Agencies need clear governance and strong leadership to guide Section 508 programs, which establishes the importance of accessibility, improves compliance, and minimizes legal exposure. An agency’s IT Accessibility/508 program’s success also depends on the involvement of many other key players.
The tables below list the roles and responsibilities for agency officials, content creators and other stakeholders.
| Role |
Responsibilities |
| Agency Chief Acquisition Officer (CAO) |
- Responsible for agency performance of acquisition activities and acquisition programs, including the development of the agency’s acquisition workforce.
- Ensures Section 508 requirements are incorporated into any ICT that is procured by the agency, in collaboration with the agency Chief Information Officer (CIO).
|
| Agency Chief Diversity and Inclusion Officer |
- Coordinates efforts to promote diversity, equity, inclusion, and accessibility within the agency.
|
| Agency Chief Information Officer (CIO) |
- Establishes the agency-wide Section 508 program, provides leadership of the program, ensures the program is adequately resourced, and appoints the agency Section 508 program manager.
- Ensures the Section 508 program manager has sufficient delegated authority, support, and resources.
- Ensures Section 508 accessibility considerations are incorporated into the planning, operation, and management of any ICT that is developed, used, or maintained by the agency.
- Ensures Section 508 requirements are incorporated into any ICT that is procured by the agency, in collaboration with agency CAO.
|
| Agency Chief Human Capital Officer (CHCO) |
- Develops training plans to identify who should receive training on digital accessibility and establishes training schedules for appropriate staff on Section 508 compliance, in consultation with the Section 508 program manager.
|
| Agency Equal Employment Opportunity Officer |
- Responsible for coordinating obligations to applicants or employees with disabilities in the Federal Government under Section 501 of the Rehabilitation Act of 1973, including the reasonable accommodation and complaint processing regulations in 29 C.F.R. Part 1614.
|
| Agency Senior Procurement Executive (SPE) |
- Responsible for management direction of the acquisition systems of an Executive branch agency, including the implementation of the unique acquisition policies, regulations, and standards of the agency.
|
| Agency Section 508 Program Manager |
- Manages Section 508 Program on behalf of the agency CIO (or designee), to include 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 and/or 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 regards to ICT accessibility.
- Manages and coordinates:
- Assistance to acquisition officials and developers in procuring or building accessible ICT;
- Evaluation of web content, software, and/or hardware for Section 508 conformance;
- Section 508 training;
- Creation and review of electronic documents for Section 508 conformance; and
- Provision of alternative formats.
|
| Contracting Officer |
- 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).
|
| Contracting Officer’s Representative (COR) and Requiring Officials |
- 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.
|
| Heads of Federal Agencies |
- Ensures that individuals involved in acquisition planning and requirements specify needs, develop plans, specifications, etc. that address ICT accessibility using standards issued in 36 CFR part 1194.
|
| Information Technology Program and Project Managers |
- 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.
|
| Product Managers |
- Ensures that ICT, such as websites and digital services, meets the needs of individuals with disabilities and conforms to Section 508 standards.
- Meets and collaborates regularly with the Section 508 program manager and other staff responsible for Rehabilitation Act compliance, including the provision of reasonable accommodations, to ensure ICT is accessible and usable.
|
| Purchase Card Holders |
- Confirms the accessibility of ICT prior to purchase.
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The following roles and responsibilities are defined in OMB memorandum, Strengthening Digital Accessibility and the Management of Section 508 of the Rehabilitation Act (M-24-08).
| Role |
Responsibilities |
| Access Board (USAB) |
- Develops and issues Section 508 accessibility standards.
- Provides technical assistance and trainings on Section 508 to Federal agencies.
- Supports the development of accessibility tools and best practices.
|
| CIO Council Accessibility Committee |
- Serves as the principal interagency forum to support and improve the implementation of Section 508.
|
| Department of Justice (DOJ) |
- Collaborates with the General Services Administration to collect and evaluate information from all Federal agencies to ascertain status of compliance with Section 508.
- Biennially prepares and submits to the President and Congress a report on and recommendations regarding the state of Federal agency compliance with Section 508 requirements, including the quantity and categorization of individual complaints that are collected and resolved.
|
| Department of Homeland Security (DHS) |
- Maintains and updates, as needed, the Trusted Tester Conformance Test Process.
- Manages the Section 508 Trusted Tester Program, which includes training and formal accessibility testing certification for the Trusted Tester Process.
|
| Federal Acquisition Regulatory (FAR) Council |
- Incorporates Access Board standards into the Federal Acquisition Regulation (FAR) as appropriate.
|
| General Services Administration (GSA) |
- Provides Section 508 technical assistance to Federal agencies, in collaboration with the Access Board.
- Maintains Section508.gov, in collaboration with the Access Board, as a central information resource for agencies on Section 508 management and implementation.
- Annually prepares and submits a comprehensive report, in consultation with OMB, to Congress on the accessibility of Federal ICT, by agency and government-wide, recommendations that agencies or Congress can take to improve compliance with Section 508, and GSA activities and plans to support and improve agency compliance.
- Leads the development and management of tools, such as the Accessibility Requirements Tool and the Solicitation Review Tool, for use in agency activities, including acquisition, IT, and Section 508 management functions.
- Continues incorporation of Section 508 conformance metrics or Accessibility Conformance Reports (ACR) into ICT related Governmentwide Acquisition Contracts (GWAC).
|
| Office of Inspector General (IG) |
- Provides independent oversight of agency Section 508 compliance, as needed.
|
| Office of Management and Budget (OMB) |
- Develops Government-wide policies on the management of information resources, including information technology.
- Assists agencies, including GSA, DOJ, and the Access Board, as they implement and ensure compliance with Section 508 standards.
|
Key Agency Stakeholders
The roles and responsibilities cited in this article were informed by federal regulations, policies and commonly accepted information technology industry roles and best practices listed in the Reference and Resources section.
| Role |
Responsibilities |
| Audio, Video and Multimedia Creators |
- Create and publish accessible audio, video and synchronized media content.
- In collaboration with website managers, ensure that media has playback controls, captioning, audio description, and text alternatives.
|
| Content Creators & Document Authors |
- Create and publish accessible content, documents, products and systems.
|
| Developers |
- Create and maintain software, websites and mobile applications that conform with Section 508 Standards.
|
| Enterprise architecture |
- Ensure the accessibility of the IT portfolio products and services that the agency procured, develops, uses and maintains.
|
- Ensure that individuals involved in acquisition planning and requirements generate specific needs, develop plans, specifications, etc., that address IT accessibility using standards issued in 36 CFR part 1194.
|
| Procedural, Training and Education Developer/Designer |
- Ensure Section 508 requirements and best-practices are integrated into electronic content, such as procedures, training materials, online training and learning management systems.
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| Quality Assurance Specialist/Tester |
- Evaluate agency ICT for conformance with Section 508 standards, and maintain record of findings.
|
| Scrum master |
- Ensure product backlog items are clearly defined and managed efficiently.
|
| Security engineering |
- Collaborate with project managers, Section 508 program managers, and enterprise architecture professionals to ensure agency IT portfolio products and authenticated and transactional services conform with Section 508 standards.
- Ensure that ICT products and services avoid introducing security risks associated with non-conformance.
|
| UI/UX and CE Designers |
- Ensure that user interfaces and experiences enable people with disabilities to access information equivalent to those without disabilities in accordance with Section 508 standards issued in 36 CFR part 1194.
|
| Website Managers/Content Managers |
- Ensure Section 508 accessibility considerations are incorporated into the planning, operation, monitoring, upgrading and management of any website that the agency procures, develops, uses, or maintains.
- Ensure that electronic content and media published and distributed on the agency's website conform with Section 508 standards.
- Ensure that publicly available websites conform with the U.S. Web Design System.
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| Agency Employees |
- Create and publish accessible content, products and systems.
- Create, publish, and collaborate using accessible techniques and best practices.
- Schedule and host meetings and other events using accessible materials and techniques to ensure people with disabilities have equivalent access to information.
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Reporting
The roles and responsibilities cited in this article were informed by federal regulations, policies and commonly accepted information technology industry roles and best practices listed in the Reference and Resources section.
| Role |
Responsibilities |
| Department of Justice (DOJ) |
- Biennially, conduct a survey of all Federal agencies to ascertain status of compliance with Section 508.
- Biennially, prepare and submit to the President and Congress a report on, and recommendations regarding, the state of Federal agency compliance with Section 508.
|
| Federal Agencies |
- Evaluate the extent to which the agency’s ICT are accessible to and usable by individuals with disabilities per the Instructions and criteria of the annual Government-wide Section 508 Assessment.
- Prepare and submit a report containing the evaluations to the GSA and OMB.
|
| General Services Administration (GSA) |
- Annually, conduct a survey of all Federal agencies to ascertain status of compliance with Section 508.
- Provide technical assistance to agencies regarding their annual assessments and data submissions.
- In coordination with OMB, prepare and submit to the Committees on Appropriations and Homeland Security and Governmental Affairs of the Senate and the Committees on Appropriations and Oversight and Reform of the House of Representatives a report on, and recommendations regarding, the state of Federal agency compliance with Section 508.
- Post agency submissions as an open Government data asset on a public website.
|
| Office of Management and Budget (OMB) |
- In coordination with GSA and USAB, disseminate amended or updated criteria, the metrics by which compliance will be assessed, and instructions to Federal departments or agencies for annual evaluation and reporting.
|
| U.S. Access Board (USAB) |
- Provide technical assistance to agencies regarding their annual assessments and data submissions.
|
References and Resources
Reviewed/Updated: December 2023
