Section 508 Accessibility Program

NO. 13800 (Rev. 1) | DATE: October 6, 2020

SUBJ: Section 508 Accessibility Program

TO: All NCUA Staff

REFERENCES:

• Section 508 of the Rehabilitation Act of 1973, as amended (29 U.S.C § 794 (d))
• Information and Communication Technology (ICT) Final Standards and Guidelines, 36 CFR Parts 1193 and 1194
• Web Content Accessibility (WCAG) Guidelines 2.0

Purpose

To establish a Section 508 Accessibility Program for the NCUA in accordance with federal regulations to ensure individuals with disabilities have equivalent access to all NCUA Information Communications Technology (ICT), to include products, services, and communications. This applies to federal employees as well as the general public.

Cancellation

NCUA Instruction 13800, Section 508 Accessibility Program, issued December 7, 2017, is hereby canceled and should be removed from the files.

Background

Section 508 of the Rehabilitation Act of 1973 was enacted to eliminate barriers to information and the technology used to access information. It creates opportunities for people with disabilities and encourages the development of technology products and services using accessible design.

Section 508 applies when federal agencies develop, procure, maintain, or use Information and Communications Technology (ICT). Federal agencies must ensure that employees with disabilities have access to ICT that is comparable to the access enjoyed by employees without disabilities, unless doing so would impose an undue burden on the agency.

Policy

All NCUA personnel must comply with the NCUA’s Section 508 Accessibility Program policies, procedures, standards, guidelines, and controls.

Section 508 Requirements Process

There are six phases of the Section 508 Requirements Process. The six phases include:

1. Initial Planning & Pre-Acquisition
2. Detailed Planning & Acquisition
3. Configuration & Testing
4. Acceptance
5. Deployment
6. Operations

The applicability of each phase is dependent upon whether or not the ICT is developed or procured. These phases are defined along with the required documentation on the NCUA Section 508 website.

Section 508-related requests (including training inquiries) must be submitted to OneStop*. A summary of testing results will be provided for remediation. Required corrections must be resubmitted for Section 508 Program Manager approval prior to release.

*For files posted on NCUA.gov or MyCreditUnion.gov, please continue to follow NCUA Instruction 1760. The Section 508 validation process is built-in to the posting procedures for these websites.

Procurement

When planning an acquisition involving ICT, accessibility is a legal requirement. To ensure accessibility is properly documented in ICT procurements, accessibility requirements must be determined. Market research must be conducted to research ICT vendors and solicitation language must cover Section 508 requirements. When evaluating vendor proposals, compliance must be validated by the NCUA. The NCUA Acquisition Policy Manual (APM) includes information to assist with Section 508 requirements in solicitations. Additional information can be found on General Services Administration (GSA) Buy Accessible Products and Services webpage. As part of the Office of Management and Budget (OMB) reporting process, solicitations must be tracked to confirm Section 508 requirements are included in all ICT procurements.

Complaint Procedures

Individuals should file a complaint if they believe that ICT products maintained, procured, developed, or used by the NCUA do not comply with accessibility standards. Internal complaints should be submitted to OneStop and will be routed appropriately. External complaints will be handled following the instructions on the NCUA’s public accessibility webpage.

Scope

This policy applies to all employees, contractor personnel, interns, and other non-government employees conducting business for the NCUA, or on its behalf through contractual relationships or memoranda of agreement.

Definitions

Accessibility – Ensuring that individuals with disabilities have equivalent access to products, services and systems.

Information – Any communication or representation of knowledge such as facts, data, or opinions in any medium or form including text, numerical, graphic, cartographic, narrative, 3 or audiovisual forms. (Defined in OMB Circular A-130, Transmittal Memorandum #4, Management of Federal Information Resources, 6(a)).

Rehabilitation Act of 1973 – The Act requires access to programs and activities that are funded by federal agencies or needed for federal employment.

Section 508 – A federal law which requires agencies to provide all people with disabilities, whether employees or members of the public, access to information that is comparable to access available to others.

Responsibilities

This policy outlines key responsibilities for NCUA leadership and staff. A complete list of roles and responsibilities is available on the GSA Section 508 website, and some key NCUA roles and responsibilities are listed below.

Office of External Affairs and Communications (OEAC)

• Appoint a Section 508 Program Manager responsible for organizing and supporting the implementation of Section 508.
• Develop and maintain an agency-wide Section 508 Accessibility Program.
• Develop and maintain Section 508 policies and procedures to address all general applicable requirements for Section 508.
• Ensure the NCUA has trained personnel or resources to assist in complying with Section 508 requirements.
• Ensure the NCUA reports annually to the agency head on the effectiveness of the agency Section 508 program. Submit required reports to OMB, the Department of Justice and the CIO Council.
• Maintain baseline reports which will be transparent to all of the NCUA.
• Develop and maintain a Section 508 Intranet site that provides training on accessibility topics including best practices; provides examples of common errors and how to fix them; and educates the agency on Section 508.

Office of the Chief Financial Officer (OCFO)

• Conduct validation of procurement solicitations and provide data to the Section 508 Program Manager to ensure incorporation of Section 508 contract language into Statements of Work and Performance Work Statements.
• Track the validation of procurement solicitations to support the biannual report to OMB.

Office of the Chief Information Officer (OCIO)

• Ensure Section 508 requirements are incorporated into all NCUA’s ICT life cycle activities, including enterprise architecture, design, development, testing, deployment, and ongoing maintenance activities.
• Coordinate with OEAC on the testing and validation of Section 508 conformance claims prior to deployments.
• Ensure Section 508 testing documentation is retained for all internal and external applications and websites maintained by OCIO.

Effective Date

This instruction is effective immediately and will remain in effect until cancelled or superseded.

For further information, please contact NCUA’s Section 508 Program Manager at Section508@NCUA.gov. Additional resources for the NCUA’s Section 508 Accessibility Program can be found on the NCUA Central Section 508 site.

/s/

Larry Fazio
Executive Director

Authoring Office
OEAC