceptance is contingent on meeting requirements.
Maintain a collaborative but firm stance.
Documentation Discipline
Keep detailed records:
Test results.
Defect tracking.
Acceptance decisions.
This protects both the agency and the CO.
Sample Performance Metrics
Validation and Acceptance
Percentage of deliverables reviewed for accessibility prior to acceptance.
Percentage of deliverables rejected or conditionally accepted due to accessibility issues.
Defect Management
Percentage of identified accessibility defects remediated within required timelines.
Average time to resolve critical accessibility defects.
Oversight Effectiveness
Reduction in accessibility issues discovered before acceptance.
Reduction in accessibility issues discovered after acceptance.
Alignment between ACR claims and actual product conformance.
Documentation and Compliance
Completeness of accessibility documentation in contract files.
Accuracy and consistency of evaluation records.
Collaboration and Integration
Frequency of coordination with 508 Program Manager and technical teams.
Frequency of accessibility testing integrated into development cycles.
Scroll the table to view additional rows and columns.
Table 2: RACI matrix of overlapping Section 508 responsibilities (COR)
Activity
COR
CO
Program Office
Section 508 Program Manager
Vendors
Define accessibility requirements
R
A
R
R
I
Establish acceptance criteria
R
A
R
R
I
Review ACR or equivalent
R
A
C
R
I
Coordinate ICT accessibility testing
R
C
R
R
R
Validate deliverables
R
A
R
C
R
Track accessibility defects
R
C
R
C
R
Recommend acceptance/rejection
R
A
C
C
I
Monitor contractor performance
R
A
R
C
R
Enforce remediation day-to-day
R
A
R
C
R
Maintain documentation
R
A
C
C
I
Key Section 508-related Responsibilities
Best Practices
Creates and publishes digital content, such as documents, web content, presentations, emails, and multimedia, that conforms to Section 508 standards.
Applies accessible authoring practices, including proper use of headings, lists, tables, color contrast, meaningful link text, text alternatives, and plain language.
Applies an HTML-first approach for publishing online content in place of electronic document formats such as PDF and Word.
Ensures documents and files, such as PDFs, Word, PowerPoint, and spreadsheets, are properly structured, tagged, and Section 508 conformant prior to distribution or publication.
Ensures multimedia content includes captions, transcripts, and audio descriptions, as applicable, and is delivered through a standards-conformant media player.
Uses approved templates, tools, and content management systems that support accessibility.
Collaborates with content managers, Section 508 program managers, and other staff to ensure accessibility requirements are understood and met.
Participates in accessibility training and applies learned practices in day-to-day content creation.
Remediates existing content as directed, prioritizing high-impact or frequently accessed materials.
Sample Text to Include in a Position Description
Ensures that all content produced complies with accessibility requirements under Section 508 of the Rehabilitation Act and is usable by individuals with disabilities. The incumbent applies accessible authoring practices to documents, web content, and multimedia, and uses approved tools and templates to support compliance.
Reviews content for Section 508 conformance prior to publication, remediates identified issues, and collaborates with content managers, the Section 508 program manager, and other stakeholders to ensure consistent implementation of accessibility standards.
Strategies For Engagement & Alliance Building
Content Managers and Web Managers
Follow established:
Content standards.
Publishing workflows.
Seek review or approval when required.
Section 508 Program Manager
Use:
Checklists.
Job aids.
Ask for clarification on complex Section 508 Standards.
IT and Platform Teams
Report barriers in:
Templates.
Authoring tools.
Ensure authoring tools support accessible outputs.
Program Offices and SMEs
Encourage:
Plain language.
Clear structure.
Ensure accessibility is part of content development — not added later.
Training and Peer Support
Participate in role-based training.
Share accessible examples and best practices across teams.
Sample Performance Metrics
Content Accessibility Quality
Percentage of content created that meets Section 508 standards on first review.
Reduction in common accessibility errors, such as missing alt text, insufficient color contrast, and missing programmatic headings.
Compliance and Process Adherence
Percentage of content reviewed for accessibility prior to publication.
Use of approved accessible templates and tools.
Remediation
Timeliness in correcting accessibility issues following established timelines.
Participation in remediation of legacy content.
Training and Adoption
Completion of required accessibility training.
Demonstrated application of accessibility practices in daily work.
User Impact
Reduction in accessibility-related feedback or complaints tied to authored content.
Improved usability of content for individuals with disabilities.
RACI Matrix for Content Creator Roles and Responsibilities
Scroll the table to view additional rows and columns.
Ensures all digital content, such as web pages, documents, multimedia, and social media, conforms to Section 508 standards and agency policies.
Establishes and enforces content ICT accessibility standards, workflows, and publishing practices to ensure consistent compliance across all digital channels.
Reviews and approves content prior to publication to verify Section 508 conformance, including structure, formatting, alternative text, captions, transcripts, and document tagging.
Collaborates with the Section 508 Program Manager, IT teams, and designers to ensure content is accessible within the technical capabilities of agency platforms.
Provides guidance, training, and support to content creators, editors, and program offices on how to create Section 508 conformant content.
Ensures ICT accessibility is integrated into content management systems, templates, and publishing tools.
Coordinates remediation of inaccessible legacy content and prioritizes high-impact or high-visibility materials.
Monitors digital content for accessibility issues using automated and manual testing tools and processes.
Ensures multimedia content, such as videos and audio, includes appropriate captions, transcripts, and audio descriptions, as applicable.
Collaborates with communications, public affairs, and program offices to ensure accessibility is maintained across all public-facing and internal communications.
Tracks and reports on content accessibility metrics, including compliance rates and remediation progress.
Sample Text to Include in a Position Description
Ensures that all digital content complies with Section 508 accessibility requirements and is usable by individuals with disabilities. The incumbent establishes content standards, reviews materials for Section 508 conformance prior to publication, and provides guidance and training to content creators and program offices.
Collaborates with the Section 508 program manager, IT teams, and communications staff to ensure ICT accessibility is integrated into content workflows, templates, and tools. The incumbent monitors content for accessibility compliance, coordinates remediation efforts, and tracks performance metrics.
Promotes accessibility awareness and ensures that digital communications are aligned with agency policies and standards.
Strategies For Engagement & Alliance Building
Section 508 Program Manager Collaboration
Align on:
Content standards and checklists.
Testing approaches, including automated and manual testing.
Establish clear escalation paths for complex issues.
Communications and Public Affairs
Integrate ICT accessibility into:
Editorial workflows.
Approval processes.
Ensure accessibility is treated as a publishing requirement.
IT and Content Management System (CMS) Teams
Advocate for:
Accessible templates.
Authoring tools that are accessible and support accessible outputs.
Sufficient authority to decline the publishing of non-conformant information.
Ensure platform accessibility defects are addressed or mitigated.
Program Offices and Content Contributors
Provide:
Simple, actionable guidance.
Job aids and checklists.
Shift responsibility left; authors create accessible content from the start.
Training and Culture
Deliver targeted training for:
Web editors.
Document authors.
Social media managers.
Reinforce accessibility as part of everyday content creation, accessible by default.
Sample Performance Metrics
Content Compliance
Percentage of published content meeting Section 508 Standards.
Percentage of content reviewed for accessibility prior to publication.
Remediation
Reduction in inaccessible legacy content over time.
Time to remediate high-priority accessibility issues.
Quality and Consistency
Reduction in recurring accessibility errors, such as missing alternative text or insufficient color contrast.
Adoption rate of accessible templates and standardized formats.
Training and Adoption
Percentage of content creators trained in accessibility.
Measurable improvement in accessibility quality post-training.
User Experience
Reduction in accessibility-related complaints tied to content.
Improved usability feedback from individuals with disabilities.
RACI Matrix for Content Manager Roles and Responsibilities
Scroll the table to view additional rows and columns.
Ensures the experiences and perspectives of individuals with disabilities are considered when evaluating, designing, and improving agency services and digital experiences.
Collaborates with the Section 508 program manager, user experience (UX) designers, product managers, and program offices to incorporate accessibility and usability considerations into customer experience initiatives.
Conducts or supports user research, customer feedback collection, journey mapping, and service assessments that include individuals with disabilities.
Identifies barriers that may affect customer satisfaction, task completion, or equitable access to agency services and communicates findings to responsible stakeholders.
Supports the integration of accessibility and inclusive design principles into customer experience strategies, policies, and service improvement efforts.
Uses qualitative and quantitative data to assess the effectiveness of agency services for all users, including people with disabilities.
Promotes customer-centered and inclusive approaches to service delivery across agency programs and business functions.
Collaborates with accessibility, reasonable accommodation, and service delivery teams to better understand customer needs and identify opportunities for improvement.
Supports continuous improvement initiatives by monitoring customer feedback, identifying trends, and recommending corrective actions.
Sample Text to Include in a Position Description
Serves as a customer experience (CX) professional responsible for improving the quality, accessibility, and effectiveness of agency services and digital experiences.
Applies customer experience principles, user research methods, and data analysis techniques to understand customer needs and identify opportunities for service improvement.
Collaborates with program offices, accessibility professionals, designers, and technology teams to ensure agency services are inclusive and usable by all customers, including individuals with disabilities.
Gathers and analyzes customer feedback, evaluates service performance, and recommends improvements that enhance accessibility, usability, and customer satisfaction.
Supports agency efforts to incorporate accessibility and inclusive design principles into service delivery and customer experience initiatives.
Strategies For Engagement & Alliance Building
Section 508 Program Manager and Accessibility Staff
Incorporate accessibility considerations into customer research and service assessments.
Share customer feedback and usability findings related to accessibility barriers.
Collaborate on identifying opportunities to improve accessibility and customer satisfaction.
UX Designers and Product Teams
Ensure user research includes individuals with disabilities.
Validate that service improvements address both accessibility and usability concerns.
Use journey maps and service blueprints to identify accessibility pain points.
Program Offices and Service Owners
Identify customer needs and barriers across agency services.
Support continuous improvement efforts based on customer feedback and performance data.
Reasonable Accommodation Staff
Understand recurring accommodation requests and service challenges.
Identify opportunities to improve services proactively rather than relying solely on accommodations.
Communications and Content Teams
Ensure customer-facing communications are understandable, accessible, and user-centered.
Promote plain language and inclusive communication practices.
Sample Performance Metrics
Customer Experience Outcomes
Improvement in customer satisfaction scores.
Reduction in customer-reported barriers to accessing services.
Improvement in task completion rates for digital services.
Accessibility Considerations
Percentage of customer research activities that include individuals with disabilities.
Number of accessibility-related customer insights incorporated into service improvements.
Demonstrated consideration of accessibility in CX initiatives and recommendations.
Service Improvement
Number of customer experience improvements implemented based on user feedback.
Reduction in recurring customer complaints related to service accessibility or usability.
Data and Analysis
Timeliness and quality of customer experience reporting.
Identification of trends and actionable recommendations supported by customer data.
Collaboration and Engagement
Evidence of coordination with accessibility, product, UX, and service delivery teams.
Stakeholder satisfaction with customer experience support and recommendations.
Scroll the table to view additional rows and columns.
Table 5: RACI matrix of overlapping Section 508 responsibilities (CX)
Activity
CX Professional
Content Manager
Developers
IT Product Manager
Program Office
Section 508 PM
UX Designer
Gather customer feedback
R
I
I
C
C
C
C
Conduct user research
R
I
I
C
C
C
R
Include people with disabilities in research
R
I
I
C
C
C
R
Identify customer barriers
R
I
I
C
C
C
C
Recommend service improvements
R
C
I
R
C
C
C
Measure customer experience outcomes
R
I
I
C
C
C
I
Integrate accessibility into CX initiatives
R
I
I
C
I
R
C
Promote accessible service delivery
R
C
I
C
R
C
C
Key Section 508-related Responsibilities
Best Practices
Supports the Section 508 program manager in planning, implementing, and overseeing the agency-wide accessibility program.
Responsible for adequately staffing the accessibility program and ensuring Section 508 integration across agency business functions.
Manages and coordinates efforts to establish policies, processes, and programs that enable agency compliance with Section 508 and related accessibility laws, regulations, and standards.
Measures the effectiveness of program activities by establishing, monitoring, and reporting on performance metrics.
Interprets and applies Section 508 and related accessibility laws, regulations, and standards across a broad range of organizational activities, including procurement, development, maintenance, and use of ICT.
Advises agency leadership, program offices, acquisition teams, and technical staff on the implementation of accessibility requirements.
Ensures coordination with Section 508 subject matter experts (SME), developers, designers, content creators, and testers to support consistent application of accessibility standards.
Supports remediation of accessibility defects or gaps identified in ICT systems, content, or processes.
Participates in accessibility training initiatives and promotes continuous improvement and adoption of best practices across the agency.
Supports the Section 508 program manager in developing and presenting the business case for ICT accessibility compliance across all relevant mission areas across the agency.
Assists with reporting to leadership on accessibility program status, challenges, and achievements.
Sample Text to Include in a Position Description
Serves as deputy Section 508 program manager, supporting the Section 508 program manager in implementing an agency-wide accessibility program.
Ensures Section 508 compliance is integrated across all agency business functions and ICT lifecycles.
Manages program staffing, assists in establishing policies and processes, and interprets accessibility laws, regulations, and standards across agency operations, including procurement, development, and maintenance of ICT.
Helps establish and monitor performance metrics to measure program effectiveness, provides guidance to agency personnel on accessibility implementation, and coordinates with SMEs, developers, designers, content creators, and testers to ensure consistent application of accessibility requirements.
Promotes continuous improvement, participates in training initiatives, and supports leadership in reporting on accessibility program status and outcomes.
Suggested Qualifications
Skills and expertise in project management, IT governance, IT acquisition, accessibility testing and validation, use of assistive technology, compliance analysis, training, and communications.
Strategies For Engagement & Alliance Building
Section 508 Program Manager
Serve as the primary operational partner, helping translate strategic goals into actionable program initiatives.
Provide updates on staffing, resource allocation, and program performance.
Align priorities and escalate issues as needed.
CIO and Agency Leadership
Keep leadership informed about program effectiveness, resource needs, and major accessibility risks.
Support decision-making for agency-wide accessibility initiatives.
Section 508 SMEs
Collaborate to provide consistent guidance to program offices and ICT teams.
Leverage SMEs’ technical and policy expertise to resolve complex accessibility questions.
Acquisition Officers, including CAO, CO, and COR
Ensure Section 508 requirements are included in procurement planning.
Advise acquisition teams on compliance risk for ICT purchases.
IT, Product, UX, and Development Teams
Ensure Section 508 compliance is integrated early in the ICT lifecycle.
Facilitate coordination between program oversight and project implementation.
Content Managers and Creators
Promote adoption of accessible content practices and standards.
Provide guidance on accessible templates, tools, and workflows.
Testers
Coordinate testing schedules and clarify requirements to ensure consistent evaluation.
Support remediation planning for identified accessibility defects.
Track remediation, defect logs, and timelines to Section 508 conformance.
Sample Performance Metrics
Program Effectiveness
Percentage of ICT projects, content, and deliverables meeting accessibility standards at the first review.
Number of ICT accessibility issues resolved within established timelines.
Level of compliance improvement over time across agency ICT and content.
Resource Management
Timeliness and effectiveness of resource allocation for program activities.
Policy and Process Implementation
Percentage of accessibility policies, processes, and procedures adopted across business units.
Evidence that program processes are consistently applied and updated based on best practices.
Stakeholder Engagement
Satisfaction levels from SMEs, program offices, IT teams, and content teams with guidance and support provided.
Number of collaborative initiatives undertaken to resolve ICT accessibility issues.
Metrics and Reporting
Accuracy and timeliness of performance metric collection and reporting.
Use of metrics to identify trends, gaps, and areas for improvement in the program.
Measured improvements in year-over-year outcomes in the Annual Section 508 Assessment.
Training and Continuous Improvement
Percentage of staff completing required accessibility training.
Demonstrated application of learned practices in ICT development, content creation, and program operations.
RACI Matrix for Deputy Section 508 PM Roles and Responsibilities
Scroll the table to view additional rows and columns.
Develop, test, and maintain ICT applications, systems, and digital services in conformance with Section 508 standards.
Implement accessible code using appropriate semantic structure, keyboard operability, focus management, and compatibility with assistive technologies.
Integrate accessibility requirements into all phases of development, including design, requirements, coding, testing, and deployment.
Collaborate with the Section 508 program manager, designers, product managers, business analysts, and testers to ensure accessibility requirements are understood and implemented correctly.
Use automated and manual testing tools to identify and remediate accessibility defects during development.
Ensure compatibility with assistive technologies such as screen readers, magnification software, voice input, and keyboard-only navigation.
Address accessibility defects identified through testing, user feedback, or audits, and verify remediation prior to release.
Contribute to the development and use of accessible components, design systems, and reusable code libraries.
Review and interpret Accessibility Conformance Reports (ACRs) or test reports for third-party components and ensure proper integration.
Maintain awareness of ICT accessibility standards, best practices, and emerging technologies to continuously improve implementation.
Document accessibility features, limitations, and known issues as part of system documentation.
Sample Text to Include in a Position Description
Ensures that all code and technical implementations conform to applicable accessibility requirements under Section 508 of the Rehabilitation Act. The incumbent integrates accessibility into the web and software development lifecycle and collaborates with product managers, designers, and the Section 508 program manager to implement accessible solutions.
Conducts accessibility testing using automated and manual methods, remediates identified defects, and ensures compatibility with assistive technologies. The incumbent contributes to reusable accessible components and supports continuous improvement of digital accessibility practices across development teams.
Strategies For Engagement & Alliance Building
IT Product Manager and IT Program Manager Partnership
Translate accessibility requirements into:
User stories.
Acceptance criteria.
Ensure accessibility is part of the “definition of done”.
UX and Design Collaboration
Align on:
Accessible interaction patterns.
Visual and structural design requirements.
Provide feedback when designs introduce ICT accessibility barriers.
Section 508 Program Manager and Testers
Validate implementation against Section 508 standards.
Clarify complex requirements and edge cases.
Incorporate testing early and often.
Content Managers
Ensure content management system (CMS) outputs and templates support accessible content.
Prevent content-level issues caused by technical limitations.
DevOps and CI/CD Integration
Incorporate automated accessibility testing into pipelines.
Prevent regressions of ICT platforms, software, and electronic content through continuous testing.
Sample Performance Metrics
Code Accessibility Quality
Percentage of code or components meeting Section 508 Standards.
Reduction in accessibility defects introduced during development.
Defect Remediation
Time to resolve accessibility issues identified during testing.
Percentage of defects resolved prior to release.
Testing Integration
Use of automated accessibility testing tools in development workflow.
Frequency of manual accessibility validation.
Reusability and Standards
Contribution to accessible component libraries or design systems.
Adoption of standardized accessible patterns across applications.
Collaboration and Continuous Improvement
Participation in accessibility training and knowledge sharing.
Demonstrated integration of ICT accessibility into development practices.
RACI Matrix for Developer Roles and Responsibilities
Scroll the table to view additional rows and columns.
Table 7: RACI matrix of overlapping Section 508 responsibilities (Developer)
Activity
Developers
CO
COR
Content Manager
EA
IT PM
IT Product PM
Section 508 Program Manager
UX/Design
Implement accessible code
R
I
I
C
C
C
C
C
R
Integrate accessibility into SDLC
R
I
I
C
C
R
R
C
R
Accessibility testing, dev-level
R
I
C
I
I
C
C
R
R
Remediate ICT accessibility defects
R
I
C
C
I
C
C
C
R
Contribute to design systems/components
R
I
I
I
R
I
C
C
R
Validate assistive technology compatibility
R
I
C
I
I
I
C
R
R
Document accessibility features/issues
R
I
I
I
I
C
C
C
I
Key Section 508-related Responsibilities
Best Practices
Integrates Section 508 standards into enterprise architecture planning, including technology roadmaps, standards, reference models, and system design patterns.
Ensures architecture documentation, technology inventories, and related artifacts reflect the latest ICT accessibility conformance status, known accessibility limitations, and associated risks.
Ensures ICT solutions are designed with accessibility built in from the outset, reducing costly remediation later in the lifecycle.
Collaborates with the Chief Information Officer, Section 508 program manager, program offices, and development teams to identify accessibility dependencies and constraints.
Reviews ICT system architectures and designs to validate compliance with Section 508 Standards and accessibility best practices.
Provides guidance on the selection and configuration of enterprise platforms, tools, and services to support accessible ICT.
Supports the evaluation of ICT procurements by reviewing architectural documentation and ensuring proposed solutions meet ICT accessibility requirements.
Develops reusable design patterns, templates, and reference architectures that incorporate accessibility principles for agencywide use.
Monitors emerging technologies and industry standards to recommend updates to architecture standards and practices that improve accessibility.
Supports the Section 508 program manager in conducting accessibility risk assessments at the system and enterprise levels.
Contributes to training and awareness initiatives by advising developers and system owners on accessibility integration in architecture and design.
Sample Text to Include in a Position Description
Ensures that accessibility requirements under Section 508 are integrated into the agency’s enterprise architecture, system designs, documentation, and technology roadmaps. The EA provides guidance to program offices, developers, and acquisition teams on how to design ICT solutions that are accessible and compliant.
Reviews system architectures, provides reusable design patterns, and recommends accessible technologies and configurations. The EA collaborates with the CIO, Section 508 program manager, and program offices to evaluate proposed ICT solutions for compliance with Section 508 and accessibility best practices.
Monitors emerging trends and industry standards to enhance accessibility across the enterprise architecture and supports training and awareness initiatives to embed accessibility principles into the design lifecycle.
Strategies For Engagement & Alliance Building
CIO and Governance Alignment
Embed ICT accessibility checkpoints in architecture review boards.
Ensure ICT accessibility is treated as a non-negotiable requirement in design approval.
Section 508 Program Manager Collaboration
Validate that enterprise design decisions meet technical accessibility standards.
Provide feedback for remediation and improvement.
Program Office or Development Team Engagement
Advise on accessible design patterns, frameworks, and components.
Participate in design reviews for major ICT initiatives.
Support early identification of accessibility risks.
Procurement and Acquisition Coordination
Review architectural documentation for accessibility compliance pre-procurement.
Recommend architectural standards to include in contracts.
Knowledge Sharing and Training
Develop templates, patterns, and guidance for accessible design.
Coach developers, system owners, and architects on Section 508 integration.
Sample Performance Metrics
Design and Architecture Compliance
Percentage of ICT systems reviewed with ICT accessibility standards incorporated.
Number of reusable design patterns or templates created that incorporate Section 508 standards.
Risk Mitigation
Percentage of high-impact systems with ICT accessibility risks identified and mitigated early in the design lifecycle.
Guidance and Adoption
Number of architecture review board recommendations acted upon related to ICT accessibility.
Usage rate of accessible design patterns and templates across ICT projects.
Collaboration and Influence
Stakeholder satisfaction with accessibility guidance and support.
Evidence of coordination with CIO, Section 508 PM, and program teams on ICT accessibility design decisions.
Scroll the table to view additional rows and columns.
Table 8: RACI matrix of overlapping Section 508 responsibilities (EA)
Activity
EA
CO
COR
Developers
Program Office
Section 508 Program Manager
Integrate Section 508 into enterprise architecture
R
I
I
C
C
C
Design review and ICT accessibility validation
R
I
I
R
R
C
Provide accessible design patterns and templates
R
I
I
R
C
C
Evaluate proposed ICT solutions for Section 508 compliance
R
C
I
R
R
C
Architectural guidance to acquisition
R
R
I
I
C
C
Monitor emerging accessibility technologies
R
I
I
C
I
C
Support Section 508 risk assessments
R
I
I
C
C
A
Training and knowledge sharing
R
I
I
R
C
C
Key Section 508-related Responsibilities
Best Practices
Ensures ICT products and digital services, including websites, applications, and platforms, meet the needs of individuals with disabilities and conform to Section 508 standards.
Collaborates regularly with the Section 508 program manager, IT project managers, designers, developers, and reasonable accommodation staff to ensure ICT is accessible, usable, and inclusive.
Defines product requirements that include accessibility and usability criteria from the outset, integrating Section 508 standards into feature design, user stories, and acceptance criteria.
Prioritizes ICT accessibility in product roadmaps, release planning, and feature development to ensure timely compliance with Section 508 requirements.
Reviews Accessibility Conformance Reports (ACRs), test reports, and other accessibility documentation to validate that features meet established standards before release.
Works with user experience (UX) teams, designers, and content creators to test products with users with disabilities and ensure the product’s usability.
Tracks accessibility issues through product backlogs, ensuring remediation of defects and verification prior to release.
Maintains ongoing awareness of ICT accessibility best practices, emerging standards, and technology trends to continuously improve the product’s accessibility.
Collaborates with acquisition, contracting, and IT teams to ensure accessibility requirements are reflected in procurements of digital tools, platforms, and components.
Provides guidance, training, and awareness to development teams, designers, and content owners regarding accessibility integration in product development.
Sample Text to Include in a Position Description
Ensures that all ICT products and services are designed, developed, and deployed in a manner that meets the needs of individuals with disabilities and complies with Section 508 standards. The product manager collaborates with the Section 508 program manager, IT project managers, developers, UX teams, and content creators to integrate accessibility into product requirements, feature design, testing, and release planning.
Tracks accessibility defects, validates product conformance through documentation and testing, and prioritizes remediation. The product manager also ensures accessibility requirements are incorporated into procurements of digital platforms and tools used for the product.
Promotes accessibility awareness, provides guidance to development teams, and continuously monitors emerging trends and best practices to improve the accessibility and usability of ICT products.
Strategies For Engagement & Alliance Building
Section 508 Program Manager Collaboration
Align product requirements with Section 508 standards.
Ensure ICT accessibility validation and testing plans are in place.
IT Project Managers and Developers
Integrate accessibility requirements and acceptance criteria into user stories, tasks, and sprints.
Ensure accessibility defects are tracked and remediated in backlog management.
UX, Design, and Content Teams
Conduct user testing with individuals with disabilities.
Apply accessibility best practices in design, navigation, and content.
Acquisition and Procurement
Ensure ICT accessibility is addressed when acquiring tools, platforms, or services.
Review vendor accessibility claims and documentation for products being integrated.
Reasonable Accommodation Staff
Incorporate feedback from users requiring reasonable accommodations.
Validate that products remain usable for all end users.
Sample Performance Metrics
Accessibility Compliance
Percentage of product features meeting Section 508 standards at release.
Percentage of accessibility defects resolved prior to product release.
User Testing and Usability
Number of usability tests conducted with users with disabilities.
User satisfaction scores from individuals with disabilities.
Documentation and Validation
Percentage of features validated via ACR or equivalent accessibility documentation.
Timeliness and completeness of ICT accessibility validation before release.
Product Roadmap and Prioritization
Percentage of accessibility-related requirements included in product backlog.
Number of releases with ICT accessibility integrated as a core criterion.
Collaboration and Awareness
Evidence of accessibility guidance provided to development, UX, and content teams.
Frequency of collaboration with Section 508 PM and IT project managers.
RACI Matrix for IT Product Manager Roles and Responsibilities
Scroll the table to view additional rows and columns.
Consistent with the Federal Acquisition Certification for Program and Project Managers, and the Office of Personnel Management Competency Model for IT Program Management, ensures Section 508 is considered throughout the acquisition and information technology lifecycles.
Meets and collaborates regularly with the Section 508 program manager and reasonable accommodation program staff to ensure ICT is accessible and usable.
Best Practices
Ensures compliance with Section 508 standards in alignment with the Federal Acquisition Certification for Program and Project Managers (FAC-P/PM) and the OPM IT Program Management Competency Model.
Coordinates ICT accessibility testing and validation activities, including working with contracting officer’s representatives, developers, and SMEs to verify conformance.
Ensures ICT accessibility risks are identified, documented, and mitigated in project plans, schedules, and risk registers.
Reviews vendor-submitted Accessibility Conformance Reports (ACRs) or test reports and integrates findings into project decision-making and acceptance criteria.
Provides guidance to project teams on ICT accessibility best practices and ensures adherence to Section 508 standards throughout project execution.
Tracks accessibility-related metrics, milestones, and corrective actions, reporting results to senior leadership, program offices, and Section 508 program manager.
Ensures that all project documentation, including requirements, design documents, test plans, and deployment plans, reflects ICT accessibility considerations.
Coordinates with acquisition, contracting, and development teams to ensure accessibility requirements are properly incorporated into contracts, task orders, and iterative deliverables.
Sample Text to Include in a Position Description
Ensures that Section 508 requirements are integrated into all project phases, from requirements definition through deployment and sustainment. The IT PM collaborates with the Section 508 program manager, developers, program offices, and reasonable accommodation staff to ensure ICT solutions are accessible and usable.
Manages accessibility risks, coordinates validation and testing activities, and ensures that vendor-submitted accessibility documentation is reviewed and integrated into project acceptance criteria. The IT PM tracks and reports accessibility metrics and ensures that project deliverables meet established Section 508 Standards.
Supports acquisition and contracting teams by providing guidance on accessibility requirements and ensuring that accessibility considerations are maintained throughout the project lifecycle.
Strategies For Engagement & Alliance Building
Section 508 Program Manager Collaboration
Regularly review ICT accessibility requirements, testing plans, and remediation status.
Escalate accessibility risks promptly for mitigation.
CIO and Enterprise Architects
Ensure project designs and ICT solutions comply with enterprise accessibility standards.
Integrate ICT accessibility into solution architecture decisions.
Acquisition and CO/COR Coordination
Review vendor ACRs, test reports, and accessibility documentation before acceptance.
Confirm deliverables align with contractual accessibility requirements.
Program Office and Development Teams
Conduct iterative ICT accessibility testing at each milestone.
Provide guidance and resources on best practices and Section 508 Standards.
Reasonable Accommodation and User Engagement
Incorporate feedback from users with disabilities to validate usability.
Use real-world testing scenarios where possible.
Sample Performance Metrics
Accessibility Compliance
Percentage of projects with Section 508 requirements integrated into all phases.
Percentage of project deliverables reviewed and validated for ICT accessibility.
Risk Management
Number of ICT accessibility risks identified and mitigated proactively.
Average time to resolve ICT accessibility defects within the project lifecycle.
Vendor Oversight
Percentage of vendor deliverables meeting accessibility criteria on first submission.
Accuracy and completeness of ACR or test report evaluations integrated into project decisions.
Project Tracking and Reporting
Timeliness and quality of ICT accessibility metrics and milestone reporting.
Percentage of corrective actions implemented within planned schedules.
User Satisfaction
Critical feedback from users with disabilities during testing or deployment.
Number of post-deployment ICT accessibility issues reported.
RACI Matrix for IT Program Manager Roles and Responsibilities
Scroll the table to view additional rows and columns.
Ensures public-facing and internal communications are accessible to individuals with disabilities and conform to Section 508 requirements.
Incorporates accessibility considerations into communication strategies, outreach initiatives, public awareness campaigns, and stakeholder engagement activities.
Creates, reviews, publishes, or coordinates the publication of accessible communications materials, including web content, social media posts, newsletters, presentations, reports, multimedia, and other digital content.
Ensures communications products include appropriate accessibility features, such as alternative text, captions, transcripts, accessible document structure, meaningful link text, and accessible multimedia formats.
Collaborates with content managers, content creators, UX designers, and the Section 508 program manager to establish accessible communications workflows and practices.
Reviews communications materials prior to publication to identify and address accessibility issues.
Promotes the use of plain language to improve understanding and access for diverse audiences.
Coordinates with program offices and agency leadership to ensure accessibility requirements are considered during communications planning and execution.
Supports accessibility awareness initiatives by helping communicate accessibility-related policies, resources, training opportunities, and program accomplishments.
Participates in accessibility training and applies accessibility best practices to communications activities.
Sample Text to Include in a Position Description
Ensures that communications materials comply with accessibility requirements under Section 508 of the Rehabilitation Act and are usable by individuals with disabilities.
Applies accessible communication practices to digital content, documents, presentations, multimedia, and social media and collaborates with accessibility, content, and technology professionals to support compliance.
Supports agency outreach and engagement efforts by promoting accessible communications practices and helping ensure information is available to all audiences.
Strategies For Engagement & Alliance Building
Section 508 Program Manager and Accessibility Staff
Establish accessibility review processes for communications products.
Coordinate on accessibility guidance, awareness campaigns, and communications policies.
Consult on complex accessibility questions related to multimedia, social media, or public-facing content.
Content Managers and Content Creators
Promote consistent accessibility standards and publishing practices.
Share templates, checklists, and communication guidance.
Coordinate reviews and approvals for high-visibility content.
UX Designers and Web Teams
Ensure digital communications support accessible user experiences.
Coordinate on campaign landing pages, web content, and digital engagement activities.
Program Offices and Leadership
Integrate accessibility requirements into communication planning from the beginning.
Ensure communications timelines account for accessibility reviews and remediation when needed.
Customer Experience (CX) Teams
Incorporate customer feedback and accessibility-related insights into communication strategies.
Help ensure communications effectively reach and engage diverse audiences.
Sample Performance Metrics
Accessible Communications
Percentage of communications products meeting accessibility requirements prior to publication.
Reduction in accessibility issues identified in published communications materials.
Use of accessible templates, workflows, and communication tools.
Quality and Consistency
Percentage of multimedia content published with required captions, transcripts, or other accessibility features.
Adoption of plain language communication practices across communications products.
Reduction in recurring accessibility errors within communications materials.
Outreach and Engagement
Successful delivery of accessibility-related awareness campaigns, training promotions, or outreach initiatives.
Evidence that communications effectively reach intended audiences, including individuals with disabilities.
Stakeholder satisfaction with accessibility support provided by communications staff.
Continuous Improvement
Completion of accessibility training and application of learned practices.
Implementation of process improvements that increase accessibility and efficiency in communications workflows.
RACI Matrix for Communications Roles and Responsibilities
Scroll the table to view additional rows and columns.
Table 11: RACI matrix of overlapping Section 508 responsibilities (Comms)
Activity
Public Affairs / Communications
Content Creator
Content Manager
CX Professional
Program Office
Section 508 PM
UX Designer
Develop communication strategies
R
I
C
C
C
I
C
Create accessible communications
R
R
C
I
C
C
I
Review communications for accessibility
R
C
R
I
I
C
I
Publish public-facing communications
R
C
C
I
C
I
I
Promote accessibility awareness
R
I
I
I
C
C
I
Coordinate outreach campaigns
R
I
I
C
C
I
C
Ensure multimedia accessibility
R
C
C
I
I
C
I
Promote plain language
R
C
C
C
C
C
I
Key Section 508-related Responsibilities
Best Practices
Conducts comprehensive Section 508 conformance validation testing of web content, media, such as audio, video, and multimedia, and electronic documents, such as PDFs, Word documents, PowerPoint presentations, and Excel spreadsheets.
[If applicable] Conducts testing of software and mobile applications.
[If applicable] Conducts testing of kiosks and hardware.
Applies Section 508 Standards and WCAG 2.0 Level AA success criteria using manual and automated testing techniques per agency policy.
Uses standardized federal testing methods, including [insert approved Section 508 testing methodology(ies)].
Generates Section 508 test reports, including defect severity and remediation recommendations.
Provides Section 508 guidance and technical support to internal teams and stakeholders.
Engages with content creators and developers to guide remediation efforts.
Tracks and reports Section 508 testing status, remediation progress, and metrics to support program governance.
Reviews Accessibility Conformance Reports (ACRs) and provides feedback for procurement decision making.
Collaborates with developers, content creators, program managers, and procurement officials to improve Section 508 compliance.
[If applicable] Delivers training or workshops on ICT accessibility and Section 508 requirements.
[If applicable] Supports integration of Section 508 conformance in agency SDLC, Agile processes, and acquisition workflows.
Sample Text to Include in a Position Description
Serves as a Section 508 Accessibility Tester and technical consultant responsible for evaluating digital products, services, and electronic content developed, procured, maintained, or used by the agency for conformance with Section 508 Standards.
Performs ICT accessibility testing using approved manual and automated testing methods, including evaluation of web content, software applications, documents, multimedia, and other ICT. Documents accessibility defects, assigns severity, provides remediation recommendations, and verifies corrective actions prior to release or acceptance.
Collaborates with the Section 508 program manager, Section 508 SMEs, developers, designers, content creators, IT project managers, product managers, contracting officials, and vendors to support accessibility conformance throughout the ICT lifecycle.
Reviews accessibility documentation, including Accessibility Conformance Reports and test reports, and provides findings to support acquisition, development, remediation, and acceptance decisions.
Supports agency accessibility program governance by tracking testing status, reporting metrics, identifying recurring accessibility issues, and contributing to continuous improvement of testing practices, guidance, and training.
Strategies For Engagement & Alliance Building
Section 508 Program Manager
Coordinate testing priorities, reporting needs, and program-level accessibility metrics.
Support consistent use of approved testing methodologies and reporting formats.
Escalate recurring or high-risk accessibility defects that may affect program compliance.
Provide testing data to support agency reporting, governance, and continuous improvement.
Section 508 SME
Consult on complex, ambiguous, or high-risk accessibility findings.
Align on interpretation of Section 508 Standards, WCAG criteria, and agency guidance.
Collaborate on test methodology updates, defect severity models, and remediation recommendations.
Support consistency in testing decisions across ICT products and teams.
Developers and IT Teams
Provide clear defect reports with steps to reproduce, expected behavior, actual behavior, impact, and remediation guidance.
Participate in defect triage and remediation discussions.
Validate fixes before release and help prevent accessibility regressions.
Promote accessibility testing earlier in development cycles.
UX, Design, and Product Teams
Identify accessibility issues related to interaction design, visual design, navigation, focus order, and usability.
Provide feedback on design patterns, prototypes, and user flows before development is complete.
Support usability testing with individuals with disabilities, where appropriate.
Help ensure accessibility is reflected in acceptance criteria and product requirements.
Content Managers and Content Creators
Test documents, web content, multimedia, and other digital content for Section 508 conformance.
Provide remediation guidance for common issues such as missing headings, poor reading order, inaccessible tables, missing alt text, and insufficient color contrast.
Promote accessible authoring practices and use of approved templates.
Support remediation of legacy or high-impact content.
IT PMs and Product PMs
Coordinate accessibility testing schedules within project timelines and release plans.
Ensure accessibility defects are tracked in project backlogs and resolved before release or acceptance.
Support risk-based prioritization of accessibility defects.
Support review of ACRs and vendor-submitted accessibility documentation.
Provide testing findings to inform procurement decisions and acceptance of deliverables.
Identify gaps between vendor accessibility claims and actual product performance.
Support validation of contractual Section 508 requirements.
Vendors
Communicate accessibility defects clearly and consistently.
Confirm remediation expectations, timelines, and retesting procedures.
Validate vendor fixes before acceptance.
Encourage vendors to provide accurate, complete, and current accessibility documentation.
Sample Performance Metrics
Testing Coverage
Percentage of ICT products, releases, documents, or deliverables tested for Section 508 conformance.
Percentage of high-impact or high-risk ICT tested prior to release or acceptance.
Percentage of required test types completed, such as automated testing, manual testing, keyboard testing, screen reader testing, and document accessibility testing.
Testing Quality
Accuracy and completeness of Section 508 test reports.
Reduction in reopened defects due to incomplete testing or unclear findings.
Consistency of findings with approved testing methodology and agency standards.
Stakeholder satisfaction with clarity and usefulness of test results.
Defect Identification and Remediation
Number and severity of accessibility defects identified during testing.
Percentage of accessibility defects resolved within established timelines.
Average time to remediate critical or high-severity accessibility defects.
Percentage of remediated defects successfully validated on first retest.
Reduction in repeat accessibility defects across releases or teams.
Lifecycle Integration
Percentage of projects with accessibility testing integrated into SDLC, Agile, or release workflows.
Number of accessibility defects identified before final delivery or production release.
Reduction in late-stage accessibility defects.
Frequency of accessibility testing performed during iterative development cycles.
Procurement and Documentation Support
Percentage of ACRs or vendor test reports reviewed within established timelines.
Number of procurement or acceptance decisions supported by accessibility testing findings.
Accuracy of comparisons between vendor accessibility claims and tested product conformance.
Reporting and Program Support
Timeliness of testing status reports, defect summaries, and remediation updates.
Use of testing metrics to identify trends, recurring issues, and training needs.
Contribution of testing data to Section 508 program reporting and continuous improvement.
Training and Knowledge Sharing
Number of training sessions, demonstrations, job aids, or testing guidance materials supported or delivered.
Improvement in team understanding of accessibility defects and remediation techniques.
Reduction in common accessibility errors following tester guidance or training.
RACI Matrix for Section 508 Tester Roles and Responsibilities
Scroll the table to view additional rows and columns.
Table 12: RACI matrix of overlapping Section 508 responsibilities (Tester)
Activity
Section 508 Tester
Section 508 Program Manager
Section 508 SME
CO/COR
Content Manager/Creator
Developers
IT PM/Product PM
UX/Design
Vendors
Develop accessibility test plans
R
C
C
I
C
C
R
C
I
Conduct Section 508 conformance testing
R
C
C
I
C
C
I
C
C
Perform manual accessibility testing
R
I
C
I
C
C
I
C
C
Use automated accessibility testing tools
R
I
C
I
C
C
I
I
C
Test electronic documents and multimedia
R
C
C
I
R
I
I
I
C
Document accessibility defects
R
C
C
I
C
I
C
I
C
Assign severity and remediation recommendations
R
C
C
I
C
C
C
C
C
Track accessibility defects through remediation
R
C
C
C
C
R
R
C
R
Validate remediation and retest fixes
R
C
C
I
C
R
C
C
R
Review ACRs and vendor test reports
R
C
R
R
I
I
C
I
C
Support procurement and acceptance decisions
C
C
R
R
I
I
C
I
C
Report testing metrics and trends
R
A
C
I
I
I
C
I
I
Support accessibility training and knowledge sharing
Manages the Section 508 Program on behalf of the agency CIO or designee, including developing and maintaining agency policies, guidebooks, and disseminating best practices.
Supports the agency’s efforts to create an accessible and inclusive ICT environment for all employees and members of the public with disabilities.
Coordinates and collaborates with other staff responsible for Rehabilitation Act compliance, including the provision of reasonable accommodations.
Provides consultation to, or participates in, agency capital planning, business case development, and IT governance to ensure ICT activities appropriately integrate Section 508 compliance across the IT and acquisition lifecycles.
Assesses and seeks to address the needs of the public and employees with disabilities with regard to ICT accessibility.
Manages and coordinates:
Assistance to acquisition officials and developers in procuring or building accessible ICT.
Evaluation of web content, software, and hardware for Section 508 conformance.
Section 508 training.
Creation and review of electronic documents for Section 508 conformance.
Provision of alternative formats.
Best Practices
Provides Section 508 guidance to agency programs and project teams for buying, building, maintaining, and using technology products and services.
Leads compliance management activities for digital services and technology covered under Section 508, including:
Addressing compliance requirements in design, acquisition, development, and maintenance lifecycles and processes.
Ensuring conformance claims are validated.
Develops policy, supports budget formulation, and addresses issues associated with digital accessibility with agency subcomponents, if applicable.
Promotes Section 508 awareness through training and outreach activities and advocates use of shared resources.
Leads technical discussions, meetings, conferences, demonstrations, and negotiations to improve accessibility of agency IT products and solutions.
Collaborates with internal and external stakeholders to promote accessibility and with customers or business partners.
Analyzes and re-engineers business processes to improve efficacy and efficiency.
Provides consultation and advice on development and implementation of digital accessibility plans, including development of remediation plans, risk analyses, and review of contractor accessibility provisions.
Provides support for Section 508 testing and for remediating accessible electronic content, such as documents and forms, to conform to the Section 508 standards.
Oversees the requirements planning, procurement, design, modification, integration, testing, and deployment of accessible ICT.
Tests ICT, such as large or complex web applications or electronic content, for Section 508 requirements and accessibility using a regimented test methodology that includes automated web scanning and testing, manual code inspection, and user testing with assistive technology, and delivers design recommendations to improve the accessibility of ICT.
Coordinates the collection of data to complete the annual Section 508 Assessment.
Develops and implements agencywide policy that ensures Section 508 compliance and outlines validation measures that can be tracked and processed.
Reviews and approves ICT products and services for conformance to the Section 508 standards.
Reviews technology solicitations for proper inclusion of Section 508 requirements.
Serves as a Section 508 subject matter expert (SME) for technical evaluation of solicitations.
Explains technical and functional accessibility concepts to technical and nontechnical personnel verbally, in written communications, and through briefings and formal presentations.
Encourages professional development and recognition of accessibility professionals across the agency.
Sample Text to Include in a Position Description
Serves as the agency Section 508 Program Manager, managing the Section 508 Program on behalf of the agency Chief Information Officer or designee. Develops and maintains agency Section 508 policies, procedures, guidebooks, standards, and best practices to support compliance with Section 508 of the Rehabilitation Act and related accessibility requirements.
Through oversight of ICT accessibility programs, ensures effective planning, management, validation, and continuous improvement of the accessibility of information and communication technology systems, digital services, electronic content, and related products used by employees and members of the public.
Provides expert guidance to program offices, acquisition officials, project teams, developers, designers, testers, content creators, and agency leadership on integrating Section 508 requirements into acquisition, design, development, testing, deployment, maintenance, and governance activities.
Coordinates agency-wide Section 508 training, testing, reporting, remediation planning, risk management, and annual assessment activities. Reviews accessibility documentation, supports validation of conformance claims, and advises on acceptance, remediation, and risk mitigation for ICT products and services.
Collaborates with reasonable accommodation staff, accessibility professionals, enterprise architects, IT governance bodies, customer experience teams, public affairs, and other stakeholders to promote an accessible ICT environment for individuals with disabilities.
Strategies For Engagement & Alliance Building
CIO and Agency Leadership
Align the Section 508 Program with agency mission priorities, IT governance, customer experience, and digital service objectives.
Provide regular briefings on program status, risks, resource needs, compliance trends, and annual assessment outcomes.
Frame accessibility as a core requirement for mission delivery, public access, workforce inclusion, and risk management.
Secure leadership support for policy enforcement, staffing, training, and remediation priorities.
Deputy Section 508 Program Manager
Delegate operational responsibilities for program execution, coordination, metrics tracking, and stakeholder engagement.
Align on priorities, escalation paths, staffing needs, and resource allocation.
Coordinate policy implementation, training delivery, testing oversight, and remediation tracking.
Ensure continuity of program operations and consistent communication across agency components.
Section 508 SMEs
Rely on SMEs for technical and policy interpretation of complex accessibility requirements.
Co-develop guidance, job aids, testing approaches, risk models, and training materials.
Ensure consistent application of Section 508 Standards across acquisitions, development efforts, content, and testing.
Use SME expertise to resolve complex or high-risk accessibility questions.
Acquisition Officials
Ensure Section 508 requirements are included early in acquisition planning, market research, solicitations, contracts, task orders, and acceptance criteria.
Support review of ACRs, vendor claims, and accessibility test reports.
Promote consistent contract language, deliverable expectations, and validation practices.
Help acquisition teams identify and mitigate accessibility risks before award and prior to acceptance.
IT Governance, Enterprise Architecture, and Capital Planning Teams
Embed Section 508 checkpoints into IT governance, architecture review boards, investment reviews, and capital planning processes.
Ensure accessibility is considered in technology roadmaps, enterprise standards, reference architectures, and system design decisions.
Identify accessibility risks early in the lifecycle and require mitigation plans for high-impact systems.
Promote accessible platforms, tools, templates, and reusable patterns across the enterprise.
IT PMs, Product Managers, Developers, and UX Teams
Ensure Section 508 requirements are incorporated into user stories, acceptance criteria, product roadmaps, release planning, and development workflows.
Promote iterative accessibility testing throughout the software development lifecycle (SDLC) or Agile process, rather than only at final delivery.
Support remediation planning and prioritization for accessibility defects.
Encourage teams to build accessibility into design and development practices from the outset.
Testers
Coordinate approved testing methodologies, tools, reporting formats, and severity definitions.
Use testing results to identify trends, recurring defects, and training needs.
Ensure defects are tracked, remediated, and validated prior to release or acceptance.
Support consistent testing practices across products, platforms, and content types.
Content Managers, Content Creators, and Communications Teams
Establish accessible content standards, templates, workflows, and review processes.
Promote accessible authoring practices for documents, web content, multimedia, presentations, social media, and internal communications.
Ensure accessibility is included in publishing workflows and communications planning.
Prioritize remediation of high-impact, high-visibility, or frequently accessed content.
Customer Experience and Reasonable Accommodation Staff
Coordinate to identify barriers experienced by individuals with disabilities.
Use customer feedback, accommodation trends, usability findings, and service data to improve ICT accessibility.
Ensure accessibility improvements reduce the need for individual workarounds where systemic fixes are possible.
Program Offices and Business Owners
Clarify shared responsibility for Section 508 implementation within programs and services.
Support integration of accessibility into program planning, service delivery, budgeting, and performance management.
Help program offices understand accessibility risks, obligations, and remediation priorities.
Encourage ownership of accessibility outcomes beyond the Section 508 Program office.
Sample Performance Metrics
Program Governance and Compliance
Percentage of agency ICT projects with Section 508 requirements integrated into planning, acquisition, development, testing, and sustainment activities.
Percentage of applicable ICT reviewed or validated for Section 508 conformance prior to release, deployment, or acceptance.
Percentage of agency components or business units implementing approved Section 508 policies, procedures, and workflows.
Evidence that Section 508 requirements are incorporated into IT governance, acquisition governance, and capital planning processes.
Annual Assessment and Reporting
Timeliness and completeness of annual Section 508 Assessment data collection and submission.
Accuracy and quality of data submitted for agency-wide Section 508 reporting.
Year-over-year improvement in annual Section 508 Assessment results.
Use of assessment findings to identify trends, gaps, corrective actions, and resource needs.
Acquisition and Procurement Integration
Percentage of ICT solicitations reviewed for Section 508 requirements prior to award.
Percentage of ICT procurements that include appropriate accessibility requirements, deliverables, and acceptance criteria.
Percentage of vendor ACRs or accessibility documentation reviewed and validated, as appropriate.
Reduction in accessibility issues identified after contract award or product acceptance.
Testing and Validation
Percentage of high-impact ICT tested using approved Section 508 testing methodologies.
Percentage of accessibility defects remediated within established timelines.
Average time to resolve critical or high-severity accessibility defects.
Reduction in recurring accessibility defects across systems, content, or vendors.
Percentage of conformance claims validated prior to acceptance or deployment.
Policy, Process, and Maturity
Number of Section 508 policies, procedures, guidebooks, templates, or job aids developed or updated.
Evidence that agency accessibility processes are consistently applied across ICT lifecycles.
Improvement in accessibility maturity across agency components or programs.
Reduction in inconsistent or conflicting accessibility decisions across teams.
Training, Outreach, and Workforce Development
Percentage of targeted staff completing required or recommended Section 508 training.
Number of role-based training sessions, workshops, briefings, or office hours delivered.
Improvement in staff accessibility competency based on assessments, feedback, or reduced defect trends.
Increased participation in accessibility communities of practice or knowledge-sharing activities.
Remediation and Risk Management
Number of accessibility risks identified, documented, and mitigated.
Percentage of remediation plans completed within established timelines.
Reduction in unresolved high-risk accessibility issues.
Evidence that accessibility risks are included in project risk registers, governance reviews, or leadership briefings.
Stakeholder Engagement and Support
Stakeholder satisfaction with Section 508 Program guidance, consultation, and support.
Number of cross-functional initiatives completed to improve ICT accessibility.
Frequency of coordination with acquisition, IT, UX, content, communications, CX, and reasonable accommodation teams.
Evidence that customer or employee feedback from individuals with disabilities informs program priorities.
User Impact
Reduction in accessibility-related complaints or reported barriers.
Improved usability feedback from individuals with disabilities.
Reduction in repeat accessibility issues affecting public-facing or employee-facing ICT.
Evidence that accessibility improvements increase equitable access to agency information, services, or systems.
RACI Matrix for Section 508 PM Roles and Responsibilities
Scroll the table to view additional rows and columns.
Maintain guidebooks, templates, and best practices
A
C
C
R
C
C
R
C
C
Integrate Section 508 into IT governance
A
I
I
R
C
R
C
I
C
Integrate Section 508 into acquisition planning
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Review solicitations for Section 508 requirements
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Review ACRs and vendor claims
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Coordinate Section 508 testing strategy
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Conduct Section 508 testing
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Validate conformance claims
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Track accessibility defects and remediation
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Escalate high-risk accessibility issues
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Coordinate Section 508 training and outreach
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Support accessible document and content processes
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Coordinate alternative format support
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Coordinate with reasonable accommodation staff
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Collect annual Section 508 Assessment data
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Report program metrics to leadership
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Promote continuous improvement and maturity
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Key Section 508-related Responsibilities
Best Practices
Provides expert guidance on the interpretation and application of Section 508 standards across ICT, including software, web, documents, and multimedia.
Interprets and applies Section 508 and related accessibility laws, regulations, and standards across a broad range of organizational activities, including procurement, development, maintenance, and use of ICT.
Provides expertise to support the development and implementation of policies, processes, and programs that enable agency compliance with accessibility laws and regulations.
Advises program offices, acquisition teams, developers, designers, and content creators on how to implement accessibility requirements effectively.
Tests complex or high-risk ICT for accessibility using manual and automated testing tools and recommends solutions to meet compliance requirements.
Assists in evaluating Accessibility Conformance Reports (ACRs) and test reports for accuracy, completeness, and risk, particularly for complex or enterprise-level procurements.
Collaborates with the Section 508 program manager and other stakeholders to ensure consistent application of accessibility standards and guidance across the agency.
Provides technical assistance and troubleshooting for accessibility barriers identified during procurement, development, testing, or production.
Supports ICT accessibility testing efforts by clarifying requirements, interpreting results, and recommending remediation approaches.
Supports the measurement of Section 508 program effectiveness by helping define performance metrics and monitoring outcomes.
Contributes to accessibility training, job aids, and knowledge-sharing initiatives across the agency.
Monitors updates to accessibility standards, guidance, and best practices, and communicates impacts to stakeholders and helps facilitate the integration of these updates into agency processes and policies as appropriate.
Promotes the integration of accessibility into enterprise architecture, design systems, and development practices.
Supports the development and implementation of plans, policies, program procedures, standards, infrastructures, and architectures that enable Section 508 compliance.
Selects appropriate Section 508 automated testing tools, configuring and integrating them into the test environment and with reporting and monitoring tools.
Sample Text to Include in a Position Description
Serves as a Section 508 subject matter expert, providing technical and policy expertise to ensure agency compliance with accessibility requirements under Section 508 of the Rehabilitation Act.
Interprets and applies accessibility standards across a wide range of agency activities, including acquisition, development, and content creation.
Advises stakeholders across the organization on the implementation of accessibility requirements and supports the development of policies, processes, and guidance to enable consistent compliance.
Evaluates accessibility documentation such as Accessibility Conformance Reports, provides recommendations to mitigate accessibility risks, and assists in resolving complex accessibility issues.
Collaborates with the Section 508 program manager to promote consistent application of standards and supports the development of performance metrics to assess program effectiveness.
Strategies For Engagement & Alliance Building
Section 508 Program Manager
Serve as a strategic advisor on:
Policy interpretation.
Program consistency.
Co-develop guidance and metrics.
Acquisition, including CAO, CO, and COR
Support:
Requirements development.
Market research.
ACR, vendor claims, and test report evaluation.
Reduce accessibility risk early in procurement.
Developers and IT Teams
Provide:
Practical implementation guidance.
Troubleshooting for complex issues.
Help translate standards into code-level solutions.
UX, Design, and Product Teams
Interpret standards into:
Usable interaction patterns.
Design guidance.
Bridge Section 508 compliance and usability.
Testers
Clarify:
Ambiguous requirements.
Edge cases and expected behavior.
Help interpret test results and prioritize fixes.
Content and Communications
Provide guidance on:
Complex document structures.
Multimedia accessibility.
Promote consistent content practices.
Sample Performance Metrics
Advisory Effectiveness
Stakeholder satisfaction with ICT accessibility guidance.
Reduction in repeated or escalated accessibility issues.
Risk Reduction
Early identification of ICT accessibility risks in acquisitions and projects.
Reduction in late-stage ICT accessibility defects.
Consistency and Standardization
Adoption of standardized interpretations and guidance.
Reduction in conflicting accessibility decisions across teams.
Metrics and Program Support
Contribution to defining ICT accessibility performance metrics.
Evidence of improved program outcomes based on SME guidance.
Knowledge Sharing
Number of training, guidance documents, or job aids developed.
Number of individuals trained within the organization.
Increased ICT accessibility competency across stakeholder groups.
RACI Matrix for Section 508 SME Roles and Responsibilities
Scroll the table to view additional rows and columns.
Interpret Section 508 and other accessibility standards
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Advise on implementation approaches
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Evaluate ACRs and test reports
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Support policy and guidance development
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Troubleshoot complex issues
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Support testing interpretation
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Define ICT accessibility metrics
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Report program metrics
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Provide training and knowledge sharing
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Promote enterprise consistency
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Key Section 508-related Responsibilities
Best Practices
Designs user interfaces and experiences for ICT that conform to Section 508 Standards and support usability for individuals with disabilities.
Applies accessible design principles, including color contrast, typography, layout, spacing, and visual hierarchy.
Ensures designs support keyboard navigation, logical focus order, and clear interaction patterns.
Creates and maintains accessible design components, patterns, and style guides that align with agency design systems.
Specifies accessibility requirements within design artifacts, such as wireframes, mockups, prototypes, and annotations, including form labels, error handling, and interaction behaviors.
Collaborates with developers to ensure design intent is implemented accurately and accessibly.
Works with the Section 508 program manager and SMEs to interpret ICT accessibility requirements and incorporate them into design solutions.
Participates in usability and accessibility testing, including testing with assistive technologies and users with disabilities, as appropriate.
Identifies and resolves potential accessibility barriers during the design phase.
Ensures consistency of accessible design patterns across products, platforms, and services.
Supports the remediation of accessibility issues by updating design solutions and guidance.
Promotes inclusive design practices that go beyond compliance to improve overall user experience.
Sample Text to Include in a Position Description
Ensures that all designs comply with accessibility requirements under Section 508 of the Rehabilitation Act and support usability for individuals with disabilities.
Applies accessible design principles to layouts, interactions, and visual elements, and incorporates accessibility requirements into design artifacts and specifications.
Collaborates with developers, product managers, and the Section 508 program manager to ensure accessibility is integrated into the design and development lifecycle.
Participates in usability and accessibility testing and contributes to the development of accessible design systems and patterns.
Strategies For Engagement & Alliance Building
IT Product Manager or IT PM
Align on:
User needs, including users with disabilities.
Accessibility acceptance criteria.
Ensure accessibility is built into product requirements.
Developers
Provide:
Clear, annotated designs.
Interaction specifications.
Validate that implemented UI matches accessible design intent.
Section 508 SME and Section 508 Program Manager
Collaborate on:
Interpreting standards into design decisions.
Resolving complex or ambiguous requirements.
Ensure consistency across teams.
Testers
Partner on:
Identifying design-driven accessibility issues.
Validating usability and interaction patterns.
Content Managers and Creators
Ensure:
Design supports accessible content structure.
Templates enable proper heading, reading order, and media use.
Sample Performance Metrics
Design Accessibility Quality
Percentage of design artifacts that incorporate ICT accessibility requirements.
Reduction in accessibility defects traced to design decisions.
Prevention of Defects
Decrease in rework due to accessibility issues identified during development or testing.
Early identification of accessibility risks during the design phase.
Consistency and Standards
Adoption of accessible design components and patterns.
Contribution to and use of design systems.
Collaboration Effectiveness
Developer and tester feedback on clarity and usability of design specifications.
Reduced misalignment between design and implementation.
User Experience Outcomes
Improved usability for individuals with disabilities.
Reduction in accessibility-related user complaints tied to design.
