Section 508 requirements apply when maintaining as well as developing and procuring ICT. When ICT maintenance and support services are acquired, Section 508 accessibility requirements must be considered when specifying agency need and documenting the RFP.
Section 508 Due Diligence for Maintenance and Support Acquisitions
Include Section 508 for ICT Upgrades, Patches, and Fixes
The program should already understand the accessibility of existing ICT, typically from an associated GPAT/VPAT. Continuing maintenance and support acquisitions should specify that any changes to the existing ICT shall not reduce, and when possible should enhance, the accessibility of the ICT being maintained.
Require Section 508 for ICT Help Desk and Support
When support services for existing ICT products are acquired, the requiring authority should identify applicable Section 508 accessibility requirements from the Access Board Standard CFR 1194 Subpart D.
Don't Forget Section 508 for ICT Information and Documentation
Make sure to consider requirements from the Access Board Standard CFR 1194 Subpart D for ICT information and documentation, as well as vendor support.
Common Mistakes in Section 508 Due Diligence
- Not considering Section 508 requirements for maintenance of ICT products.
- Making a general mention of Section 508, but not identifying specific requirements from CFR 1194 that apply.
- Not considering Section 508 for ICT information, documentation, and support
- Not documenting Section508 exception determinations.