On January 24th, 2013 the Obama Administration published a memorandum from the Office of Management and Budget (OMB) containing the Strategic Plan for Improving Management of Section 508 of the Rehabilitation Act. The plan provides overall guidance from the Office of Management and Budget directing Federal government agencies to speed the implementation of the Section 508 requirements. The memo largely focuses on two areas of policy: (i) technology development through CIO offices and (ii) procurement through agency acquisitions.
The OMB memo identifies the following key issues that impede the full implementation of the Section 508 requirements:
- The standards are not fully understood, and there is a lack of operational awareness of how to implement the standards;
- There is no specific set of measures for defining what a successful Section 508 program looks like;
- The workforce of Federal government agencies – notably in the acquisition and information technology lifecycles – are not consistently trained to address the specific Section 508 requirements.
This leads to a situation where the implementation of Section 508 across agencies is inconsistent. This is in line with the results of the 2012 DoJ Section 508 report, which indicated huge gaps between a few leading agencies with well-developed accessibility programs and the majority of agencies, which have few to no Section 508 programs. Recognizing this, the plan seeks to provide a comprehensive, government-wide approach to develop and maintain an accessible Federal government IT infrastructure. The plan’s focus is principally on the management practices and approaches necessary to drive the operational solutions for the issues noted above. In turn, the plan focuses on three key areas: increasing transparency, strengthening accountability and improving collaboration.
The transparency section of the plan references some of the current inter-government work that has been completed by the Accessibility Committee of the Federal Chief Information Officers (CIO) Council. Notably, the Committee has provided a series of accessibility best practice posts including three notable posts that provide recommendations on how to develop Internet accessibility policy, agency-wide Section 508 policy and ensure accessibility issues are considered when developing agency IT directives.
Outside of referencing this information, the plan provides for two directives:
- That the General Services Administration (GSA) develop and share with OMB an action plan for “transforming www.section508.gov into the one-stop source of information and communication for successfully managing Section 508 implementation throughout the acquisition lifecycle.” Basically, updating and expanding the current site to focus on acquisition support.
- That all Federal agencies include accessibility statements on all websites. There are a variety of requirements for a good accessibility statement, but the memo focuses on three minimum items: (i) contact information for the Section 508 program, (ii) date of the last update for the statement and (iii) providing a method for site users to provide comments and feedback on the agency’s Section 508 program.
The strengthening accountability section is principally focused on providing clearly defined roles, responsibilities, processes and assessments of the Section 508 activities of an agency. To address that, the memo includes the following five action areas:
- Each agency CIO must send the name of the Section 508 coordinator for the agency to the GSA by March 25th, 2013. Thereafter, if the Section 508 coordinator changes, the agency must notify the GSA within 90 days.
- By March 1, 2013, the CIO Council will develop a standard template for reporting key compliance measures for Section 508. This will include measurements of agency website compliance and agency procurement processes.
- By June 29th, 2013 – or 120 days after the template above is developed – agency CIOs and CAOs will develop a plan for completing an agency baseline assessment of the Section 508 program.
- By December 30, 2013, agencies will complete their assessment and share the information with the CIO Council Accessibility Committee.
- Starting between April 1 and June 30th 2014 – Q3 of fiscal 2014 – agencies will share progress with OMB on improving baseline assessment measures with OMB.
The improving collaboration section of the strategic plan focuses on providing a framework of improving government-wide Section 508 activities and resources. It principally focuses on activities that GSA must take to help implement the Section 508 program and activities. These include:
- By June 30th, 2013, update the Reference Manual for Section 508 Coordinators.
- By June 30th, 2013, share with the CIOC and CAOC plans for updating and extending the Buy Accessible Wizard.
- By October 1, 2013, provide updated Section 508 courses for acquisition personnel.
- As the Section 508 Refresh occurs, coordinate with the Access Board to roll out the standard updates to Section 508 Coordinators and members of the acquisition workforce.