Q1. Why does my component have to conduct a self-evaluation?
A: On August 7, 1998, Congress amended section 508 of the Rehabilitation Act. Under the new law, all Federal agencies and departments must conduct self-evaluations and report to the Attorney General the current extent to which their electronic and information technology is accessible to and usable by persons with disabilities, including Federal employees and members of the public who seek information or services from those agencies.
Q2: Why does my component have to fill out the attached Questionnaires and Checklists?
A: Staff at the Department of Justice have prepared this Questionnaire to provide an easy, time-efficient, step-by-step method for evaluating the extent to which technology is accessible to persons with disabilities. Your agency has chosen to use this method to comply with its statutory duty of self-evaluation and has designated you a "Component Contact."
Please note that although this package may appear overwhelmingly large at first glance, much of the bulk is due to its user-friendly design. There is duplication so that each part of the package can be used as a stand-alone document. This way, you do not have to make a lot of decisions about what information should be conveyed to each appropriate person within your component or how to handle a particular issue: appropriate distribution and use instructions are repeated throughout the package.
As a Component Contact, you should do the following:
(1) distribute the appropriate portions of the attached Component Questionnaire and associated Checklists (provide both hard copies and electronic versions of all documents) to a representative sample of persons throughout your component, (2) including:
- Contracting Officers ("CO");
- Contracting Officer Technical Representatives ("COTR's");
- employees with procurement warrants;
- employees with signature authority to commit agency funds;
- key Information Technology personnel responsible for computers or telecommunications;
- persons responsible for software development or procurement;
- "Web masters" or equivalent persons; and
- any other people knowledgeable about your component's electronic and information technology.
(2) collect the completed forms, including electronic copies, by [blank], the date set by your agency;
(3) enter all information from the Component Questionnaire onto the Internet web page established for this purpose: www.508.org (3) and print a copy for your records;
(4) return a print-out of your Internet submission to your Designated Agency Official:
Q3: Should each person who receives the attached Questionnaire answer all questions based on his or her knowledge of the agency as a whole?
A: No. Each such person should complete the Questionnaire and submit the information on the Internet only as it pertains to the limits of his or her authority or control within your component to ensure that overlapping responses are not generated. Your Designated Agency Official will inform you if you are responsible for evaluating a particular agency-wide application, such as agency-wide pages on the World Wide Web or agency-wide e-mail systems.
Q4: How will our information be used by the Attorney General?
A: The Attorney General will report to the President the extent to which electronic and information technology used by the federal government is accessible to and useable by persons with disabilities. Your agency's answers will assist the Attorney General in preparing a thorough and accurate "snapshot" evaluation of the extent to which persons with disabilities have equal access to and use of technology as persons who do not have disabilities, as well as helping her make appropriate follow-up recommendations.
Q5: Why is the Department requiring components to submit their information on the Internet?
A: Submission of information on the Internet will automatically enter all component information into a searchable database that will greatly facilitate the preparation of the Attorney General's report to the President, while resulting in substantial cost-savings.
Q5: What is "electronic and information technology?"
A: Section 508 requires the Access Board, by February 7, 2000, to define "electronic and information technology" in a manner that is consistent with the definition of "information technology" used in the Clinger-Cohen Act, 40 U.S.C. § 1401(3). The Clinger-Cohen definition of information technology includes "any equipment or interconnected system or subsystem of equipment, that is used in the automatic acquisition, storage, manipulation, management, movement, control, display, switching, interchange, transmission, or reception of data or information." 40 U.S.C. § 1401(3)(A). It includes, but is not limited to, "computers, ancillary equipment, software, firmware, and similar procedures, services (including support services) and related resources." § 1401(3)(B).
Section 508 specifically exempts from coverage national security systems, as that term is used in section 5142 of the Clinger-Cohen Act, 40 U.S.C. § 1452.
Because the Access Board will not issue its definition of "electronic and information technology" until February 7, 2000, you should not infer that a specific example of technology covered by this Questionnaire is "electronic and information technology" for which the Access Board will be publishing standards.
Q6: Are there any published standards that will guide my agency in determining the extent to which its electronic and information technology is currently accessible to and useable by persons with disabilities?
A: No. The Access Board is charged with developing such standards by February 7, 2000. In the interim, however, there are many private and governmental resources upon which you can draw. Many of these resources are listed in the "Resource List" that is distributed with this document.
Q7: I don't understand why it is important for my agency to determine whether its mainstream electronic and information technologies are accessible. Can't people with disabilities use separate assistive technologies specifically designed for them instead?
A: Not necessarily. The increasing complexity and interaction of electronic and information technologies often makes it impossible to "layer" assistive technologies for use on top of mainstream applications unless those applications were designed with accessibility in mind. For example, someone who is blind may use a word processing program in conjunction with a screen reader, which is designed to "voice" the information portrayed on the screen to the user. If an agency's word processing program uses icons without text labels, the screen reader cannot work properly and the person who is blind would be unable to use the word processor. While non-disabled employees would be able to access file libraries and shared files, the inaccessible word processor would lock out the user with a disability from many aspects of information sharing.
Q8: Some of the questions in the Component Questionnaire ask whether a specific example of technology used by my agency is accessible to people with certain types of disabilities. Does this mean that there is always a technological solution that will provide access to people with all kinds of disabilities?
A: No. There are some types of technology for which there are currently no ways to make them accessible to persons with disabilities. If accessible technology does not exist, then an agency may rely on the "undue burden" defense of section 508 and may procure inaccessible technology. Even if it is an undue burden to provide accessible technology, federal agencies must ensure that access to information is provided through some other accessible means.
Q9: In what other instances is the "undue burden" defense applicable?
A: An agency may legitimately claim that procurement of accessible technology is an "undue burden" -- and thus not required by section 508 -- when it would pose a "significant difficulty or expense," such as when accessible technology is generally unavailable in the mass market or when it is significantly too expensive to be obtained given the scope of the procurement at issue. Even if it is an undue burden to provide accessible technology, federal agencies must ensure that access to information is provided through some other accessible means.
Q10: Can our agency by-pass the self-evaluation process and provide the Attorney General with information about our agency's reasonable accommodation policies and procedures?
A: No. This self-evaluation process focuses on your technology rather than looking at how your agency provides reasonable accommodations to specific individuals with known disabilities. It is important that you conduct this self-evaluation without regard to whether your agency or its components have employees with disabilities or communicate with members of the public who have disabilities.
Q11: What topics are covered by the Component Questionnaire?
A: The Component Questionnaire covers the following topics:
- Procurement Policies and Procedures
- Computer and Network Based Applications and Services
- Information Transaction Machines
- Other IT Equipment
1. For persons with disabilities, additional copies of this document are available on computer disk and in alternate formats including large print, Braille, and audio cassette, by calling the following numbers at the Department of Justice, Civil Rights Division:
Section 508 Coordinators:
ADA Information Line:
Alternate format copies for persons with disabilities may also be requested via e-mail to: email@example.com
This document is available on the Section 508 Home Page of the Civil Rights Division, U.S. Department of Justice: http://www.usdoj.gov/crt/508/508home.html
3. If you do not have the ability to use the Internet, inform your Designated Agency Official as soon as possible so that he or she may make arrangements for another agency employee to enter the information onto the Internet page. You must use a government computer when entering your data on the Internet site; for security reasons, the page is designed to reject entries from non-governmental users whose home Internet address does not end in the suffix ".gov" or ".mil."
Last revised March 24, 1999