Section 508 Compliance for Contracting Officer’s Technical Representatives and Program & Project Managers - PowerPoint PPT Presentation

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Section 508 Compliance for Contracting Officer’s Technical Representatives and Program & Project Managers. Topics. Section 508 …………………...…….......................... 3 Roles and Responsibilities ..………………………… 7 How to comply with Section 508

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Section 508 Compliance for Contracting Officer’s Technical Representatives and Program & Project Managers

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Section 508 Compliance forContracting Officer’s Technical Representatives and Program & Project Managers

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Section 508 …………………...…….......................... 3

Roles and Responsibilities ..………………………… 7

  • How to comply with Section 508

    Section 508 Acquisition Process …………………… 21

    DHS Systems Engineering Life Cycle Alignment …. 31

  • Section 508 EIT Accessibility Plan

    Where To Go for Help …….…………………………... 64

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Section 508 of the Rehabilitation Act

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Section 508 is a Law

  • Section 508 of the Rehabilitation Act of 1973 as amended 1998

    • Ensures people with disabilities have access to and use of Electronic and Information Technology (EIT), including:

      • Electronic data, Information, and Support services

    • Encoded in CFR 36:1194 and added to the Federal Acquisition Regulations at Section 39.2

      • The U.S. Access Board developed accessibility standards

    • Applies to:

      • Federal agencies in support of employees and members of the public with disabilities

      • All DHS EIT contracts and contract actions

  • Enforceable as of June 21, 2001

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The Purpose

  • Section 508 is intended to provide equal access and use of information for people with disabilities and eliminate barriers to employment

  • DHS is obligated to:

    • Require compliance with applicable Section 508 Technical Standards

    • Perform Market Research and Section 508 Analysis of Alternatives

    • Procure the most compliant products and services that meet the program business need!

    • Document compliance

  • DHS is not obligated to:

    • Procure anything that DOES NOT meet the business need

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Key Term: Section 508 Compliant

Section 508 compliance requires both a legal and atechnicalapproach to compliance

Legal compliance (required by FAR 39.2) includes documenting:

  • Market research

  • WhichSection 508 technical standards apply

  • Any applicable Section 508 (legal) exceptions

  • Which standards cannot be met, if any

  • Including the documentation in the contract file

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Technical Compliance

Technical compliance includes:

  • Documenting howthe product meets the technical standards that apply

  • Ensuring that all custom development meets the applicable Section 508 technical standards

  • Planning for Section 508 compliance in project requirements, design, integration, testing, and acceptance criteria before release

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StakeholderRoles & Responsibilities

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  • OAST

  • Component Section 508 Coordinator

  • Contracting Officers Technical Representative (COTR)

  • Requiring officials

  • Project or Program Managers who manage the work on behalf of the customer:

    • the person with the business requirement

    • the program owner

  • Section 508 Subject Matter Experts

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Section 508 Program OfficeRoles & Responsibilities

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Office of Accessible Systems & Technology (OAST)

  • OAST leads the department-wide implementation of Section 508

    • Provides strategic direction, technical support, and training to ensure DHS employees and customers with disabilities have equal access to information and data

  • Office of the Chief Information Officer (OCIO)

  • Office for Civil Rights & Civil Liberties (CRCL)

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OAST Program Management

  • Sets Section 508 policy for all of DHS

  • Provides DHS governance to ensure Section 508 compliance is part of decision-making activities

  • Evaluates and reports on DHS compliance with Section 508

  • Offers guidance and technical assistance to DHS personnel on reasonable accommodations

  • Develops and delivers training

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OAST Program Management

  • Reviews all acquisitions over 2.5 million

  • Authorizes all requests for:

    • National Security Exception

    • Undue Burden Exception

  • Provides the DHS Accessibility Requirements Tool (DART)



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OAST Program Management

  • Mans the DHS accessibility help desk providing subject matter experts who are available to help you with all aspects of Section 508 compliance, including procurement review, application and document testing, standards and exception analysis, and general information and training.

  • Evaluates and reportson DHS compliance with Section 508

  • Is available for technical assistance to DHS Components when acquiring EIT

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Component Section 508 Coordinator

  • Authorize component requests for:

    • Back Office Exception

    • Fundamental Alteration Exception

    • Incidental to Contract Exceptions

  • Are required to review component IT acquisitions with dollar value less than $2.5 million

  • Provide Section 508 technical assistance

  • Participate in IT governance activities regarding Section 508 compliance.

  • Report component Section 508 implementation status

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Contracting Officer’s Technical Representative Roles & Responsibilities

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Contracting Officer’s Technical Representative

Has to ensure proper contractual and project activities occur for three areas:

  • Acquisition Support Responsibilities

  • Project Management Responsibilities

  • Ensuring proper documentation

    • From Requiring Official

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Acquisition Support Role

Acquisition Support Section 508 Activities:

  • Ensure Section 508 standards and exceptions are identified and included in Contractual language

    • Purchase Requests


    • PRISM

    • FirstSource Appendix G

    • EAGLE Task Orders Appendix H

  • Ensure Section 508 exceptions , if any, are requested and authorized

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COTR Project Management Role

  • Ensure DHS SELC Alignment & Project Life-cycle Support

    • Confirm Acceptance Testing

    • Confirm Remediation Plan, if needed

    • Confirm required artifacts (documentation) per the Section 508 EIT Accessibility Plan (CPPM Training)

  • Ensure that Requiring Officials provide documentation

    • Description of Market Research performed

    • If compliant product is not available show which Section 508 standards are not met

    •  Basis for exception decision

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Requiring Official and Project Manager Roles & Responsibilities

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Requiring Official Role

Requiring Official Section 508 Role:

  • Define functional requirements for their business needs.

  • Identify applicable Section 508 technical standards and exceptions

  • Obtain authorization for exceptions or seek advice when needed (DHS Forms #4103, 4105, 4107, 4108, 4109)

  • Perform market research for items that best meet business needs (DHS Form #4106)

    • Identify the most compliant that meet business needs

  • Draft contract Section 508 language using DART

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Program or Project Manager

  • Knowledge of DHS SELC Alignment and Project Life Cycle Support activities ensures:

    • Identification of Section 508 technical standards or exceptions

    • Authorization for exceptionsis obtained

    • Market research is performed

      • The most compliant product that meet business needs is chosen (DHS Form #4106)

    • Section 508 issues are resolved or a remediation plan is approved.

  • Communication, Communication, Communication

    • Talk to the right people

    • Get the right people talking to each other

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    Section 508 Subject Matter Expert

    • Advise on lifecycle requirements

    • Test EIT products for Section 508 compliance

    • Recommend technical development solutions

    • Review market research/alternative analyses

    • Train key personnel

    • Explain Section 508 governance activities

      Request SME assistance at

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    Section 508 Acquisition Process

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    Acquisition Process: Need, Analyze, Obtain, Deploy

    • Clearly define your Business Need

    • Product or service must meet the Business Need

      • If the product or service does not do what you need it to do then what good is it?

      • If a product is Section 508 compliant but doesn’t meet the Business Need, you do not have to buy it.

    • Collect and analyze relevant market information

    • Identify possible sources for the acquisition

    • Perform effective market analysis and industry knowledge

    • Select and document the most 508 compliant product that meets business needs!

      • DHS FORM # 4106

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    Market Research Form

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    • Compliance requires market research

      • Custom, commercial, or free

      • Section 508 compliance requires documenting analysis of alternatives

      • Summarizes additional documentation required

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    Most Compliant

    • If no fully-compliant product is available, the agency must procure the most compliant product that meets the business needs

    • Commercial products that do NOT fully meet Section 508 Technical Standards require market research documentation

      • DHS 4106 - Most Compliant Product - Market Research Form

    • Most compliant product

      • No COTS product exists that meetsALLthe applicable 508 technical requirements OR

      • Fully compliant products cannot be furnished in time to satisfy the agency’s delivery requirements

    • With most compliant product the vendor must be given a list of defects and asked for a remediation plan

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    Voluntary Product Accessibility Template (VPAT)

    • Provided by EIT Product Vendor to Show 508 Compliance

    • Assists Federal contracting officials and other buyers in making preliminary assessments regarding the availability of commercial Electronic and Information Technology products and services with features that support accessibility.

    • It is assumed and recommended that offerers will provide additional contact information to facilitate more detailed inquiries.

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    Voluntary Product Accessibility Template (VPAT)

    Bluebeam PDF Revu version 6.5.4

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    Other Sources


      • OAST Section 508 Test results

    • Test the product

      • Ask the vendor for a test version

      • Request Section 508 testing OR

      • Have your “Trusted Testers” do the testing

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    Section 508 Acquisition Language

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    DHS Accessibility Requirements Tool (DART)

    • Tool generates Section 508 language for acquisition SOW, PWS, RFP, RFQ and SOO

    • Provides summary of Section 508 requirements

    • Select applicable Section 508 exceptions and technical standards

    • Copy Section 508 language from tool

    • Paste into acquisition documentation

      DART is available under the DHSConnect, MGMT >> CIO >> OAST >> OAST Component Resources

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    Commercial Vendors

    • Perform based on standard procurement language:

      • For any COTS or GOTS procured EIT

        • Does this acquisition include a requirement for QA or IV&V testing?

      • Sample DART Tool Contract language

        • 36 CFR 1194.2(b) – (COTS/GOTS products), When procuring a product, each agency shall procure products which comply with the provisions in this part when such products are available in the commercial marketplace or when such products are developed in response to a Government solicitation.

      • Custom (developed in response) requires additional contract & lifecycle language

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    Standard Procurement Language

    Section 508 requirements are applicable to all Federal procurements including…

    • EAGLE – Task Orders

    • First Source – Appendix G

    • Information Technology Acquisition Review (ITAR) – Management Directive 0007.1

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    DHS SELC Alignment

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    • DHS Acquisition Instruction/Guidebook #102-01-001: Appendix B Version 2.0, Sep 2010

      • Ensuring that appropriate activities are planned and implemented in each stage of the life cycle to increase the project’s success

      • DHS Connect > Organization > Components > Management (MGMT) > Chief Information Officer (CIO) > Offices > Enterprise Business Management Office (EBMO) > Systems Engineering Life Cycle

      • Search for “SELC”

    • Section 508 compliance relies on common life cycle documents and activities!


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    Section 508 EIT Accessibility Plan

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    Building Accessibility in is Cost Effective

    • Planning saves money!

    • It is expensive to retrofit software to meet accessibility standards

    • The cost of revision is estimated to be

      - 1.5 to 6 times greater during development than during the design phase

      - 60 to100 times greater after release

      [Pressman, 2005]

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    Several steps to the project, it all begins with an idea and more planning

    Stage 1: Solution Engineering & Planning

    Stage 2: Requirements Definition

    Stage 3: Design & Development

    Stage 4: Integration & Test

    Stage 5: Implementation & Operations

    Project managers and developers might relate to this as a classic waterfall development approach, but it is iterative and can be adapted to rapid application development or other methods

    Section 508 EIT Accessibility Plan

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    Exiting Solutions Engineering and Planning

    There are 2 ways to fulfill the requirements for this section:

    • Have a documented and authorized exception

    • Complete the preliminary work for requirements definition

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    Before Planning Begins

    • National Security Exception Request and Authorization Form (DHS Form 4105)

      • Usually known during planning if the project will involve National Security

      • Recognized Section 508 exception

      • Section 508 compliance includes clearly documenting any exceptions

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    What are you engineering?

    What are you planning to buy?

    What are you planning to build?

    How will you select the best products?

    What is the business need?

    Solution Engineering & Planning

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    • Considerations

      • Identify Section 508 Exceptions that might apply

        • Section 508 Exceptions Worksheet

      • Identify the applicable Section 508 Technical Standards

        • Section 508 Applicable Standards Worksheet

      • Select the most compliant product available

        • DHS Form 4106: Most Compliant Product Market Research Formand supporting documents

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    Exceptions Worksheet

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    • Assists in

    • Identifying possible exceptions

    • Asking the right questions

  • Legal Section 508 compliance requires clearly documenting any exceptions

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    • Requires Section 508 Coordinator approval

    • EIT acquired by a contractor incidental to a contract

    • Back Office (Maintenance only) Equipment

    • Fundamental Alteration

  • Requires OAST Director approval

    • National Security Systems

    • Undue Burden

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    Exceptions Worksheet Screenshot

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    Applicable Standards Worksheet

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    • Used as a documentation template

      • Reminder to include Section 508 in other generic project documentation

      • Possibly unused until later in the life cycle

      • Copy and paste into your requirements documents

      • Do not edit or modify standards

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    Functional Performance Criteria

    • Requires at least one mode of operation and information retrievalforEIT that can be used by persons with the following impairments:

      • § 1194.31(a & b)Vision (blind and low vision),

      • § 1194.31(c & d) Hearing (Deaf and hard of hearing),

      • § 1194.31(e) Speech & Communication OR

      • § 1194.31(f) Fine Motor Control

    • Remember § 1194.31 Functional Performance Criteria

      • Always apply

      • Are met by complying with the Section 508 technical standards

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    Subpart B – Technical Standards

    • Your role includes identifying EIT as categorized by the technical standards:

      • § 1194.21 Software applications and operating systems

        (Windows, Microsoft Word / Excel)

      • § 1194.22 Web-based information and applications

        (Web pages, linked documents, forms, Internet and intranet applications)

      • § 1194.23 Telecommunications

        (telephones, voicemail systems)

      • § 1194.24 Video and multimedia

        (broadcasts, videotapes, webcasts)

      • § 1194.25 Self contained, closed products

        (copiers, plotters, fax machines, kiosks)

      • § 1194.26 Desktop and portable computers

        (laptops, desktops, PDAs)

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    Applicable Standards Screenshot

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    Market Research Form

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    • Compliance requires market research

      • Custom, commercial, or free

      • Section 508 compliance requires documenting analysis of alternatives

      • Summarizes additional documentation required

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    Initial planning complete, now at requirements definition

    Stage 1: Solution Engineering & Planning - done

    Stage 2: Requirements Definition

    Project managers typically

    Complete their initial research

    Finish clarifying requirements with stakeholders

    Have a desired approach

    Have selected the desired technologies

    Requirements Definition

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    Exiting Requirements Definition

    To fulfill the Section 508 requirements of this section you need to:

    • Review and, if needed, update the preliminary work you have done for requirements definition.

    • Copy and paste the identified applicable Section 508 standards from the Applicable Standards Worksheet into the project’s requirements documents.

    • Complete market research for procurements.

    • Ensure Section 508 compliance is required in contracts.

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    Updated Section 508 EIT Accessibility Plan

    Request any Section 508 Exceptions

    Identify the applicable Section 508 Technical Standards

    Project’s Requirements Documents

    Include Section 508 Functional Performance Criteria

    Include Section 508 Technical Standards

    Requirements Traceability Matrix

    Market Research for Most Compliant Products

    Requirements Definition

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    Section 508 Contractual Requirements

    • DHS Accessibility Requirements Tool (DART)

      • Provides required Section 508 contract language

      • Copy and paste into contract “AS IS”

      • Do not modify or simplify. This is legal language!

      • Link on the OAST website under “OAST Component Resources”


    • Information Technology Acquisition Review (ITAR)

    • OAST Assistance Available


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    DART Screenshot

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    requirements defined, now at design and development

    Stage 2: Requirements Definition - done

    Stage 3: Design & Development

    All developed or customized EIT must be fully Section 508 compliant

    Documents, Plans, Schedules & Rework includes Section 508

    Technology plan might have changed during development

    Development bug fixes, defect tracking, testing

    Code to the Standards

    Standards-based approach is best practice

    Design & Development

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    Exiting Design & Development

    To fulfill the Section 508 requirements of this section you need to:

    • Ensure the Systems Acceptance Test Plan show Section 508 requirements and how they will be tested

    • Have all human interfaces tested for Section 508

    • Have all training and user documentation tested for Section 508

    • Remediate Section 508 issues as identified

    • If you do not have a defect tracking system, you can use the sample Section 508 Remediation Plan for defect tracking

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    Systems Engineering Life Cycle

    • Developed or Customized IT must be fully compliant

      • If it doesn’t meet criteria for an exception, must be compliant

      • Section 508 has technical requirements that must be included with each new version release

      • Ongoing development testing includes scheduling and fixing defects before release

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    Project Plan Timelines

    • Project Plans must include Section 508

      • Include:

        • Time for evaluation

        • Section 508 in customer acceptance tests

        • Section 508 EIT Accessibility Plan items in planning milestones

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    Ongoing Daily Development

    • Planned Integration and Software Development Life Cycle

      • Remediation plan

        • Tracks defects

        • Verifies development team notified of defects

        • Supports development teams that do not have external bug tracking systems for stakeholders

        • Dates are key information

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    About Testing

    • Test using OAST approved testing methodologies

    • Ensure electronic documentation and electronic trainings, including webinars, meet Section 508 requirements

    • Code to the Standards

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    • Code to the standards

      • Benefits include flexibility, future-proofing, and technology best practices

      • Do not code to specific Assistive Technologies (AT) e.g., JAWS Screen Reader

      • Develop and code using standard APIs

    • Just because it works with JAWS does not mean it is Section 508 compliant

      • It may not work with other assistive technologies

    • If AT does not work with EIT that is coded to the standards; the deficit is in the AT

      Code to the Standards!

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    Development almost done, time to test

    Stage 3: Design & Development - done

    Stage 4: Integration & Test

    The purpose of the Integration and Test Stage is to demonstrate that the solution developed satisfies all defined requirements (DHS SELC)

    Short area on plan, but key milestone for any development

    Section 508 testing and remediation should be completed before Integration

    Transitioning to operations and support

    Integration & Test

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    Support for End-Users

    • Transition to Support Document

      • Notifies Help Desk of special configurations

      • Notifies Operations of special permissions or deployment issues

      • Includes communications to agency and staff

        To satisfy the requirements of the Integration and Test stage, you need to ensure that user help, administrator instructions and the help desk are aware of any custom configurations or workarounds needed until the vendor remediates the defects.

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    All aboard! Train is leaving! Project goes live

    Stage 1: Solution Engineering & Planning

    Stage 2: Requirements Definition

    Stage 3: Design & Development

    Stage 4: Integration & Test

    Stage 5: Implementation & Operations

    Section 508 Remediation Planning

    New design and development might still introduce new technologies

    Implementation & Operations

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    Exiting Implementation and O&M

    To fulfill the Section 508 requirements of this section you need to:

    • Have a plan to handle Section 508 defects reported by users.

    • Ensure the help desk knows what to do if an issue is reported by user of assistive technology.

    • Ensure the help desk has TTY capabilities for deaf users. (1194.41c)

    • Use a Section 508 Remediation Plan to track and remediate issues that arise after deployment.

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    Proactively Solving Issues

    Section 508 Remediation Plan

    • Tracks “defects”

    • Verifies development team is notified of defects

    • Is used to proactively ask vendors for compliant solutions

    • Must have timelines!

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    Sample Remediation Plan

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    Plan in Plain English

    • Last page of the 508 plan.

    • List of what needs to be done.

    • Helpful for non-technical customers.

    • Links to plan stages

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    Plan for Section 508

    • Project Managers must have a Section 508 EIT Accessibility Plan that:

      • Meets DHS SELC requirements and ensures Section 508 compliance

      • Includes plan information and documentation that must be submitted in order to comply with Section 508 for each phase in a project’s EIT Life Cycle

      • Identifies points of contact (POC) and assignment of responsibility to specific individuals, as needed

    • A separate plan and set of artifacts is needed for each individual EIT project or distinct technology

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    Identify your Section 508 Subject Matter Expert (SME)

    Document market research

    Buy the “Most Accessible” product that meets your business needs


    Test using OAST testing process

    Plan Early

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    Where To Go For Help

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    Help is Available

    Component Section 508 Coordinator

    • Current List on OAST Website

    • DHSConnect / Organization / Components / Management /

      / Chief Information Office / Offices / Office of Accessible Systems

    • Or search DHSConnect for “OAST”

      DHS Accessibility Help Desk

    • 202-447-0440 (voice)

    • 202-447-5857 (TTY)

    • or

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