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Ensuring Section 508 Compliance

Ensuring Section 508 Compliance. How to include Section 508 in acquisitions, grants, and business initiatives Gary M. Morin, NIH Section 508 Program, Analyst. Ensuring Section 508 Compliance. How to include Section 508 in acquisitions, grants, and business initiatives

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Ensuring Section 508 Compliance

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  1. Ensuring Section 508 Compliance How to include Section 508 in acquisitions, grants, and business initiatives Gary M. Morin, NIH Section 508 Program, Analyst

  2. Ensuring Section 508 Compliance How to include Section 508 in acquisitions, grants, and business initiatives Gary M. Morin, NIH Section 508 Program, Analyst

  3. Today’s Discussion • Integrating Section 508 in the procurement process, specifically the HHSAR language. • Why 508 is important to include in RFAs and how to do it. • Business Initiatives and Section 508. • Q&A - now’s your chance!

  4. Disability Laws Rehabilitation Act: • 501: ensures Fed agency applicant & employee accessibility and non-discrimination • 503: ensures Federal Gov’t Contractor (>$10,000) non-discrimination • 504: ensures non-discrimination by “any program or activity” that is funded by the Federal Gov’t • 508: requires agencies “procure, maintain, and use” EIT that is accessible. Americans With Disabilities Act: • Title I – Requires employee accessibility (including State/tribal Gov’t) • Title II – Requires accessibility to all state activities by the public

  5. Section 508 • Covers Electronic and Information Technology (EIT) • Requires “comparable access” • A civil rights law achieved via acquisitions

  6. Section 508 • Standards-based • Accessibility, not accommodation • No cost/value factor – 508 is not a value calculation! • Most like Security • Some limited, rare exceptions

  7. Integrating Section 508 in Acquisitions – CO/COTR • Contracting Officer • Ensure Requiring Official meets 508 responsibilities • Act as conduit for vendor questions/responses • Enforce HHS Section 508 policy and HHSAR • Ensure Clearances • COTR • Determine Applicable Provisions • Evaluate Vendor responses (HHS PAT – Product Assessment Template) • Monitor Change request impact on Section 508 • Include Section 508 in acceptance testing

  8. Integrating Section 508 in Acquisitions – Requiring Official • Acquisitions Planning • Determining if EIT • Identify COTR or 508 SME • Evaluation Criteria • Clearance • Applicable Provisions • 36 CFR 1194 (.21-.41) • Language (SOW) • From HHSAR • Must include applicable provisions

  9. Integrating Section 508 in Acquisitions – Requiring Official • EPLC • 508 Critical Partner • conditions • Exceptions • 508 Coordinator Clearance • Evaluation • Reading the PAT • Acceptance • Test against HHS acceptance criteria • Engage Section 508 Coordinator when needed

  10. Integrating Section 508 in Acquisitions – The bottom line • Acquisitions planning • Exceptions signoff • Solicitations : • Use the right language! (HHSAR) – warrants 508 • Include applicable provisions in SOW • Get a PAT • Contracts: • Language (again!) • Acceptance criteria (checklists) • Option Years • Require 508 Annual Report

  11. Why 508 is important to Grants and Agreements • Overlapping laws • 504 • ADA • Telecommunications Act • Liability & Due Diligence • HHS’ name is on many of these materials • Guilt by association • Cost of litigation/public impact

  12. How to include electronic access in Grants/Agreements • Tie to Section 504 requirement • Modify existing 504 language to require accessible IT in program activities • Require accessible electronic documents • Reference HHS acceptance criteria/checklists • States may have equivalent standards

  13. MOAs with other Fed agencies • GovTrip and MyPay – the story so far • Require Section 508 • Identify applicable provisions • Mandate HHS acceptance criteria unless other formal acceptance criteria used • Require documentation (PAT) at a minimum • General issue resolution • What is the mechanism for issue resolution if HHS is unsatisfied?

  14. Business Initiatives and 508 • Communications and Marketing to SDB and DV-owned businesses • Referrals to Section 508 coordinator for help with understanding 508 requirements • Possible business opportunities • Testing 508 compliance • Subcontracting re: 508 development • Helping vendors fill out PATs

  15. Gary M. Morin, Program Analyst NIH Office of the Chief Information Officer  (301) 402-3924 Voice, (301) 451-9326 TTY/NTS (240) 380-3063 Videophone; (301) 402-4464 Fax Section 508 Guidance, http://www.hhs.gov/web/508/index.html [DILBERT cartoon used with Scott Adams’s Permission] Questions and Answers

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