Play 10 describes how to test and validate Section 508 conformance. Testing will produce a list of issues that need to be tracked, prioritized, and resolved over the long term. End users may also report technology accessibility issues that need to be assessed, tracked, prioritized, and resolved. Regardless of the source of the problem, the resolution may pose a cost to the agency. If the issue is non-conformance with Section 508, the agency has to guard against perpetuating the error in future upgrades and procurements.
o How does your agency identify and track technology accessibility issues from initial report through resolution?
o What process do you use to categorize, prioritize, troubleshoot, and identify root causes of accessibility issues?
o Do you have a well-defined policy to handle Section 508 complaints that supports the Department of Justice’s Model Section 508 Complaint Policy?
o Develop a process to track and monitor accessibility:
- For internal projects and software development, assess your bug tracking system for suitability in tracking accessibility issues.
- Assess your current Help Desk suitability for tracking and resolving accessibility issues reported by end-users.
- Train Help Desk staff to recognize accessibility issues and alert the Section 508 Team.
o Develop a process to assess and troubleshoot the issue:
- Is the problem caused by the technology product, third party components used by the product, the operating environment the product is deployed in, the assistive technology used to access the product, or some other source?
- Is the problem caused by a lack of training or communications?
- Is the problem caused by a usability issue?
- Is the problem caused by non-compliance with the Section 508 standards?
o Develop a process to categorize accessibility issues. For example:
- Issues resulting from legal complaints/actions: These items require formal, careful, expedited handling by the 508 Program Team, the IT department, general counsel, and possibly external Federal entities (DOJ, GSA, etc.).
- Technical compliance issues identified through testing or informal user reports: These items need to be addressed through risk mitigation processes.
- Deployment issues resulting from how, where and when IT services and technology are provided.
o Develop a process to prioritize issues. For example:
- Critical issues may prevent an end user from accessing or using the technology.
- Major issues may make it extremely difficult, but not impossible, for an end user to ensure access or use the technology.
- Minor issues do not materially affect the use of the product, but may represent a technical defect.
o Develop an escalation process to address the need for correction action based on risk and impact on end users.
o Develop a process to evaluate, select, and track corrective action plans.
o Develop and implement a process for managing 508 complaints.
- Utilize guidance provided by the Department of Justice to develop an agency Section 508 Complaint Policy based on your agency’s 504 Complaint Policy.
- Ensure easy means are in place for persons with disabilities to comment on accessibility without filing a formal complaint.
- Review the current agency Section 504 complaint policy and procedures. Note, accommodations may be appropriate even when ICT meets the 508 accessibility requirements.
o Establish a help desk dedicated to addressing accessibility issues, staffed by individuals specially trained to troubleshoot accessibility issues.
o Develop a reporting capability to aggregate and analyze accessibility issues.
o Assure Section 508 complaint data is used to identify areas of improvement in the agency’s use of technology, as well as its application of the agency Section 508 Policy.