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

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

Page 1: 1 Section 508 Cookbook How to Create a Section 508 Program From Scratch.

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Section 508 Cookbook

How to Create a Section 508 Program From

Scratch

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Section 508 Cookbook

Recipes for Creating a Section 508

Program

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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

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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 organization’s policies and constraints (e.g., funds)

• Have admin or program management skills. Tech support should be available as needed

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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

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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

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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

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Ingredients – Team Members

Team member characteristics• Good grasp of their area’s 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

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Ingredients – Team Members

Team members should represent• Cost centers or major areas in agency• OP• OGC• Area responsible for Electronic procurement

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Ingredients – Team Members

Team Members should represent Office of CIO• Web services• Software development• Acquisition management• Testing and evaluation• Section 504 IT coordinator

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Mixing – Current Process

• Flow chart each area’s 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.

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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

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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)

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Mixing - Proposed Process

Based the proposed process on:

Awareness.

Responsibility.

Enforcement.

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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

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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)

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Mixing - Proposed Process

Responsibilities

USPTO checklist for Procurements

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Mixing - Proposed Process

Requisitioner Requisition Number1

Program Office EIT Coordinator Review

Product Description

Check all appropriate

boxes

Exemptions to Section 508 Back-Office (Mostly includes data centers and comm closets type-equipment)

Fundamental Alteration (for example, cell phones, PDAs, pagers, hand-held devices)

Subparts and Categories for Section 508 ComplianceSubpart B - Technical categories of standards (procurement may include more than one)

Software applications and operating systems (36 CFR part 1194.21)

Web-based internet and intranet information and application (36 CFR part 1194.22)

Telecommunication products (36 CFR part 1194.23)

Video and multi-media products (36 CFR part 1194.24)

Self-contained, closed products (36 CFR part 1194.25

Desktop and portable computers (36 CFR part 1194.26)

Subpart C - Functional performance criteria (only when Subpart B does not apply)

Subpart D - Information, documentation, and support documentation requirements

Market Analysis for Section 508 Compliance

Initial appropriate

boxes

Products available, but they do not meet any of the appropriate standards

Product(s) compliant (i.e., previously approved as compliant or on desktop computer contract)

Limited product availability (one product meet more 508 standards than others) (attach analysis)

Only one product meets functional specifications (attach justification)

Requisitioner Date

Technical DateSignatures required to certify accuracy and completeness of the checklist and Section 508 compliance.

EIT Procurement Checklist

Note: For an EIT procurement to be awarded, it must have a completed and attached procurement and vendor checklist. This includes sole source procurements. Exempt products only require a procurement checklist.

for Section 508 Compliance

Service and maintenance agreements (only for technical-type support)

Pre-Award Action for EIT Procurements for information on completing this checklist, see Instructions or your EIT Coordinator

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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

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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

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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

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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

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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

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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

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Mixing - Proposed Process

Finalizing Process

• Draft documents, checklists and instructions for processing products

• Have team members review

• Develop plan and schedule to implement process

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Mixing - Proposed Process

Finalizing ProcessHave the plan and process reviewed and approved by:

• Management

• OP

• OGC• Other appropriate areas (e.g., OCR, OCIO)

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Mixing - Proposed Process

Finalizing ProcessImplement process

• Develop training packages for employees, contractors and vendors

• Schedule training and implementation date

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Mixing - Proposed Process

Finalizing ProcessPromote process• Team members promote in their areas• Use agency-wide announcement system• Train…and train again…and again• Promote positive points of program• Ensure 508 is part of budget, development,

procurement, deployment and web discussions

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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

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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 agency’s 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

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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

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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

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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 Coordinator’s initials on the

checklist

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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

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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

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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

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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.

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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 stop procurement one time on

vendor who would not complete checklist and the word got out to employees, OP and vendors.

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Baking –Product Procurement

Lessons-learned• Ensured that procurement requests were quickly

processed by the EIT Coordinator• Whenever there was a major issue or problem,

immediately scheduled meeting with OGC and buyer. Meetings sometimes lasted more than an hour, but always found solution.

• Spot check of FY2003 end-of-year IT procurements showed that every one was processed according to the Section 508 procedure

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Baking –Software Development

Certification: Project manager for creating new or revising existing software. Signs checklist in beginning to make the product compliant.

Responsibilities. Project Manager:

• Completes the checklist and certifies compliance• Ensure final product is compliant

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Baking –Software Development

Process:• Developer meets with EIT Coordinator,

determines appropriate 508 standards and completes checklist

• EIT Coordinator reviews and initials• EIT Coordinator is the only person authorized to

grant exemption

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Baking –Software Development

Process:• If there is a contractor involved, the USPTO uses

the following statement on the contract to ensure 508 compliance:

In accordance with Section 508, the USPTO requires that all IT products

delivered under this Contract comply with the applicable EIT

accessibility standards issued by the Architecture and Transportation

Barriers Compliance Board set forth at 36 CFR part 1194.

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Baking –Software Development

Process:

• Define functional requirements

• Determine which Section 508 standards are applicable

• Provide requirements to testing area (TA)

• TA generates testing methodology

• TA tests and passes or fails package

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Baking –Software Development

Checks and Balances• Technical Review Board ensures 508 is in Life

Cycle Management process. If not, development does not proceed

• System can not go into production until it has been successfully tested for 508 compliance. No exception for going into production and correcting deficiencies later

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Baking –Software Development

Checks and Balances

When a project manager challenges test results, the EIT coordinator independently test the product and makes final determination

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Baking –Software Development

Lessons-learned• Developers must have in depth knowledge of 508

standards• Software standards are mostly and simply good

coding practices• Always develop to the standards and not the

assistive technology (e.g., JAWS)• Need independent and periodic evaluation of 508

standards during the development cycle.

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Baking –Software Development

Lessons-learned

Testing Software• Current no SW testing tools• Use of screen reader can be effective eval tool

when used by experienced individual• JAWS and compliance• When testing, use two different tools

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Baking –Web Documents

Certification: Individual creating document to be posted

Responsibilities. Individual creating document:• Completes the checklist and certifies compliance• Obtains the Webmaster’s initials on the checklist.

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Baking –Web Documents

Process. Individual coding document:• Checks document to ensure it is compliance. If

there are questions, have the Accessibility Team evaluate document

• Completes Section 508 Web checklist • Has webmaster review and initial checklist • Submits document to webmaster for posting

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Baking –Web Documents

Checks and Balances• Webmaster will not initial checklist unless it has been

completed signed• Webmaster is only person authorized to approve

exceptions/exemptions• Webmaster will only post a web document that has a

completed checklist. If the webmaster doesn’t obtain a completed checklist, then the webmaster assumes responsibility for ensuring 508 compliance

• Noncompliant posted documents must be corrected in a specific time frame or they will be pulled off the web

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Baking –Web Documents

Lessons-learned• Most web authors do not understand Section 508. Must

have the webmaster as the focal point in the process and must hold them responsible.

• Prove to management and web authors that making a product compliant is not that difficult or time consuming. Best way to accomplish this is set a precedent by quickly correcting a web-site problem. Publicize the event as a win-win situation.

• Publicly recognize outstanding compliant web-sites. We made it a quarterly award that was posted so everyone in PTO could read about it.

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Baking –Web Documents

Lessons-learned• Web authors signing document to certify compliance is

not as effective as signature certification in other area.

• Most effective tool was to threaten a couple times to not post noncompliant documents or to pull noncompliant documents from the web.

• Most government agencies have more web-site requirements than just Section 508. All the requirements needs to be posted so web authors are aware of them and don’t just address Section 508.

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More General Tips

• The only way to determine compliance is by reading code

• Accessibility tools were not designed as test tools• Always use two different testing tools when

evaluating compliance• Most sighted people are not proficient enough in

JAWS to accurately evaluate compliance

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Baking – Credit Cards

Certification: Card holder who signs for the credit card purchase

Responsibilities. Credit card holder:• For purchases under $2500, completes the

checklist and certifies compliance• For purchases over $2500, completes the

checklist and ensures a completed Procurement checklist is attached. Card holder still signs the form, but 508 compliance is responsibility of buyer.

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Baking – Credit Cards

Background. • Management thought everyone was using the

same worksheet. In fact, everyone had modified it to fit their own needs.

• The worksheet was outdated and time consuming to complete.

• Created standardized worksheet that was quicker to complete and had space for individual modifications

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Baking – Credit Cards

Background. Credit card purchases in the PTO fell into one of three areas:• PC, printers, scanner could only be purchased from an

agency-wide, 508 compliant contract• Many IT items were exempt (e.g., PDAs) or not IT (e.g.,

paper, office supplies, travel, conference fees)• All other IT items had to be tested before they could be

used on the enterprise architecture. If it wasn’t 508 compliant, it had to be returned to the vendor.

This made it easy for the credit card holder to certify compliance

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Baking – Credit Cards

Process. Credit card holder:• Reviewed the purchase request and ensured 508

documentation was attached for purchases over $2500

• Completed and signed the worksheet.• Processed the request once the Approving

Official signed the form• All paperwork was retained for end of month

reconciliation with OP and Office of Finance

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Baking – Credit Cards

Checks and Balances • If the card holder did not require the buyer to

include 508 documentation for purchases over $2500, then the credit card holder was responsible for compliance

• The Approving Official reviewed the worksheet for justification and documentation before signing and authorizing the purchase

• OP and Office of Finance reviewed monthly all credit card transactions

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Baking – Credit Cards

Lessons Learned • With the proper training, not one of the 140+

credit card holders objected to the process• It is difficult to enforce compliance to the

process. Near term goal should be to raise level of awareness. Compliance will follow,

• Having a standardized yet flexible worksheet worked well and resulted in everyone adopting it

• Much confusion on what is and isn’t an IT purchase (e.g., office supplies, paper)

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Baking – Credit Cards

Lessons Learned • The under $2500 procurements represent

probably the largest number of procurements and probably the ones with the most questions

• Some resistance on IT purchases for specific individuals who were not disabled. Common sense should prevail.

• Many managers concerned that 508 will hinder their ability to quickly purchase small items. Have not found that to be the case.

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And Even More General Tips

• Strike “undue burden” from your 508 vocabulary. Not an acceptable solution plus it has demanding requirements.

• Visit agencies with operational 508 programs and benchmark their processes

• Offer training for several years. It is the second year that everyone starts to believe you are serious about 508 and they had better listen in class.

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General Tips

Participate in high-level meetings, working groups, and conference to better understand 508 at higher level and have access to people who can answer questions

Have ability to evaluate products to determine if they are compliant or have problems. Best if you act as an independent source.

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General Tips

• There are no current evaluation tools to evaluate software. Remember that accessibility tools were not designed to evaluate products for compliance.

• Enforce small, easy to make compliant issues first. Build employee/management expectations that 508 is not difficult nor expensive.

• Constantly look for ways to promote 508. It is amazing how easily get can get overlooked.

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…enjoy your cooking