Homeland
Security
Section 508 Compliance
for
Contracting Officer’s Technical
Representatives and
Program & Project Managers
Office of Accessible Systems & Technology
Homeland
Security
Topics
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 …….…………………………...
2
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Section 508 of the Rehabilitation Act
Office of Accessible Systems & Technology
Homeland
Security
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 a
technical approach to compliance
Legal compliance (required by FAR 39.2) includes
documenting:
• Market research
• Which Section 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 how the 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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Stakeholder
Roles & Responsibilities
Office of Accessible Systems & Technology
Homeland
Security
Stakeholders
• 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 Office
Roles & Responsibilities
Office of Accessible Systems & Technology
Homeland
Security
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)
– http://dhsconnect.dhs.gov/org/comp/mgmt/cio/oast/
– http://accessibility.dhs.gov
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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 reports on 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
Office of Accessible Systems & Technology
Homeland
Security
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
SOO, SOW, IGCE, ARD, RFP, RFI
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
Office of Accessible Systems & Technology
Homeland
Security
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 exceptions is 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 http://accessibility.dhs.gov
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Section 508 Acquisition Process
Office of Accessible Systems & Technology
Homeland
Security
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
• Compliance requires
market research
Image fills this entire area
– Custom, commercial, or
free
– Section 508 compliance
requires documenting
analysis of alternatives
– Summarizes additional
documentation required
(OR originates at the upper
left corner of the area
outlined and is sized to the
full width or height of this
bounding box.)
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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 meets ALL the 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
• http://accessibility.dhs.gov/PublicAppRepository.aspx.
– 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
Office of Accessible Systems & Technology
Homeland
Security
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
Solution
Engineering
Planning
Requirements
Definition
Office of Accessible Systems & Technology
Design
Development
Integration
& Test
Implementation
Operations &
Maintenance
Homeland
Security
DHS SELC
• 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!
– MNS, CONOPS, AoA, RTM, SRD, FRD, TRD
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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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Section 508 EIT Accessibility Plan
Solution
Requirements
Integration
Planning
– Several
steps to the project,
it all beginsDesign
with an ideaDevelopment
and more planning
Definition
& Test
Engineering
Implementation
Operations &
Maintenance
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
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Exiting Solutions Engineering and
Planning
There are 2 ways to fulfill the requirements for
this section:
1. Have a documented and authorized exception
2. Complete the preliminary work for
requirements definition
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Before Planning Begins
• National Security
Exception Request and
Authorization Form (DHS
Form 4105)
–
–
–
41
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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Solution
Engineering
•
•
•
•
Planning
Solution Engineering & Planning
Requirements
Definition
Design
Development
Integration
& Test
Implementation
Operations &
Maintenance
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?
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Solution
Engineering
Planning
Planning
Requirements
Definition
Design
Development
Integration
& Test
Implementation
Operations &
Maintenance
• 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 Form and supporting documents
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Exceptions Worksheet
• Assists in
Image fills this entire area
–
(OR originates at the upper
left corner of the area
outlined and is sized to the
full width or height of this
bounding box.)
–
Identifying possible
exceptions
Asking the right questions
• Legal Section 508
compliance requires
clearly documenting any
exceptions
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Exceptions
• 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
• Used as a documentation
template
Image fills this entire area
– 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
(OR originates at the upper
left corner of the area
outlined and is sized to the
full width or height of this
bounding box.)
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Functional Performance Criteria
• Requires at least one mode of operation and
information retrieval for EIT 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
• Compliance requires
market research
Image fills this entire area
– Custom, commercial, or
free
– Section 508 compliance
requires documenting
analysis of alternatives
– Summarizes additional
documentation required
(OR originates at the upper
left corner of the area
outlined and is sized to the
full width or height of this
bounding box.)
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Solution
Engineering
Planning
Requirements
Definition
Requirements Definition
Design
Development
Integration
& Test
Implementation
– Initial planning complete, now at requirements definition
Operations &
Maintenance
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
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Exiting Requirements Definition
To fulfill the Section 508 requirements of this section you
need to:
1. Review and, if needed, update the preliminary work
you have done for requirements definition.
2. Copy and paste the identified applicable Section 508
standards from the Applicable Standards Worksheet
into the project’s requirements documents.
3. Complete market research for procurements.
4. Ensure Section 508 compliance is required in
contracts.
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Solution
Engineering
Planning
Requirements
Definition
Requirements Definition
Design
Development
Integration
& Test
Implementation
Operations &
Maintenance
• Considerations
– 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
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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”
http://dhsconnect.dhs.gov/org/comp/mgmt/cio/oast/
• Information Technology Acquisition Review
(ITAR)
• OAST Assistance Available
– accessibility@dhs.gov
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DART Screenshot
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Design & Development
Requirements
– requirements
defined,Design
now atDevelopment
design andIntegration
development
Planning
Implementation
Definition
& Test
Solution
Engineering
Operations &
Maintenance
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
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Exiting Design & Development
To fulfill the Section 508 requirements of this section you
need to:
1. Ensure the Systems Acceptance Test Plan show
Section 508 requirements and how they will be tested
2. Have all human interfaces tested for Section 508
3. Have all training and user documentation tested for
Section 508
4. Remediate Section 508 issues as identified
5. 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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Solution
Engineering
Planning
Requirements
Definition
About Testing
Design
Development
Integration
& Test
Implementation
Operations &
Maintenance
• 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
• 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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Solution
Requirements
–
Development
Planningalmost done, time to test
Engineering
Definition
•
•
•
•
Integration & Test
Design
Development
Integration
& Test
Implementation
Operations &
Maintenance
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
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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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Implementation & Operations
Requirements
– All aboard!
Train
is leaving!
goes Integration
live
Planning
Design Project
Development
Solution
Engineering
Definition
& Test
Implementation
Operations &
Maintenance
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
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Exiting Implementation and O&M
To fulfill the Section 508 requirements of this section you
need to:
1. Have a plan to handle Section 508 defects reported
by users.
2. Ensure the help desk knows what to do if an issue is
reported by user of assistive technology.
3. Ensure the help desk has TTY capabilities for deaf
users. (1194.41c)
4. 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 nontechnical
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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Plan Early
• Identify your Section 508 Subject Matter
Expert (SME)
• Document market research
• Buy the “Most Accessible” product that
meets your business needs
• CODE TO THE STANDARDS!
• Test using OAST testing process
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Where To Go For Help
Office of Accessible Systems & Technology
Homeland
Security
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)
– Accessibility@dhs.gov or http://accessibility.dhs.gov
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