**SECTION 508 OF THE REHABILITATION ACT OF 1973**

**How will you ensure Section 508 compliance?** (Ensure that all
accessibility design and testing activities and their associated costs
are included within project schedule and included as part of the total
estimated cost of the project.)

***Section 508*** ***should be considered in all systems*** ***purchased
or retrofitted after June 21, 2001***. There is no reference to Section
508 in the form 300-1; however, this does not mean excluding the Section
508 requirement when this using this form. Section 508 is now included
on the 300 as *Item 7, I.G., Acquisition Strategy*. This section should
be addressed in detail, unless the procurement being addressed meets one
of the five general exemptions set forth in Attachment (3) the
Departmental policy published in IRM Bulletin 2001-006, dated and signed
by the Chief Information Officer, January 25, 2002.

When addressing this question in the acquisition process, remember to
include Section 508 compliance in the requirements analysis. Think about
what procedure to follow to ensure Section 508 compliance and outline
the steps in the comments on the 300. If the product delivered is not
508-compliant, then there should be a remedy at not cost to the
Government. Include this stipulation in the purchase contract.

**How will you know whether a product is 508-compliant?**

Research the products on the market.

-   Ask questions of different vendors

-   Request a demonstration of a product, focusing on 508 features

-   Request a demonstration copy

> \- Have IT technical personnel or other appropriate personnel review
> it.

-   Publish an RFI, Request for Information in the Commerce Business
    Daily

-   

General Services Administration (GSA) specifies whether or not a vendor
on the GSA schedule is 508-compliant. There are many 508 vendors on the
GSA schedule. This is a helpful place to begin research. See the GSA
website.

Section 508 requires the Federal government to purchase information
technology that is 508-compliant. To comply with this law and be able to
fulfill Government requirements, the private sector has done an
excellent job in developing and refining technology to accommodate the
Section 508 requirement. The vendors are knowledgeable about Section 508
and are willing to work with the Government to acquire the appropriate
technology.

**Where in the process does the 508-compliant requirement originate?**

The requirement originates with whom ever writes the requirements
analysis, usually the end user or the program office. Section 508 should
be addressed in **ALL** IT acquisitions. If it falls under one of the
exemptions, a statement of exemption should be included in the
procurement package. If it is an undue burden, an undue burden statement
should be included in the package. When contracting personnel review the
procurement package, it should not go forward without proper 508
documentation. This means the contracting personnel will either return
the package to be completed, or will call the appropriate persons to
complete it.

**Why is it so important for Section 508 to be addressed in IT
procurement packages?**

Because Section 508 is the law and specifies an avenue for complaint,
Federal agencies are vulnerable to lawsuits being filed by employees or
the general public for non-compliance. While there is no monetary award
under Section 508, a lawsuit could last years, cost thousands or dollars
and end up in Federal court. If a procurement package becomes part of a
court case, the package should have adequate documentation for Section
508, so that it is very clear that the Department or its bureaus and
offices appropriately addressed Section 508 issues. This is particularly
important for claims of undue burden or exemption.

**Where is official guidance for Section 508?**

-   IRM Bulletin 2001-006, dated January 25, 2002

-   Federal Acquisition Regulation, effective June 25, 2001

-   Department of the Interior Acquisition Policy Release, dated May 1,
    2001

**Reference web sites.**

**- [www.section508.gov](http://www.section508.gov/)**

**- [www.access-board.gov](http://www.access-board.gov/)**

**- [www.gsa.gov](http://www.gsa.gov/)**

**Departmental Contact:**

**Nancy Trent, Section 508 Coordinator**

**202-208-6051**

[**nancy_trent@os.doi.gov**](mailto:nancy_trent@os.doi.gov)

**April 1, 2003**