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Policy & Management
Section 508 Program Team Roles and Responsibilities
Section 508 program managers (PM) collaborate with various teams committed to and responsible for ensuring their important role in their agency’s overall Section 508 compliance efforts. To achieve success, a Section 508 Program Office must be integrated throughout the entire agency. The Section 508 Program Office should function as a support service, assisting various groups, teams, and divisions within the agency in meeting their digital accessibility goals and obligations. Each of these groups have their own responsibilities for implementing Section 508 policy in the organization. The goal of this document is to outline the scope of each of these functions and to provide guidance on what collaboration might look like between your Section 508 Program Office and stakeholders across IT, procurement, acquisition, human capital, contracting, and customer experience.
As you consider how the Section 508 Program Office is integrated into your organization, note that the landscape for Section 508 Program stakeholders differs whether you’re part of a Chief Financial Officers (CFO) Act agency, a component or subcomponent of a CFO Act agency, or a small independent agency. These differences may show up in the amount of staffing resources or funding available that can be applied to the implementation of Section 508 policy.
Whether you’re working as a solo Section 508 PM, additional duties as assigned, or as part of a Section 508 Program team, the Section 508 program should serve as a resource, offering advisory support and oversight to cross-functional stakeholders with respect to digital accessibility considerations. The Section 508 PM coordinates with domain experts across the agency to promote information and communication technology (ICT) compliance and conformance. Whether you are a Section 508 PM or part-time Section 508 PM, this document can:
Assist you in the hiring process to build out your Section 508 program.
Help you identify the core functions required when establishing or maturing a Section 508 PM role at your agency.
Envision what collaboration might look like between the Section 508 program and key stakeholders across the organization.
Identify which services you might want to offer to agency stakeholders looking for assistance in their Section 508 compliance and conformance activities.
Section 508 Team Functions, Roles and Responsibilities
The table below outlines the essential functions for implementing Section 508 accessibility program goals, including the roles and responsibilities of stakeholders with whom Section 508 PMs collaborate, as per OMB guidance (M-24-08). Section 508 PMs should focus on promoting a sense of ownership and independence amongst the functional experts throughout their agency. By having experts serve as advisors or on an advisory group, the Section 508 program enables them to develop and refine their Section 508 skills and competencies within their domain.
Some of these stakeholder may not exist in smaller agencies or subcomponents. In such cases, if a Section 508 PM is preparing a budget justification for additional staff, they can use the functional responsibilities listed below as a guide for drafting future position descriptions or identifying staffing needs and skill requirements for their Section 508 program.
Team Function
Stakeholders
Section 508 Program Manager Support Tasks
Acquisition and Procurement
Chief Acquisition Officer (CAO)
Agency senior procurement executives
Purchase card holders
IT Program Managers (ITPMs)
Requiring Officials
Contracting Officer’s Representatives
Give guidance on requirements gathering in accordance with Section 508 requirements.
Provide consultation to agency capital planning and business case development to ensure ICT activities appropriately integrate Section 508 compliance across the acquisition lifecycle.
Provide guidance on how to perform technical review of requirements, solicitations, and specification documents.
Provide guidance on the test procedures and protocols to assess product accessibility and evaluate the ability of products to meet Section 508 standards and specifications.
Assist internal staff in testing and filling out Accessibility Conformance Reports (ACRs) and help make determinations on compliance of the associated ICT with applicable Section 508 standards as needed.
Information Technology (IT)
Agency Chief Information Officer (CIO)
IT Program and Project Managers
Product Managers
Software Developers and Testers
Test Automation Engineering Teams
Serve as the key liaison for the CIO, represent the CIO at federal meetings, conferences, and training sessions on Section 508; and participate in governmentwide forums to raise awareness of accessibility issues and programs.
Assist with identifying appropriate testing methodologies and developing formally approved test processes (e.g., hardware, kiosks, software, mobile).
Conduct Section 508 conformance testing and produce detailed test reports.
Assist with identifying the source of failures in code, defect severity, and with remediation planning.
Assist teams in identifying appropriate automated test tools, setting up automated test scripts, configuring tools, and determining manual testing needs to maximize resources and expedite testing.
Provide technical expertise to configure reports from automated tools and incorporate them into pipeline reporting tools.
Guide teams through authorization processes for network approval of tool installation.
Assist teams in determining if automated accessibility testing tools will help them meet their goals.
Assist with conducting test planning.
Human Capital
Agency Chief Human Capital Officer (CHCO)
Agency Equal Employment Opportunity (EEO) Officer
Identify ICT accessibility training needs of agency and provide training solutions.
Promote Section 508 awareness through training and outreach activities.
Advise on inclusion of ICT accessibility core values in EEO compliance and mission-related strategic planning.
Give guidance on how to include Section 508 compliance in leadership and management performance plans.
Contracting
Contracting Officers
Contracting Officer’s Representatives
Requiring Officials
IT Project Managers
Ensure every aspect of procurement considers accessibility standards and meets Section 508 and Federal Acquisition Regulations (FAR) requirements.
Determine if Section 508 requirements have been met for contract deliverables via an audit of provided test results.
Provide recommendations on when to accept or reject deliverables.
Obtain and interpret Section 508 conformance information (e.g., ACRs) from vendors and contractors.
Obtain and interpret accessibility capability statements from potential contractors.
Customer Experience (CX) and Design
Customer and User Experience Executives
IT Program Managers
Product Managers
User Experience Researchers
Front-End Developers
Information Architects
Service Designers
Advise on how an accessible design is a good design.
Explain how people with disabilities interact with ICT.
Help project teams create an enjoyable customer experience for all users through good UX design.
Help implement universal design in usability and UI design activities.
Actively participate in design reviews.
Assist in creating accessible design patterns and an accessible design system.
Assist with development of content that is usable and accessible across devices.
Involve people with disabilities in design reviews to obtain better user-centered design input.
Building a Well-Coordinated Section 508 Program Team
Section 508 PMs should be targeted in their efforts to socialize the importance of all domain experts involved in Section 508 compliance and conformance. There are a variety of benefits to establishing a cadence of continual collaboration, connection, communication, and interdependence amongst Section 508 stakeholders and experts across acquisition, human capital, IT, CX, and contracting.
Section 508 Program Management Collaboration with Acquisition, Procurement and Contracting Functions
Benefits:
Equips acquisition teams with the knowledge and skills to address Section 508 requirements.
Integrate critical development practices, like accessibility testing, earlier in the acquisition lifecycle. Lowers risk of persons with disabilities being unable to use ICT.
Avoids post-release costs to remediate inaccessible technology after purchase.
Improves oversight of contract deliverables prior to acceptance.
Potential Outcomes:
Relationships with acquisition teams.
Expertise with procurement and Section 508 knowledge.
Relationships with project teams.
More accessible ICT.
Section 508 Program Management Collaboration with IT Functions
Benefits:
Increases knowledge of testing methodologies throughout the organization.
Increases ability to spot accessibility errors during development.
Reduces likelihood for accessibility issues to be first identified at the end of the life cycle.
Increases accessibility knowledge and capabilities of the development community.
Potential Outcomes:
Relationships with project teams.
Project's use of an automated test environment that supports Section 508 testing rulesets.
Service provider knowledge of:
Agile and DevOps process
Trusted Tester
Industry-standard automated testing frameworks
Automated testing tools and rulesets
Development expertise
Keeping abreast of changing technology and ability to assess impact to rule set configuration, etc.
Availability of testing experts, with experience in testing various types of technology, who can perform a full range of ICT testing.
A defined test process for each type of ICT that will be tested.
Improved accessibility of the organization's ICT portfolio.
Section 508 Program Management Collaboration with CX, UX, and Design Functions
Benefits:
Enables design requirements to be addressed earlier in the design process.
Lowers risk of developers not being able to develop systems that are accessible due to inaccessible designs or templates.
Avoids later costs to remediate inaccessible technology after development.
Potential Outcomes:
Service provider knowledge of accessible design processes and research methods that support Universal Design (UD) and User Experience Design (UX), Universal Design for Learning (UDL), and principles of Human Computer Interaction (HCI).
Access to lab environments to support user research and testing with users who have disabilities.
Improved accessibility of the organization's ICT portfolio.
