To ensure that all IT systems are accessible to all users, with and without disabilities, the Office of Environmental Information (OEI) and the Office of Civil Rights (OCR) formed the Section 508 Executive Council in 2012. The Council’s mission is to improve Section 508 compliance across the Agency by
fostering more executive management level involvement. The Council launched a general re-evaluation of its Section 508 responsibilities under the Rehabilitation Act of 1998 to create a more robust EPA policy. In addition to the Executive Council, OEI serves as the overall lead for the Section 508 Program at EPA. The Section 508 Coordinator and Assistant Coordinator provide training and consultation on 508 for EPA employees, and provide support to the Executive Council.
The Council, composed of Senior Executives and managers from regional and program offices, originally formed five workgroups that focus on key areas of Agency 508 needs and support: Policy; Procurement and Grants; Testing; Standardization and Procedures; Program Assurance; and Training, Communications and Outreach. These workgroups are responsible for creating the policies, procedures and programs for integrating accessibility into IT and are discussed below.
11.2.1 Section 508 Executive Council
The Section 508 Executive Council meets bi-monthly to discuss and resolve Section 508 issues at EPA. The Executive Council directs actions to the various workgroups for further investigation and development before making recommendations to the CIO.
11.2.2 Section 508 Policy Workgroup
The Section 508 Policy Workgroup is charged with revising the Agency’s Section 508 policy and developing a governance charter for the Section 508 Executive Council. The Workgroup coordinates with all other 508 workgroups to make sure that their input and roles are included in the Section 508 policy.
In 2014, the Policy Workgroup revised the policy, expanding and providing additional detail in the following areas:
Clarifying roles and responsibilities across the Agency for implementing Section 508; codifying the Section 508 Executive Council and its workgroups
Clarifying accessibility requirements (Section 508 Standards) for phones, electronic communications and computers
Clarifying the distinction between Section 508 and Reasonable Accommodation requirements under the provisions of the 1973 Rehabilitation Act
Setting forth the expectations and integral role of Section 508 in the Agency’s activities, including testing, verification and a greater accountability for 508 compliance
Defining procedures for approval and testing of electronic and information technology (EIT) The Policy Workgroup will continue to shepherd future revisions of the Section 508 policy and associated procedures through the Agency’s policy process.
11.2.3 Procurements and Grants Workgroup
The Procurements and Grants Workgroup works closely with the Office of Acquisition Management (OAM) to implement the following:
EPA Acquisition Regulation (EPAAR) Clause 1552.211-79: Compliance with EPA Policies for Information Resource Management has been updated to include additional language and guidance emphasizing accessibility.
Clarification of EPA grants language to ensure that accessibility considerations are included in the grants process.
The EPA Office of Acquisition Management (OAM) added a new requirement, effective FY 2015, for all Contracting Officers Representatives (CORs) to take Section 508 training.
Future/Planned Work: OAM is working with OEI to develop more usable Section 508 training for contracting officers and contract specialists. Training modules will incorporate EPA-specific business processes. OAM has also appointed a dedicated Section 508 liaison to work with OEI. Activities will include serving on EPA’s Section 508 Testing, Standardization and Procedures Workgroup, developing and delivering Section 508 training to the contracting community and writing requirements documents for testing agency-wide electronic and information technology for Section 508 compliance.
11.2.4 Testing, Standardization and Procedures Workgroup
The Testing, Standardization and Procedures Workgroup is developing a testing and approvals Procedure to accompany the draft 508 Policy and is exploring the standardization of Assistive Technology (AT) used at the Agency. To help shape the Procedure and the AT Standardization efforts, the workgroup conducted site visits with the U.S. Department of Education, the U.S. Department of Veterans Affairs, the U.S. Internal Revenue Service and the U.S. Department of Homeland Security to learn how these agencies test their electronic and information technology for Section 508 compliance.
Future/Planned Work: The Testing, Standardization and Procedures Workgroup will develop an Agency- wide standard operating procedure that EPA employees can follow to approve and test electronic information technology for Section 508 compliance. The Workgroup will also develop recommendations on standardizing the AT used at the agency, along with versions to test new EIT for compatibility and user
acceptance. Finally, the Workgroup will develop a form that information resource managers can use as a guide to determine when they should test software for Section 508 compliance.
11.2.5 Program Assurance Workgroup
In January 2013, the White House and OMB issued the Strategic Plan for Improving Management of Section 508 of the Rehabilitation Act. Within the Strategic Plan are requirements for each agency to complete Section 508 assessments and to develop a Performance Measurement Plan (PMP). The Program Assurance Workgroup developed initial metrics and measures that EPA uses to assess the Section 508 Program. The Workgroup also drafted the PMP, which was submitted to OMB in November 2013. Future/Planned Work: The Program Assurance Workgroup no longer functions as a formal workgroup. The Section 508 Coordinator and the Assistant Section 508 Coordinator will continue to work on the planned assessments and complete the associated OMB Strategic Report requirements.
11.2.6 Training, Communications and Outreach Workgroup
The Training, Communications and Outreach Workgroup provides training and improves communication and outreach efforts for the Section 508 Program and the Section 508 Executive Council’s work. It has addressed the following:
Expanded outreach materials and events including a new 508 Intranet site, outreach materials such as the “Think 508 First” brochure and “Captioning at EPA” Factsheet and October Disability Employment Awareness Month activities.
Examined what trainings are or have been offered at EPA regarding Section 508 and is developing recommendations on future trainings that may be required for EPA employees.
Created the Section 508 Community Forum, which is a voluntary program for any person at EPA interested in Section 508 issues. The Forum will help improve Section 508 communication across EPA as well as provide opportunities for input, feedback and recommendations from
stakeholders on EPA’s Section 508 program and services.
Future/Planned Work: This workgroup will conduct regular 508-related communications, outreach and awareness events. It will also help determine and coordinate date and meeting planning for future Community Forum meetings, and will explore required and recommended trainings for EPA employees. In addition, this workgroup will also work with Region 4 staff to develop a possible required Disability Awareness training that will cover a range of accessibility topics including Section 508.
11.2.7 Other Section 508 Program and Disability Work at the Agency
The Section 508 Coordinator and the Reasonable Accommodations Coordinator have partnered to provide a joint Section 508 and Reasonable Accommodations training for employees and a separate training for managers in all the regional offices during calendar year 2013. These trainings were announced in an Agency-wide memo.
EPA is committed to building and sustaining a model EEO program. The Management Directive 715 Report for 2013 is the most recent report on how EPA strives to eliminate any barriers to equal employment opportunity to accomplish its mission by attracting and retaining a highly qualified and diverse workforce.