Web Accessibility Guidelines - Section 508 Checklist: Part 2

In the first part of this series, we looked at the two main accessibility regulations in the United States, the ADA and Section 508, with a focus on the latter. Section 508’s initial checklist, dating from the year 2000 contained two sections relevant for the development and usage of accessible technologies, which was thought to be in line with the web content accessibility guidelines known as the WCAG 1.0. Entities looking to understand web accessibility compliance had at their disposal the US Access Board's Information and Communication Technology (ICT) and the Accessibility 508 Standard and Guidelines. 

However, in 2018 an amended version was issued which cited W3C's web accessibility guidelines under WCAG 2.0 as the standard for web accessibility. This version of the web content accessibility guidelines takes into account the higher level of complexity that disability entails, but it also simplifies the process of web accessibility compliance. Below we include the new checklist. While the old Standard offered a list of principles, the Revised Standard, which can be found on the official website of the US General Service Administration (GSA) for Section 508, and which relies on web content accessibility guidelines WCAG 2.0, asks a series of questions that entities should answer to determine whether or not the standard applies, depending on the type of information and communication technology used in their organization. The Revised Standard offers a technology verification checklist to entities that plan to purchase or use technology that incorporates content accessibility.

To be kept in mind is the fact that, at this time, the most current version of the WCAG is version 2.2, which removes one of the success criteria in previous versions, and adds nine new ones instead. We have discussed this in a previous blog post.

Revised 508 Standard - Checklist

Electronic Content

Question 1 - Is the content comprised of records+ maintained by the National Archives and Records Administration (NARA) pursuant to Federal record keeping statutes?

• If Yes, the electronic content component of the ICT item does not have to conform to the Revised 508 Standards.
  • If the ICT contains hardware or software components, proceed below to those sections, below.
• If No, proceed to Question 2

Question 2 - Will the content be public-facing?

• If Yes, proceed to Question 4
• If No, proceed to Question 3

All public facing electronic content must be accessible. The standards define ”public facing” as content made available by an agency to members of the general public. Section E205 of the Revised 508 Standards specifies which electronic content, including web, software, multimedia and electronic documents, must conform to the technical requirements. Usually, public facing content is published on the web (for example, on an agency website, blog, form, or social media page). However, public facing content might also be made available in non-web formats, such as information displayed on screens or interactive kiosks in waiting areas.

Question 3 - Will the content be an official agency communication that is not public-facing?

• If Yes, proceed to Question 4
• If No, the electronic content component of the ICT item does not have to conform to the Revised 508 Standards.
  • If the ICT contains hardware or software components, proceed below to those sections.

Electronic content that is not public facing but is official business, and is communicated through one or more of the nine categories below is an ”agency official communication” and must be accessible. The content might be broadly disseminated or sent to individual agency employees or members of the public. The method of delivery does not determine whether electronic content is ”agency official communication.” Such content may be disseminated via an internal agency website or intranet, or by other delivery modes. Common transmittal means include, but are not limited to: emails, text messages, phone alerts, storage media, and downloadable documents.

The nine categories of agency official communication (with examples) are listed below. All of the following examples are provided to help provide further understanding of these categories. The examples are not all-inclusive. Contact the U.S. Access Board for assistance with interpreting and applying these categories.

1. Emergency notifications - Examples include: evacuation notices, active shooter alerts, text messages conveying emergency instructions (e.g., ”remain in place”), hazardous weather alerts, and operational notices regarding unscheduled closures.
2. An initial or final decision adjudicating an administrative claim or proceeding - Examples include: an electronic notice or alert of an approved, denied, or pending claim sent to a business or other organization, or to an individual.
3. Internal or external program or policy announcements - For example, an electronic notification of a new agency policy or a change to an existing program requirement.
4. A notice of benefits, program eligibility, employment opportunity, or personnel action - For example: an electronic notice sent to a member of the public or employee describing government benefits to which they are entitled; information on whether an individual is eligible for benefits from, or can participate in a government program; information on the status of an application for enrollment in a program; notification of an official personnel action indicating a promotion, adverse action, or other personnel decision affecting a government employee; a job announcement.
5. A formal acknowledgment of receipt - For example: an email acknowledging receipt of payment; a notice posted to a program participant’s web page containing his or her personal account information and acknowledging that he or she successfully submitted certain records.
6. Survey questionnaires - Examples include: a set of written questions (open-ended or multiple choice) developed for the purpose of a survey or data analysis such as a questionnaire assessing employee training needs; an employee satisfaction survey; a questionnaire used to gather information related to gauging satisfaction with a government program. This category does not include questions submitted during litigation or legal proceedings.
7. Templates or forms - For example: an electronic document template used to create official agency documents or presentations; a web page template created to establish a common look and feel for a website; an official agency form that must be completed by employees or members of the public.
8. Educational or training materials - Examples include: interactive online training courses; self-paced training course; educational webinars; other educational presentation formats; support materials for such activities including, electronic worksheets, training manuals, and tests.
9. Intranet content designed as a web page - For example: an intranet page listing files for downloading; shared calendars; an internal employee locator; and other html web pages distributed internally via an agency Intranet. This category does not include files within a listing distributed via the agency intranet that are not in one or more of the nine categories above.

NOTE: An exception provides that NARA is not responsible for remediating records sent to them by other agencies

Question 4 - Will the electronic content be web-based?

• If Yes, the following Standards apply:
  • 602 Support Documentation
  • 603 Support Services
  • All WCAG A & AA Success Criteria
• If No, the following Standards apply:
  • 602 Support Documentation
  • 603 Support Services
  • All WCAG A & AA Success Criteria apply except:
    • 2.4.1 Bypass Blocks
    • 2.4.5 Multiple Ways
    • 3.2.3 Consistent Navigation
    • 3.2.4 Consistent Identification

Software

Question 1 - Is the software assistive technology (i.e., any item, piece of equipment, or product system used to increase, maintain, or improve functional capabilities of individuals with disabilities)?

• If Yes, the software component of the ICT item does not have to conform to the Revised 508 Standards.
  • If the ICT contains hardware components, proceed below to that section.
• If No, proceed to Question 2

Question 2 - Will the software be web-based?

• If Yes, the following Standards apply:
  • All WCAG A & AA Success Criteria
  • 502 Interoperability with Assistive Technology
  • 503 Application
  • 602 Support Documentation
  • 603 Support Services
  • 302 All Functional Performance Criteria

1. Note: Applies when Chapter 5 does not address one or more functions of ICT (E204), or when an agency invokes ”equivalent facilitation” (E101.2)

• Proceed to Question 3
• If No, the following Standards apply:
  • All WCAG A & AA Success Criteria apply – EXCEPT the following:
    • 2.4.1 Bypass Blocks
    • 2.4.5 Multiple Ways
    • 3.2.3.Consistent Navigation
    • 3.2.4 Consistent Identification
  • 502 Interoperability with Assistive Technology
  • 503 Application
  • 602 Support Documentation
  • 603 Support Services
  • 302 All Functional Performance Criteria
    • Note: Applies when Chapter 5 does not address one or more functions of ICT (E204), or when an agency invokes ”equivalent facilitation” (E101.2)
• Proceed to Question 3

Question 3 - Is the software also an authoring tool?

• If Yes, the following additional Standards apply:
  • 504 Authoring Tools
• If No, stop. No additional Standards for software apply.
  • If the ICT contains hardware components, proceed to the next section.

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• All-in-one platform: One interface combining Privacy and Accessibility compliance with global regulations, at an affordable price;
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• ReadyCompliance: Covering 30+ data privacy regulations;
• Six preconfigured accessibility profiles, as well as 25+ display adjustments that allow visitors to customise their individual experience.

You can convince yourself and see Clym in action by booking a demo or reaching out to us to discuss your specific needs today.