US Department of Veterans Affairs
As the Veterans Integrated Service Network (VISN) 10 Accessibility Compliance Officer, I was responsible for the network’s compliance with Section 508 of the Rehabilitation Act of 1973.
This included developing a local SOP, enforcement of Section 508 requirements, education of staff, and certifying compliance of websites and documents.
STANDARD OPERATING PROCEDURE
VISN 10 Accessibility / Section 508 Compliance
SOP V10-24-001
VISN 10 Network Office
Cincinnati, OH
Human Resources
Education Office
Signatory Authority: Chair, Organizational Health Committee
Effective Date: December 2023
Responsible Owner: Accessibility Compliance Officer
Recertification Date: December 2028
1. PURPOSE AND AUTHORITY
a. The purpose of this Standard Operating Procedure (SOP) is to establish processes ensuring external-facing websites, intranet pages, SharePoint sites, and documents within VISN 10 are compliant with Section 508 of the Rehabilitation Act. This SOP must be followed by employees who create and manage these materials and their supervisors.
b. This SOP sets forth mandatory procedures and processes to ensure compliance with the Section 508 addendum to the Rehabilitation Act of 1973.
2. PROCEDURES
a. Requirements. Section 508 of the Rehabilitation Act requires federal agencies, including the Department of Veterans Affairs, to make Electronic and Information Technology (EIT) accessible to individuals with disabilities and ensuring EIT is compatible with commonly used assistive technology, such as screen readers, and the transcription of audiovisual media.
(1) Accessibility.
(a) VHA will author fully accessible documents, regardless of the intended audience. Accessible documents conform to industry-standard practices ensuring information is available to persons with visual and hearing impairments; non-sighted persons; and non-hearing persons.
(b) The minimum compliance goal for EIT is to adhere to the World Wide Web Consortium’s (W3C) Web Content Accessibility Guidelines (WCAG) 2.0 standards (ISO/IEC 40500) level AA. The principles of the WCAG are:
1. Perceivable.
a. Provide text alternatives for any non-text content so it can be understood, such as large print, braille, speech, symbols, or simpler language.
b. Provide alternatives for time-based media, such as recording and sharing a live training so it may be reviewed at the user’s speed or providing adjustable playback speed for recorded content.
c. Create content that can be presented in different ways (for example simpler layout) without losing information or structure.
d. Make it easier for users to see and hear content including separating foreground from background.
2. Operable.
a. Make all functionality available from a keyboard.
b. Provide users enough time to read and use content.
c. Design content to not act in ways known to cause seizures (such as flashing/strobing animation).
d. Provide ways to help users find content and navigate within the content.
3. Understandable.
a. Make text content readable and understandable.
b. Make web pages appear and operate in predictable ways.
c. Prevent users from misinterpreting content.
4. Robust.
a. Maximize compatibility with current and future user agents—software which retrieves, renders, and facilitates end-user interaction with web content—including assistive technologies.
(c) The WCAG 2.0 Level AA compliance checklist is available at: https://www.w3.org/TR/2006/WD-WCAG20-20060427/appendixB.html
(2) Universal Design.
(a) Responsible parties will implement principles of Universal Design, within the constraints of the Veterans Affairs Tier-1 Guidelines. Principles of Universal Design are:
1. Equitable use. The design is useful and marketable to people with diverse abilities. A website that is designed so that it is accessible to everyone, including people who are blind, employs this principle.
2. Flexibility in use. The design accommodates a wide range of individual preferences and abilities. A museum that allows a visitor to choose to read or listen to a description of the contents of a display case employs this principle.
3. Simple and intuitive. Use of the design is easy to understand, regardless of the user’s experience, knowledge, language skills, or current concentration level. Science lab equipment with control buttons that are clear and intuitive employs this principle.
4. Perceptible information. The design communicates necessary information effectively to the user, regardless of ambient conditions or the user’s sensory abilities. Video captioning employs this principle.
5. Tolerance for error. The design minimizes hazards and the adverse consequences of accidental or unintended actions. An educational software program that provides guidance when the user makes an inappropriate selection employs this principle.
6. Low physical effort. The design can be used efficiently and comfortably, and with a minimum of fatigue. Doors that open automatically employ this principle.
7. Size and space for approach and use. The design provides appropriate size and space for approach, reach, manipulation, and use, regardless of the user’s body size, posture, or mobility. A science lab with adjustable tables employs this principle.
b. Training. The VISN Accessibility Compliance Officer will facilitate and disseminate national-level and vendor trainings regarding Accessibility and Section 508 compliance and its requirements, universal design principles, and industry-standard accessibility and compliance tools.
3. ASSIGNMENT OF RESPONSIBILITIES
a. VISN Accessibility Compliance Officer. The VISN Accessibility Compliance Officer is responsible for providing guidance, review, and overall direction to VISN 10 network, medical center leaders responsible for documents, and supports Local Coordinators, Web Administrators, and Document Authors.
b. Coordinators. Public Affairs Officers are responsible for ensuring their VAMC and subordinate facilities’ EIT is compliant with Section 508. This includes overseeing the implementation of this SOP to affect EIT Accessibility compliance for their facility for any content hosted on the VA internet and intranet or any other channels for external release. They will oversee and delegate tasking for compliance reviews and liaise with stakeholders and the VISN Accessibility Compliance Officer for reporting and to resolve issues as they occur.
c. Approvers. Any who approves EIT prior to distribution. Approvers will review content for compliance and return to authors for remediation of issues. Examples of approvers:
(1) Web Administrators. Responsible for ensuring websites on internet and intranet pages as well as hosted media and documents comply with Section 508. They will perform tasked compliance reviews, affect corrective action plans, and maintain accessibility conformance reports.
(2) Health Education Specialists. Ensure EIT submitted to them for review and EIT sourced from vendors for the purpose of Veteran education is reviewed for accessibility and direct non-compliant EIT to its creator for remediation. Education Specialists will also ensure the content of EIT intended for Patient Education is within the reading-level requirements set forth by the VHA National Desktop Library and the National Library of Medicine’s Health Literacy guidelines.
(3) Medical Facility Patient Education Committee Members. Ensure EIT submitted to them for review and EIT sourced from vendors for the purpose of Veteran education is reviewed for accessibility and direct non-compliant EIT to its creator for remediation.
d. Authors. Any person who develops and produces EIT. Authors are responsible for ensuring EIT is compliant and will route completed documents to approvers for distribution. Examples of authors:
(1) EIT Developer. Any person developing EIT will ensure their products are fully accessible in its end-state prior to distribution.
(2) Medical Media. Medical Media staff and their supervisors are to ensure EIT is developed with the goal of being fully accessible throughout production. This includes incorporating universal design principles, workflows facilitating live transcription and closed captioning of video products and tagging EIT for screen-readers.
4. DEFINITIONS
a. Electronic and Information Technology (EIT): Information technology and any equipment or interconnected system or subsystem of equipment, that is used in the creation, conversion, or duplication of data or information. Some examples of EIT are Telecommunications Products (i.e., Phones); Information Kiosks and Transaction Machines; Websites; Multimedia; and office equipment (such as copiers and fax machines).
5. REVIEW
a. Website and Document Compliance Reviews.
(1) Using Accessibility Tools, Web Administrators must use accessibility tools to review external-facing websites, intranet pages, and SharePoint sites, and hosted documents for compliance with Section 508 requirements on a weekly basis. Tools may include screen readers, automated testing tools, manual testing techniques, and compliance services (such as Site Improve). The goal is to consistently exceed WCAG 2.0 level AA criteria.
(2) Users who are Administer online content (intranet, internet, & SharePoint sites) must report the results of the compliance review to the Public Affairs Officer, including any non-compliance issues found and any corrective actions taken. Issues will be submitted, and status will be updated using the VISN 10 Accessibility Compliance SharePoint tool.
(3) Web Administrators will report results of weekly compliance reviews to the Local Coordinator monthly unless an issue is identified. For immediate compliance issues, the Local Coordinator should be informed immediately so it can be remediated. Local Coordinators will collate and report their sites’ reports to the VISN 10 Accessibility Compliance Officer on a monthly basis.
b. Non-compliant EIT Remediation Timeline.
(1) Non-compliant EIT identified during reviews must be addressed (remediated or removed within 10 business days from the date identified.
(2) Web Administrators and Document Authors will prioritize addressing issues that impact the most users or present the greatest barriers to accessibility.
(3) When compliance issues are identified, Web Administrators and Document
Authors must develop a corrective action plan to address the issues and ensure compliance with Section 508. The corrective action plan should include specific actions, timelines, and the responsible parties.
(4) The Local Coordinator will conduct reviews while corrective action is in
progress and affirm compliance of affected EIT has been achieved. If compliance has not been achieved, corrective action plan should be reviewed and revised as necessary.
If compliance cannot be achieved at the Local Coordinator’s level, this should be reported to the VISN Accessibility Compliance Officer.
(5) If the issue is on a website template VHA Digital Media should be notified of
the issue and the notice should include the URL, a screenshot of the issue, and relevant code for the issue.
6. REFERENCES
a. Section 508 of the Rehabilitation Act of 1973: https://www.section508.gov/manage/laws-and-policies/
b. VA Directive 6221, Accessible Information and Communications Technology (ICT): https://www.va.gov/digitalstrategy/docs/VA_Directive_6221_16_Oct_2017.pdf
c. VA Directive 6102, Internet and Intranet Services: https://www.va.gov/vapubs/viewPublication.asp?Pub_ID=1056&FType=2
d. VA Web Governance, supplemental to VA Directive 6102: https://digital.va.gov/web-governance/
e. Tier 1 Graphic Standards Guidelines: https://www.va.gov/opa/publications/graphicstandards/va_graphicstandardsguide_508_0113.pdf
f. VA.gov | Design System: https://design.va.gov/
g. VHA National Desktop Library reading-level requirements: https://www.va.gov/LIBRARY/Patient_Education.asp
h. National Library of Medicine Health Literacy: https://www.nnlm.gov/guides/intro-health-literacy
i. W3C WCAG 2.0: https://www.w3.org/TR/WCAG20/
j. W3C WCAG 2.0 Level AA checklist: https://www.w3.org/TR/2006/WD-WCAG20-20060427/appendixB.html
k. U.S. Web Design System (USWDS): https://designsystem.digital.gov/
7. REVIEW
This SOP must be reviewed, at minimum, at recertification, when there are changes to governing documents and any regulatory requirement for more frequent review.
8. RECERTIFICATION
This SOP is scheduled for recertification on or before the last working day of December 2028. In the event of a contradiction with national policy, the national policy supersedes and controls.
9. SIGNATORY AUTHORITY
X—-
Human Resources Officer, VISN 10
X—-
Network Director, VISN 10