Email this Article Email   

CHIPS Articles: Ensuring Your Solicitation is Section 508 Compliant

Ensuring Your Solicitation is Section 508 Compliant
By Sherrian Finneran - October-December 2011
Since 1998, when Congress amended the Rehabilitation Act, all federal agencies, including the Department of Defense, are required to make electronic and information technology (E&IT) accessible to individuals with disabilities. The law applies to all federal agencies when they develop, procure, maintain, or use electronic and information technology.

Accessible E&IT includes technologies that allow those who are blind or visually impaired to easily obtain information on websites and participate in online training. Exceptions to compliance are identified by the Federal Acquisition Regulation (FAR), part 1194, as detailed below.

In June 2011, the Department of Defense Chief Information Officer published DoD Manual, 8400.01-M, "Procedures for Ensuring the Accessibility of Electronic and Information Technology (E&IT) Procured by DoD Organizations." The manual, available at, assigns responsibilities and provides procedures for implementing Section 508 requirements.

The manual provides guidance to requiring officials, purchasers and requesters to ensure that their acquisition meets U.S. Access Board accessibility standards unless a FAR exception applies. Requiring officials must conduct market research to find products or services that meet the standards. Market research results must be attached to the purchase request or, in the case of a contract for services, the statement of work (SOW). Requiring officials must also include draft technical specifications, minimum requirements and a statement of applicable U.S. Access Board standards. If it applies, officials must include a statement documenting non-availability of accessible products or services, or include a statement that meeting accessibility requirements causes an undue burden for the agency.

Contracting officers or procurement officials are instructed to review SOWs and purchase requests to ensure that Section 508 requirements are properly addressed and that applicable documents are provided by the requiring office.

In July 2010, the Office of Management and Budget issued a memo, "Improving the Accessibility of Government Information," directing agencies to take stronger steps toward improving the acquisition and implementation of accessible technology. The memo directed the General Services Administration (GSA) Office of Governmentwide Policy to review solicitations posted on the federal business opportunities website,, for compliance with Section 508 and to report the results of the reviews quarterly to OMB beginning fiscal year 2011.

GSA is also directed to provide review results to applicable agencies. Since that time, GSA sends emails to agencies either congratulating them for a job well done or providing them with opportunities to improve their solicitations for compliance with Section 508.

There are a number of resources to assist agencies in their compliance with Section 508. As part of its statutory requirement, GSA provides technical assistance to agencies on Section 508 implementation. GSA created a number of tools, available at, to help agencies develop accessible requirements, test the acceptance process, and share lessons learned and best practices.

Users may also access training by clicking the 508 Universe Training link,

Related CHIPS Articles
Related DON CIO News
Related DON CIO Policy

CHIPS is an official U.S. Navy website sponsored by the Department of the Navy (DON) Chief Information Officer, the Department of Defense Enterprise Software Initiative (ESI) and the DON's ESI Software Product Manager Team at Space and Naval Warfare Systems Center Pacific.

Online ISSN 2154-1779; Print ISSN 1047-9988
Hyperlink Disclaimer