GSA Government-wide Section 508 Accessibility Program

Section 508 Roles and Responsibilities

These are some of the acquisition and information technology roles and responsibilities for implementing and managing an agency Section 508 program for Information and Communication Technology (ICT) as outlined by the OMB’s Strategic Plan for Improving Management of Section 508 of the Rehabilitation Act

Requiring Official/Government Buyer Roles and Responsibilities

Anyone and everyone is or can be a Requiring Official/Government Buyer. This includes
  • Requiring Official, sometimes called Program Officer or Requesting Official
  • Statement of Work (SOW) Writers

As soon as you decide you want to procure something, regardless of your grade level or position description, you become the "Buyer". For example, a secretary ordering a fax machine or a statistician ordering software is a Requiring Official. As long as you are in the process of buying something or considering a purchase, you are a Requiring Official. Requiring officials represent the actual customer side - they "own" the need that will be met by the contract. They may be an IT specialist or program manager or other mission-side representative. If you are a requiring official you may have several different types of responsibilities where you need knowledge and understanding of Section 508 Standards. Your responsibilities regarding Section 508 implementation include:

  • Determine your need, Section 508 relevance and exceptions, and specific Section 508 technical and performance requirements. The requiring official must identify which standards would apply to the procurement, using the Access Board's ICT Accessibility Standards at 36 CFR part 1194. The physical and functional characteristics of the ICT and its intended use to meet program requirements determine which specific technical provisions of the Section 508 standards apply. OMB’s Strategic Plan for improving management of Section 508 of the Rehabilitation Act requires that Requiring Officials include appropriate Section 508 accessibility standards in acquisition planning and requirement documents.
  • Conduct market research on accessibility of available ICT. Technical specifications and minimum requirements would be developed based on the market research results and agency needs. This information should be submitted with the purchase request.
  • Provide RFP language for solicitation, assist in choosing the best proposal during source selection, and conduct inspection and acceptance during ICT delivery. The requiring official must document in writing the non-availability, including a description of market research performed and which standards cannot be met, and provide documentation to the contracting officer for inclusion in the contract file. Requiring and ordering activities must ensure supplies or services meet the applicable accessibility standards at 36 CFR Part 1194, unless an exception applies, at the time of issuance of task or delivery orders. OMB’s Strategic Plan for improving management of Section 508 of the Rehabilitation Act requires that Requiring Officials Verify that products or services delivered under an agreement meet the accessibility terms and conditions included in a contract prior to accepting deliverables.

As a Requiring Official/Government Buyer you should coordinate with:

  • IT Specialists to identify 508 applicability and accessibility requirements
  • IT/Testing Specialists to identify inspection and acceptance criteria for deliverables
  • Program Management to determine proposal evaluation factors
  • Contracting Officers to ensure that accessibility requirements, inspection and acceptance criteria, and evaluation factors are appropriately represented in the solicitation
  • Testing Specialists to develop test plans and conduct delivery inspection, testing and acceptance

Go to Buyer page

Contracting Roles and Responsibilities

Contracting roles for Section 508 implementation include:
  • Procurement Official
  • Contracting Officer
  • Contracting Specialist
  • Contracting Officer’s Representative (COR)
  • Contracting Officer’s Technical Representative (COTR)

The Contracting Officer's responsibilities include:

  • Planning the acquisition along with the rest of the acquisition team, including the user (the Requiring Official). OMB’s Strategic Plan for improving management of Section 508 of the Rehabilitation Act requires that Contracting Officer: Review and comply with the of FAR 11.002(f) and 39.2 by ensuring Section 508 standards are considered in acquisition planning documents and procurement requirements for ICT and that deliverables meet accessibility standards and include appropriate Section508 accessibility standards in requirements and acquisition planning documents and agreements.
  • Assisting the Requiring Official in performing market research for accessible ICT.
  • Assisting the Requiring Official in drafting specifications and minimum requirements/agency needs, when these are needed for procurement.
  • Ensuring there is competition and that the contracting file shows what happened, as the FAR directs.
  • Awarding the contract or order after complying with procurement statutes and regulations (generally summarized and discussed in the Federal Acquisition Regulation), and any additional agency regulations and order.

The CO must coordinate with the Requiring Official to:

  • Confirm that the Section 508 applicability and accessibility requirements are included in the SOW The Contracting Officer must ensure the Statement of Work (SOW)/solicitation document is accessible. For example, a scanned document is not accessible to someone who has to use a screen reader such as JAWS.
  • Ensure that requirements, inspection and acceptance criteria and evaluation factors are appropriately represented in the solicitation. The CO must ensure the Requiring Official has included Section 508 technical requirements, conducted market research, and documented Section 508 due diligence.
  • Determine proposal evaluation factors
  • Participate in proposal evaluation

The COTR/COR is responsible for managing the contract once it is awarded. The COTR/COR may also assist with the development the SOW. OMB’s Strategic Plan for improving management of Section 508 of the Rehabilitation Act requires that Contracting Officer’s Representative include appropriate Section 508 accessibility standards in acquisition planning and requirement documents and verify that products or services delivered under an agreement meet the accessibility terms and conditions included in a contract prior to accepting deliverables. Go to Contracting page

Internal IT Developers Roles and Responsibilities

Internal IT developers are responsible for ensuring compliance with Section 508 for the products and services that are created within the Department/Agency environment. This means they need to determine when Section 508 applies, what accessibility requirements are applicable, and identify testing, inspection and acceptance criteria for internal deliverables (i.e., software development, Intranet development, internal IT maintenance and services). Agency IT Developers should coordinate with the program requiring authority to:
  • Identify 508 applicability and accessibility requirements
  • Determine inspection and acceptance criteria for deliverables

Agency IT Developers should also coordinate with the IT Testing Specialists to conduct delivery inspection, testing and acceptance. Go to Developer/Tester page

Heads of Federal Agencies including CIO and CAO Roles and Responsibilities

OMB’s Strategic Plan for improving management of Section 508 of the Rehabilitation Act requires that Head of agencies ensure that individuals involved in acquisition planning and requirements generation specify needs; develop plans, specifications, etc. that address ICT accessibility using standards issued in 36 CFR part 1194. Agency Chief Information Officer (CIO)’s role and responsibilities as outlined by the OMB’s Strategic Plan include:
  • Establish the agency Section 508 program, provide leadership of the program, and appoint the agency Section 508 coordinator/manager.
  • Ensure Section 508 accessibility considerations are incorporated into the planning, operation, and management of any ICT that is developed, used, or maintained by the agency.
  • In collaboration with agency CAO, ensure Section 508 is considered in ICT procured by the agency.

CIO office staff may need to determine the current technical requirements for IT systems. They may also need to participate in Section 508 testing, compliance monitoring, measurement, and disclosure activities. CIO office may coordinate with the Requiring Official to:

  • Identify applicability and accessibility technical requirements
  • Determine testing, inspection and acceptance criteria for deliverables
  • Determine proposal evaluation factors
  • Participate in technical evaluation of proposal

The CIO office may also coordinate with IT Testing/Specialists to conduct delivery inspection, testing and acceptance Agency Chief Acquisition Officer (CAO)’s role and responsibilities as outlined by the OMB’s Strategic Plan include:

  • Responsible for agency performance of acquisition activities and acquisition programs, to include development of the agency’s acquisition workforce.
  • In collaboration with the Chief Information Officer (CIO), ensure Section 508 requirements are incorporated into any ICT that is procured by the agency.

Go to Executive page

Section 508 Coordinator Roles and Responsibilities

Federal Section 508 Coordinators are responsible for organizing and supporting the implementation of Section 508 within their respective departments and agencies and have been appointed by their department/agency as the central point of contact for information concerning accessibility issues and solutions. Section 508 Coordinator responsibilities include, but are not limited to:
  • Defining the roles and responsibilities of the Coordinator, establish a team of subject matter experts to assist, and coordinate all reporting requirements.
  • Coordinating the integration of Section 508 accessibility needs into department/agency budget, strategic, and IT capital plans.
  • Supporting validation of accessible IT systems performance prior to deployment.
  • Coordinating and providing sources of education and training to key personnel within the department/agency, identify available resources, and stay abreast of procurement changes to the FAR that will affect the purchase of any new equipment or software.
  • Section 508 Coordinators should establish contacts with other department/agency coordinators to share information about your organization’s implementation strategies.

Section 508 Coordinator’s role and responsibilities as outlined by the OMB’s Strategic Plan include:

  • Manage an agency Section 508 program on behalf of the agency CIO, to include developing and maintaining agency policies, guidebooks, and disseminating best practices.
  • Provide consultation to, or participate in, agency capital planning and/or business case development and IT governance to ensure ICT appropriately considers Section 508 across the IT and acquisition lifecycles.
  • Partner with other Section 508 Coordinators throughout the Federal Government to assist in meeting Section 508 goals and objectives
  • Consider additional detailed responsibilities as provided for in the GSA Resource Manual for Section 508 coordinators which will be located and maintained at Section 508.gov

A complete listing of Section 508 IT Coordinator(s) is available at this site. If your department/agency does not currently have a Section 508 Coordinator or is not listed you should contact your Office of the Chief Information Officer (OCIO). If you do not have an OCIO, contact whoever is in charge of Information and Communication Technology. Go to Section 508 Coordinator page

ICT Vendor Roles and Responsibilities Regarding Section 508 Implementation

If you manufacture, build, design, create, teach, or resell an ICT product or service than you are an ICT vendor. If as an ICT vendor you want to do business with the Federal government, then you must know how to demonstrate that your ICT conforms to the Section 508 Standards. ICT Vendor responsibilities include, but are not limited to:
  • Facilitate how you sell Information and Communication Technology (ICT) products and services to the government;
  • Provide an easy way to showcase accessibility information about your products and services for government buyers;
  • If YOU want to do business with the Federal Government, then your ICT product or service must be accessible as defined by these Standards.
  • In your response to a solicitation, you may need to provide language to show not only your understanding of the regulations and requirements but also how well your product or service complies with the Standards.

Go to Vendor page

Approving Official (AO) Roles and Responsibilities

In purchase card programs, the Approving Official ensures that the purchase card is used properly. The AO authorizes cardholder purchases and ensures that the statements are reconciled and submitted to the designated billing office in a timely manner. The AO should also review proposed purchases to ensure that purchase cardholders comply with Section 508 requirements. See OMB Circular A-123 Appendix B for more information about policies and procedures for government charge card programs. Go to Micro-Purchase page for tools and resources for applying Section 508 to credit card purchases.