GSA Government-wide Section 508 Accessibility Program

How to Identify User Needs

One of the requirements in the Revised 508 Standards is to identify user needs for information and communication technology (ICT):

  • E203.2 User Needs - When agencies procure, develop, maintain, or use ICT they shall identify the needs of users with disabilities to determine:
    • How users with disabilities will perform the functions supported by the ICT; and
    • How the ICT will be developed, installed, configured, and maintained to support users with disabilities.

Improve Accessibility Testing

To identify and design for the user needs of people with disabilities, IT employees (especially developers) need to understand how disabled users interact with technology. Contact your agency’s Section 508 Program Office for assistance. They can help you:

  • Schedule ongoing demonstrations for IT staff, showing how a user with a disability may use a specific type of assistive technology;
  • Conduct user testing on systems or apps that the organization/agency already uses,  to show IT staff how users interact with those systems;
  • Ask your agency’s Employee with Disabilities Resource Group for ideas on how to demonstrate IT user needs of employees with disabilities, and involve them in user testing;
  • Help IT developers and User Experience (UX) staff to become familiar with accessibility testing, such as:
    • Conduct a demo of 508 Program staff testing a familiar app or system;
    • Demonstrate remediation of common accessibility issues;
    • Ensure IT developers have access to accessibility development and testing tools;
    • Establish a loan program for licenses of accessibility tools; or
    • Provide developers with recommendations of accessibility testing training resources.

Compliant From the Start

At the agency level, ensure that accessibility is integrated from the beginning, rather than an afterthought.

  • Ensure accessibility compliance is built into the agency’s IT life cycle management (LCM) framework;
  • Provide training to agency enterprise and project level IT governance personnel (project managers, decision-making bodies, etc.) on best practices for incorporating accessibility into their LCM;
  • Revise LCM artifacts such as templates, to include users with disabilities in all instances that address users and stakeholders;
  • Provide development teams with examples of user personas for people with disabilities;
  • Find and recruit developers who want to develop expertise in accessibility; point out that accessibility skills are valuable for career advancement;
  • Use a standardized accessibility testing methodology across your entire organization;
  • Provide guidance on when to bring an accessibility subject matter expert (SME) into the development process.

Update Policies

Assign responsibilities to project level IT governance stakeholders (e.g., system owners, project managers).

  • Identify the needs of individuals with disabilities and incorporate them into all designs, acquisition plans, and development activities.
  • If using an agile methodology, ensure the functionality requirements are built into the individual development sprints and continuously monitored, and actively manage sprint backlogs of requirements to ensure user needs of disabled people are not forgotten or neglected.

Assign responsibilities to enterprise level IT governance stakeholders (e.g., design, development, or change control boards).

  • Ensure the needs of individuals with disabilities are identified and appropriately incorporated into all designs, acquisition plans, development and modifications.
  • If using an agile methodology, ensure that functionality requirements are built into the individual development sprints, continuously monitored, and that project level stakeholders are actively managing sprint backlogs of requirements to ensure such functionality is not forgotten or neglected.


In an earlier Notice of Proposed Rulemaking, the Access Board explained, “This section proposes that, when agencies procure, develop, maintain or use ICT, they must identify the business needs of individuals with disabilities affecting vision, hearing, color perception, speech, dexterity, strength, or reach, in order to determine how such users will perform the functions supported by such ICT. The provision would also require agencies to assess how the ICT will be installed, configured, and maintained to support users with disabilities. The list of disabilities in this provision parallels the functional performance criteria proposed in Chapter 3.  The Board intends, through this provision, to reinforce the fundamental principle that agencies have an affirmative, continuing obligation under Section 508 to maintain the accessibility of ICT.”

The final rule changed the phrase “business needs” to “user needs”.

These best practices were developed by the U.S. Federal Government Revised 508 Standards Transition Workgroup. Members include the U.S. Federal CIO Council Accessibility Community of Practice, the U.S. Access Board, and the General Services Administration.

Page Reviewed/Updated: October 2017