The DDOE is committed to ensuring that its Electronic Information Technology (EIT) meets Section 508 standards. EIT, sometimes referred to as E&IT, is information technology (IT), as defined at FAR 2.101, and any equipment or interconnected system or subsystem of equipment that is used in the creation, conversion, or duplication of data or information. In addition to IT, EIT includes:
- World Wide Web sites;
- Multimedia (including videotapes); and office equipment, such as copiers and fax machines.
- telecommunication products, such as telephones;
- information kiosks;
- transaction machines;
Section 508 refers to a statutory section in the Rehabilitation Act of 1973 (refer to 29 U.S.C. 794d). Congress significantly strengthened Section 508 in the Workforce Investment Act of 1998. Its primary purpose is to provide access to and use of Federal executive agencies’ electronic and information technology (EIT) by individuals with disabilities. The statutory language of Section 508 can be found at section508.gov.
Section 508 requirements are separate from, but complementary to, requirements in Sections 501 and 504 of the Rehabilitation Act that require, among other things, that agencies provide reasonable accommodations for employees with disabilities, provide program access to members of the public with disabilities, and take other actions necessary to prevent discrimination on the basis of disability in their programs.
Section 508 requires that when DDOE is developing, procuring, maintaining, or using electronic and information technology, DDOE will take into account the needs of all end users – including people with disabilities. Doing so enhances the ability for employees with disabilities to have access to and use of information and data that is comparable to that provided to others. Similarly, DDOE procurement of accessible EIT enhances the ability of members of the public with disabilities who are seeking information or services from the DDOE to have access to and use of information and data that is comparable to that provided to others. Comparable access is not required if it would impose an “undue burden” on the DDOE. If the DDOE invokes the undue burden exception, the statute requires the information and data to be provided to individuals with disabilities by an alternative means of access.
The goal of Section 508 is that EIT be compatible with assistive technology. In some cases, the standards require that the acquired EIT be readily usable without the need for assistive devices. Also, multimedia presentations that require captioning and descriptive video must have these features built into the product, as it is impractical to expect end users to add on their own captions or descriptions. However, for most products — such as software, web pages, and computers — achieving compatibility with assistive technology is the goal of the standards.
The requirements of Section 508 apply to an agency’s procurement of EIT, as well as to the agency’s development, maintenance, or use of EIT irrespective of the origin of the EIT (in-house development or commercially acquired). If an EIT item is maintained or developed by both contractor and DDOE employees, it is still covered by Section 508 standards. See A.3 with respect to type of work Section 508 covers. Unless an exception applies, if the product is a deliverable under a contract it must conform to the applicable standards regardless of the mix of labor used to produce it.
The DDOE is responsible for complying with Section 508 as a whole and making nonavailability and exception determinations when needed. As such, the DDOE has implemented policies and procedures to ensure any new websites, applications, and procurements meet Section 508 standards. Additionally, the DDOE is working to remedy accessibility issues found in historical content with a focus on the Department of Education website.
As of January, 2017, Section 508 has been updated to include the WCAG 2.0 standards. To meet the DOE’s Section 508 requirements for EIT, products and services must satisfy level A and level AA of WCAG 2.0. Vendors, bidders, and suppliers are strongly encouraged to provide or create a Voluntary Product Accessibility Template (VPAT).
Information about WCAG 2.0 is available at the W3C website. Information about the VPAT is available from ITI website.