1 Section 508 Cookbook How to Create a Section 508 Program From Scratch

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Transcript of 1 Section 508 Cookbook How to Create a Section 508 Program From Scratch

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1 Section 508 Cookbook How to Create a Section 508 Program From Scratch Slide 2 2 Section 508 Cookbook Recipes for Creating a Section 508 Program Slide 3 3 Ingredients Agency Support Discuss with upper management their: Expectations of a program and goals Level of support they will provide Concept of your role and responsibilities Resources ($$ and personnel) Tip: Know what they will really do versus what they say they will do Slide 4 4 Ingredients 508 Coordinator Characteristics of a Coordinator Has authority base (either grade or management support) to be able to make decisions, take action, and enforce process and policy Understand the organizations policies and constraints (e.g., funds) Have admin or program management skills. Tech support should be available as needed Slide 5 5 Ingredients 508 Coordinator Characteristics of a Coordinator Solution/customer oriented. Strive for win-win situations. Working relationship with: Office of General Counsel (OGC) Office of Procurement Office of CIO Believes in Section 504 and 508 Understands/involved with Section 504 Slide 6 6 Ingredients 508 Coordinator Why understand and be involved with Section 508? Only way to truly understand 508 Grievance process for 508 should overlay 504 Many 508 issues overlay 504 (design to 508 and have 504 make it usable to employees) There are infinitely more legal action against 504 than 508 Slide 7 7 Ingredients 508 Coordinator Why understand and be involved with Section 508? 504 can result in $300K compensatory damages. While 508 may not be funded, 504 must be. Many 508 claimed programs are actually 504. Need to know the difference. Efforts with 504 helps resolve 508 employee problems before they become a grievance Slide 8 8 Ingredients Team Members Team member characteristics Good grasp of their areas processes, procedures and policies Can speak for their management If necessary, can make decisions Has experience or represents their area in either procurement, Section 504 and/or IT issues Slide 9 9 Ingredients Team Members Team members should represent Cost centers or major areas in agency OP OGC Area responsible for Electronic procurement Slide 10 10 Ingredients Team Members Team Members should represent Office of CIO Web services Software development Acquisition management Testing and evaluation Section 504 IT coordinator Slide 11 11 Mixing Current Process Flow chart each areas procurement/ development process from conception to implementation. Identify critical areas and problems Identify areas that are similar, unique, and/or can be changed Identify roles and responsibilities throughout the process Develop a standardized process that will work in each area. Slide 12 12 Mixing Current Process Develop standardized roles and responsibilities Determine how 508 compliance will be determined, monitored, and enforced. Determine checks-and-balances in process to ensure compliance. Get team buy-in Slide 13 13 Mixing - Proposed Process Tips: Keep as close to the current process as possible Have process flexible so areas can personalize for unique requirement Each team member should have vested interest in process (e.g., make them local 508 coordinators) Slide 14 14 Mixing - Proposed Process Based the proposed process on: Awareness. Responsibility. Enforcement. Slide 15 15 Mixing - Proposed Process Awareness Inform employees, contractors, and vendors of the program Concentrate on individuals who have a role/ responsibility in the program Create an easily accessible intranet site that outlines the process and includes the standards and checklists Slide 16 16 Mixing - Proposed Process Awareness Intranet site should include: Outlines the process Includes standards as written in law Includes plain English version of standards Standards written as questions so they can be used to determine status of compliance Includes supporting docs (e.g., checklist) Slide 17 17 Mixing - Proposed Process Responsibilities USPTO checklist for Procurements Slide 18 18 Mixing - Proposed Process Slide 19 19 Mixing - Proposed Process Responsibilities Lessons-learned on Procurement Checklist Only 508 coordinator approves exceptions Keeps coordinator in the loop on problems Reinforce who coordinator is Precludes abuse of exceptions Slide 20 20 Mixing - Proposed Process Responsibilities Lessons-learned 508 only initials checklist Two types of maintenance Updates of form for lessons learned Sole source Previously Emphasize that buyer is legally responsible Slide 21 21 Mixing - Proposed Process Responsibilities Lessons-learned Have buyer sign and certify 508 compliance Project Manager: _____________________ Date:_____ Signature required to certify accuracy and completeness of checklist and Section 508 compliance Slide 22 22 Mixing - Proposed Process Responsibilities Tips Importance of having buyer sign document Some has assumed in writing responsibility for compliance Most people unwilling to break law after they certified Strong argument for people willing to ignore law Slide 23 23 Mixing - Proposed Process Responsibilities Lessons learned on Market Research/Vendor Checklist Use of and how have proven very effective Vendors can not compete for contract until they have completed the checklist and are proven to be compliant. Even sole source procurements require checklist. Completed checklist is official part of procurement process Slide 24 24 Mixing - Proposed Process Enforcement Products can not be accepted without signed checklist Vendors not considered w/o checklist SW can not be deployed w/508 deficiencies Contractors resolve deficiencies at their own expense Non-compliant web pages pulled from Inter/intranet Slide 25 25 Mixing - Proposed Process Finalizing Process Draft documents, checklists and instructions for processing products Have team members review Develop plan and schedule to implement process Slide 26 26 Mixing - Proposed Process Finalizing Process Have the plan and process reviewed and approved by: Management OP OGC Other appropriate areas (e.g., OCR, OCIO) Slide 27 27 Mixing - Proposed Process Finalizing Process Implement process Develop training packages for employees, contractors and vendors Schedule training and implementation date Slide 28 28 Mixing - Proposed Process Finalizing Process Promote process Team members promote in their areas Use agency-wide announcement system Trainand train againand again Promote positive points of program Ensure 508 is part of budget, development, procurement, deployment and web discussions Slide 29 29 Mixing General Tips Establish an accessibility tool (AT) baseline Allows for more effective and efficient use and maintenance of AT Less AT interface problems Creates more standardized and easier to implement accommodations Simplifies accessibility with each new AT revision Simplifies training requirements and documentation Slide 30 30 Mixing General Tips Know the law: Only way you can develop legal solutions to problems. Be part of the solution and not the problem with 508 issues. You are your agencys expert and incorrect info can have major impact on people and money When confronted when unique exemptions, make sure you totally understand requirement Questions on interpretation, call fellow coordinators, working group or Access Board Slide 31 31 Mixing General Tips Exceptions and Disclaimers Establish well-defined standards for exemptions and disclaimers. Avoid exceptions to the standards Define back office. Often challenged Very limited use of disclaimers. Easily overused and abused. Monitor web sites and training modules for disclaimers Slide 32 32 Mixing General Tips Team Members Ensure each everyone feels like they have contributed to the process Have all team members buy-in Make them part of process and give them responsibilities Officially recognize them for their role Slide 33 33 Baking Product Procurement Certification: Individual buying the product signs checklist to certify that the product is compliant Responsibilities. Person buying the product: Performs all 508 requirements (e.g., market survey, vendor checklist) Completes the checklist and certifies compliance Obtains the EIT Coordinators initials on the checklist Slide 34 34 Baking Product Procurement Process. Person buying the product: Determines functional requirements Conducts market survey on vendors who meets functional requirements Has vendors who meet functional requirements complete 508 standards checklist Determines which vendor meets the most 508 standards Slide 35 35 Baking Product Procurement Process. Person buying the product: Completes 508 Procurement checklist and include appropriate documentation (e.g., sole source justification, vendor checklists, market survey results, requisitions) Has EIT Coordinator review and initial checklist. Initials show that the checklist has been reviewed, but does not mean that Coordinator is responsibility for compliance. Submit package to OP Slide 36 36 Baking Product Procurement Checks and Balances EIT Coordinator will not initial checklist unless it has been completed and appropriate documentation is attached. EIT Coordinator is only person authorized to approve exceptions/exemptions OP will only process IT purchase request with a completed checklist. If they do not, OP assumes responsibility for ensuring 508 compliance Slide 37 37 Baking Product Procurement Checks and Balances Products that run on the USPTO enterprise architecture must be successfully tested for compatibility and 508 compliance by a testing office in the OCIO. Products that fail are returned to the vendor. Slide 38 38 Baking Product Procurement Lessons-learned Much opposition from employees until they understood the process. Emphasize functional requirements drive procurement, not accessibility Prove to management and employees that you are part of the solution, not the problem. Buyer signing/certify compliance is very effective Only had to threatened to s