Framework for Designing and 

Implementing Accessible Information 

and Communication Technology (ICT) 

Strategic Plans

Accessible Technology in the Workplace Initiative

This paper was funded by the Office of Disability Employment Policy, U.S. Department of Labor under a contract to Concepts, 

Inc. The paper was submitted by Concepts, Inc., with lead author, Robert “Bobby” Silverstein (Principal, Powers, Pyles, Sutter 

& Verville, PC), and portions reviewed by Judy Brewer (Director, Web Accessibility Initiative, World Wide Web Consortium). 

The opinions contained in this paper do not necessarily represent those of the U.S. Department of Labor or any other agency or 

department of the federal government. 
Table of Contents

INTRODUCTION.......................................................................................................................................1

I. OVERVIEW AND NEED FOR FRAMEWORK............................................................................1

A. Role of Information and Communication Technology in Business and Society .............................1

B. Accessible Technology—The Gateway Civil Rights Issue for People with Disabilities ................1

C. Legal/Policy Context .......................................................................................................................2

D. The Business Case and Emerging Business Practices.....................................................................3

E. Values and Guiding Principles—the Concept of Universal Design ................................................3

F. Building the Framework for an Accessible ICT Strategic Plan.......................................................4

II. ACTION STEP 1: UNDERSTAND THE TERMINOLOGY AND TARGET POPULATION..4

A. The Terminology .............................................................................................................................5

B. The Target Population......................................................................................................................8

III. ACTION STEP 2: UNDERSTAND THE POLICY FRAMEWORK............................................9

A. Federal Civil Rights Laws .............................................................................................................10

The Americans with Disabilities Act (ADA).................................................................................10

Sections 501, 503 and 504 of the Rehabilitation Act of 1973, as amended...................................11

Applicability of ADA and Sections 501, 503 and 504 of the Rehabilitation Act to Accessible ICT, 

including the Internet.....................................................................................................................11

B. Federal Standards and International Guidelines Regarding Accessible ICT.................................12

Section 508 of the Rehabilitation Act of 1973, as amended..........................................................12

Section 255 of the Telecommunications Act of 1996....................................................................13

C. International Accessibility Standards Applicable to Websites......................................................13

D. Applicability of Section 508 and WCAG 2.0 to Private Sector Employers ..................................15

E. United Nations Convention on the Rights of Persons with Disabilities ........................................16

F. Summary—Importance of Understanding the Policy Framework.................................................16

IV. ACTION STEP 3: UNDERSTAND THE BUSINESS CASE .......................................................18

V. ACTION STEP 4: SELF-ASSESS ICT PRACTICES, SET GOALS AND ESTABLISH 

PRIORITIES FOR IMPROVEMENT ...................................................................................................20

VI. ACTION STEP 5: ADVANCE CORPORATE POLICIES, PRACTICES AND 

PROCEDURES.........................................................................................................................................21

A. Introduction....................................................................................................................................21

B. Software Applications and Operating Systems..............................................................................21

C. Websites.........................................................................................................................................21

D. Telecommunications Products.......................................................................................................23

E. Video or Multimedia Products.......................................................................................................24
F. Self-Contained, Closed Products...................................................................................................24

G. Desktop and Portable Computers...................................................................................................24

H. Information, Documentation and Support .....................................................................................25

I. Online Application Systems ..........................................................................................................25

VII. ACTION STEP 6: ESTABLISH AN INFRASTRUCURE FACILITATING 

IMPLEMENTATION OF THE POLICIES ..........................................................................................28

A. Leadership and Team Approach (Managers Across Divisions) ....................................................28

B. Outsourcing and Procurement........................................................................................................29

1. Outsourcing.........................................................................................................................29

2. The Procurement Process....................................................................................................29

3. Role of Procurement or Contracting Officials....................................................................31

C. Accessibility Training for In-House Staff......................................................................................32

D. Deployment....................................................................................................................................33

VIII. ACTION STEP 7: COMMIT TO ACCOUNTABILITY AND CONTINUOUS 

IMPROVEMENT.....................................................................................................................................33

A. Appointment of ADA Coordinator, Chief Technology Accessibility Officer and Designation of 

Accountable Managers............................................................................................................................33

B. Notice of Policy and Responsible Persons and Offices.................................................................35

C. Participation by Individuals with Disabilities and Outside Experts...............................................35

D. Measurable Objectives, Benchmarks and Prioritizing Areas Needing Improvement....................35

Prioritizing by Barriers ..................................................................................................................36

Prioritizing by Area........................................................................................................................37

E. Monitoring, Auditing, Reporting and Continuous Improvement...................................................38

IX. ACTION STEP 8: IDENTIFY AVAILABLE RESOURCES......................................................39

A. General Regulatory Guidance (on Sections 503, 504 and 508 of the Rehabilitation Act of 1973, as 

amended).................................................................................................................................................39

B. Understanding the Business Case ..................................................................................................39

C. Acquiring and Purchasing Accessible Technology .......................................................................39

D. Understanding Assistive Technologies..........................................................................................40

Vision Impairments........................................................................................................................40

Dexterity and Mobility Impairments .............................................................................................40

Hearing Impairments .....................................................................................................................40

Learning Impairments....................................................................................................................40

Language and Communication Impairments.................................................................................40

E. Accessibility Testing Tools............................................................................................................41

F. Accessibility Training Resources...................................................................................................41

G. Implementing Accessible Software Applications and Operating Systems....................................41
H. Creating Accessible Websites........................................................................................................42

I. Creating Accessible Online Job Applications................................................................................42

J. Creating Accessible Documents....................................................................................................42

K. Selecting Accessible Telecommunications Products (mobile phones, etc.) ..................................42

L. Creating Accessible Videos and Multi-media Products.................................................................43

M. Accessibility of Desktop and Portable Computers ........................................................................43

N. Accessibility of Social Media ........................................................................................................43

O. Sample Accessibility Evaluation Tools and Checklists.................................................................43

P. Best Practices.................................................................................................................................44

X. APPENDIX: COMPREHENSIVE BENCHMARKING TOOL.................................................45

A. ACTION STEP 1: UNDERSTAND THE TERMINOLOGY AND TARGET POPULATION...45

B. ACTION STEP 2: UNDERSTAND THE POLICY FRAMEWORK...........................................46

C. ACTION STEP 3: UNDERSTAND THE BUSINESS CASE ......................................................47

D. ACTION STEP 4: SELF-ASSESS ICT PRACTICES, SET GOALS AND ESTABLISH 

PRIORITIES FOR IMPROVEMENT....................................................................................................47

E. ACTION STEP 5: ADVANCE CORPORATE POLICIES, PRACTICES AND 

PROCEDURES......................................................................................................................................48

F. ACTION STEP 6: ESTABLISH AN INFRASTRUCURE FACILITATING 

IMPLEMENTATION OF THE POLICIES ...........................................................................................56

G. ACTION STEP 7: COMMIT TO ACCOUNTABILITY AND CONTINUOUS 

IMPROVEMENT. ..................................................................................................................................60

H. ACTION STEP 8: IDENTIFY AVAILABLE RESOURCES......................................................64

XI. ENDNOTES.......................................................................................................................................65
1 

INTRODUCTION: 

As technology continues to transform the workplace, demand is growing for the development, 

purchase, maintenance and use of information and communication technology (ICT)1 that is 

accessible to and usable by all applicants and employees, including individuals with disabilities. 

Leading companies recognize that fostering an accessible workplace is the smart thing to do, 

both from a business standpoint and a legal perspective. This paper provides a framework that 

can be used to develop technical assistance tools to help employers (including government 

contractors) design, purchase, lease, maintain and use ICT that is accessible to and usable by 

people with disabilities and others.

More specifically, the Framework can be used as a tool for self-assessment to make easy pointby-point comparisons with current strategies and practices. In addition, the Framework can help 

a company develop a corporate-wide, comprehensive strategic plan (affirmative action program, 

where applicable) for adopting and implementing accessible ICT policies, practices and 

procedures for assessing progress made over time and ensuring continuous improvement. 

Further, the Framework can be used as a tool for internal staff development and training. 

In addition to the Framework, the paper also includes a comprehensive Benchmarking Tool, 

located in the Appendix, which companies could use to conduct a self-assessment and create 

their own corporate-wide, comprehensive strategic plan (affirmative action program, where 

applicable), including accountability mechanisms and methods for ensuring continuous 

improvement. This Benchmarking Tool is organized in accordance with the key components of 

an Accessible ICT Strategic Plan outlined herein. 

 

I. OVERVIEW AND NEED FOR FRAMEWORK

A. Role of Information and Communication Technology in Business and Society 

Information and communication technologies (ICT), particularly Web-based Internet and 

Intranet information and applications, play a significant and ever-expanding role in everyday life 

in the United States. The role of ICT impacts commerce through the purchase of goods and 

services and how we exchange information. In addition, ICT has become a major gateway to 

employment, primarily because recruiting and hiring systems are often Web based. In many 

cases, the only way to apply for a job or to sign up for an interview is via the Internet. 

Additionally, job applicants research employment opportunities online and use the Internet to 

learn about potential employers’ needs and policies, as well as inquire about job opportunities. 

Furthermore, companies are using Intranet Web sites to conduct job-related testing, provide 

training to their employees, and share information about fringe benefits and corporate events and 

activities.

B. Accessible Technology—The Gateway Civil Rights Issue for People with Disabilities

In light of the critical role ICT plays in contemporary society, including in the employment 

context, the federal government is now recognizing accessible ICT as the most critical civil 
2 

rights issue for people with disabilities. The Department of Justice (DOJ) recently recognized 

that: 

“As more and more of our social infrastructure is made available on the Internet – in 

some cases, exclusively online – access to information and electronic technologies is 

increasingly becoming the gateway civil rights issue for individuals with disabilities.”2

Faced with the reality that ICT can open doors for people with disabilities, the federal 

government is also recognizing that technological advances will leave people with disabilities 

behind if employers do not purchase and use accessible ICT and ICT developers and 

manufacturers do not make their new products accessible. In carrying out its responsibilities 

under the Americans with Disabilities Act (ADA) and the Rehabilitation Act of 1973, as 

amended, including Section 501 (affirmative action for federal agencies), Section 503 

(affirmative action by government contractors), Section 504 (nondiscrimination by recipients of 

federal aid), and Section 508 (procurement of electronic and information technology by federal 

agencies), the federal government is now recognizing that it: 

“must make sure that the legal protections for the rights of individuals with disabilities 

are clear and sufficiently strong to ensure that innovation increases opportunities for 

everyone. We must avoid the travesty that would occur if the doors that are opening to 

Americans from advancing technologies were closed for individuals with disabilities 

because we were not vigilant.”3

C. Legal/Policy Context

DOJ has made the following statements regarding the need to provide greater clarity in official 

policy pronouncements regarding accessible ICT, particularly access to the Internet. According 

to DOJ:4

• “Voluntary standards have generally proved to be sufficient where obvious business 

incentives align with discretionary governing standards as, for example, with respect to 

privacy and security standards designed to increase consumer confidence in e-commerce. 

There has not, however, been equal success in the area of accessibility.” 

• “The [Web Accessibility Initiative of the World Wide Web Consortium] (WAI) 

leadership has recognized this challenge and has stated that in order to improve and 

accelerate Web accessibility it is important to "communicat[e] the applicability of the 

Americans with Disabilities Act to the Web more clearly, with updated guidance * * * ." 

Achieving the Promise of the Americans with Disabilities Act in the Digital Age – 

Current Issues, Challenges, and Opportunities: Hearing Before the Subcommittee on the 

Constitution, Civil Rights and Civil Liberties, H. Committee On the Judiciary, 111th 

Cong. (Apr. 22, 2010) (statement of Judy Brewer, Director, Web Accessibility Initiative 

at the W3C ̈

).” 

• “It is clear that the system of voluntary compliance has proved inadequate in providing 

website accessibility to individuals with disabilities. See, e.g., National Council on 
3 

Disability, The Need for Federal Legislation and Regulation Prohibiting 

Telecommunications and Information Services Discrimination (Dec. 19, 2006), available 

at http://www.ncd.gov/publications/2006/Dec282006 (last visited June 29, 2010) 

(discussing how competitive market forces have not proven sufficient to provide 

individual with disabilities access to telecommunications and information services).”

Thus, it appears that the federal government is recognizing the need to take a more active role in 

ensuring, through the formal regulatory process, that people with disabilities have effective and 

meaningful access to ICT under our nation’s civil rights laws, including Internet-based 

information and applications. 

D. The Business Case and Emerging Business Practices

In addition to recognizing the evolving legal and policy context in the United States and around 

the world, many companies are choosing to design, purchase and deploy accessible ICT for other 

business reasons. The business case for accessible ICT includes improved efficiency by 

addressing the personal needs of all ICT users, including those with sensory, physical and mental 

impairments, age-related limitations and temporary limitations, as well as those who are novices. 

Accessible technology also helps businesses support workforce diversity, recruit from a larger 

pool of candidates, and enhance team collaboration and communication among all employees, 

including those with disabilities.5

Best and promising business practices regarding accessible ICT are emerging. These business 

practices include securing support from executive leadership, such as the Chief Executive 

Officer (CEO), and a company-wide involvement and designation of respective roles and 

responsibilities by key managers (team approach), including the Chief Information Officer, the 

Chief Acquisition Officer, the Chief Procurement Officer, human resources, education and 

training, financial and marketing. These business practices also include: 

• The development and implementation of a comprehensive strategic action plan that 

includes assessing needs and current levels of accessibility of websites and other ICT 

used in the company; 

• Setting accessibility goals and establishing priorities; 

• Adopting policies, practices and procedures regarding design, content production, 

purchasing, training and deployment; 

• Establishing a corporate-wide infrastructure; and 

• Adopting monitoring, accountability and continuous improvement mechanisms and 

strategies to meet the goals, including the establishment of measurable objectives and 

benchmarks and the appointment of a Chief Technology Accessibility Officer.

6

 

E. Values and Guiding Principles—the Concept of Universal Design 

Many of the companies that are adopting accessible ICT policies, practices and procedures are 

doing so in part based on recognition of the concept/philosophy of “universal design” (i.e., 

designing, purchasing, leasing, maintaining and deploying products and services that are usable 

by people with the widest possible range of functional capabilities). This includes products and 
4 

services that are directly usable (without requiring assistive technologies) and those that are 

made compatible or interoperable with assistive technologies.7 

Accessible ICT, including accessible websites, offer significant advantages that go beyond 

access for people with disabilities. Some of these benefits include reducing website maintenance 

time, reducing bandwidth requirements and server load, enabling content repurposing on 

different devices, and simplifying forward migration to advanced standards that provide 

expanded capabilities for business websites.8

 

F. Building the Framework for an Accessible ICT Strategic Plan

As stated in the introduction, this paper provides a framework that can be used to develop 

technical assistance tools to help employers (including government contractors) design, 

purchase, lease, maintain and use ICT that is accessible to and usable by people with disabilities 

and others. More specifically, this paper serves as a framework for developing and implementing 

an accessible ICT strategic plan that includes the following core action steps: 

• Understand Key Terminology and Target Population 

• Understand the Policy Framework

• Understand the Business Case 

• Self-Assess ICT Practices, Set Goals and Establish Priorities for Improvement 

• Advance Corporate Policies, Practices and Procedures

• Establish an Infrastructure to Facilitate Implementation of the Policies

• Commit to Accountability and Continuous Improvement 

• Identify Available Resources 

The Framework may be used as a tool for self-assessment to make easy point-by-point 

comparisons with current strategies and practices. The Framework can also be used to help guide 

a company’s thinking about the best course for developing a corporate-wide, comprehensive 

strategic plan (affirmative action program, where applicable) for adopting and implementing 

accessible ICT policies, practices and procedures, for assessing progress made over time, and 

ensuring continuous improvement. Further, the Framework can be used as a tool for internal staff 

development and training. 

This Framework does not create any new legal requirements or change current legal 

requirements. Instead, it lists examples of strategies and practices that employers have found to 

be effective in enhancing employment opportunities for qualified individuals with disabilities 

through accessible ICT. 

II. ACTION STEP 1: UNDERSTAND THE TERMINOLOGY AND TARGET 

POPULATION

The first action step a company may want to take in its efforts to meet the needs of qualified 

individuals with disabilities through the development, procurement, maintenance and use of 

accessible ICT is to review the key terms used to describe accessible ICT and the target 
5 

populations affected by inaccessible ICT systems. Frequently used acronyms are also identified 

and their meaning articulated.

A. The Terminology9

Access Board. The Access Board is an independent federal agency that develops and maintains, 

among other things, accessibility guidelines and standards, provides technical assistance and 

training on the guidelines and standards, and enforces accessibility standards for federally funded 

facilities. Section 508 of the Rehabilitation Act requires the Access Board to publish standards 

setting forth a definition of electronic and information technology (also referred to as 

information and communication technology, ICT) and technical and performance standards. The 

Access Board’s official name is the Architectural and Transportation Barriers Compliance 

Board. 

Accessible technology. Technology that can be used by people with a wide range of abilities 

and disabilities. It incorporates the principles of universal design. Each user is able to interact 

with the technology in ways that work best for him or her. Accessible technology is either 

directly accessible—in other words, it is usable without assistive technology—or it is compatible 

with standard assistive technology.10 

Alternate formats. Alternate formats usable by people with disabilities may include, but are not 

limited to: Braille, ASCII text, large print, Web, e-mail, CD-ROM/DVD, recorded audio, other 

electronic formats.

Alternative methods. Alternate methods are different means of providing information, including 

product documentation, to people with disabilities. Alternate methods may include, but are not 

limited to: voice, fax, relay service, TTY, Web posting, e-mail, sign language, instant messaging, 

mobile texting, captioning, audio description, text to speech syntheses. 

ADA. The Americans with Disabilities Act of 1990 is a comprehensive civil rights law 

prohibiting discrimination on the basis of disability in the areas of employment, public services, 

public accommodations and telecommunication relay services for hearing impaired and speech 

impaired individuals.

Assistive technology. Any item, piece of equipment or system, whether acquired commercially, 

modified or customized, that is commonly used to increase, maintain or improve functional 

capacities of individuals with disabilities. The term includes traditional assistive technology 

hardware and software along with mainstream technology used for assistive purposes, virtual 

assistive technology delivered as a Web service and integration of products into a system that 

provides assistive technology functions that allow individuals with disabilities to access 

information and communication technology. Examples include:

• Screen enlargers that act like magnifiers to help people with low vision;

• Onscreen keyboards that allow people who are unable to use a standard keyboard to 

select keys using methods such as a pointing device or switch;

• Voice recognition (instead of using a mouse or keyboard);
6 

• Alternative input devices that enable individuals to control their computers through 

means other than a standard keyboard or pointing devices, e.g., head-operated 

pointing devices and sip and puff systems controlled by breathing;

screen readers that allow users who are blind to hear what is happening on their 

computer by converting the screen display to digitized speech, etc. 

Disability. As defined by the Americans with Disabilities Act, the term 'disability' means, with 

respect to an individual: 

(A) a physical or mental impairment that substantially limits one or more major life 

activities of such individual; 

(B) a record of such an impairment; or 

(C) being regarded as having such an impairment.11

GPAT. Government Product/Service Accessibility Template is a solicitation documentation tool 

produced by the BuyAccessible Wizard to assist federal contracting and procurement officials in 

fulfilling the market research requirements associated with Section 508 regulations. 

Information and communication technology (ICT), which is also referred to as electronic 

and information technology (EIT). ICT includes information technology and any equipment or 

interconnected system or subsystem of equipment, that is used in the creation, conversion or 

duplication of data or information. ICT also includes information technology and any equipment 

or interconnected system or subsystem of equipment, which is used in the automatic acquisition, 

storage, analysis, evaluation, manipulation, management, movement, control, display, switching, 

interchange, transmission, reception or broadcast of data or information. The term includes, but 

is not limited to, electronic content, including e-mail, electronic documents and Internet and 

Intranet websites; telecommunications products, including video communication terminals; 

computers and ancillary equipment, including external hard drives; software, including operating 

systems and applications; information kiosks and transaction machines; videos; IT services; and 

multifunction office machines that copy, scan and fax documents. 

Note: “Electronic and information technology (EIT)” is a term used in the 1998 amendments to 

Section 508 of the Rehabilitation Act to define the scope of products covered under Section 

508.12 

Information technology. Any equipment or interconnected system or subsystem of equipment, 

that is used in automatic acquisition, storage, analysis, evaluation, manipulation, management, 

movement, control, display, switching, interchange, transmission or reception of data or 

information. The term information technology includes computers, ancillary equipment, 

including software, firmware and similar procedures, services (including support services) and 

related resources.

Interoperability. Assistive technology and ICT interoperability is the ability of assistive 

technology (both soft and hard) and standard ICT (both soft and hard) from multiple vendors to 

exchange and use information meaningfully and without adverse system consequences, or when 

possible, the need for special configuration or adaptation on the part of the user. 
7 

Online application system. An online application system includes, but is not limited to, all 

electronic or Web-based systems that an employer uses in all of its personnel activities.13

Operable controls. A component of a product that requires physical contact for normal 

operation. Operable controls include, but are not limited to, input and output trays, card slots, 

keyboards or keypads.

Platform accessibility services. Services provided by a platform enabling interoperability with 

assistive technology, such as but not limited to accessibility Application Programming Interfaces 

(API) or Document Object Model (DOM). 

Section 501. Section 501 of the Rehabilitation Act of 1973, as amended prohibits discrimination 

on the basis of disability by federal agencies and requires such agencies to take affirmative 

action to hire and promote qualified individuals with disabilities.

Section 503. Section 503 of the Rehabilitation Act of 1973, as amended prohibits discrimination 

on the basis of disability by government contractors and requires such contractors to take 

affirmative action to hire and promote qualified individuals with disabilities.

Section 504. Section 504 of the Rehabilitation Act of 1973, as amended prohibits discrimination 

on the basis of disability by recipients of federal financial assistance. 

Section 508. Section 508 of the Rehabilitation Act of 1973, as amended requires that when 

federal agencies develop, procure, maintain or use electronic and information technology, federal 

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

the access and use by federal employees who are not individuals with disabilities, unless an 

undue burden would be imposed on the agency. Section 508 also requires that individuals with 

disabilities who are members of the public seeking information or services from a federal agency 

have access to and use of information that is comparable to that provided to the public who are 

not individuals with disabilities, unless an undue burden would be imposed on the agency. 

Furthermore, it requires the Access Board to publish standards setting forth the definition of EIT, 

also referred to as ICT, and technical and functional performance standards for such technology.

Section 255 of the Telecommunications Act of 1966. Section 255 of the Telecommunications 

Act of 1996 requires manufacturers to ensure that telecommunications equipment or customer 

premises equipment are designed, developed and fabricated to be accessible to and usable by 

individuals with disabilities when it is readily achievable to do so and readily achievable means 

easily accomplishable without much difficulty or expense. The Access Board is given 

responsibility for developing accessibility guidelines for telecommunication equipment and 

customer premises equipment in conjunction with the Federal Communications Commission

(FCC). 

Telecommunications. The transmission, between or among points specified by the user, of 

information of the user’s choosing, without change in the form or content of the information as 

sent and received. 
8 

TTY. An abbreviation for teletypewriter. Machinery or equipment that employs interactive text 

based communications through the transmission of coded signals across the telephone network. 

TTYs may include, for example, devices known as TDDs (telecommunication display devices or 

telecommunications devices for deaf persons) or computers with special modems. TTYs are also 

called text telephones. 

Universal design. The concept or philosophy for designing and delivering products and services 

that is usable by people with the widest possible range of functional capabilities. This includes 

products and services that are directly usable (without requiring assistive technologies) and those 

that are made compatible with assistive technologies. 

Video description. The insertion of verbal or auditory descriptions of on-screen visuals intended 

to describe important visual details that are contained in, or that cannot be understood from, the 

main audio output alone. Video descriptions supplement the regular audio track of a program and 

are usually inserted between dialogue narrations to provide information about actions, characters 

and on-screen text that appear without verbalization. Video descriptions are a way to let people 

who are blind or have low vision know what is happening on-screen. 

VPAT. Voluntary Product Accessibility Template is a tool used to document a product's 

conformance with the accessibility standards under Section 508 of the Rehabilitation Act. The 

purpose of the VPAT is to assist federal contracting officials and other buyers in making 

preliminary assessments regarding the availability of commercial information and 

communication technology products and services with features that support accessibility.

WCAG. The Web Content Accessibility Guidelines are recognized voluntary international 

guidelines for Web accessibility created by the Web Accessibility Initiative (WAI) of the World 

Wide Web Consortium (W3C). These guidelines detail how to make Web content and Web 

applications accessible to individuals with disabilities. The most recent and updated version is 

WCAG 2.0, published in December 2008. 

B. The Target Population 

According to DOJ, millions of people have disabilities, including visual, auditory, physical, 

speech, cognitive and neurological disabilities, that affect their use of ICT.

14 

People who are blind or have low vision are often the most affected by inaccessible information 

and electronic technology. Many individuals with visual impairments use an assistive technology 

known as a screen reader that enables them to access the information on computers or websites. 

Screen readers read text aloud as it appears on the computer screen. Individuals who are blind 

may also use refreshable Braille displays, which convert the text of websites to Braille. 

Sometimes, those individuals will use keyboards in lieu of a mouse to move up and down on a 

screen or sort through a list and select an item.
9 

People who have difficulty using a computer mouse because of mobility impairments, for 

example, may use an assistive technology that allows them to control software with verbal

commands. But websites and other technologies are not always compatible with those assistive 

technologies. Challenges for persons with mobility impairments include navigating and 

interacting with Web pages (e.g., difficulty moving the cursor with the required precision) or 

lacking the requisite manual dexterity or hand-eye coordination to use a standard keyboard. They 

will often use mouse and keyboard alternative assistive devices or helper applications such as a 

head wand or voice recognition software. 

Captioning of streaming videos may also be necessary in order to make them accessible to 

individuals who are deaf or hard of hearing. Additionally, telephones with TTY capability or 

amplified sound provide accessible communication for these individuals.

Challenges for persons with cognitive impairments and neurological disabilities using 

websites include lack of consistent navigation structure, lack of illustrative non-text materials,

and flickering or blinking design elements. 

The most common barriers on websites are posed by images or photographs that do not provide 

identifying text. A screen reader or similar assistive technology cannot read an image.

Thus, when images appear on websites without identifying text there is no way for the individual

who is blind or has low vision to know what is on the screen. The simple addition of a tag or 

other description of the image or picture will keep an individual using a screen reader oriented 

and allow him or her to gain access to the information the image depicts.

Similarly, complex websites often lack navigational headings or links that would make them

easy to navigate using a screen reader. With simple instruction, Web designers can easily add 

those headings. They may also add cues to ensure the proper functioning of keyboard commands. 

They can also set up their programs to respond to voice interface technology. 

III.ACTION STEP 2: UNDERSTAND THE POLICY FRAMEWORK

Our nation’s civil rights laws require that covered entities provide equal opportunity to 

qualified individuals with disabilities. Equal opportunity means an opportunity to obtain the 

same level of performance, or to enjoy the same level of benefits and privileges that are available 

to similarly situated individuals without disabilities. It is unlawful for the covered entity to use 

standards, criteria or methods of administration that have the purpose or effect of 

discriminating on the basis of disability. This includes entering into contracts or other 

arrangements that have a discriminatory effect. In other words, a covered entity is prohibited 

from doing indirectly that which it is prohibited from doing directly. 

In addition, our nation’s civil rights laws include responsibilities for government contractors and 

federal agencies to take affirmative action to employ and advance in employment individuals 

with disabilities and disabled veterans, including but not limited to recruitment, advertising and 

job application procedures. These job application procedures include online application systems. 
10

The duty to take affirmative action regarding the employment of qualified persons with 

disabilities subsumes the duty not to discriminate. Nondiscrimination is the starting point—the 

first step required of any government contractor or federal agency in fulfilling its affirmative 

action obligation. However, affirmative action includes much more than nondiscrimination on 

the basis of disability by an employer; it includes instituting a system of proactive/positive 

measures/steps that provide qualified persons with disabilities effective opportunity with respect 

to all employment activities (e.g., recruitment, selection, hiring, placement, promotion, transfer, 

layoff, termination, compensation and training) at all levels of employment (including the 

executive level). 

The system of proactive/positive measures/steps includes efforts by government contractors or 

federal agencies to prevent discrimination on the basis of disability before it occurs by 

periodically carefully and thoroughly evaluating and monitoring their employment practices to 

identify/detect barriers to employment and, where such barriers are identified, eliminate/remedy 

them. Affirmative action also includes expanded outreach, recruitment, mentoring, training and 

management development and creating a work environment that actively welcomes and fosters 

advancement of qualified persons with disabilities. Affirmative action does not include quotas or

granting preferences to individuals with disabilities.15

In addition to our nation’s civil rights laws, international treaties provide civil rights protections 

for people with disabilities and international organizations are establishing accessibility 

standards for websites. 

Below is a brief description of key laws, international conventions and international accessibility 

standards/guidelines that may have applicability to employers:

• The Americans with Disabilities Act

• Sections 501, 503, 504 and 508 of the Rehabilitation Act of 1973, as amended 

• Section 255 of the Telecommunications Act of 1996 

• Web Content Accessibility Guidelines 2.0

• The UN Convention on the Rights of Persons with Disabilities

A. Federal Civil Rights Laws

The Americans with Disabilities Act (ADA)

Congress adopted the Americans with Disabilities Act (ADA) in 1990.16 The statute is a

comprehensive, broad-reaching mandate to eliminate discrimination on the basis of disability in 

the areas of employment (Title I), state and local governments (Title II), public accommodations 

(Title III) and telecommunication relay services for hearing impaired and speech impaired 

individuals (Title IV). DOJ is responsible for enforcement and implementation of Titles II and III 

of the ADA, which cover state and local government entities and private businesses, 

respectively. The Equal Employment Opportunity Commission (EEOC) and the DOJ enforce 

Title I of the ADA (EEOC for private employers and DOJ for state and local governments). The 

FCC is responsible for the implementation and enforcement of Title IV. 
11

Under the ADA, it is unlawful for a covered employer to discriminate on the basis of disability 

against a qualified individual with a disability in regard to any term, condition or privilege of 

employment, including recruitment, advertising and job application procedures; hiring, 

promotion and termination; and fringe benefits, apprenticeships, training and sponsored 

activities, including social and recreational programs. It is also unlawful for a covered employer 

to participate in a contractual or other arrangement or relationship that has the effect of 

subjecting the covered employer’s own qualified applicant or employee with a disability to 

discrimination. Unlawful discrimination includes the failure to provide opportunities to 

participate in or benefit from a privilege of employment that are equal to and as effective and

meaningful as those afforded to other individuals and the failure to provide reasonable 

accommodations unless to do so would result in undue hardship.17 

Sections 501, 503 and 504 of the Rehabilitation Act of 1973, as amended 

Title V of the Rehabilitation Act of 1973, as amended contains a number of provisions designed 

to safeguard the civil rights of people with disabilities. 

• Section 501 of the Rehabilitation Act protects qualified persons with disabilities from 

employment discrimination by federal departments and agencies. In addition, each 

federal department or agency is required to develop an affirmative action plan for hiring, 

placing and advancing qualified individuals with disabilities within the department or 

agency.18

• Under Section 503 of the Rehabilitation Act, covered government contractors are 

prohibited from engaging in discrimination and are required to take affirmative action to 

employ and advance in employment qualified persons with disabilities. Certain 

government contractors are required to develop affirmative action programs.19

• Section 504 of the Rehabilitation Act of 1973 prohibits discrimination in federally 

assisted and federally conducted programs and activities.20

Applicability of ADA and Sections 501, 503 and 504 of the Rehabilitation Act to Accessible 

ICT, including the Internet

When Congress enacted the ADA and Sections 501, 503 and 504 of the Rehabilitation Act, the 

Internet as we know it today as the venue for information, commerce, services, activities and 

employment did not exist. For that reason, although the ADA and Sections 501, 503 and 504 

guarantee the protection of the rights of individuals with disabilities in a broad array of activities, 

neither law expressly mentions the Internet or contains requirements regarding developing 

technologies. Because the Internet was not in general public use when Congress enacted the 

ADA and the Attorney General and other department or agency officials promulgated regulations 

to implement it, neither the statute nor the regulations expressly mention it. But the statute and 

regulations create general rules designed to guarantee people with disabilities equal access to all 

of the important areas of American civic and economic life. And DOJ made clear, in the 

preamble to the original 1992 ADA regulations, that the regulations should be interpreted to keep 

pace with developing technologies. 28 C.F.R. pt. 36, App. B.21 
12

DOJ has long taken the position that both state and local government websites and the websites 

of private entities that are public accommodations are covered by the ADA. In other words, the 

websites of entities covered by both Title II and Title III of the statute are required by law to 

ensure that their sites are fully accessible to individuals with disabilities.22 

According to DOJ, there is no doubt that the Internet sites of state and local government entities 

are covered by Title II of the ADA. Similarly, there is no doubt that the websites of recipients of 

federal financial assistance are covered by Section 504 of the Rehabilitation Act. DOJ has 

affirmed the application of these statutes to Internet sites in a technical assistance publication, 

Accessibility of State and Local Government Websites to People with Disabilities 

(http://www.usdoj.gov/crt/ada/websites2.htm), and in numerous agreements with state and local 

governments and recipients of federal financial assistance. DOJ’s technical assistance 

publication also provides guidance with simple steps to ensure that government websites have 

accessible features for individuals with disabilities. 

On July 26, 2010, DOJ published an Advance Notice of Proposed Rulemaking regarding 

Nondiscrimination on the Basis of Disability; Accessibility of Web Information and Services of 

State and Local Government Entities and Public Accommodations.

23 DOJ is soliciting public 

comments on various issues relating to the establishment of specific regulatory requirements for 

making services, programs and activities accessible via the Web. 

B. Federal Standards and International Guidelines Regarding Accessible ICT

Section 508 of the Rehabilitation Act of 1973, as amended 

Section 508 of the Rehabilitation Act requires that when federal departments or agencies 

develop, procure, maintain or use electronic or information technology, they must ensure that the 

technology is accessible to and usable by people with disabilities, unless an undue burden would 

be imposed on the department or agency.24 Section 508 ensures that federal employees with 

disabilities have access to, and use of, the information and data they need to do their job, which 

reduces barriers to job success and upward mobility. The law also helps ensure that members of 

the public with disabilities have the ability to access government information and services. 

Section 508 also requires the Access Board to publish standards setting forth a definition of 

electronic and information technology and technical and functional performance criteria for such 

technology. The Access Board is also required to periodically review and, as appropriate, amend 

the standards to reflect technological advances in electronic and information technology. The 

Board published the standards on December 21, 2000.

25 On March 22, 2010, the Access Board 

published in the Federal Register26 an Advance Notice of Proposed Rulemaking (ANPRM) 

updating and modernizing the Telecommunications Act Accessibility Guidelines and the 

Electronic and Information Technology Standards. It issued a second ANPRM on these same 

issues on December 8, 2011.27 Through the proposed updates, the Access Board is addressing 

new technology and seeks to harmonize, to the extent possible, its criteria with other standards 

and guidelines in order to improve accessibility and facilitate compliance. In particular, the 

Access Board is seeking to harmonize its Section 508 standards with the World Wide Web 

Consortium (W3C) Web Content Accessibility Guidelines (WCAG) 2.0 (December 11, 2008).

The WCAG 2.0 is described more fully below. 
13

Section 508 uses the procurement process to ensure that ICT acquired by the federal government 

is accessible to individuals with disabilities. The law also sets up an administrative process under 

which individuals with disabilities can file a complaint alleging that a federal agency has not 

complied with the standards. 

The standards define the types of technology covered and set forth a minimum level of 

accessibility. The standards also provide criteria specific to various types of technologies, 

including:

• Software applications and operating systems

• Web-based information and applications 

• Telecommunication products

• Video and multimedia products

• Self-contained, closed products (e.g., information kiosks, calculators, fax machines)

• Desktop and portable computers 

The standards provide technical specifications and performance-based requirements, which focus 

on functional capabilities of covered ICT. According to the Access Board, this approach is 

designed to recognize the dynamic and continually evolving nature of the ICT as well as the need 

for clear and specific standards to facilitate compliance. Certain provisions are designed to 

ensure compatibility with assistive technology people with disabilities use for ICT access, such 

as screen readers, Braille displays and TTYs.

Section 255 of the Telecommunications Act of 1996 

Section 255 of the Telecommunications Act of 1996 requires manufacturers to ensure that 

telecommunications equipment or customer premises equipment are designed, developed and 

fabricated to be accessible to and usable by individuals with disabilities when it is readily 

achievable to do so and readily achievable means easily accomplishable without much difficulty 

or expense. The Access Board is given responsibility for developing accessibility guidelines for 

telecommunication equipment and customer premises equipment in conjunction with the FCC. 

C. International Accessibility Standards Applicable to Websites28

The Web Accessibility Initiative (WAI) of the World Wide Web Consortium (W3C ̈) creates 

internationally recognized voluntary standards for Web accessibility, including guidelines for 

Web content, authoring tools, browsers and media players. Specifically, the Web Content 

Accessibility Guidelines (WCAG) detail how to make Web content and Web applications 

accessible to individuals with disabilities and older people. The most recent and updated version 

of the WCAG, the WCAG 2.0, was published in December 2008 and is available at 

http://www.w3.org/TR/WCAG20/ (last visited June 29, 2010). According to the WAI, the 

WCAG 2.0 "applies broadly to more advanced technologies; is easier to use and understand; and 

is more precisely testable with automated testing and human evaluation." See WAI, Web Content 

Accessibility Guidelines (WCAG) Overview, available at http://www.w3.org/WAI/intro/wcag.php 

(last visited June 29, 2010). It is supported by an extensive and expanding library of technical 
14

resources for Web developers, including implementation techniques29 for HTML, CSS, 

Scripting, Flash and additional Web technologies. 

The WCAG 2.0 contains 12 guidelines addressing Web accessibility. Each guideline contains 

testable criteria for objectively determining if Web content satisfies the guideline. In order for a 

Web page to conform to WCAG 2.0, the Web page must satisfy applicable “Success Criteria” for 

these guidelines under one of three conformance levels: A, AA or AAA. The three levels of 

conformance indicate a measure of accessibility and feasibility. Level A, which is the minimum 

level of conformance for access, contains criteria that provide basic Web accessibility and that 

are the most feasible for Web content developers. Level AA, which is the intermediate level for 

access, contains enhanced criteria that provide more comprehensive Web accessibility and yet 

are still feasible for Web content developers. Level AAA, which is the maximum level of access, 

contains criteria that may be less feasible for Web content developers. In fact, WAI does not 

recommend that Level AAA conformance be required as a general policy for entire websites 

because it is not possible to satisfy all Level AAA criteria for some content. See W3C ̈, 

Understanding WCAG 2.0: Understanding Conformance (Dec. 2008), 

http://www.w3.org/TR/UNDERSTANDING-WCAG20/conformance.html (last visited June 29, 

2010). 

To give an overview of the types of considerations necessary for making a website accessible, 

WCAG 2.0 can be briefly paraphrased as follows. Please note that this is not definitive text and 

should not be used for conformance, only for examples: 

WCAG 2.0 At A Glance30

Perceivable

 * Provide text alternatives for non-text content.

 * Provide captions and other alternatives for multimedia.

 * Create content that can be presented in different ways, 

 including by assistive technologies, without losing meaning. 

 * Make it easier for users to see and hear content.

Operable

 * Make all functionality available from a keyboard. 

 * Give users enough time to read and use content. 

 * Do not use content that causes seizures. 

 * Help users navigate and find content. 

Understandable

 * Make text readable and understandable. 

 * Make content appear and operate in predictable ways.

 * Help users avoid and correct mistakes. 
15

Robust

* Maximize compatibility with current and future user tools. 

D. Applicability of Section 508 and WCAG 2.0 to Private Sector Employers 

As explained above, federal civil rights statutes and implementing regulations require that all 

privileges offered to individuals without disabilities be offered to individuals with disabilities, 

whether the privileges are provided directly by the company or through contract or other 

arrangement with another entity. This means individuals with disabilities must be provided an 

opportunity to take advantage of these privileges that is equal to and as effective as that provided 

to others. 

To date, there are no explicit standards for accessible ICT included in disability rights 

regulations applicable to private sector employers, state and local governments, and public 

accommodations. In recognition of the critical importance of accessible ICT in the exercise of 

these privileges, federal agencies are, however, taking steps to clarify the applicability of these 

generic policies under the ADA and the Rehabilitation Act to the development, procurement, 

maintenance and use of accessible ICT in handbooks and other informal guidance and specifying 

the existence of applicable standards (e.g., Section 508 and WCAG 2.0) that may serve as “safeharbors.”31 For example, the Department of Health and Human Services (HHS) recently issued 

Guidance for Exchange and Medicaid Information Technology (IT) Systems, Version 1.0 

(November 2, 1010). With respect to standards for accessibility, this document states32: 

“Systems shall include usability features or functions that accommodate the needs of 

persons with disabilities, including those who use assistive technology. State enrollment and

eligibility systems are subject to the program accessibility provisions of Section 504 of the 

Rehabilitation Act, which include an obligation to provide individuals with disabilities an 

equal and effective opportunity to benefit from or participate in a program, including those 

offered through electronic and information technology. At this time, the Department will 

consider a recipient’s websites, interactive kiosks, and other information systems addressed 

by Section 508 Standards as being in compliance with Section 504 if such technologies meet 

those Standards. We encourage states to follow either the 508 guidelines or guidelines that 

provide greater accessibility to individuals with disabilities. States may wish to consult with 

latest Section 508 guidelines issued by the US Access Board or W3C’s Web Content 

Accessibility Guidelines (WCAG) 2.0.” (emphasis added)

With respect to Section 508, it should be noted that all of the Web-based documents developed 

by the General Services Administration (GSA) for use by federal agencies and vendors are 

available for use by private sector employers by simply signing in as a guest.33 With respect to 

WCAG 2.0, it should be noted that numerous supporting technical and educational documents 

developed by W3C are also available to the public.34 Also, as mentioned above, the Access 

Board recently published an Advance Notice of Proposed Rulemaking that, among other things, 

is designed to harmonize the Section 508 standards with WCAG 2.0. 
16

E. United Nations Convention on the Rights of Persons with Disabilities

The United Nations General Assembly adopted the Convention on the Rights of Persons with 

Disabilities in 2006. So far, 148 countries have signed and 100 have ratified this Convention. On 

July 30, 2009, Susan Rice, President Obama's ambassador to the United Nations, signed the 

convention at U.N. headquarters in New York. President Obama has pledged to submit the 

Convention to the Senate for its ratification (advise and consent). 

Article 9 of the Convention addresses accessibility. The article specifies that to enable persons 

with disabilities to live independently and participate fully in all aspects of life, States Parties 

shall take appropriate measures to ensure to persons with disabilities access, on an equal basis 

with others, to, among other things, information and communications, including information and 

communication technologies and systems. More specifically, Article 9 specifies that States 

Parties shall also take appropriate measures to promote access for persons with disabilities to 

new information and communications technologies and systems, including the Internet, and 

promote the design, development, production and distribution of accessible information and 

communication technologies and systems at an early stage, so that these technologies and 

systems become accessible at minimum cost.

F. Summary—Importance of Understanding the Policy Framework

As explained above, there are several sets of standards describing how to make ICT, including 

websites, accessible to individuals with disabilities. Some employers may elect to use the 

standards that were developed and are maintained by the Access Board in accordance with 

Section 508 and Section 255 of the Telecommunications Act; whereas other employers may elect 

to use the WCAG 2.0 guidelines developed and maintained by the WAI of the W3C. For 

purposes of this Framework, either set of standards/guidelines is appropriate. 

The importance for private sector employers of understanding the policy framework is evident 

by reviewing policy guidance recently issued by the U.S. Department of Education (ED) on the 

rights of students with disabilities when educational institutions use technology.35 Using the 

policy pronouncements in the ED guidance, the following text illustrates the possible application 

of nondiscrimination standards regarding accessible emerging technologies in the employment 

context by substituting “company” or “employer” for “schools” and substituting “applicants” and 

“employees” for “students.” 

Employers should consider accessibility issues up front when they are deciding whether to create 

or acquire ICT and when they are planning how the ICT will be used. To that end, employers 

should include accessibility requirements and analyses as part of their acquisition procedures. 

Employers should keep in mind their obligation to ensure that applicants and employees with 

disabilities receive the privileges of employment in an equally effective and equally integrated 

manner. Among the questions employers should ask are: 

• What employment opportunities and privileges does the company provide through the 

use of the ICT?

• How will the ICT provide these opportunities and privileges?
17

• Does the ICT exist in a format that is accessible to individuals with disabilities?

• If the ICT is not accessible, can it be modified (see below about additional questions 

related to modifications), or is there a different technological device available, so that 

applicants and employees with disabilities can obtain the employment opportunities and 

privileges in a timely, equally effective and equally integrated manner?

Example: An employer intends to establish a Web mail system so that employees can 

communicate with each other and with managers; receive important messages from the company 

(e.g., a message about a health or safety concern); and communicate with individuals outside the 

company. The company must ensure that the employment benefits, services and opportunities 

provided to applicants and employees through a Web mail system are provided in an equally 

effective and equally integrated manner. Before deciding what system to purchase, the company 

should make an initial inquiry into whether the system is accessible to individuals who are blind 

or have low vision (e.g., whether the system is compatible with screen readers and whether it 

gives users the option of using large fonts). If a system is not accessible as designed, the 

company should take further action to determine whether an accessible product is available, or 

whether the inaccessible product can be modified so that it is accessible to applicants or 

employees who are blind or have low vision. 

In making the determination about modifications or the purchase and use of different devices 

available, the questions a company should ask include: 

• What employment opportunities and privileges of employment does the company provide 

through the use of ICT?

 

• What can the company do to provide applicants and employees with disabilities equal 

access to the employment privileges or opportunities provided through the use of the 

ICT?

• How will the employment opportunities and privileges provided to applicants and 

employees with disabilities compare to the opportunities and privileges that the ICT 

provides to applicants and employees without disabilities? Three relevant questions are:

o Are all the employment opportunities and privileges that are available through the use 

of the ICT equally available to applicants and employees with disabilities through the 

provision of accommodations or modifications (i.e., do applicants and employees 

with disabilities have the opportunity to acquire the same information, engage in the 

same interactions, and enjoy the same services as nondisabled applicants and 

employees)?

o Are the employment opportunities and privileges provided to applicants and 

employees with disabilities in as timely a manner as those provided to applicants and 

employees without disabilities (i.e., do the time frames under which opportunities and 

privileges are received by applicants and employees meet the requirement that 

applicants and employees with disabilities be provided privileges and opportunities in 

an equally effective and equally integrated manner)? 
18

o Will it be more difficult for applicants and employees with disabilities to obtain the 

employment opportunities and privileges than it is for applicants and employees 

without disabilities (i.e., does ease of use for applicants and employees with 

disabilities meet the requirement that applicants and employees with disabilities be 

provided privileges and opportunities in an equally effective and equally integrated 

manner)? 

Example: The training department at a company creates an online course that includes 

instruction, posting of assignments and other course content, and a forum where employees 

can discuss their course work with the instructor and each other. The instructor would like to 

incorporate video clips into the course, but is unable to obtain the video clips with audio 

descriptions. As a modification, the instructor creates separate audio descriptions for each 

video clip that narrate what is taking place in the video, and places them in a separate section 

of the online course. The online course includes links that enable persons who use screen 

readers to bypass the video clips completely and instead listen to the audio descriptions. 

Here, the use of detailed audio descriptions that are a part of the online course would provide 

employees with disabilities access to the same opportunities and benefits in an equally 

effective and equally integrated manner. Companies should also think about whether other 

accommodations may be needed to provide equal access. For example, an employee who 

uses a screen reader may need extra time to take an online examination because it may take 

time for the screen reader to process information displayed on a screen and provide that 

information to the employee. 

IV. ACTION STEP 3: UNDERSTAND THE BUSINESS CASE 

In making the business case for developing, procuring, maintaining or using accessible ICT, it is 

important to recognize that every company is different and every CEO or leading figure within 

each company is different—every business has a different motivator. Thus, there is a need to 

provide business leaders and decision makers with different approaches, opportunities and

information to determine what constitutes a compelling business case.36 

Below are examples of factors that can be used to make the business case for developing, 

procuring, maintaining or using accessible ICT.37 

• In an era when technology is redefining the workplace and creating a knowledge-based 

economy that places a high value on communication, collaboration and mobility, 

accessibility is increasingly essential in doing business.

• Accessible technology addresses the personal needs of all computer users, including those 

with sensory, physical, and learning and language impairments and age-related limitations, 

making it easier for companies to empower employees as well as serve customers and engage 

with partners. 

• As technology continues to transform the workplace, demand is growing for accessible 

technology that can accommodate the needs and preferences of all users. 
19

• Businesses are looking for more effective ways to recruit, empower and retain valuable 

employees and to increase their efficiency and productivity. 

• In today’s connected world, technology is at the heart of all of these initiatives. Yet to 

achieve these goals, companies must make technology and its benefits accessible to the 

largest possible number of people, regardless of age or ability.

• Accessible technology can make it easier for anyone to see, hear and use a computer. 

Accessible technology enables people with a wide range of abilities, including those with 

disabilities, age-related impairments or temporary limitations, in addition to novice computer 

or Web users, to adjust technology to accommodate their individual visual, dexterity, 

hearing, learning and language needs and preferences or to modify their personal technology 

experience. 

• Accessibility makes it easier for anyone to see, hear and use a computer and to personalize 

their computers to meet their own needs and preferences. If technology is truly accessible, it 

can be adjusted to meet the needs and preferences of people with a wide range of abilities, 

not just those with disabilities. 

• Most people who use computers also benefit from at least some accessibility features and 

settings that enable them to personalize their computers and work environments. 

• Accessible technology helps businesses support workforce diversity, recruit from a larger 

pool of candidates and enhance team collaboration and communication among all employees, 

including those with disabilities. For example, accessible technology can facilitate 

communication between sighted and non-sighted colleagues by providing just-in-time 

delivery of information without the need for special printing by enabling people who are 

blind or who have vision impairments to enlarge or customize fonts, choose high-contrast 

settings for greater visibility, or use a screen reader to access team documents.

• The percentage of the workforce represented by individuals 55 years and older is increasing. 

As a result of functional limitations that result from aging, these employees will require 

environmental modifications and/or technology accommodations. As the global population 

continues to grow older and the number of age-related impairments increases, so does the 

need for accessible and assistive technology. Many people with age-related disabilities 

develop those impairments during their working lives. 

• Companies that make accessibility a priority are sending a clear message to employees and 

customers alike that their needs matter. And that can breed satisfaction and loyalty. 

• Companies that make accessibility a priority in their business can advertise job openings, 

requests for proposals, and other opportunities on the websites that are accessible. 

• Another powerful consideration for making accessibility a part of any business is the sheer 

number of people around the world who need accessible technology, could benefit from 

using it, or choose to use accessible technology for a more comfortable or convenient 
20

experience. In the U.S., about one in five residents (54.4 million people) reported having 

some level of disability in 2005. Microsoft and Forrester Research report that more than half 

(57%) of computer users in the U.S. could likely benefit from accessible and assistive 

technology due to mild to moderate difficulties or impairments that interfere with their ability 

to use a computer or to perform routine tasks. 

• In addition, many nations are extending civil rights protections for people with disabilities 

that encompass accessibility and digital inclusion. Some governments are requiring 

procurement officials to purchase the most accessible products available, creating economic 

incentives for businesses to build accessible technology products. 

• For companies that manufacture technology, building accessible products and marketing 

them to people with disabilities can be advantageous. Customers with disabilities and their 

families, friends and associates represent a trillion dollar market segment. Like other market 

segments, they purchase products and services from companies that best meet their needs – 

and when buying technology, that means products that are accessible and usable.

V. ACTION STEP 4: SELF-ASSESS ICT PRACTICES, SET GOALS AND ESTABLISH 

PRIORITIES FOR IMPROVEMENT 

Given the business case and policy mandates for providing accessible ICT, it is advisable for 

organizations to self-assess their internal and external technologies and set priorities for 

improvement. This will help facilitate the adoption of formal, written policies, practices and 

procedures to enhance employment opportunities and privileges of employment for individuals 

with disabilities through accessible ICT. 

Companies should begin by considering all of the ICT used or offered by their organization and

then making a list of those platforms, devices and applications. This will position them to 

evaluate the accessibility of each item on their inventory by considering the user experience of 

applicants, employees, and customers who have various disabilities; and the ability of their tools 

and processes to support production of accessible materials. This exercise may involve formal 

testing of ICT applications with automated accessibility testing tools. (See Section Action Step 8

for helpful testing resources.) Others answers may be found by interviewing existing employees 

with certain disabilities or conducting informal focus groups. The Appendix of this document 

contains a sample checklist to help guide organizations through the self-assessment exercise. 

It is likely that this process will identify ICT in the organization that is not accessible to and

usable by people with disabilities. Remedying all of the identified issues at once may not be 

realistic for some organizations due to cost and legacy IT infrastructure constraints. However, 

leading companies commit to making all the necessary changes, either immediately or in the 

longer term. (See Action Step 7 for more information on setting priorities and measurable 

objectives.) 
21

VI.ACTION STEP 5: ADVANCE CORPORATE POLICIES, PRACTICES AND 

PROCEDURES

A. Introduction

As mentioned previously, to enhance employment opportunities and privileges of employment 

for individuals with disabilities through accessible ICT, it is necessary to refine and advance 

corporate policies, practices and procedures that define the nature and scope of the commitment. 

Best and promising business practices regarding accessible ICT include the adoption of formal, 

written policies, practices and procedures. ICT procurements or ICT projects (developed, 

maintained or used) should comply with specific technical ICT accessible standards and 

functional performance criteria. These include: 

• Software applications and operating systems

• Web-based Intranet and Internet information applications

• Telecommunication products

• Video and multimedia products

• Self-contained, closed products

• Desktop and portable computers 

A summary of the current Section 508 regulations applicable to each of these topic areas,38

which are expected to be replaced with more updated provisions at some future date,39 follows. 

B. Software Applications and Operating Systems

Most of the specifications for software pertain to usability for people with vision impairments. 

For example, one provision requires alternative keyboard navigation, which is essential for 

people with vision impairments who cannot rely on pointing devices, such as a mouse. Other 

provisions address animated displays, color and contrast settings, flash rate and electronic forms, 

among others.40 Companies should consider these issues when assessing their internal business 

applications, such as accounting/financial software, travel booking systems, time entry 

applications, client databases, customer relationship management (CRM) software and other 

applications. E-mail systems, instant messaging applications and operating systems also fall into 

this category. All employees, regardless of disability, should be able to access these systems 

with or without assistive technologies. 

C. Websites

Making websites accessible is neither difficult nor especially costly, and in most cases providing 

accessibility will not result in changes to the format or appearance of a site.41 It has been shown 

that businesses can flourish while producing accessible websites and services. In particular, it 

has been shown that the WCAG 2.0 guidelines are feasible for simple “Mom and Pop” websites, 

as well as for complex and dynamically-generated million-page websites.42 

Web accessibility is about designing and coding pages so as many people as possible can access 

them effectively and efficiently (universal design). Web accessibility specifically ensures 
22

effective and meaningful opportunities for individuals with disabilities to use and interact with 

the company through the Internet and company website. 

According to the Access Board, the criteria for Web-based technology and information included 

in the Section 508 regulation43 are based on access guidelines developed by the WAI of the 

W3C. Many of these provisions ensure access for people with vision impairments who rely on 

various assistive technology products to access computer-based information, such as screen 

readers, which translate what's on a computer screen into automated audible output, and 

refreshable Braille displays. Certain conventions, such as verbal tags or identification of graphics 

and format devices, like frames, are necessary so that these devices can "read" them for the user 

in a sensible way. The standards do not prohibit the use of website graphics or animation. 

Instead, the standards aim to ensure that such information is also available in an accessible 

format. Generally, this means use of text labels or descriptors for graphics and certain format 

elements. (HTML code already provides an "Alt Text" tag for graphics that can serve as a verbal 

descriptor for graphics.) This section also addresses the usability of multimedia presentations, 

image maps, style sheets, scripting languages, applets and plug-ins, and electronic forms. 

Below are examples of areas of focus and practices regarding accessible websites that a company

may want to adopt.44

Website Home Pages: 

• External Internet homepage (mission, activities, information about programs, benefits, 

information about products and services, publication of resources, employment postings). 

• Internal Intranet homepage (mission, activities, programs and benefits, products and 

services, resources, employment postings).

• Web-based forms (applying for programs and benefits, ordering products or services, 

feedback, contact information search, publication resource search, filing a complaint, 

employment search).

• Web-based applications (applying for programs, benefits, ordering products or services, 

training/learning, travel reservation, time and attendance, recordkeeping/tracking, survey, 

employment)

Items on a Website: 

• Portable document files (.pdfs)

• Multimedia content (video and audio)

• Flash content

• Word processing files

• PowerPoint or other presentation files

• Data tables

• Spreadsheet files

• JavaScript or other scripts
23

• Java applets

• Blogs (web logs)

• Facebook

• MySpace

• Twitter

• YouTube 

• Flickr

Typical barriers (key issues)45:

• Images not labeled properly with an alternative text description;

• Inconsistent navigation including poor hypertext link text;

• Inaccessible forms for Web users who are blind and use screen reader software;

• Information validation techniques that cause problems with adaptive technology used by 

people with disabilities; and

• Information laid out in tables (for example job listings frequently are not coded properly 

for accessibility). 

Create an Accessible Website:

• Determine internal accessibility standards for website. See, for example the standards 

developed by the Access Board implementing Section 508 of the Rehabilitation Act46 and 

the WCAG guidelines.

47 WCAG 2.0 is based on a series of success criteria prioritized 

into three levels.

• Develop a strategic plan to upgrade the accessibility of current site. 

• Use latest Web design software that has inbuilt accessibility prompts.

• Test site’s accessibility using available tools (software) and repeat whenever new 

templates are introduced.48

• Consider using experts and individuals with different impairments to audit website.

• Communicate required standards to everyone involved, including vendors/suppliers.

• Ensure that the employees and suppliers who are involved with Web design, maintenance 

and content development have Web accessibility awareness training.

• Review and update guidelines regularly to incorporate latest developments in Web 

accessibility, particularly changes to the Section 508 and WCAG guidelines. 

D. Telecommunications Products

The provisions in the Section 508 regulations related to telecommunication products are 

designed primarily to ensure access to people who are deaf or hard of hearing.49 This includes 

compatibility with hearing aids, cochlear implants, assistive listening devices and TTYs. TTYs 

are devices that enable people with hearing or speech impairments to communicate over the 

telephone; they typically include an acoustic coupler for the telephone handset, a simplified 

keyboard and a visible message display. One requirement calls for a standard non-acoustic TTY 

connection point for telecommunication products that allow voice communication but that do 

provide TTY functionality. Other specifications address adjustable volume controls for output, 
24

product interface with hearing technologies, and the usability of keys and controls by people who 

may have impaired vision or limited dexterity or motor control. 

Future updates to the Section 508 regulations are likely to include accessibility considerations for 

mobile telephones and other wireless devices, which many organizations are issuing to their 

employees. When choosing these devices, employers should consider the ability to connect an 

alternative headset to particular devices; whether the keys on the keypad are easily discernible 

from one another; whether there are adjustable contrast and brightness controls; whether the 

handset has non-slip grips to prevent the phone from slipping out of the hand; and other display 

characteristics such as the screen size, adjustability of font sizes and more.

50 

E. Video or Multimedia Products 

The Section 508 regulations specify standards for video or multimedia products.51 Multimedia 

products involve more than one media and include, but are not limited to, video programs, 

narrated slide productions and computer generated presentations. Provisions address caption 

decoder circuitry (for any system with a screen larger than 13 inches) and secondary audio 

channels for television tuners, including tuner cards for use in computers. The standards also 

require captioning and audio description for certain training and informational multimedia 

productions developed or procured by federal agencies. The standards also provide that display 

or presentation of alternate text or audio descriptions shall be user-selectable, unless permanent.

It is an exemplary practice to apply these same standards to webcasting and video conferencing 

systems, which many companies are using to help employees communicate from multiple 

locations. Likewise, these practices should be incorporated into corporate events and activities, 

where videos can be captioned and audio described, and where presentation materials can be 

provided in alternative formats. 

F. Self-Contained, Closed Products 

The Section 508 regulations specify standards regarding self-contained, closed products.52 This 

section covers products that generally have embedded software but are often designed in such a 

way that a user cannot easily attach or install assistive technology. Examples include information 

kiosks, information transaction machines, copiers, printers, calculators, fax machines and similar 

types of products. The standards require that access features be built into the system so users do 

not have to attach an assistive device to it. Other specifications address mechanisms for private 

listening (handset or a standard headphone jack), touch screens, auditory output and adjustable 

volume controls, and location of controls in accessible reach ranges. 

G. Desktop and Portable Computers 

The Section 508 regulations include a section that focuses on keyboards and other mechanically 

operated controls, touch screens, use of biometric form of identification, and ports and 

connectors. These standards include ensuring that controls and keys are tactilely discernible 

without activating the controls or keys; that controls and keys are operable with one hand and do 
25

not require tight grasping, pinching or twisting of the wrist; and that the status of all locking or 

toggle controls or keys is visually discernible and discernible either through touch or sound.53

H. Information, Documentation and Support 

The Section 508 regulations include standards that address access to all information, 

documentation and support provided to end users (e.g., federal employees) of covered 

technologies.54 This includes user guides, installation guides for end-user installable devices, and 

customer support and technical support communications. Such information must be available in 

alternate formats upon request at no additional charge. Alternate formats or methods of 

communication can include Braille, cassette recordings, large print, electronic text, Internet 

postings, TTY access, and captioning and audio description for video materials. 

I. Online Application Systems

Online application systems have gained popularity because they can be used by companies to 

streamline the hiring process, including: developing position descriptions, attracting candidates, 

processing resumes, qualifying job applicants, selecting candidates and making employment 

offers. Below are descriptions of key components of a typical online application system:

55 

• Website Integration

• Job Posting and Distribution Tools

• Application and Resume Submission 

• Communication Between Applicant and Employer 

• Resume Extraction and Management 

• Candidate Search and Selection Process (including Ranking and Rating)

• Employee Offer Management

Each feature of the online application system should be reviewed to determine whether it is 

accessible through the company’s website.56 Web accessibility is about designing and coding a 

company’s pages so as many people as possible can access them effectively and efficiently 

(universal design). Web accessibility specifically ensures effective and meaningful opportunities 

for individuals with disabilities to use and interact with the company through the Internet and 

company website and ultimately apply for jobs through the online application system.

• Website Integration. Connects the company’s website with staffing (i.e., job seekers can 

submit their resume and complete an online job application). The candidate’s information 

streams directly from the website into Applicant Tracking database. 

• Job Posting and Distribution Tools. A company is able to access millions of job 

seekers by automatically posting their job opening from open requisitions to their internal 

and corporate website and to hundreds of other popular Internet job boards (from big 

boards to niche and specialized jobboards). 

• Application and Resume Submission. Candidates can submit their resume 

electronically and complete an online job application. 
26

• Communication Between Applicant and Employer. The company can control when 

communication with the applicant occurs and what is communicated to the applicant. 

• Resume Extraction and Management. The company is able to:

o Add new resumes to a database; 

o Extract detailed information from resume to improve the quality of job order 

matches; 

o Keep track of actions performed on each applicant until applicant is employed; 

o Import resumes thru e-mails, batch upload or real time; and 

o Configure resumes from different sources as resume repositories. 

• Candidate Search and Selection Process (Including Ranking and Rating) 

o Companies define their own candidate selection process; 

o Multiple search options provided from the resume repositories to search for best 

match; and

o Each candidate’s database record and resume can be viewed from the search 

results and if an e-mail address is provided, candidates can be e-mailed directly 

from the search results without losing the search results. 

• Employee Offer Management

o Once a candidate is initially identified as suitable (ranking and rating), track the 

candidate through the major stages of the recruiting process, such as: 

 Prescreening

 Technical skills screening

 Reference checking

 Resume submission

 Interviewing

 Employment offer sent

 Offer accepted.

o Activities for each candidate are recorded so that hiring metrics can be tracked for 

reporting purposes. Also allows a candidate who has been selected to be 

converted to an employee. 

According to OFCCP, if a company (in the case of Section 503, a government contractor) 

routinely offers applicants various methods of applying for jobs and all methods of 

application are treated equally, then an employer may, but need not, ensure that its online 

application system is fully accessible.57 But, if a company only uses an online application 

system to accept applications for employment, it should ensure that potential applicants with 

disabilities either can use the system or can submit an application in a timely manner through 

alternative means as an interim measure until the website is made fully accessible. This 

includes providing a means to contact the company, other than through the online system, to 

request any reasonable accommodation needed to provide an applicant with a disability an 

equal opportunity to apply and be considered for the company’s jobs. At a minimum, the 
27

notice should contain the name of the person to contact and the process for requesting an 

accommodation.

As explained under Action Step 2, equal opportunity means an opportunity to obtain the 

same level of performance, or to enjoy the same level of benefits and privileges of 

employment that are available to similarly situated employees or applicants without 

disabilities. Factors to consider in determining whether an opportunity is equal to and as 

effective as that provided to others may include providing the same degree of efficiency, 

immediacy and convenience. 

Below are examples of practices regarding the use of an alternative means of application for 

employment that a company may want to adopt as interim measures until the website is made 

fully accessible.58

• Determine how the alternative method provides equal opportunity (e.g., provides the 

same degree of efficiency, immediacy and convenience). 

• Advertise the alternative means on the website as an interim measure until the 

company’s website is fully accessible. Emphasize that it is an alternative and is 

intended only for candidates who cannot use the mainstream system, or who are 

unreasonably disadvantaged by doing so.

• Highlight the benefits of applying online while assuring applicants that if they cannot 

apply online they will not face discrimination.

• Provide person-to-person communication. Train and equip HR personnel and “webhelp” team to communicate with people with disabilities e.g., textphones, online 

instant message.

• Keep candidates in the mainstream. Feed candidates back into the mainstream process 

as quickly as possible. 

• Provide for a representative not involved in the employment process to enter 

information into online application system on their behalf (or outsource this function 

to their applicant tracking provider).

• Note: it is discriminatory to automatically direct all candidates with disabilities to the 

alternative means.

• If you provide candidates with the option to receive e-mail or text alerts about future 

vacancies, ensure people with disabilities who have applied offline also have access 

to this service. 

Having an online application system that includes universal design features or that includes 

many accessibility features for individuals with disabilities does not relieve a contractor of its 

obligations to provide reasonable accommodations if needed to address the inability of an 

applicant with a disability to use or access the online system.59

Below are examples of practices regarding the provision of reasonable accommodations in 

the context of online application systems that a contractor may want to adopt.60

• Notify the applicant of the right to request a reasonable accommodation if he or she is 

unable or limited in ability to use or access the online system as a result of disability 
28

unless the contractor can demonstrate that the accommodation would impose an 

undue hardship on the operation of its business. 

• Include in a notice an explanation of how to obtain reasonable accommodations via 

its online application system as well as on its paper applications and job 

announcements.

• The notices should contain the name of the person to contact and the process for 

requesting the reasonable accommodation. 

• The notices should be prominently displayed and included at the beginning of the 

online application process.

VII. ACTION STEP 6: ESTABLISH AN INFRASTRUCURE FACILITATING 

IMPLEMENTATION OF THE POLICIES

To realize and sustain the vision and promises reflected in the formal written policies, practices 

and procedures (Action Step 5), it is necessary to establish corporate infrastructure and 

organizational strategies.61 Best and promising practices regarding the establishment of a 

corporate infrastructure and organizational strategies implementing an accessible ICT policy

include:

• Leadership and Team Approach

• Outsourcing and Procurement

• Training

• Deployment

A. Leadership and Team Approach (Managers Across Divisions) 

Leadership at the highest level of business is critical to secure “buy-in” and establish and sustain 

a corporate-wide culture (not limited to HR) that increases awareness, creates expectations, and 

enhances commitment to hiring, retention and advancement of persons with disabilities through 

accessible ICT. The outcome of successful leadership will be a corporate commitment that is 

pervasive and lasts much longer than the terms of office of one or two corporate leaders that 

currently support its commitment.62 

While leadership at the highest levels of a business is necessary to implement and sustain the 

corporate-wide commitment, it is also critical to recognize that CEOs are policymakers—not 

policy implementers/enforcers or the people who are actually implementing the work (i.e., 

people exercising day-to-day responsibility for lines of business where hiring and product 

development occur). There is a need to secure a network of responsible individuals consisting of 

policymakers, policy enforcers and policy implementers (different lines of business).63 

Best practice regarding implementation of an accessible ICT policy includes formalizing a team 

approach (e.g., an accessibility team comprised of managers across divisions including ADA 

compliance (ADA Coordinator), HR, ICT (the Chief Information Officer) and the Chief 

Technology Accessibility Officer, procurement (the Chief Acquisition Officer), education and 

training, financial and marketing). 
29

B. Outsourcing and Procurement

1. Outsourcing

Many companies choose to outsource all or part of their responsibilities to purchase, develop, 

procure or maintain ICT including the design and maintenance of websites. As explained under 

Action Step 2 (Understand the Policy Framework), it is unlawful for companies to participate in 

a contractual or other arrangement or relationship that has the effect of subjecting the company’s 

own qualified applicants or employees with disabilities to the discrimination prohibited by the 

regulations. In other words, from a civil rights compliance perspective, the company is 

responsible for making decisions regarding accessible ICT, not the vendor. Companies must 

comply with applicable standards. Below are examples of practices regarding outsourcing that a 

company may want to adopt:64 

• Conduct a detailed review of all current ICT in line with the company’s standards and 

work with third party suppliers to ensure that the company’s ICT is truly accessible. 

• Identify who needs to be involved in overcoming barriers, including suppliers and 

partners (minimizing the risks of outsourcing).

• Insist that job boards on which the company advertises are accessible to people with 

disabilities. 

• Make business reasons for adopting accessible ICT policy when suppliers are invited 

to tender a proposal. 

• Ensure contracts stipulate that suppliers will, when relevant, apply ICT accessibility 

standards. 

• Stipulate who will be responsible for meeting the cost of adjustments.

• Ensure the technology can be used by any employees with disabilities who are 

involved in recruitment, including those who use assistive technology. 

• Give suppliers and business partners a copy of ICT accessibility guidelines.

2. The Procurement Process

A well-written solicitation goes a long way toward ensuring the procurement of accessible ICT.65

The solicitation should:

• State that the ICT must be accessible. 

• Indicate which provisions of the applicable accessible ICT standards apply to purchase. 

• Request accessibility information from vendors that respond to solicitation. 

• Evaluate received proposals based on responses to accessibility requirements. 

• Let vendors know of plans to inspect deliverables based on meeting accessibility 

requirements (i.e., “acceptance testing”).

It is not enough to simply state that the ICT products or services that the company intends to buy 

must conform to the applicable accessible ICT standards. The procurement officer should 

identify ICT deliverables covered by the accessible ICT standards and then identify the 

applicable technical standards; functional performance criteria; and information, documentation 

and support that apply to each ICT deliverable. It is not permissible to leave it to the vendor to 
30

determine if accessible ICT standards are relevant to the solicitation or which standards are 

applicable. The company is responsible for making these decisions, not the vendor. ICT vendors 

do not have to comply with anything—companies must comply with applicable standards by 

procuring products that conform. Vendors who don’t make products that conform to the standard 

are not likely to remain customers of the company for very long until they do. 

Creating a compliant ICT solicitation is not difficult if companies include accessibility in 

procurement planning, identify specifically the provisions that apply to the ICT deliverables 

being procured, and conduct accessibility market research. These processes cannot be done ad 

hoc; companies need to have a detailed process for addressing accessible ICT. The 

BuyAccessible System, a set of free Web-based tools developed by GSA for federal government 

agencies, provides companies with such a process.

66 

Below is a checklist prepared by GSA for determining compliant solicitations using Section 508 

standards. The checklist may be used by private sector employers. 

DO THE FOLLOWING:

• Provide a clear statement that an ICT Accessibility Standard (such as Section 508 

or WCAG 2.0) does or does not apply to the solicitation. 

• Indicate if an exception is being claimed. 

• Indicate applicable technical section and provision of the ICT contract 

deliverables. 

• Indicate functional performance criteria applicable to the ICT contract 

deliverables. 

• Indicate which information, documentation and support requirements are 

applicable to the ICT contract deliverables. 

• Specify applicable accessibility factors as evaluation criteria. 

• Request accessibility information from the responder. 

• Specify applicable accessibility factors as inspection and acceptance criteria. 

• Ensure the solicitation and any associated documents and attachments are in an 

accessible format.

AVOID THE FOLLOWING: 

• Do not request that an ICT Accessibility Standard’s (such as Section 508 or 

WCAG 2.0) relevance be determined by the vendor. 

• Do not request that the ICT Accessible Standard applicability be determined by 

the vendor. 

• Do not request that ICT Accessibility Standard exceptions be determined by the 

vendor. 

• Do not request an ICT deliverable accessibility certification of compliance (Note: 

Potential vendors should be asked to provide information on conformance with 

the stated accessibility factor requirement through a VPAT or GPAT or other 

documentation. This proof of conformance is not the same as a request for a 
31

certificate of compliance, as there is currently no certifying body for Section 508 

accessibility.) 

3. Role of Procurement or Contracting Officials67 

As explained above, a compliant solicitation should, among other requirements, articulate the 

specific accessible ICT standards that apply to the solicitation, not simply include a reference or 

assurance of compliance with the standards. The Chief Acquisition Officers (CAOs) and Chief 

Information Officers (CIOs) working with the Chief Accessible Technology Officer, play key 

collaborative roles in the area of securing the purchase of accessible ICT. CAOs and CIOs, in 

consultation with the Chief Accessible Technology Officer, should review their procurement and 

information technology acquisition policies and procedures to validate that the accessible ICT 

standards are appropriately considered and clearly stated in solicitation documents. CAOs should 

consider sampling agency procurements that include ICT to ensure they properly specify the 

appropriate accessible technology standards. 

CIOs should have specific obligations including monitoring implementation of the requirement 

that selected information resource systems or processes facilitate accessibility. Also, CIOs

should ensure ICT capital planning and control comply with applicable accessible ICT 

requirements (i.e., CIOs should instruct agency project managers to review capital planning and 

investment control documentation for compliance with applicable accessible ICT standards). 

1. A procurement or contract official can use the http://www.BuyAccessible.gov

website to:

• Determine if a purchase is subject to the applicable accessible technology 

standard (such as Section 508 or WCAG 2.0).

• Find language for the solicitation. 

• Find companies and do market research to buy ICT products or services. 

• Provide documentation for compliance. 

2. A procurement or contracting official is responsible for producing specific language 

for solicitations for ICT products and services. This will include:

• Basic language regarding Section 508/WCAG 2.0 relevance. 

• Section 508/WCAG 2.0 applicability. 

• Section 508/WCAG 2.0 factors for proposal evaluation. 

• Section 508/WCAG 2.0 criteria for deliverable acceptance. 

In addition, the procurement or contracting official will evaluate acquisition deliverables 

based on generally accepted inspection and/or test methods. 

3. The contracting officer—the person with the actual authority to enter into, administer 

and/or terminate contracts and make related determinations and findings—must 

understand the requirements of Section 508/WCAG 2.0 relative to procuring ICT
32

products and services. The contracting officer’s responsibilities include: 

• Awarding the contract after complying with procurement statutes and 

regulations (FAR). 

• Assisting the requiring official in performing market research for accessible 

ICT. 

• Assisting the appropriate official in drafting specifications and minimum 

requirements/agency needs when these are need for procurement. 

• Ensuring there is competition and that the contracting file shows what 

happened, as the FAR directs. 

C. Accessibility Training for In-House Staff 

It is often stated that “people often don’t know what they don’t know.” It is a best and promising 

practice for companies to extend training and professional development opportunities to all 

offices, divisions and departments of the company. The company should also expand its base of 

knowledge and experience through various strategies, demonstrations and newsletters.68 

The following is a list of staff for which training provided by the Chief Accessible Technology 

Officer and others would be appropriate:

• ADA coordinators

• Program managers

• Contracting or procurement officers

• Software developers

• Web developers

• Video/multimedia developers

• IT Help desk staff

• Others

The following are possible topics for inclusion in the training: 

• ICT accessibility standards 

• How to buy accessible ICT

• How to create accessible software

• How to create an accessible website

• How to create accessible electronic forms

• How to create accessible electronic documents

• How to create accessible pdfs

• How to caption video or multimedia

• How to evaluate software, websites and other documents for accessibility
33

D. Deployment 

After a company has purchased or developed accessible ICT, it still has to deploy it throughout 

the company. To realize the greatest productivity benefits from accessible ICT, companies 

should:69

• Establish a mechanism for centralized expertise and/or payment for assistive technology 

devices and services. 

• Provide for specialized expertise to assess and evaluate an applicant’s or employee’s need 

for assistive technology, where necessary and appropriate.

• Train staff in accessibility assessment.

• Enter into strategic partnerships with resources in the community to gain insight, 

information and expertise regarding accessible ICT, including assistive technology 

devices and services. 

• Provide online resources for learning about specific types of assistive technology 

products. 

• Provide training to employees interested in learning more about how to use assistive 

technologies and/or accessibility features of various products. 

• Involve persons with disabilities in the implementation of accessible ICT policy by 

establishing a group of employees impacted by the policy.

 

VIII. ACTION STEP 7: COMMIT TO ACCOUNTABILITY AND CONTINUOUS 

IMPROVEMENT

The adoption of written policies, practices and procedures and the establishment of corporate 

infrastructure and organizational systems are necessary components of an ICT accessibility 

strategic plan. However, ensuring implementation is the end goal. Best business practices include 

establishing accountability mechanisms and methods for ensuring continuous improvement. 

Such mechanisms and methods include:

• Appointment of ADA Coordinator, Appointment of Chief Technology Accessibility 

Officer and Designation of Responsible Managers

• Notice of Policy and Responsible Persons and Offices 

• Participation by Individuals with Disabilities and Outside Experts

• Establishment of Measurable Objective and Benchmarks

• Monitoring, Auditing, Reporting and Continuous Improvement

• Prioritizing Areas Needing Improvement

A. Appointment of ADA Coordinator, Chief Technology Accessibility Officer and 

Designation of Accountable Managers

Designation of authority and assigning responsibility for implementation is a central feature of 

any implementation effort. Specific examples of strategies and practices regarding the 

designation of responsibility for implementation that have proven successful include: 70
34

(1) Assigning responsibility to specific individual(s) (Chief Technology Accessibility 

Officer) for implementation of the employer’s accessible ICT strategic plan.

(2) Providing these official(s) top management support and, if appropriate, staff to manage 

the implementation of this strategic plan (affirmative action program), and a reasonable 

budget. 

(3) Identifying the individual on all internal and external communications regarding the 

company's ICT strategic plan. 

(4) Defining the scope of responsibility for implementation to include, among others, the 

following functions:

• Developing the strategic plan. 

• Assisting in the identification of problem areas and in the development of 

solutions to those problems. For example, making available and keeping 

updated office addresses, 1-800 telephone numbers and e-mail addresses of the 

ADA Coordinator(s) and the Chief Accessible Technology Officer. This 

information should be accessible on the company’s “Diversity and 

Accessibility” page, which should be accessible via a link that is predictable and 

in an accessible location on the company’s website home page, in a format 

accessible to persons with disabilities. 

• Coordinating activities of accessible ICT team members.

• Monitoring the effectiveness of the program on a continuing basis through the 

development and implementation of an internal audit and reporting system that 

measures the effectiveness of the program. 

• Keeping upper management informed of progress and problems within the 

company through quarterly reports.

• Providing department managers with a copy of the strategic plan and reviewing 

the plan with them on an annual basis to ensure knowledge of their 

responsibilities for implementation of the plan. 

• Reviewing the plan with all managers and supervisors at all levels to ensure that 

the policy is understood and is followed in all activities.

• Auditing the contents of company bulletin boards and Web sites annually to 

ensure that compliance information is posted and up-to-date.

• Serving as liaison between the company and enforcement agencies.

• Advising managers and supervisors annually of their responsibilities under the 

company’s plan and of their obligations to:

o Review the company’s policy with subordinate managers and supervisors to 

ensure that they are aware of the policy and understand their obligations; and

o Assist in the identification of problem areas, formulate solutions, and establish 

departmental goals and objectives when necessary.

(5) The office(s) or person(s) who have the responsibility for implementing and ensuring 

compliance with the policy should provide the following services to ensure compliance:
35

• Assist acquisition officials in preparing accessible ICT language in ICT contracts

• Assist developers in designing software that complies with accessible ICT standards

• Create or repair electronic documents to comply with ICT accessibility standards

• Evaluate websites

• Evaluate software

• Evaluate hardware

• Provide training

• Provide alternate formats

B. Notice of Policy and Responsible Persons and Offices 

Post and maintain a copy of the summary description of the ICT accessibility policy on the 

company’s “Diversity and Accessibility” page, which should be accessible via a link that is a 

predictable and in an accessible location on the company website homepage, in a format 

accessible to persons with disabilities (i.e., HTML). The summary description is available in 

alternate formats (such as large print, Braille, audio recording, electronic formats) upon request 

with reasonable promptness.71 

C. Participation by Individuals with Disabilities and Outside Experts

In order to enhance accountability and ensure that policies, practices and procedures truly 

enhance access for applicants and employees with disabilities, it is important to involve people 

with disabilities and outside efforts in the monitoring and implementation. Best practices include 

the following:72

• Involve people with disabilities at each stage, particularly when testing whether the 

changes the company has made are successful. 

• Develop relationships with experts and learn what other companies are doing.

• Adopt the benchmarks and measures by teams that include experts knowledgeable about 

accessible and usable electronic and information technology and persons with disabilities.

• Seek input from employees with disabilities using employee surveys and focus groups 

and discussions with employee diversity and advisory groups regarding the workplace 

environment. Include persons with disabilities and members of employee resource groups 

on self-assessment endeavors (e.g., progress and monitoring teams).

D. Measurable Objectives, Benchmarks and Prioritizing Areas Needing Improvement

A “conformance evaluation” or audit of an organization’s information and communications 

technology (ICT) will help companies self-assess the accessibility of their existing technologies 

and plot a course for improvement. Setting measurable objectives and benchmarks at the onset 

of this exercise is key to the evaluation and strategic planning process.
36

While no official method of evaluating ICT accessibility exists, many organizations offer 

checklists, scorecards and grid-based tracking documents designed to help users evaluate their 

compliance with Section 508 and other accessibility practices. See the Appendix for a partial list 

of these resources, as well as a sample benchmarking tool. 

Some of these technical assessments feature a specific scoring mechanism (e.g., where a red 

score signifies a lack of Section 508 compliance, yellow indicates partial compliance and green 

indicates that the technology application is fully accessible).73 Whether adopting this sort of 

scoring taxonomy or another, it is a best practice for companies to evaluate each ICT application 

or platform consistently, and to assign a benchmark “score” to each item at the start of the 

exercise so that success can be measured. 

It is equally important to set measurable objectives by prioritizing ICT applications that need 

accessibility modifications and setting dates by which improvements will be implemented. Such 

objectives should be included in the strategic plan and monitored frequently. (See following 

section.) 

As mentioned above, it is highly likely that a company’s self-assessment exercise will identify 

ICT in the organization that is not accessible to and usable by people with disabilities. 

Remedying all of the identified issues at once may not be realistic for some organizations due to 

cost and legacy IT infrastructure constraints. However, leading companies commit to making all 

the necessary changes, either immediately or in the longer term. 

Organizing a prioritized list of accessibility errors and problems is an exemplary practice that can 

make the improvement process more manageable while ensuring the most critical repairs are 

made first. Priority projects may vary for each company. Some (particularly organizations 

subject to Sections 503, 504 and 508) may choose to address their regulatory compliance 

shortcomings first. Others may begin by fixing applications that have been the subject of 

complaints by users with disabilities. Tasks may also be categorized by ease/level of effort, cost 

and timing. For example, if a company is about to replace a system, it is usually more logical to 

ensure that the new application is fully accessible rather than spending time and effort on fixing 

the legacy system. 

The W3C provides guidance on setting priorities for improving website accessibility. It 

recommends setting a target standard for compliance, for example WCAG 2.0 Level AA (which 

includes Level A and Level AA). It also explains that in some website retrofitting situations, 

organizations might define a multi-tiered target with different dates for different levels, for 

example, “meet WCAG 2.0 Priority Checkpoints in key Web pages within two months, and meet 

those Checkpoints in all pages within nine months.” Additional guidance from W3C includes 

the following: 

Prioritizing by Barriers74

• One approach to retrofitting is to fix all of the Level A barriers first, and then fix Level 

AA barriers later. There are several disadvantages to this approach: having to go back 

over templates, style sheets and pages multiple times; missing easy-to-do, lower priority 
37

items; and getting stuck on a few hard problems, instead of getting lots of easy things 

done quickly. 

• A more effective approach in most cases is to do all of the high impact and easy repairs 

while working on a page, template, style sheet, etc. Then address harder problems later. 

This approach has several advantages: it usually takes less time overall and many

changes are completed quickly. This helps demonstrate a commitment to improving the 

accessibility of a website as soon as is feasible.

• To plan for retrofitting, consider two parameters for prioritizing the order in which to 

address accessibility barriers: impact and effort. For each accessibility barrier, determine:

• Impact on people with disabilities. Accessibility barriers are often identified by 

WCAG 2.0 Checkpoint. Each Checkpoint has a priority that helps determine the 

impact of a particular accessibility barrier. The actual impact on users of a specific 

barrier depends on the context of your site. For example, poor color contrast in the 

main content has high impact on some people with disabilities, whereas in generic 

footers it may have low impact. Evaluating with users with disabilities also helps 

determine the impact of accessibility barriers in a website.

• Effort required for repair. The time, cost and skills to repair a barrier varies greatly 

based on parameters such as the type of repair and the development environment. For 

example, repairing barriers in footers could require a simple change to the template 

that is automatically propagated throughout the website, or could require changing 

every page manually. Repairing missing alternative text equivalents requires knowing 

the content and understanding how the text is used; whereas, changing a site to 

effectively use style sheets requires CSS skills.

Prioritizing by Area75

• Another aspect of prioritizing retrofitting is determining which areas to work on first. 

It is usually best to first repair those areas that have the greatest impact on users' 

experience with a website. Depending on how a site is developed, many barriers may 

be able to be repaired through: 

• Templates that impact many pages

• Style sheets that impact many pages

• Elements that impact many pages, such as navigation bars and scripts

• Certain pages may have higher priority, such as:

 The home page, which is often the first entry point to the site

 The main pages and functionality based on the purpose of the site, 

including: 

• The path to get there from the common entry points

• The path to complete transactions, such as ordering products

• Frequently-used (high traffic) pages and functionality, including the path to get 

there and complete transactions
38

E. Monitoring, Auditing, Reporting and Continuous Improvement

Companies understand that “what is measured is what counts.”76 Monitoring, auditing and 

reporting systems are necessary to ascertain whether current accessible ICT policies, practices 

and procedures are effective. Specific examples of strategies and practices regarding monitoring, 

auditing and reporting systems that have proven successful include:77

(1) Designing and implementing an audit and reporting system that will:

• Measure the effectiveness of the company’s strategic plan. 

• Determine the degree to which the company’s goals, priorities and objectives have 

been attained.

• Indicate any need for remedial action.

(2) Where the company’s strategic plan is found to be deficient, undertaking necessary action 

to bring the program into compliance.

(3) Identifying trends and/or issues for making informed decisions on issues needing more 

attention.

(4) Tracking information that could be used to assess the effectiveness of the accessible ICT 

policy. 

(5) Using the accessible ICT diagnostic evaluation benchmarks and measures to continuously 

improve and enhance the accessibility and usability of the ICT. 

(6) Establish a continuous feedback mechanism that includes a state-of-the-company briefing 

to the CIO every six months with respect to the accessibility and usability of electronic 

and information technology, and annually to the CEO with respect to progress made in 

implementing the affirmative action program, including reaching benchmarks.

(7) Establishing a complaint tracking system. The company might implement a toll-free 

telephone number (ADA Comment/Complaint Line) and an e-mail address (ADA e-mail 

address) that are used solely to receive comments and complaints relating to treatment or 

access to company services, benefits, privileges, advantages, facilities and 

accommodations for individuals with disabilities. The ADA coordinators should ensure 

that each call and e-mail with requests or comments requiring a response will receive a 

response within fourteen days after it is received. The ADA e-mail address can provide 

an automatically generated acknowledgement of receipt of incoming mail. 

(8) Providing for quarterly reports regarding implementation of the company’s strategic plan 

In quarterly reports, identify completion dates and identify the manager who is 

accountable and responsible for ensuring that the action item is completed in a timely 

manner. If action items are not completed in a timely manner, company managers should 

be held accountable for their performance deficiencies. 
39

IX. ACTION STEP 8: IDENTIFY AVAILABLE RESOURCES 

There exists a wealth of information and resources to help companies understand accessibility 

and successfully meet the needs of qualified individuals with disabilities through the 

development, procurement, maintenance and use of accessible ICT. The final action step a 

company can take in support of these efforts is to identify and review the educational material 

available. Below is a sampling of available resources offered by the federal government and key 

nongovernmental organizations: 

A. General Regulatory Guidance (on Sections 503, 504 and 508 of the Rehabilitation Act of 

1973, as amended) 

• Resources for understanding and implementing Section 508 - http://www.section508.gov 

• Resources for understanding and complying with Section 503 - 

http://www.dol.gov/compliance/laws/comp-rehab.htm and 

http://www.dol.gov/ofccp/regs/compliance/sec503.htm 

• Fact sheet for understanding rights under Section 504 from the U.S. Department of 

Health and Human Resources - 

http://www.hhs.gov/ocr/civilrights/resources/factsheets/504.pdf 

• Frequently asked questions about Section 504 from the U.S. Department of Education - 

http://www2.ed.gov/about/offices/list/ocr/504faq.html 

B. Understanding the Business Case 

• Information about the business case for hiring people with disabilities Employer 

Assistance and Resource Network (EARN) - http://www.askearn.org/BusinessCase 

• Information about building a business case for hiring people with disabilities from 

Disability Works - http://www.disabilityworks.org/default.asp?contentID=150 

C. Acquiring and Purchasing Accessible Technology

• Resources and tools to help in meeting Section 508 requirements, from GSA - 

http://www.buyaccessible.gov 

o Training for Buyers- https://app.buyaccessible.gov/baw/training/index.html 

o Training for Sellers- http://www.buyaccessible.gov/BAPSD_Training.ppt 

• Sample procurement language from the National Center on Disability and Access to 

Education (NCDAE) - http://ncdae.org/resources/articles/procurement.php#samples 

• Guidance on creating Section 508 compliant IT solicitations from the federal government

- http://www.section508.gov/docs/GuidanceonCreating508CompliantITSolicitations.pdf 
40

• Equipment demonstrations, equipment loans, a device-exchange program, training and 

public awareness initiatives from the Maryland Department on Disability MTAP Program

- http://www.mdod.maryland.gov/MTAP%20Home.aspx 

D. Understanding Assistive Technologies 

Vision Impairments

• Overview of assistive technologies from the American Federation for the Blind (AFB) - 

http://www.afb.org/Section.asp?SectionID=4&TopicID=31 

• Article on assistive technologies for individuals with vision impairment from the Arizona 

Technology Access Program (AzTAP) - http://www2.nau.edu/aztapp/geriatric/articles/article6.pdf 

Dexterity and Mobility Impairments

• Article on assistive technologies for individuals with motor disabilities from WebAIM -

http://webaim.org/articles/motor/assistive

• Article on computer use for individuals with motor disabilities from the University of 

Washington DO-IT Center - 

http://www.washington.edu/doit/Brochures/Technology/wtmob.html 

Hearing Impairments 

• Hearing assistive technology overview from the American Speech-Language Hearing 

Association (ASHA) - http://www.asha.org/public/hearing/treatment/assist_tech.htm 

• Hearing assistive technology overview from the Hearing Loss Association of America - 

http://www.hearingloss.org/content/hearing-assistive-technology 

Learning Impairments 

• Article on assistive technology for individuals with learning disabilities from the South 

Carolina Assistive Technology Program - http://www.sc.edu/scatp/ld.htm 

• Technology guide for individuals with learning disabilities from LD Online, a leading 

resource on learning disabilities - 

http://www.ldonline.org/indepth/technology/techguide.html 

Language and Communication Impairments 

• Article on assistive technology for individuals with speech impairments from the Arizona 

Technology Access Program (AzTAP) - http://www2.nau.edu/aztapp/geriatric/articles/article11.pdf 
41

• Module on expressive language disorders, including relevant assistive technologies, from 

the Access Project at Colorado State University - 

http://accessproject.colostate.edu/disability/modules/LD/tut_comm_dis.cfm?display=pg_

2 

E. Accessibility Testing Tools

• List of web accessibility evaluation tools from the Web Accessibility Initiative (WAI) -

http://www.w3.org/WAI/RC/tools/complete

• Accessibility testing and validation information from the Texas Health and Human 

Services System -

http://architecture.hhsc.state.tx.us/myweb/Accessibility/policy_htm/ch6.htm 

• Testing website accessibility information from the U.S. Department of Commerce - 

http://www.osec.doc.gov/webresources/bestpractices/bp3_accessibility_testing.htm 

• Flash accessibility course, including testing information, from the U.S Department of 

Veterans Affairs - http://www.ehealth.va.gov/508/flash 

F. Accessibility Training Resources

• Overview of accessibility presentations and training from the Web Accessibility Initiative 

(WAI) - http://www.w3.org/WAI/training 

• Article on web accessibility training from the University of Washington Access IT 

program - http://www.washington.edu/accessit/articles?73 

• Accessible University from the University of Washington - 

http://www.washington.edu/accesscomputing/AU 

• Web accessibility training from Cornell University Information Technology Department - 

http://www.cit.cornell.edu/policies/accessibility/training.cfm 

• Training Services from Knowability, a disability advocacy organization - 

http://www.knowbility.org/v/training-services 

• Training services from the U.S. Access Board - http://www.accessboard.gov/training.htm 

G. Implementing Accessible Software Applications and Operating Systems

• e-Accessibility Toolkit from ITU and G3iCT - http://www.eaccessibilitytoolkit.org/toolkit/technology_areas/software 
42

• Accessible software tutorial from the U.S. Access Board - http://www.accessboard.gov/sec508/software-tutorial.htm 

• Software accessibility resources from Mozilla - 

http://www.mozilla.org/access/resources.html 

H. Creating Accessible Websites

• Summary of Web Content Accessibility Guidelines - 

http://www.w3.org/WAI/WCAG20/glance 

• Tips for designing accessible websites, including the self-assessment SNAP tool from the 

Job Accommodation Network (JAN) - http://askjan.org/media/webpages.html

• Accessible design resources from the Employer Assistance and Resource Network 

(EARN) - http://www.askearn.org/keyword-links.cfm?KeywordID=437 

• Summary listing of the Section 508 web accessibility standards - 

http://section508.gov/index.cfm?fuseAction=stdsdoc#Web 

• Article on accessible online chats from WebAIM - 

http://webaim.org/articles/archives/chats/ 

I. Creating Accessible Online Job Applications

• Article on making online application processes accessible from the Job Accommodation 

Network (JAN) - http://askjan.org/corner/vol02iss05.htm 

J. Creating Accessible Documents

• Article on creating accessible Microsoft Word documents from WebAIM - 

http://webaim.org/techniques/word 

• Resources for creating accessible documents from the Maine Department of Education's 

Maine CITE Program - http://www.mainecite.org/awd/accdocs.html 

• Guidance on creating accessible PDFs in the federal government - 

http://www.section508.gov/docs/pdfguidanceforgovernment.pdf 

• A “How To” guide on creating accessible documents from the University of California - 

Hastings http://www.uchastings.edu/accessibility/Creating-Accessible-Documents.pdf 

K. Selecting Accessible Telecommunications Products (mobile phones, etc.)

• The Global Accessibility Reporting Initiative, or GARI, a complete database of 

accessible cell phones - http://www.accesswireless.org/Find/Gari.aspx 
43

• Android review from the American Federation for the Blind (AFB)- 

http://www.afb.org/afbpress/pub.asp?DocID=aw110202 

• Resources on accessible telecommunications products from the Trace Center at the 

University of Wisconsin- http://trace.wisc.edu/world/telecomm/ 

• Article on accessible telecommunications and office equipment from the Center for 

Excellence in Disabilities at the University of West Virginiahttp://www.cedwvu.org/publications/itbooklet/telecom.php 

L. Creating Accessible Videos and Multi-media Products

• Accessible video files tutorial from Texas A&M Universityhttp://webaccess.tamu.edu/education/tutorials/video.html

 

• Article on creating video and multimedia products for people with sensory impairments 

from the DO-IT Center at the University of Washingtonhttp://www.washington.edu/doit/Brochures/Technology/vid_sensory.html 

• Factsheet on accessible webcasts from the DO-IT Center at the University of 

Washington- http://www.washington.edu/doit/print.html?ID=1205 

• Tutorial on creating accessible videos from Michigan State Universityhttp://webaccess.msu.edu/tutorials/accessible-videos.html 

M. Accessibility of Desktop and Portable Computers

• Overview of accessible computer hardware from the Royal National Institute for the 

Blind Digital Accessibility Team (UK) - 

http://www.tiresias.org/research/guidelines/hardware.htm 

• Article on adapting computers to make them more accessible from Vision Awarehttp://www.visionaware.org/making-computers-accessible 

 

N. Accessibility of Social Media

• Article on promising practices on how to address accessibility issues in social media from 

the Non Profit Technology Network- http://www.nten.org/blog/2011/07/11/addressingaccessibility-social-media 

O. Sample Accessibility Evaluation Tools and Checklists 
44

• Article on accessibility evaluation tools from WebAIM - http://webaim.org/articles/tools 

• WAVE, a free accessibility evaluation tool from WebAIM - http://wave.webaim.org 

• Web accessibility evaluation tools from the Guild of Accessible Web Designers - 

http://www.gawds.org/show.php?contentid=65 

• Accessibility evaluation toolkit and resources from the Victoria government (AU) -

http://www.egov.vic.gov.au/victorian-government-resources/manuals-and-toolkitsvictoria/accessibility-toolkit/accessibility-toolkit-section-7-a/accessibility-evaluationtools.html 

• SNAP Your Website into Shape tool from the Job Accommodation Network (JAN) - 

http://askjan.org/bulletins/SNAPTool.htm 

• Accessibility scorecard from the Business Taskforce on Accessible Technology - 

http://www.btat.org/toolkit/amm-scorecard 

P. Best Practices 

• Accessibility Best Practices Library from the CIO Council of the federal government - 

http://www.cio.gov/module.cfm/node/bpl 
45

X. APPENDIX: COMPREHENSIVE BENCHMARKING TOOL 

As technology continues to transform the workplace, demand is growing for the development, 

purchase, maintenance, and use of information and communication technology (ICT) that is 

accessible to and usable by all applicants and employees, including individuals with disabilities. 

Leading companies recognize that fostering an accessible workplace is the smart thing to do, 

both from a business standpoint and a legal one. 

Action Step 4 and Action Step 7 of the “Framework for Designing and Implementing Accessible 

Information and Communication Technology (ICT) Strategic Plans” recommend that companies 

assess their ICT practices, set goals and establish priorities for improvement. Companies are 

encouraged to consider all of the ICT used or offered by their organization; make a list of those 

platforms, devices and applications; and evaluate the accessibility of each item on their 

inventory, along with their general accessible ICT policies and practices. Companies are also 

advised to review and improve their infrastructure to facilitate the implementation of company 

policies and their accountability mechanisms and methods for ensuring continuous improvement. 

The Benchmarking Tool, which can be expanded into an interactive tool for employers, is a 

sample instrument that companies might consider using to begin this exercise. It provides a 

framework for companies to build into their own self-assessment and corporate-wide, 

comprehensive strategic plan (affirmative action program, where applicable), including 

accountability mechanisms and methods for ensuring continuous improvement. 

More specifically, this Benchmarking Tool is organized in accordance with the key components 

of an Accessible ICT Strategic Plan:

• Understand the Terminology and Target Population 

• Understand the Policy Framework

• Understand the Business Case 

• Self-Assess ICT Practices, Set Goals and Establish Priorities for Improvement 

• Advance Corporate Policies, Practices and Procedures

• Establish an Infrastructure Facilitating Implementation of the Policies

• Commit to Accountability and Continuous Improvement 

• Identify Available Resources 

This Benchmakring Tool does not create any new legal requirements or change current legal 

requirements. Instead, it facilitates the identification of strategies and practices that employers 

may want to adopt to enhance employment opportunities for qualified individuals with 

disabilities through accessible ICT. 

A. ACTION STEP 1: UNDERSTAND THE TERMINOLOGY AND TARGET 

POPULATION

The first action step a company may want to take in its efforts to meet the needs of qualified 

individuals with disabilities through the development, procurement, maintenance and use of 
46

accessible ICT is to review the key terms used to describe accessible ICT and the target 

populations affected by inaccessible ICT systems. 

Questions to consider: 

1. Does your company identify and define the key terms used to describe and implement the 

accessible ICT strategic plan?

2. Does your company take steps to identify the target population of applicants and 

employees affected by inaccessible ICT systems and the target population that could 

benefit from accessible ICT, including people who:

• Are blind or have low vision?

• Have mobility impairments?

• Are deaf or hard of hearing?

• Have cognitive impairments and neurological disabilities?

• Are older workers?

B. ACTION STEP 2: UNDERSTAND THE POLICY FRAMEWORK

Our nation’s civil rights laws require that covered entities provide equal opportunity to 

qualified individuals with disabilities. Equal opportunity means an opportunity to obtain the 

same level of performance, or to enjoy the same level of benefits and privileges that are available 

to similarly situated individuals without disabilities. It is unlawful for the covered entity to use 

standards, criteria or methods of administration that have the purpose or effect of discriminating 

on the basis of disability. This includes entering into contracts or other arrangements that have a 

discriminatory effect. In other words, a covered entity is prohibited from doing indirectly that 

which it is prohibited from doing directly. 

In addition, our nation’s civil rights laws include responsibilities for government contractors and 

federal agencies to take affirmative action to employ and advance in employment individuals 

with disabilities and disabled veterans, including but not limited to recruitment, advertising and 

job application procedures. These job application procedures include online application systems. 

Questions to consider: 

1. Has your company reviewed the applicable federal and state nondiscrimination and 

affirmative action laws, regulations and guidelines, including:

• The Americans with Disabilities Act (ADA)? 

• Sections 503 and 504 of the Rehabilitation Act of 1973, as amended? 

• The United Nations Convention on the Rights of Persons with Disabilities? 

2. Has your company reviewed standards that may be used to determine whether ICT is 

accessible, including:
47

• Section 508 of the Rehabilitation Act of 1973, as amended? 

• Section 255 of the Telecommunications Act of 1996? 

• Web Content Accessibility Guidelines (WCAG) 2.0 developed by the Web 

Accessibility Initiative (WAI) of the World Wide Web Consortium (W3C)? 

• The United Nations Convention on the Rights of Persons with Disabilities?

C. ACTION STEP 3: UNDERSTAND THE BUSINESS CASE 

In making the business case for developing, procuring, maintaining or using accessible ICT, it is 

important to recognize that every company is different and every CEO within each company is 

different—every business has a different motivator. Thus, there is a need to provide business 

leaders and decision makers with different approaches, opportunities and information to 

determine what constitutes a compelling business case. 

Questions to consider: 

1. Does your company understand the business case for developing, procuring, maintaining and 

using accessible ICT? In other words, does your company identify and understand the 

benefits of accessible ICT, such as: 

• Enhanced communication, collaboration and efficiency?

• Reductions in costs associated with the provisions of more cost-effective 

accommodations to address the needs and preferences of users?

• Improved recruitment and retention? 

• Achievement of diversity?

• The image of corporate responsibility? 

D. ACTION STEP 4: SELF-ASSESS ICT PRACTICES, SET GOALS AND ESTABLISH 

PRIORITIES FOR IMPROVEMENT 

Given the business case and policy mandates for providing accessible information and 

communications technology (ICT), it is advisable for organizations to self-assess their internal 

and external technologies. This will help facilitate the adoption of formal, written policies, 

practices and procedures to enhance employment opportunities and privileges of employment for 

individuals with disabilities through accessible ICT. 

Questions to consider: 

1. Has your company undertaken a self-assessment of all of the ICT used or offered by the 

company and made a list of those platforms, devices and applications, and the ability of 

their tools and processes to support production of accessible materials?

2. Has your company evaluated the accessibility of each item on the inventory by 

considering the user experience of applicants, employees and customers who have 

various disabilities, including formal testing of ICT applications with automated 

accessibility testing tools? 
48

3. Has your company interviewed existing employees with certain disabilities or conducted

informal focus groups? 

E. ACTION STEP 5: ADVANCE CORPORATE POLICIES, PRACTICES AND 

PROCEDURES

Adopting Corporate Policies

To enhance employment opportunities and privileges of employment for individuals with 

disabilities through accessible ICT, it is necessary to refine and advance corporate policies, 

practices and procedures that define the nature and scope of the commitment. Best and promising 

business practices regarding accessible ICT include the adoption of formal, written policies, 

practices and procedures. 

Questions to Consider:

1. Has your company established a formal, written, company-wide policy and standards 

regarding accessible ICT?

2. Does your organization’s formal, written policy identify the office and/or person 

responsible for implementing and complying with accessible ICT policy and standards? 

3. Does your company’s formal, written policy define roles and responsibilities for ensuring 

ICT accessibility, including the Chief Technology Accessibility Officer, procurement 

officers, contracting officers, application developers and Web content managers/authors?

Applying Accessibility Standards

There are several sets of standards describing how to make ICT, including websites, accessible to 

individuals with disabilities. Some employers may elect to use the standards that were developed 

and are maintained by the Access Board in accordance with Section 508 of the Rehabilitation 

Act, as amended and Section 255 of the Telecommunications Act; whereas other employers may 

elect to use the WCAG 2.0 guidelines developed and maintained by the Web Accessibility 

Initiative (WAI) of the World Wide Web Consortium (W3C). For purposes of this 

Benchmarking Tool, either set of standards/guidelines is appropriate. ICT procurements or ICT 

projects (developed, maintained or used) should comply with specific technical ICT accessible 

standards and functional performance criteria:

o Software applications and operating systems

o Web-based Intranet and Internet information applications

o Telecommunication products

o Video and multimedia products

o Self-contained, closed products

o Desktop and portable computers
49

• Software Applications and Operating Systems 

Most of the specifications for software pertain to usability for people with vision 

impairments. For example, one provision requires alternative keyboard navigation, which is 

essential for people with vision impairments who cannot rely on pointing devices, such as a 

mouse. Other provisions address animated displays, color and contrast settings, flash rate and 

electronic forms, among others. 

Questions to consider: 

1. Has your company considered ICT accessibility when assessing its internal business 

applications, such as:

• Accounting/financial software? 

• Travel booking systems? 

• Time entry applications? 

• Client databases?

• Customer relationship management (CRM) software and other software 

applications? 

• E-mail systems? 

• Content management systems (CMS) and other web authoring tools?

• Instant messaging applications? 

• Operating systems? 

2. Are your company’s internal and external e-mails accessible? That is, if your e-mails 

are formatted in HTML, do you follow website guidelines and offer text alternatives 

and tagged images?

3. If your company uses social media applications, are they accessible? Do you caption 

any videos that you post? Do you add descriptive titles to photographs and images 

that you post? Are you descriptive in your status updates? And do you offer your 

social media content in an alternate location? (For instance, by posting it on your 

website, blog, through an accessible video player and in your company’s online photo 

gallery.)

4. Are your company word processing software products accessible? Have you trained 

your employees on ways to ensure that every document they produce can be read by 

everyone? 

5. Can all employees, regardless of disability, access these systems with or without 

assistive technologies? 

• Websites

Web accessibility is about designing and coding pages so as many people as possible can 

access them effectively and efficiently (universal design). Web accessibility specifically 
50

ensures effective and meaningful opportunities for individuals with disabilities to use and 

interact with the company through the Internet and company website. 

According to the Access Board, the criteria for Web-based technology and information 

included in the Section 508 regulation are based on access guidelines developed by the Web 

Accessibility Initiative (WAI) of the World Wide Web Consortium (W3C). 

Questions to consider: 

1. Does the company comply with the applicable standards/guidelines and address 

typical barriers, including:

• Images not labeled properly with an alternative text description?

• Inconsistent navigation including poor hypertext link text?

• Inaccessible forms for Web users who are blind and use screen reader software?

• Information validation techniques that cause problems with adaptive technology 

used by disabled people?

• Information laid out in tables? (For example job listings frequently are not coded 

properly for accessibility.)

2. When applying standards/guidelines that address typical barriers in creating the 

company’s website(s), are the following components considered: 

For Web Home Pages:

• External Internet home page (mission, activities, information about programs, 

benefits, information about products and services, publication of resources, 

employment postings)?

• Internal Intranet home page (mission, activities, programs and benefits, products 

and services, resources, employment postings)?

• Web-based forms (applying for programs and benefits, ordering products or 

services, feedback, contact information search, publication resource search, filing 

a complaint, employment search)?

• Web-based applications (applying for programs, benefits, ordering products or 

services, training/learning, travel reservation, time and attendance, 

recordkeeping/tracking, survey, employment)?

For Items on a Website:

• Portable document files (.pdfs)?

• Multimedia content (video and audio)?

• Flash content?

• Word processing files?
51

• Microsoft PowerPoint files? 

• Data tables? 

• Spreadsheet files? 

• JavaScript or other scripts? 

• Java applets? 

• Blogs (web logs)? 

• Facebook? 

• MySpace? 

• Twitter? 

• YouTube? 

• Flickr? 

3. When creating an accessible website, does the company take into consideration the 

following best practices: 

• Determine internal accessibility standards for website? (For example, the 

standards developed by the Access Board implementing Section 508 of the 

Rehabilitation Act, as amended and the World Wide Web Consortium (W3C) 

Web Content Accessibility Guidelines (WCAG). WCAG 2.0 is based on a series 

of success criteria prioritized into three levels.) 

• Develop a strategic plan to upgrade the accessibility of current site? 

• Use latest Web design software that has inbuilt accessibility prompts? 

• Test site’s accessibility using available tools (software) and repeat whenever new 

templates are introduced? 

• Consider using experts and individuals with different impairments to audit 

website? 

• Communicate required standards to everyone involved, including 

vendors/suppliers? 

• Ensure that the employees and suppliers who are involved with Web design, 

maintenance and content development have Web accessibility awareness training? 

• Review and update guidelines regularly to incorporate latest developments in 

Web accessibility, particularly changes to the Section 508 and WCAG guidelines? 

• Telecommunications Products 

The Section 508 regulations include provisions related to telecommunication products, 

including telephones, mobile devices and other wireless devices. 

Questions to Consider: 

1. Does the company comply with the accessibility standards applicable to 

telecommunications products, including accessibility standards for people who are deaf 

or hard of hearing, such as compatibility with hearing aids, cochlear implants, assistive 

listening devices and TTYs and the requirement calling for a standard non-acoustic TTY 

connection point for telecommunication products that allow voice communication but 
52

that do provide TTY functionality, and other specifications address adjustable volume 

controls for output, product interface with hearing technologies, and the usability of keys 

and controls by people who may have impaired vision or limited dexterity or motor 

control? 

2. Future updates to the Section 508 regulations are likely to include accessibility 

considerations for mobile telephones and other wireless devices, which many 

organizations are issuing to their employees. When choosing these devices, is the 

company considering the following issues:

• Ability to connect an alternative headset to particular devices?

• Whether the keys on the keypad are easily discernible from one another?

• Whether there are adjustable contrast and brightness controls?

• Whether the handset has non-slip grips to prevent the phone from slipping out of 

the hand?

• Other display characteristics such as the screen size, adjustability of font sizes and 

more?

• Video or Multimedia Products

The Section 508 regulations specify standards for video or multimedia products. Multimedia 

products involve more than one media and include, but are not limited to, video programs, 

narrated slide productions and computer generated presentations. 

Questions to Consider: 

1. Does the company comply with Section 508 or other recognized standards applicable to 

video or multimedia products such as: 

• Caption decoder circuitry (for any system with a screen larger than 13 inches) and 

secondary audio channels for television tuners, including tuner cards for use in 

computers? 

• Captioning and audio description for certain training and informational multimedia 

productions developed or procured by federal agencies? 

• Display or presentation of alternate text or audio descriptions that are user-selectable 

unless permanent? 

2. Does the company apply these same standards to webcasting and video conferencing 

systems, which many companies are using to help employees communicate from multiple 

locations? 

3. Does the company incorporate these standards for corporate events and activities, where 

videos can be captioned and audio described, and where presentation materials can be 

provided in alternative formats? 
53

• Self-Contained, Closed Products 

The Section 508 regulations specify standards regarding self-contained, closed products. This 

section covers products that generally have embedded software but are often designed in 

such a way that a user cannot easily attach or install assistive technology. Examples include: 

• Information kiosks; 

• Information transaction machines; 

• Copiers; 

• Printers; 

• Calculators; 

• Fax machines; and 

• Similar types of products. 

Questions to Consider: 

1. Does the company ensure that these products used by company applicants and employees 

comply with the standards requiring that access features be built into the system so users 

do not have to attach an assistive device to it? 

2. Do these products comply with other specifications that address mechanisms for private 

listening (handset or a standard headphone jack), touch screens, auditory output and 

adjustable volume controls, and location of controls in accessible ranges? 

• Desktop and Portable Computers 

The Section 508 regulations include a section that focuses on keyboards and other 

mechanically operated controls, touch screens, use of biometric form of identification, and 

ports and connectors. These standards include ensuring that controls and keys are tactilely 

discernible without activating the controls or keys; that controls and keys are operable with 

one hand and do not require tight grasping, pinching or twisting of the wrist; and that the 

status of all locking or toggle controls or keys is visually discernible, and discernible either 

through touch or sound. 

Questions to Consider: 

1. Do the desktop and portable computers, including laptops and tablets, purchased or 

leased by the company comply with these standards? 

Information, Documentation and Support 

The Section 508 regulations include standards that address access to all information, 

documentation and support provided to end users (e.g., federal employees) of covered 

technologies. This includes: 
54

• User guides; 

• Installation guides for end-user installable devices; and 

• Customer support and technical support communications. 

Questions to Consider: 

1. Does the company comply with these standards, including requirements that such 

information must be available in alternate formats upon request at no additional charge, 

including: 

• Braille? 

• Cassette recordings? 

• Large print?

• Electronic text?

• Internet postings? 

• TTY access? 

• Captioning and audio description for video materials? 

• Online Application Systems

Online application systems have gained popularity because they can be used by companies to 

streamline the hiring process, including: developing position descriptions, attracting 

candidates, processing resumes, qualifying job applicants, selecting candidates and making 

employment offers. 

Questions to Consider: 

1. Are the following features of the online application system determined to be accessible 

through the company’s website: 

• Website Integration? 

• Job Posting and Distribution Tools? 

• Application and Resume Submission? 

• Communication between Applicant and Employer? 

• Resume Extraction and Management? 

• Candidate Search and Selection Process (including Ranking and Rating)? 

• Employee Offer Management? 

2. Can potential applicants with disabilities either use your online job application system or 

submit an application in a timely manager through alternative means as an interim 

measure until the website is made fully accessible? 

3. If the company uses an alternative method of application as an interim measure until the 

onsite application is fully accessible, does the alternative method satisfy the following 

criteria?
55

• Provides equal opportunity (e.g., provides the same degree of efficiency, immediacy 

and convenience). 

• Is advertised as an interim measure until the company’s website is fully accessible, 

with emphasis that it is an alternative and is intended only for candidates who cannot 

use the mainstream system, or who are unreasonably disadvantaged by doing so.

• Highlights the benefits of applying online while assuring applicants that if they 

cannot apply online they will not face discrimination.

• Provides person-to-person communication. Train and equip HR personnel and “webhelp” team to communicate with people with disabilities (e.g., textphones, online 

instant message). 

• Keeps candidates in the mainstream or feeds candidates back into the mainstream 

process as quickly as possible. 

• Provides for a representative not involved in the employment process to enter 

information into online application system on their behalf (or outsource this function 

to their applicant tracking provider).

• Note: it is discriminatory to automatically direct all candidates with disabilities to the 

alternative means. If you provide candidates with the option to receive e-mail or text 

alerts about future vacancies, ensure people with disabilities who have applied offline

also have access to this service. 

4. Does the company use the following practices regarding the provision of reasonable 

accommodations in the context of online application systems? 

• Notify the applicant of the right to request a reasonable accommodation if he or 

she is unable or limited in ability to use or access the online system as a result of 

disability unless the employer can demonstrate that the accommodation would 

impose an undue hardship on the operation of its business. 

• Include in a notice an explanation of how to obtain reasonable accommodations 

via its online application system as well as on its paper applications and job 

announcements.

• The notices should contain the name of the person to contact and the process for 

requesting the reasonable accommodation. 

• The notices should be prominently displayed and included at the beginning of the 

online application process.

• Note: Having an online application system that includes universal design features or 

that includes many accessibility features for individuals with disabilities does not 

relieve a federal contractor of its obligations to provide reasonable accommodations if 

needed to address the inability of an applicant with a disability to use or access the 

online system. 

4. Does your online application site display the company’s equal employment opportunity 

(EEO) policy statement?
56

F. ACTION STEP 6: ESTABLISH AN INFRASTRUCURE FACILITATING 

IMPLEMENTATION OF THE POLICIES

To realize and sustain the vision and promises reflected in the formal written policies, practices 

and procedures (Action Step 5), it is necessary to establish corporate infrastructure and 

organizational strategies. Best and promising practices regarding the establishment of a 

corporate infrastructure and organizational strategies implementing an accessible ICT policy

include:

• Leadership and Team Approach

• Outsourcing and Procurement

• Training

• Deployment

Leadership and Team Approach (Managers Across Divisions) 

Questions to Consider: 

1. Does the company’s leadership take action steps to secure “buy-in” and establish and 

sustain a corporate-wide culture (not limited to HR) that increases awareness, creates 

expectations, and enhances commitment to hiring, retention and advancement of person 

with disabilities through accessible ICT? 

2. Does the company have a written policy signed and circulated to managers and posted on 

the website enunciating a policy regarding accessible ICT?

3. Is the company taking action steps to secure a network of responsible individuals 

consisting of corporate policymakers, policy enforcers and people doing the work 

(different lines of business) to implement the accessible ICT policy?

4. Is the company implementing a formalized a team approach (e.g., an accessibility team 

comprised of managers across divisions including ADA compliance (ADA Coordinator), 

HR, ICT (the Chief Information Officer (CIO) and the Chief Technology Accessibility 

Officer, procurement (the Chief Acquisition Officer), education and training, financial 

and marketing? 

5. Is the CEO briefed on a regular basis regarding the continuing progress in implementing 

the accessible ICT strategic plan based on written reports prepared by responsible 

managers?

Outsourcing and Procurement

Questions to Consider: 
57

Outsourcing

1. Does the company:

• Conduct a detailed review of all current ICT in line with the company’s standards 

and work with third party suppliers to ensure that the company’s ICT is truly 

accessible? 

• Identify who needs to be involved in overcoming barriers, including suppliers and 

partners (minimizing the risks of outsourcing)? 

• Insist that job boards on which the company advertises are accessible to people 

with disabilities? 

• Make business reasons for adopting accessible ICT policy when suppliers are

invited to tender a proposal? 

• Ensure contracts stipulate that suppliers will, where relevant, apply ICT 

accessibility standards? 

• Stipulate who will be responsible for meeting the cost of adjustments? 

• Ensure the technology can be used by any employees with disabilities who are 

involved with managing recruitment, including those who use assistive 

technology? 

• Give suppliers and business partners a copy of ICT accessibility guidelines? 

The Procurement Process

1. When procuring IT products for your company, do you have a written policy and/or 

detailed RFP language mandating that those products be accessible? Does the 

solicitation: 

• State that the ICT must be accessible? 

• Indicate which provisions of the applicable accessible ICT standards apply to 

purchase? 

• Request accessibility information from vendors that respond to solicitation? 

• Evaluate received proposals based on responses to accessibility requirements? 

• Let vendors know of plans to inspect deliverables based on meeting accessibility 

requirements (i.e., “acceptance testing”)?

2. Does your company evaluate received proposals based on their responses to 

accessibility requirements?

3. Before signing off on newly procured ICT for your organization, does the company

conduct “acceptance testing” on products and services received from outside vendors 

to ensure their accessibility?

 

The following checklist was prepared by General Services Administration (GSA) for 

determining compliant solicitations using Section 508 standards. The checklist may be used by 

private sector employers. 
58

DO THE FOLLOWING:

• Provide a clear statement that an ICT Accessibility Standard (such as Section 508

or WCAG 2.0) does or does not apply to the solicitation

• Indicate if an exception is being claimed

• Indicate applicable technical section and provision of the ICT contract 

deliverables

• Indicate functional performance criteria applicable to the ICT contract 

deliverables

• Indicate which information, documentation and support requirements are 

applicable to the ICT contract deliverables

• Specify applicable accessibility factors as evaluation criteria

• Request accessibility information from the responder

• Specify applicable accessibility factors as inspection and acceptance criteria

• Ensure the solicitation and any associated documents and attachments are in an 

accessible format

AVOID THE FOLLOWING: 

• Do not request that an ICT Accessibility Standard’s (such as Section 508 or 

WCAG 2.0) relevance be determined by the vendor

• Do not request that the ICT Accessible Standard applicability be determined by 

the vendor

• Do not request that ICT Accessibility Standard exceptions be determined by the 

vendor

• Do not request an ICT deliverable accessibility certification of compliance 

Note: Potential vendors should be asked to provide proof of conformance with the 

stated accessibility factor requirement through a VPAT or GPAT or other 

documentation. This proof of conformance is not the same as a request for a 

certificate of compliance, as there is currently no certifying body for Section 508 

accessibility. 

1. Role of Procurement Officials 

Does the procurement officer:

• Identify ICT deliverables covered by the accessible ICT standards and then identify the 

applicable technical standards; functional performance criteria; and information, 

documentation and support that apply to each ICT deliverable?

• Determine if a purchase is subject to the applicable accessible technology standard (such 

as Section 508 or WCAG 2.0)?

• Find language for the solicitation?

• Find companies and do market research to buy ICT products or services? 

• Provide documentation for compliance? 
59

• Produce specific language for solicitations for ICT products and services, including: 

o Basic language regarding Section 508/WCAG 2.0 relevance? 

o Section 508/WCAG 2.0 applicability? 

o Section 508/WCAG 2.0 factors for proposal evaluation? 

o Section 508/WCAG 2.0 criteria for deliverable acceptance? 

• Evaluate acquisition deliverables based on generally accepted inspection and/or test 

methods? 

2. Accessibility Training for In-House Staff 

• Does the company extend training and professional development opportunities to all 

offices, divisions and departments of the company? 

• Does the company expand its base of knowledge and experience through various 

strategies, demonstrations and newsletters? 

• Does the company’s Chief Accessible Technology Officer provide ICT accessibility 

training to staff, including, where appropriate, such as: 

o ADA coordinators? 

o Program managers? 

o Contracting officers? 

o Software developers? 

o Web developers? 

o Video/multimedia developers? 

o IT Help desk staff? 

o Others? 

• Does the training include the following topics:

• ICT accessibility standards? 

• How to buy accessible ICT?

• How to create accessible software? 

• How to create an accessible website? 

• How to create accessible electronic forms? 

• How to create accessible electronic documents? 

• How to create accessible pdfs? 

• How to caption video or multimedia? 

• How to evaluate software, websites and other documents for accessibility? 
60

3. Deployment 

• Does your company have a centralized method of providing assistive technology to 

employees (e.g., a centralized accommodation fund)? Has the company maximized the 

implementation of ICT accessibility policies and implemented the following best 

practices: 

• Establish a mechanism for centralized expertise and/or payment for assistive 

technology devices and services? 

• Provide for specialized expertise to assess and evaluate an applicant’s or employee’s 

need for assistive technology, where necessary and appropriate?

• Train staff in accessibility assessment?

• Enter into strategic partnerships with resources in the community to gain insight, 

information and expertise regarding accessible ICT, including assistive technology 

devices and services? 

• Provide online resources for learning about specific types of assistive technology 

products? 

• Train all employees (individuals with and without disabilities) so that everyone 

understands and can use the accessibility features in any technology purchased or 

developed in-house? 

• Involve persons with disabilities in the implementation of accessible ICT policy by 

establishing a group of employees impacted by the policy? 

 

G. ACTION STEP 7: COMMIT TO ACCOUNTABILITY AND CONTINUOUS 

IMPROVEMENT

The adoption of written policies, practices and procedures and the establishment of corporate 

infrastructure and organizational systems are necessary components of an ICT accessibility 

strategic plan. However, ensuring implementation is the end goal. Best business practices include 

establishing accountability mechanisms and methods for ensuring continuous improvement. 

Appointment of ADA Coordinator, Chief Technology Accessibility Officer and Designation 

of Accountable Managers

Questions to Consider:

1. Does the company assign responsibility to specific individual(s) (Chief Technology 

Accessibility Officer) for implementation of the employer’s accessible ICT strategic 

plan? 

2. Does the company provide these official(s) top management support and, if appropriate, 

staff to manage the implementation of this strategic plan (affirmative action program), 

and a reasonable budget? 

3. Does the company identify the responsible individual on all internal and external 

communications regarding the company's ICT strategic plan? 
61

4. Does the company define the scope of responsibility for implementation to include, 

among others, the following functions:

a) Developing the strategic plan? 

b) Assisting in the identification of problem areas and in the development 

of solutions to those problems. For example, making available and 

keeping updated office addresses, 1-800 telephone numbers and e-mail 

addresses of the ADA Coordinator(s) and the Chief Accessible 

Technology Officer. This information should be accessible on the 

company’s “Diversity and Accessibility” page which is accessible via a 

link that is predictable and accessible location on the company’s website 

home page, in a format accessible to persons with disabilities?

c) Coordinating activities of accessible ICT team members?

d) Monitoring the effectiveness of the program on a continuing basis 

through the development and implementation of an internal audit and 

reporting system that measures the effectiveness of the program?

e) Keeping upper management informed of progress and problems within 

the company through quarterly reports? 

f) Providing department managers with a copy of the strategic plan and 

reviewing the plan with them on an annual basis to ensure knowledge of 

their responsibilities for implementation of the plan?

g) Reviewing the plan with all managers and supervisors at all levels to 

ensure that the policy is understood and is followed in all activities?

h) Auditing the contents of company bulletin boards and Web sites 

annually to ensure that compliance information is posted and is up-todate? 

i) Serving as liaison between the company and enforcement agencies; and 

j) Advising managers and supervisors annually of their responsibilities 

under the company’s plan and of their obligations to:

(i) Review the company’s policy with subordinate managers and supervisors to 

ensure that they are aware of the policy and understand their obligations? 

(ii) Assist in the identification of problem areas, formulate solutions, and establish 

departmental goals and objectives when necessary?

5. Does the company specify the services to be provided by the office(s) or person(s) 

responsible for implementing and ensuring compliance with the policy, including:

a) Assist acquisition officials in preparing accessible ICT language in ICT contracts?

b) Assist developers in designing software that complies with accessible ICT 

Standards?

c) Create or repair electronic documents to comply with ICT accessible standards?

d) Evaluate websites?

e) Evaluate software?

f) Evaluate hardware?

g) Provide training?

h) Provide alternate formats?
62

Notice of Policy and Responsible Persons and Offices 

Questions to Consider:

1. Does the company post and maintain a copy of the summary description of the ICT 

accessibility policy on the company’s “Diversity and Accessibility” page? 

2. Is the “Diversity and Accessibility” page accessible via a link that is a predictable and in 

an accessible location on the company website home page, in a format accessible to 

persons with disabilities (i.e., HTML)? 

3. Is the summary description available in alternate formats (such as large print, Braille, 

audio recording, electronic formats) upon request with reasonable promptness? 

Participation by Individuals with Disabilities and Outside Experts

Questions to Consider:

1. Does the company involve people with disabilities at each stage of the strategic plan, 

particularly when testing whether the changes the company has made are successful?

2. Does the company develop relationships with experts and learn what other companies are 

doing?

3. Does the company adopt the benchmarks and measures by teams that include experts 

knowledgeable about accessible and usable electronic and information technology and 

persons with disabilities?

4. Does the company seek input from employees with disabilities using employee surveys 

and focus groups and discussions with employee diversity and advisory groups regarding 

the workplace environment? 

5. Does the company include persons with disabilities and members of employee resource 

groups on self-assessment endeavors (e.g., progress and monitoring teams)? 

Measurable Objectives, Benchmarks and Prioritizing Areas Needing Improvement

Questions to Consider:

1. Does the company conduct a “conformance evaluation” or audit of an organization’s 

information and communications technology (ICT) to help the company self-assess the 

accessibility of their existing technologies and plot a course for improvement? 

2. Does the company use a specific scoring mechanism (e.g., where a red score signifies a 

lack of Section 508 compliance, yellow indicates partial compliance and green indicates 

that the technology application is fully accessible)? 
63

3. Does the company assign a benchmark “score” for each ICT application or platform at the 

start of the exercise so that success can be measured? 

4. Does the company set measurable objectives by prioritizing ICT applications that need 

accessibility modifications and setting dates by which improvements will be 

implemented? Are these objectives included in the strategic plan and monitored 

frequently? 

5. Does the company organize a prioritized list of accessibility errors and problems that can 

make the improvement process more manageable while ensuring the most critical repairs 

are made first? 

6. Does the company use the W3C guidance on setting priorities for improving website 

accessibility or other guidance? 

Monitoring, Auditing, Reporting and Continuous Improvement

Questions to Consider:

1. Has the company designed and implement an audit and reporting system that will:

a. Measure the effectiveness of the company’s strategic plan? 

b. Determine the degree to which the company’s goals, priorities and objectives 

have been attained? 

c. Indicate any need for remedial action? 

2. Where the company’s strategic plan is found to be deficient, does the company undertake 

necessary action to bring the program into compliance?

3. Does the company identify trends and/or issues for making informed decisions on issues 

needing more attention?

4. Does the company track information that could be used to assess the effectiveness of the 

accessible ICT policy? 

5. Does the company use the accessible ICT diagnostic evaluation benchmarks and measures to 

continuously improve and enhance the accessibility and usability of the ICT? 

6. Does the company establish a continuous feedback mechanism that includes a state-ofthe-company briefing to the CIO every six months with respect to the accessibility and 

usability of electronic and information technology, and annually to the CEO with respect 

to progress made in implementing the affirmative action program, including reaching 

benchmarks? 

7. Does the company establish a complaint tracking system, for example implement a toll 

free telephone number (ADA Comment/Complaint Line) and an e-mail address (ADA e-
64

mail address) that are used solely to receive comments and complaints relating to 

treatment or access to company services, benefits, privileges, advantages, facilities and 

accommodations for individuals with disabilities?

8. Does the company provide for quarterly reports regarding implementation of the 

company’s strategic plan? Note: In quarterly reports, identify completion dates and 

identify the manager who is accountable and responsible for ensuring that the action 

item is completed in a timely manner. If action items are not completed in a timely 

manner, company managers should be held accountable for their performance 

deficiencies. 

H. ACTION STEP 8: IDENTIFY AVAILABLE RESOURCES 

Questions to Consider:

1. Has the company identified resources that can be used by company officials, managers, 

and other employees to carry out the roles and responsibilities specified in the strategic 

plan, including:

• Regulations, guidelines and policy briefs related to the ADA and Section 503 and 

504 of the Rehabilitation Act?

• Section 508 of the Rehabilitation Act standards, guidance, best practices, tools, 

and checklists developed by the Access Board and the General Services 

Administration?

• Resources from the World Wide Web Consortium (W3C), including tools for 

evaluating website accessibility? 
65

XI. ENDNOTES

 

1 The term “information and communication technology” (ICT) includes information technology and any equipment or interconnected system or 

subsystem of equipment, which is used in the creation, conversion, or duplication of data or information. ICT also includes information 

technology and any equipment or interconnected system or subsystem of equipment, which is used in the automatic acquisition, storage, analysis, 

evaluation, manipulation, management, movement, control, display, switching, interchange, transmission, reception or broadcast of data or 

information. The term includes, but is not limited to, electronic content, including email, electronic documents and Internet and Intranet websites; 

telecommunications products, including video communication terminals; computers and ancillary equipment, including external hard drives; 

software, including operating systems and applications; information kiosks and transaction machines; videos; IT services; and multifunction 

office machines that copy, scan, and fax documents. [36 CFR 1194.4]

2 Statement of Samuel R. Bagenstos, Principal Deputy Assistant Attorney General for Civil Rights, Department of Justice before the 

Subcommittee on the Constitution, Civil Rights and Civil Liberties, Committee on the Judiciary, U.S. House of Representatives concerning 

Emerging Technologies and the Rights of Individuals with Disabilities (April 22, 2010). [Hereinafter referred to as DOJ Testimony] at page 1. 3 DOJ Testimony at page 8.

4 The three quotes included in the text may be found in the Preamble to the DOJ Advance Notice of Proposed Rulemaking regarding

Nondiscrimination on the Basis of Disability; Accessibility of Web Information and Services of State and Local Government Entities and Public 

Accommodations 75 Federal Register 43460 (July 26, 2010). [Hereinafter referred to as DOJ Web Accessibility ANPRM] 5 See for example Accessibility: A Guide for Businesses and Organizations—Empowering employees, customers and partners with accessible 

technology. Microsoft (2011) at pages 8-10. [Hereinafter referred to as the Microsoft Accessibility Guide] 6 Roadmaps for Enhancing Employment of Persons with Disabilities through Accessible Technology, developed by participants at the Business 

Dialogue on Accessible Technology and Disability Employment (September 2007) at page 9-10. [Hereinafter referred to as Roadmaps] 7 Roadmaps at page 10. 8 Additional benefits of accessible design are discussed in Developing a Web Accessibility Business Case for Your Organization available at

http://www.w3.org/WAI/bcase/. 9 The definitions are taken from several sources, including Electronic and Information Technology Accessibility Standards (final rule codified at 

36 CFR Part 1194) [hereinafter referred to as the Section 508 Accessibility Rule]; Draft Information and Communication Technology (ICT) 

Standards and Guidelines (published in the Federal Register on March 22, 2010 at 75 Federal Register 13457 [hereinafter referred to as the 

Section 508 ANPRM]; and the BuyAccessible Wizard Glossary https://app.buyaccessible.gov/DataCenter/Glossary.jsp. 10 http://www.accessibletech.org/access_articles/general/whatIsAccessibleEIT.php. 11 http://www.ada.gov/reg2.html.

12 See http://www.access-board.gov/508.htm

13 OFCCP Program Directive Number 281 (July 10, 2008) regarding Contractors’ Online Application Selection Systems.

14 See Preamble to DOJ Web Accessibility ANPRM at 75 Federal Register 43462. See also Web Accessibility Initiative of the World Wide Web 

Consortium, http://www.W3.org/WAI/intro/people-use-web/; Silverstein, Robert. A Technical Assistance Guide for Federal Contractors 

Regarding Implementation of Online Application Systems that Meet the Needs of Qualified Individuals with Disabilities and Qualified Disabled 

Veterans, Economic Systems, Inc (July 2009); and Microsoft Accessibility Guide. 15 The summary description set out in the text regarding the duty to take affirmative action is derived from a review of multiple sources, 

including the regulations implementing Section 503 [41 CFR 60-741.43] and VEVRAA [41 CFR 60-300.43]; the OFCCP Federal Contract 

Compliance Manual; the Department of Labor, Office of Administrative Law Judges, Office of the Solicitor (Civil Rights Division) Index of 

Administrative Decisions Under Section 503:Topic 25—Affirmative Action; and EEOC Management Directive 715 (which clarifies affirmative 

action obligations of federal agencies under Section 501 of the Rehabilitation Act). See Affirmative Action for People with Disabilities—Volume 

II Modernizing the Affirmative Action Provisions of the Section 503 and VEVRAA Regulations, Economic Systems, Inc (April 30, 2010) at pages 

49-50. [Hereinafter referred to as AAP Study Volume II] 16 42 U.S.C. 12101. 17 29 CFR Part 1630. In particular, see 29 CFR 1630.4, 1630.6 and 1630.9. 18 29 U.S.C.791.

19 29 U.S.C.793. See OFCCP Program Directive Number 281 (July 10, 2008) regarding Contractors’ Online Application Selection Systems.

20 29 U.S.C.794

21 See Preamble to DOJ Web Accessibility ANPRM, 75 Federal Register 43463.

22 See Preamble to DOJ Web Accessibility ANPRM, 75 Federal Register 43464.

23 75 Federal Register 43460.

24 29 U.S.C.794d.

25 36 CFR Part 1194. 26 75 FR 13457. 27 Telecommunications Act Accessibility Guidelines; Electronic and Information Technology Accessibility Standards, 76 Fed. Reg. 76,640 

(proposed Dec. 8, 2011)(to be codified at 36 C.F.R. §§ 1193, 1194). 

28 This description of the WAI of the W3C to develop the WCAG is included in the Preamble to DOJ Web Accessibility ANPRM, 75 Federal 

Register 43463.
66

 

29 Techniques for WCAG 2.0 http://www.w3.org/TR/WCAG20-TECHS/ 30 WCAG 2.0 At A Glance http://www.w3.org/WAI/WCAG20/glance/

31 See DOJ Testimony at page 6 and Preamble to DOJ Web Accessibility ANPRM, 75 Federal Register 43464 and 43465.

32 http://www.hhs.gov/ociio/regulations/joint_cms_ociio_guidance.pdf. See also reference to WCAG 2.0 standards in the recent Settlement 

Agreement between the National Federation of the Blind of California and the Law School Admission Council with the concurrence of the 

Department of Justice (April 25, 2011). 33 See Action Step 7 for links to GSA’s resources, including the BuyAccessible Wizard www.buyaccessible.gov.

34 See Action Step 7 for links to W3C resources.

35 Dear Colleague Letter to elementary and secondary schools, http://www2.ed.gov/about/offices/list/ocr/letters/colleague-201105-pse.html and 

Frequently Asked Questions (FAQ), http://www2.ed.gov/about/offices/list/ocr/docs/dcl-ebook-faq-201105.html. 36 Roadmaps at page 9. 

37 The examples are taken from Microsoft’s Accessibility Guide, Accessible Information and Communication Technologies, Benefits to Business 

and Society at pages 5-10, Roadmaps at pages 9-10, OneVoice for accessible ICT (2009-2010), and Becoming an Employer of Choice—how 

accessibility can help you attract, recruit, and retain maturing workers, IBM April 24, 2007. See also information on customizing a Web 

accessibility business case available in Developing a Web Accessibility Business Case for Your Organization, http://www.w3.org/WAI/bcase/

and EARN’s Talent to Drive Your Business’s Success, http://www.askearn.org/BusinessCase/ 38 The descriptions in the text are taken from the following document prepared by the Access Board: Electronic and Information Technology 

Standards: An Overview, www.access-board.gov/sec508/summary.htm

39 See Access Board Advance Notice of Proposed Rulemaking updating and modernizing the Telecommunications Act Accessibility Guidelines 

and the Electronic and Information Technology Standards [75 Federal Register 13457 (March 22, 2010)] 40 See 36 CFR 1194.21.

41 DOJ Testimony at page 5. 42 Judy Brewer, Achieving the Promise of the Americans with Disabilities Act in the Digital Age—Current Issues, Challenges, and 

Opportunities, Hearing before the Subcommittee on the Constitution, Civil Rights, and Civil Liberties, House Committee on the Judiciary, (April 

22, 2010). 

43 36 CFR 1194.22.

44 See DOJ Section 508 Survey, FY 2010, U.S. Department of Justice Section 508 Survey Questions FY2010;

Recruitment Hints and Tips: Introduction; Recruitment Hints and Tips: Website access—Putting in place an action plan. http://www.barrierfreerecruitment.com. 45 See Action Step 1.

46 36 CFR Part 1194.

47 http://www.w3.org

48 See http://www.buyaccessible.gov; http://www.w3.org. 49 36 CFR 1194.23.

50 http://www.accesswireless.org/Find/Gari.aspx.

51 36 CFR 1194.24. 52 36 CFR 1194.25. 53 36 CFR 1194.26. 54 36 CFR Subpart D. 55 See Silverstein, Robert. A Technical Assistance Guide for Federal Contractors Regarding Implementation of Online Application Systems that 

Meet the Needs of Qualified Individuals with Disabilities and Qualified Disabled Veterans, Economic Systems, Inc (July 2009). 56 See OFCCP Program Directive Number 281 (July 10, 2008) regarding Contractors’ Online Application Selection Systems.

57 See OFCCP Program Directive Number 281 (July 10, 2008) regarding Contractors’ Online Application Selection Systems.

58 Recruitment Hints and Tips: Assisting people who cannot apply online—a manual fail-safe. http://www.barrierfree-recruitment.com.

59 See OFCCP Program Directive Number 281 (July 10, 2008) regarding Contractors’ Online Application Selection Systems.

60 See Appendix A to the Section 503 Regulation—Guidelines on a Contractor’s Duty to Provide Reasonable Accommodation.

61 Roadmaps at page 11. 62 Roadmaps at page 9. 63 Roadmaps at page 12. 64 Recruitment Hints and Tips: Minimizing the risk of outsourcing. http://www.barrierfree-recruitment.com.

65 Guidance on Creating 508 Compliant IT Solicitations, GSA’s Section 508 Program. Guidance on Creating 508 Compliant IT Solicitations. 66The BuyAccessible Wizard http://www.buyaccessible.gov helps define the specific requirements of a particular ICT deliverable. It also 

provides a means to convey these requirements to the vendor. Once accessibility requirements are defined, the BuyAccessible Wizard also 
67

 

provides the appropriate language to include these in the solicitation. The Wizard also provides generally accepted “good practices” to follow 

when assembling the solicitation, including:

Section 508 applicability statements, notifying when an exception is claimed, requesting accessibility information from vendors, and 

recommending an appropriate format for this information via a Voluntary Product Accessibility Template (VPAT) or a Government Product and 

Services Accessibility Template (GPAT). The Wizard also generates three additional guides to aid in the procurement of conformant EIT: 

Evaluation Guide (helps buyers evaluate various proposals based on commercial availability of their applicable provisions); Acceptance Guide 

(helps buyers evaluate various proposals based on commercial availability of their applicable provisions); and Design Guide (provides EIT 

developers with resources (internet links) that are qualified design and development methods to help ensure conformance to the applicable 

provisions based on generally accepted design and development methods). 

67See http://www.section508.gov/index.cfm?fuseAction=BuyAccessiblePO. 68 Roadmaps at page 12. 69 Roadmaps at pages 11-12; Microsoft Accessibility Guide at page 42 and 50

70 Affirmative Action for People with Disabilities—Volume II Modernizing the Affirmative Action Provisions of the Section 503 and VEVRAA 

Regulations, Economic Systems, Inc (April 30, 2010) at pages 49-50. [Hereinafter referred to as AAP Study Volume II] 71 Settlement Agreement Between the United States of America and Wells Fargo Company under the Americans with Disabilities Act, DJ#202-

11-239 (2011) at page 9. 72 Roadmaps at pages 11-12. 73 Ensuring the Accessibility of Federal Electronic and Information Technologies Procured by Federal Agencies, Memorandum for Chief 

Acquisition Officers and Chief Information Officers from Executive Office of the President (November 6, 2007). 74 Improving the Accessibility of Your Web Site, W3C Web Accessibility Initiative, http://www.w3.org/WAI/impl/improving.html 75 Improving the Accessibility of Your Web Site, W3C Web Accessibility Initiative, http://www.w3.org/WAI/impl/improving.html 76 Roadmaps at page 12. 77Affirmative Action for People with Disabilities—Volume II Modernizing the Affirmative Action Provisions of the Section 503 and VEVRAA 

Regulations, Economic Systems, Inc (April 30, 2010) at pages 44-46. See also DOJ Wells Fargo Settlement at page 16.