Technical Governance and Strategy 

NSA ICT Fundamental 

Accessibility 

Requirements

May 16, 2017
Contents 

Contents................................................................................................................................................... 2

1. Purpose ............................................................................................................................................. 3

2. Background ....................................................................................................................................... 3

3. ICT Accessibility Requirements......................................................................................................... 4

Visual Disabilities.................................................................................................................................. 4

Auditory Disabilities ............................................................................................................................. 5

Ambulatory Disabilities........................................................................................................................ 6

Cognitive or Learning Disabled (CLD) Users......................................................................................... 6

Seizures ................................................................................................................................................ 9

4. Specific ICT Standards Documents..................................................................................................10

NSA ICT Accessibility Standards .........................................................................................................10

NSA Self-Contained Product (SCP) Standards....................................................................................10

5. Supporting Documents and Guidelines..........................................................................................11

NSA/CSS Workforce Accessibility Policy.............................................................................................11

NSA ICT Accessibility Acquisition Guidance .......................................................................................11

NSA ICT Accessibility Exception Decision Tree...................................................................................11
1. Purpose

This document will provide the necessary guidance and references to ensure accessibility is incorporated

into the design, development, maintenance, and procurement of all National Security Agency

information and communication technology (ICT).

The purpose of this document is to provide guidance to employees of the National Security Agency

regarding the implementation of Section 508 of the Rehabilitation Act of 1973( 29 U.S.C. § 794 (d)), as

amended by the Workforce Investment Act of 1998 (P.L. 105-220, August 7, 1998), and the NSA ICT

Accessibility Standards. The National Security Agency is committed to making all of its information and

communication technology (ICT) accessible, especially to individuals with disabilities.

2. Background

In 1986, Congress added Section 508 to the Rehabilitation Act of 1973. Section 508 established nonbinding guidelines for ICT accessibility. On August 7, 1998, the President signed into law the Workforce

Investment Act of 1998, which included the amendments to the Rehabilitation Act. These amendments

significantly expanded and strengthened the ICT accessibility requirements in Section 508 and made

them binding on Federal agencies. Section 508, as amended, requires that when Federal agencies

procure, develop, maintain, or use ICT, they ensure that Federal employees and members of the public

with disabilities have access to and use of information and data that is comparable to the access to and

use of the information and data that is available to individuals without disabilities. Section 508 was

enacted to eliminate barriers in ICT, to make available new opportunities for people with disabilities,

and to encourage development of technologies that achieve these goals.

The first regulation implementing Section 508 was issued by the Architectural and Transportation

Barriers Compliance Board (“Access Board”), an independent Federal agency, whose primary mission is

to promote accessibility for individuals with disabilities. This regulation is referred to as the Access

Board’s “ICT Accessibility Standards,” which became enforceable on June 21, 2001. The Access Board’s

standards set forth a definition of ICT and the technical and functional provisions and performance

criteria for compliance with Section 508. The Access Board’s standards were incorporated into the

Federal Acquisition Regulation (FAR) on April 25, 2001.

NSA has made a corporate decision, backed by the CIO and Agency Board of Directors, to proactively

meet or exceed all requirements of Section 508. Absent the formal approval of a CIO waiver or 

exception, all new agency ICT is expected to meet the requirements of the Agency Accessibility

Standards starting June 1

st

, 2017. In accordance with the exception process and asset prioritization

scale, all existing ICT must achieve an evaluation score of 4.4 or higher no later than June 1

st

, 2018, and a

score of 4.8 or higher no later than January 1st

, 2019. Where the Agency Accessibility Standards are not

directly applicable to a given ICT resource, that resource shall be measured against this document or the 

Agency Self-Contained Product Accessibility Requirements, and shall conform to the same compliance

timeline. 
3. ICT Accessibility Requirements

All ICT not applying for and receiving a CIO waiver or exception shall be accessible to each of the user

communities listed below. ICT remediating to meet the NSA ICT Accessibility Standards or the Self

Contained Product Standards will meet the criteria set forth in this document. ICT owners/vendors shall 

document and demonstrate how a user from each community will be able to interact with the ICT and

accomplish all the required tasks the ICT manages or addresses.

If an ICT resource is unable to meet the interface requirements of one or more user community, the

owner/vendor shall document how the functions of the ICT will be alternately available or accessible. 

Documentation will also be required describing the negative impact to the user, and the lost/limited

functionality of the ICT due to the accessibility shortfalls.

Each of the following seven user communities should be addressed separately.

Visual Disabilities

Overview

There are an estimated 10 million blind and visually impaired people in the United States, 1.3 million of

which are considered legally blind (American Foundation for the Blind, 2008a). Vision impairments result

from conditions that range from the presence of some usable vision, low vision, to the absence of any 

vision, total blindness. Low vision is a term that describes a person with a vision impairment that cannot

be improved by correction but has some usable vision remaining. Legal blindness is defined as 20/200 or

less in the better eye with the best possible correction. Errors of refraction, diseases of the eye, and

other vision-related conditions are usually the cause of vision loss. Each of these categories includes

more specific disorders, which are described below (American Foundation for the Blind, 2008b).

Common Errors of Refraction

• Myopia (Nearsightedness): Close objects look clear while distant objects appear blurred.

• Hyperopia (Farsightedness): The ability to see objects clearly at a distance while close objects

appear blurry.

• Astigmatism: Due to the irregular curvature of the cornea, vision is blurry for both near and far

objects.

• Presbyopia: The eye lens becomes less elastic (associated with aging) and produces blurred

vision when focusing on near objects.

Common Diseases of the Eye

• Cataracts: Clouding of the eye’s lens that causes loss of vision.

• Glaucoma: Pressure inside the eye is elevated and can cause damage to the optic nerve, which

results in damage to peripheral vision.

• Macular Degeneration: There is a disturbance of blood vessels in the eye resulting in progressive

loss of central vision.

• Retinitis Pigmentosa: There is a degeneration of pigment in the eye that is needed to absorb

light and create visual images, leading to “tunnel vision” and night blindness.

• Retinopathy (due to Diabetes): Retinopathy typically affects the blood circulation of the retina,

which causes blotchy vision.
Color Vision Deficiency (Color Blindness) occurs when cone cells of the retina, which provide daylight 

and color vision, are affected and there is difficulty distinguishing among colors. Typically this only 

involves certain hues, for example a red–green deficiency; total color blindness (achromatic vision) is 

rare.

1. Blind (B) Users 

Blind users typically navigate ICT using a keyboard, touchscreen or physical controls. They do not

use a mouse or other free moving pointer device. Screen reading software such as JAWS or

NVDA reads text content on the page and presents it as speech or braille.

2. Low Vision (LV) Users 

Low vision users typically navigate ICT using a mouse or touchscreen though sometimes

keyboard interaction makes navigation easier at higher magnification. LV Users modify the

display by zooming in on the display using a magnifier such as Zoomtext or Magic or using

system, application, or browser settings. They may also modify the color scheme to better

support their vision or avoid damaging it.

3. Color Blind (CB) Users 

Color blind users are not limited in how they navigate ICT but information conveyed by color

alone may not be available to them. All instructions and information must include a secondary

means of conveying information such as texture, contrast, location, icons, or text.

Auditory Disabilities

Overview

According to the National Institute on Deafness and Other Communication Disorders, approximately 15

percent (32.5 million) of American adults report some degree of hearing loss (NIDCD, 2008). Hearing

loss is a decrease in ability to hear and can occur at birth, suddenly, or gradually over time. Depending

on the cause, hearing loss can range from mild to severe and can be reversible, temporary, or 

permanent (WebMD, 2008). There are three types of hearing loss; conductive, sensorineural, and mixed.

Conductive hearing loss is associated with the bones of the ear, the eardrum, or the membranes that

relay sound to the inner ear. Essentially, sound is not conducted through the ear and usually involves a

reduction in sound level, or the ability to hear faint sounds. Conductive hearing loss may be caused by

fluid build-up from a cold, allergies, ear infections, and benign tumors (ASHA, 2008).

Sensorineural loss is associated with the nerves that transmit messages from the inner ear to the brain.

Sensorineural hearing loss involves a reduction in sound level, ability to hear faint sounds, and also

affects ability to clearly hear and understand speech. Sensorineural hearing loss can be caused by noise

exposure, head trauma, viruses, tumors, birth injury, drugs that are toxic to the auditory system, and

genetic syndromes (ASHA, 2008).

Mixed hearing loss is characterized by a combination of both conductive and sensorineural hearing loss,

where there is damage in the outer or middle ear as well as in the inner ear or auditory nerve (ASHA,

2008).

Conductive hearing loss can often be medically or surgically corrected. However, sensorineural hearing

loss is a permanent loss that cannot be corrected. Some individuals can benefit from hearing aids and 
assistive devices that improve hearing and listening abilities. However, in some cases, a hearing aid may

not enable an individual to discriminate environmental sounds or clearly understand speech.

The degree of hearing loss is determined by measuring hearing threshold. Hearing threshold refers to

the levels in decibels (dB) at which a signal is just barely heard. A mild hearing loss is characterized as

loss at 26-40 dB. Mild hearing loss may result in difficulty hearing soft voices, speakers at a distance, or 

understanding conversation in noisy environments. A moderate hearing loss is characterized as loss at

41-55 dB and moderate to severe at 56-70 dB. In this range, conversation even in quiet environments

can be difficult and speech may need to be loud. A severe hearing loss is characterized as loss at 71-90

dB. At this level, hearing is difficult in all situations. An individual with profound hearing loss, loss at 91+

dB, may not hear even loud speech or sounds. In this instance, hearing would not be used as a primary

method for processing information and communicating (House Ear Institute, 2008).

4. Deaf and Hard of Hearing (DHH) Users 

Deaf and hard of hear users are not limited in how they navigate ICT but they rely on visual

information rather than auditory information. Captions for multimedia and audio-only content

as well as visual alerts are needed.

Ambulatory Disabilities

Overview

Multiple disabilities fall under this category which includes anything that would affect gross or fine 

motor controls. Paralysis, amputations and birth defects may lead to limited or inability to use one or 

both hands. An estimated 5.6 million Americans live with paralysis (Christopher and Dana Reeve 

foundation, 2009) and an estimated 2 million Americans live with amputations. This category also may 

also individuals with muscular dystrophy, arthritis, and fibromyalgia as well as other conditions which 

limit an individual’s ability to grip, apply force, or use fine motor control. An estimated 50 million adults 

in the United States have some form of arthritis, and one in five adults report having a diagnosis of 

arthritis (Centers for Disease Control and Prevention, 2010). By 2030, an estimated 67 million Americans 

ages 18 years or older are projected to have arthritis, and 25.9% of women and 18.3% men report a 

diagnosis of arthritis (Centers for Disease Control and Prevention, 2010). The exact prevalence of 

fibromyalgia in the U.S. population is as high as 5 million Americans ages 18 and older, with about 80-

90% being women (Office of Women's Health, U.S. Department of Health and Human Services, 2012). 

Temporary disabilities such as a broken wrist or leg also fall in this grouping. 

5. Limited Mobility (LM) Users 

Limited mobility users typically navigate using a device that relies on the keyboard focus. A wide

range of assistive technology to support LM users exist such as joysticks, mouth sticks, and voice

controls but most rely on the keyboard focus to navigate rather than a free flowing pointer.

Cognitive or Learning Disabled (CLD) Users

According to the American Association on Intellectual and Developmental Disabilities, an intellectual 

(cognitive) disability is a disability that involves significant limitations both in intellectual functioning and

in adaptive behavior. Adaptive behaviors include many everyday social and practical skills such as

interpersonal and communication skills, social problem solving and responsibility, the use of time and

money, as well as daily personal care and safety. Limitations in individuals often coexist with strengths,

and will vary from individual to individual. This disability originates before the age of 18 and 
encompasses a wide range of conditions, types, and levels. Intellectual disability is caused by factors

that can be physical, genetic, and/or social.

According to the President's Committee for People with Intellectual Disabilities, an estimated seven to

eight million Americans of all ages experience intellectual disability. Intellectual disabilities affect about

one in ten families in the United States.

Intellectual or cognitive impairments can start any time before a child reaches the age of 18 years.

Persons who have intellectual disabilities may have other impairments as well. Examples of coexisting

conditions may include: cerebral palsy, seizure disorders, vision impairment, hearing loss, and attentiondeficit/hyperactivity disorder (ADHD). Persons with severe intellectual disabilities are more likely to have

additional limitations than persons with milder intellectual disabilities (EEOC, 2011).

Developmental disabilities that may also include an intellectual disability are briefly described below.

Intellectual disabilities can also be caused by a head injury, stroke or illness. For some no cause is found.

Intellectual disabilities will vary in degree and effect from person to person, just as individual capabilities

vary considerably among people who do not have an intellectual disability. People should not make

generalizations about the needs of persons with intellectual disabilities. In some instances an intellectual 

disability will not be obvious from a person's appearance, nor will it be accompanied by a physical 

disability. Persons with intellectual disabilities successfully perform a wide range of jobs, and can be

dependable workers. (EEOC, 2011)

• Autism: Individuals with disabilities on the autism spectrum may have complex developmental

disabilities that typically appear during the first three years of life. These disabilities are the

result of a neurological disorder that affects the normal functioning of the brain, impacting

development in the areas of social interaction and communication skills. Both children and

adults with disabilities on the autism spectrum typically show difficulties in verbal and nonverbal communication, social interactions, and play or leisure activities.

• Cerebral Palsy is a condition, sometimes thought of as a group of disorders, that can involve

brain and nervous system functions such as movement, learning, hearing, seeing, and thinking.

Cerebral palsy is caused by injuries or abnormalities of the brain. Most of these problems occur

as the baby grows in the womb, but they can happen at any time during the first two years of

life, while the baby's brain is still developing.

• Down Syndrome is a genetic disorder that causes lifelong intellectual disabilities, developmental

delays and other complications. Down syndrome varies in severity, so developmental problems

range from moderate to serious. Down syndrome is the most common genetic cause of severe

intellectual disabilities in children. Individuals with Down syndrome have a higher incidence of

heart defects, leukemia, sleep apnea, and dementia later in life.

• Fetal Alcohol Syndrome is a condition that results from prenatal alcohol exposure. It is a cluster

of mental and physical birth defects that include intellectual disabilities, growth deficits, central

nervous system dysfunction, craniofacial abnormalities and behavioral instabilities. Fetal Alcohol

Effect is a less severe set of the same symptoms. It is the only form of intellectual disability that

can be totally prevented and eradicated.

• Fragile X Syndrome is a hereditary condition that can cause learning problems ranging from

subtle learning disabilities and a normal IQ, to severe intellectual disabilities and autism.
Individuals with Fragile X Syndrome may also have physical and behavioral disorders, and

speech and language delays.

• Prader-Willi Syndrome (PWS) is the most common known genetic cause of life-threatening

obesity in children. PWS typically causes low muscle tone, short stature if not treated with

growth hormone, and a chronic feeling of hunger that, coupled with a metabolism that utilizes

drastically fewer calories than normal, can lead to excessive eating and life-threatening obesity.

PWS is also characterized by motor development delays along with some behavior problems and

unique medical issues. Intellectual deficits can be present to varying degrees, but even higher

functioning individuals will have learning difficulties.

Learning Disabilities (LD) refer to a number of disorders which may affect the acquisition, organization, 

retention, understanding or use of verbal or nonverbal information. These disorders affect learning in 

individuals who otherwise demonstrate at least average abilities essential for thinking and/or reasoning.

Learning disabilities result from impairments in one or more processes related to perceiving, thinking, 

remembering or learning. Learning disabilities range in severity and may interfere with the acquisition 

and use of oral language, reading, written language, and mathematics. Learning disabilities may also 

involve difficulties with organizational skills, social perception, social interaction and perspective taking. 

(Learning Disabilities Association of Canada, 2015) 

Although learning disabilities occur in very young children, the disorders are usually not recognized until 

the child reaches school age. Learning disabilities are a lifelong condition; they are not outgrown or 

cured, though many people develop coping techniques through special education, tutoring, medication, 

therapy, personal development, or adaptation of learning skills. Approximately 4.6 million adults in the 

United States have learning disabilities (National Center for Learning Disabilities, 2014).

Learning disabilities can be divided into three broad categories with more specific disorders included in 

each (NCLD, 2015). The specific disorders are described below. 

Specific Learning Disability: A disorder in understanding or in using language, spoken or written, which 

may manifest itself in an imperfect ability to listen, think, speak, write, spell or to do mathematical 

calculations. Included in this category are expressive writing and expressive language disorders.

• Dyslexia is the term associated with specific learning disabilities in reading. Although features of

a learning disability in reading vary from person to person, common characteristics include the

difficulty with individual sounds in words, and difficulties with word decoding, fluency, rate of

reading, rhyming, spelling, vocabulary, comprehension and written expression. Dyslexia is the

most prevalent and well-recognized of the subtypes of specific learning disabilities.

• Dyscalculia is the term associated with specific learning disabilities in math. Although features

of a learning disability in math vary from person to person, common characteristics include

difficulty with counting, learning number facts and doing math calculations, difficulty with

measurement, telling time, counting money, estimating number quantities, mental math and

problem-solving strategies.

• Dysgraphia is the term associated with specific learning disabilities in writing. This term is used

to capture both the physical act of writing and the quality of written expression. Dysgraphia can
manifest in difficulties with spelling, putting thoughts on paper, and poor handwriting, including 

difficulty in forming letters or writing within a defined space, organizing thoughts on paper, 

keeping track of thoughts already written down, and difficulty with syntax, structure, and 

grammar. 

While not designated as specific subtypes of learning disabilities, there are a number of areas of 

information processing that are commonly associated with LD (NCLD, 2014).

• Auditory Processing Disorder is the term used to describe a weakness in the ability to

understand and use auditory information. Individuals may have difficulties with noticing,

comparing and distinguishing the distinct and separate sounds in words, picking out important

sounds from a noisy background, recalling information presented orally, understanding and

recalling the order of sounds and words, and difficulty with spelling, reading and written

expression.

• Visual Processing Disorder is the term used to describe a weakness in the ability to understand

and use visual information. Individuals often have difficulty noticing and comparing features of

different items and distinguishing one item from another, distinguishing a shape or printed

character from its background, distinguishing the order of symbols, words or images, difficulty

engaging in short-term and long-term recall of visual information, and understanding how

objects are positioned in space.

• Non-Verbal Learning Disabilities is the term used to describe the characteristics of individuals

who have unique learning and behavioral profiles that may overlap with dyslexia, dyscalculia

and dysgraphia but that differ in significant ways. Most notably, these individuals often have

strengths in the areas of verbal expression, vocabulary, reading, comprehension, auditory

memory and attention to detail, yet have difficulty with math computation and problem solving,

visual-spatial tasks and motor coordination, reading body language and social cues, as well as

seeing the “big picture” in social and academic contexts

• Executive Functioning Deficits is the term used to describe weaknesses in the ability to plan,

organize, strategize, remember details and manage time and space efficiently. Executive

functioning deficits are often seen in individuals who have a learning disability.

6. Cognitive & Learning Disabled (CLD) Users 

Cognitive and learning disabled users are not limited in how they navigate ICT but decisions

about design and content presentation can affect their ability to function. Consistent, simple

design along with careful use of redundant cueing (for example an icon and text together) help

with learning. Text-to-Voice programs read text content to support users with visual

processing disorder while captioning and visual cues support user with auditory processing

disorder. Some users are unable to focus on content when scrolling, animated, or content that

continually changes in a dynamic manner is visible. This applies to items such as, interactive

carousels, scrolling tickers, and animated images, etc. A method for the user to pause, disable,

or hide these components as well as access any content in a static manner is needed.

Seizures

Epilepsy is a chronic, neurological condition characterized by recurrent seizures. A seizure happens

when abnormal electrical activity in the brain causes an involuntary change in body movement or

function, sensation, awareness, or behavior (CDC, 2011). Seizures can vary from a momentary disruption 
of the senses to short periods of unconsciousness or staring spells to convulsions, and some people have

only one type of seizure, while others have more than one type (CDC, 2011). The term epilepsy can be

used interchangeably with the term seizure disorder; epilepsy is a chronic condition and cannot be

transmitted from person to person (CDC, 2011). Having a seizure does not necessarily mean that a

person has epilepsy. Only when a person has experienced two or more seizures is s/he considered to

have epilepsy (NINDS, 2011). Epilepsy affects about 2.3 million people in the United States, with

approximately 150,000 new cases reported each year (CDC, 2013).

Epilepsy has many possible causes. Anything that disturbs the normal pattern of neuron activity -- from

illness to brain damage to abnormal brain development -- can lead to seizures (NINDS, 2011). In some

cases, the brain's attempts to repair itself after a head injury, stroke, or other problem may

inadvertently generate abnormal nerve connections that lead to epilepsy (NINDS, 2011). Abnormalities

in brain wiring that occur during brain development also may disturb neuronal activity and lead to

epilepsy (NINDS, 2011). About half of all seizures have no known cause. However, in other cases, the 

seizures are clearly linked to infection, trauma, genetic influence, developmental disabilities, dementia,

or other identifiable factors (Mayo Clinic, 2011).

7. Seizure Prone (SP) Users 

Seizure Prone users are not limited in how they navigate ICT but flashing content, content that

switches rapidly between light and dark contrast, should be avoided. This applies to videos with

dramatic changes between dark and light backgrounds as well as flashing content on otherwise

static pages. Because even small areas can be magnified by seizure prone users who also are

low vision users, avoiding flashing altogether is the best approach.

4. Specific ICT Standards Documents

NSA ICT Accessibility Standards

This document captures the accessibility requirements for all software, website, and application

development, maintenance, and procurement. When evaluating the procurement of vendor training, it

shall be used in conjunction with the NSA Fundamental Accessibility Requirements document to ensure 

all aspects of compliance are met.

This document shall also be utilized to evaluate existing ICT. 

NSA ICT Self-Contained Product (SCP) Standards

This document captures the accessibility requirements for all self-contained, closed products, and shall 

be utilized in conjunction with the NSA Fundamental Accessibility Requirements document to ensure all

aspects of compliance are met. Types of SCP include, but are not limited to: information kiosks, ATMs,

fare machines, point of sale customer card payment systems, electronic building directories, information

transaction machines, copiers, printers, calculators, fax machines, and similar products.

This document shall also be utilized to evaluate existing ICT. 
5. Supporting Documents and Guidelines

NSA/CSS Workforce Accessibility Policy

This document captures the Agency requirement to meet the criteria set forth in all Accessibility

documents, guidelines, and standards.

NSA ICT Accessibility Acquisition Guidance

This document shall be used to ensure proper language is included in all NSA ICT procurement.

Appropriate language and references are supplied, along with best practices and proper pre-acceptance 

evaluation guidance.

NSA ICT Accessibility Exception Decision Tree

This document demonstrates the appropriate thresholds for exception to the NSA Workforce 

Accessibility Policy, and also captures evaluation and remediation workflow.