IT Accessibility Policy Framework - Introduction

Intended Audience

The Information Technology (IT) Accessibility Policy Framework is intended for use by federal agency leadership, Section 508 Program Managers (PMs), and other federal agency employees who wish to include Section 508 language in policies relevant to their respective workplaces.¹

Background

The General Services Administration (GSA) Office of Government-wide Policy (OGP) Government-wide IT Accessibility Program supports federal agencies to meet Section 508 requirements through its guidance and resources on accessible Information and Communications Technology (ICT).² To lay the foundation for the IT Accessibility Policy Framework, the Government-wide IT Accessibility Program Team interpreted existing agency policies through the lens of ICT accessibility, combining policy analysis with its understanding of Section 508 requirements. The team emphasized a holistic approach to Section 508 policy: Section 508 requirements should be incorporated throughout agencies’ policy directives and not be relegated to a single Section 508 policy, where the requirements would be insufficiently addressed. The resulting policy review, which evaluated the need of specific agency policies to be updated with ICT accessibility language, sets the stage for the IT Accessibility Policy Framework, a generalizable framework to help agencies remediate their policy directives. The policy review and ensuing IT Accessibility Policy Framework thus align with the team’s mandate to provide technical assistance to agencies in meeting Section 508 requirements.

Purpose

As evidenced by the agency-wide policy analysis conducted by the GSA OGP Government-wide IT Accessibility Program, many internal agency policies require updates to meet Section 508 requirements.³ However, agencies currently lack a standard framework to comprehensively identify and update their policies accordingly. Without such a holistic system, they are likely to have a patchwork of policies with wide variation in how and to what extent they address ICT accessibility. Furthermore, agencies are likely to engage in these activities independently from one another, increasing labor costs associated with Section 508 compliance, increasing legal risks associated with not meeting the Section 508 standards, and ultimately hindering equitable digital access.

The IT Accessibility Policy Framework provides agencies with guidance on how to holistically assess their internal policies against criteria, and how to remediate them to integrate ICT accessibility language. The framework also establishes standard review criteria and policy categories in order to harmonize the disparate policy evaluation methods across the federal government.

¹Section 508 of the Rehabilitation Act of 1973, 29 U.S.C.§ 794d (1998).
²ICT Standards and Guidelines, 36 C.F.R. § 1194 (2017).
³ICT Standards and Guidelines, 36 C.F.R. § 1194 (2017).

Scope

The IT Accessibility Policy Framework offers agencies a generalized, standard approach to analyzing and revising their respective policies to include ICT accessibility information. Version 1.0 of the framework provided recommendations on the substance of ICT accessibility language for different policy types. Version 1.1 aims to build on those recommendations to present standard language on ICT accessibility that agencies can lift and incorporate into their policies.

Structure

• How to Use the IT Accessibility Policy Framework: Describes policy categories recommended and not recommended for review, ICT accessibility policies that should be in place, criteria for policy evaluation, and how to map and prioritize policies according to need.
• Guidance by Policy Type: Describes likely omissions of ICT accessibility language in policies, provides recommendations on the sufficiency of ICT accessibility language across different policy types, and presents recommended language that agencies can incorporate into their policies to improve sufficiency.
• Resources and References: Catalogs relevant and non-relevant policy types and subtypes considered in the framework; provides the Policy Review Template, a generic spreadsheet template that can facilitate internal agency policy review and analysis; and includes a summary of the evaluation criteria.