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508 Web Compliance and Remediation Framework

Purpose:

The purpose of the Framework is to outline a course of actions to bring all HHS Web sites and content into compliance with Section 508 of the Rehabilitation Act; 29 U.S.C. § 794d (Section 508) and, concurrent with that effort, address critical maintenance issues.

Scope:

The Framework covers all HHS Web sites, internal or external, owned, managed or funded by Operating and Staff Divisions (OPDIVs/STAFFDIVs), whether developed by staff or acquired through contracts, cooperative agreements, grants and/or formally established partnerships with other government entities and/or the private sector.

The Framework covers traditional Web content, including all attached or linked HHS files, and all new and social media, including videos, podcasts, blogs, Wikis, and associated applications on all HHS Web sites.

Background:

Section 508 requires that Web sites and associated content created with federal funding, whether internal or external, government- or contractor-hosted, are accessible to persons with disabilities. The law has been in effect since June 21, 2001. Federal compliance – including that of HHS -- has lagged.

In FY 2006, ASPA’s Web Communications Division (WCD) moved to raise awareness of Section 508, conducting outreach, developing compliance guidance and, in concert with the Office of the Chief Information Officer, the Deputy Assistant Secretary for Acquisition Management and Policy, and the Office on Disability, developing acquisition language requiring that contract-developed Web sites, Web content, and communications products be delivered Section 508 compliant. WCD is now working with the Office of Grants to develop language requiring that Web and communications products developed under grants and cooperative agreements also be delivered 508 compliant.

In November 2007, HHS began receiving notices of Section 508 non-compliance from Accessing Digital America (ADA). Each notice included a survey of a sampling of pages from a Department-owned Web site. As of February 1, 2008, HHS had received 13 such notices covering the Office of the Secretary and 10 OPDIVs. It became clear that many Departmental Web sites were not in compliance with Section 508. HHS is establishing a Memorandum of Understanding (MOU) with ADA that will describe how the Department will address its Section 508 issues over a five-year period. Each OPDIV’s Plan will follow the template below and will implement the necessary actions to achieve Section 508 compliance and fulfill the MOU agreement. Once it is established, the MOU will be provided to each OPDIV.

WCD’s investigation into Section 508 compliance also revealed critical site maintenance issues, most notably broken links. On average, 50 percent of all Departmental pages contain a broken link. Broken links are an accessibility issue for every site visitor and seriously undermine a Web site’s utility. Since Section 508 remediation requires touching virtually every page, it only makes sense to address broken links at the same time.

Overview:

HHS recognizes the enormity of bringing the full inventory of the Department’s Web sites into Section 508 compliance. This Framework sets goals and deadlines, and allows the OPDIVs to develop their individual implementation plans within the parameters set out herein. WCD will facilitate this work by providing overall management of the Framework, developing standards and guidance, providing training, and implementing a contract for addressing Section 508 compliance issues. (The extent of the contract and its funding are being worked out so that supplemental resources are available to address compliance issues.) Other resources must come through re-prioritizing how each OPDIV allocates its Web resources, including review of planned new sites, redesigns and maintenance. The Framework is based on the following assumptions:

  • A full inventory of HHS Web holdings, listing Web sites, pages, and files, is being created. This is being done by WCD and the OPDIVS to establish a baseline inventory, and then will be continually maintained as sites/pages/files are added, deleted, or archived.
  • Full compliance and remediation will require a five-year phased approach.
  • First priority is addressing compliance moving forward. All newly posted sites and/or content must be Section 508 compliant as of January 1, 2008.
  • The second priority is addressing HTML accessibility issues.
  • The third priority is addressing legacy file (attachments or non-HTML files) issues. Legacy work will primarily focus on pages and files posted since June 2001. In rare instances, files created prior to that date may be remediated if such files are actively used today (forms, regulations, etc.).
  • A prioritization schema for remediation will be developed and guidance issued based on:
    • Audience criticality (need by persons with disabilities)
    • Level of demand (site visits, file downloads)
    • Mission criticality (public need; HHS strategic priorities)

  • This schema will be used to determine:
    • Remediation of HTML/XHTML Web infrastructure
    • Remediation of non-compliant legacy files
    • Level of accessibility
      • Immediate accessibility: available at the time of site visit
      • Accommodation: information provided in alternate format upon request

  • All Web infrastructures (HTML, navigation, applications delivering Web content, page content, links, forms, logins, and scripts) must be Section 508 compliant.
  • Public outreach files that provide content intended for the general public (fact sheets, brochures, Public Service Announcements, videos) must be accessible at the time of visit.
    • For files provided in multiple formats, at least one format—preferably HTML—must be accessible.
    • This accessible format must have the same or better functionality than other formats provided.

  • The major cornerstone of remediation will be the removal of expendable Web sites and legacy files—deleting outdated sites and material, eliminating orphan sites, removing duplicate content or pages, and cleaning up disorganized materials.
  • Standards defining compliance and technical guidance, and training on how to achieve compliance must be developed.
  • Guidance procedures governing accessibility accommodation will be developed for geographic information system (GIS) applications, data-intense documents, and certain public-sector filings that qualify for the Fundamental Alteration exception outlined in 36CFR1194.3. This guidance will be narrowly drawn, lest abuse undermine the total effort.
  • Adequate resources must be identified to support Section 508 compliance implementation.
  • Accurately measuring the Framework’s success requires establishing metrics, tracking performance, and implementing a system of regular reporting.
    • The Framework establishes a timeline and Departmental goals.
    • WCD will establish and manage a Department-wide database for tracking and reporting progress at the OPDIV level.
    • The database will:
      • Be based on a full Web site inventory.
      • Utilize IBM Policy Tester (Watchfire) to track page inventory, broken links and HTML Section 508 remediation.
      • Allow OPDIVs to directly enter file remediation updates.
      • Generate quarterly reports.

Timeline and Goals:

Immediate:

  • All new or significantly revised Web sites, all new or revised forms, and all files submitted for posting must be Section 508 compliant.
  • All Department-owned content directly linked to by Department news releases must be Section 508 compliant.

Startup:

02-11-08          ADA discussion on proposed MOU with the Web Council.

02-11-08          HHS Compliance and Remediation Framework (Framework) concept presented to Web Council.

02-12-08          ADA Notices and surveys sent to OPDIV heads and Council Representatives.

02-15-08          Framework draft distributed for comment.

02-22-08          ADA discussion comments due to WCD.

03-07-08          Framework comments due to WCD.

03-19-08          Revised Framework is discussed and reissued for final comment.

03-26-08          Revised Framework comments due to WCD.

04-08-08          Framework issued.

04-30-08          Senior Manager named to coordinate planning and implementation.

04-30-08          Web Council receives initial inventory of all HHS Web sites and pages.

05-30-08          Technical guidance and standards are in place based on identified need to date (others will be issued as
                         warranted/identified).

06-30-08          OPDIV Plans (including all organizational entities) due to WCD.

06-30-08          WCD database reporting system for Department is made available.

07-01-08          Implementation of Plans for addressing Section 508 compliance begins the first year.       

09-30-08          First reporting period closes.*

* Reporting is tied to the fiscal year to correlate with budgeting and with SES performance reviews.

Note: Phases One through Five outlined below address the remediation of existing legacy Web sites and associated files. All new sites and materials posted as of January 1, 2008 are to be fully compliant.

The Plan for each OPDIV will be developed by:

  1. Analyzing information from IBM Policy Tester – previously known as Watchfire – along with any other tools available to create inventories. IBM Policy Tester will be used to generate the baseline (HTML) inventory for all OPDIVS.
  2. Conducting an assessment of files not identified in the inventory (PDFs, forms, compressed [ZIP] files, graphics, new media, executables, etc.) to be remediated by each OPDIV.
  3. Matching assessments to the priorities outlined above, and the percentages described below. These goals, outlined below, are minimal requirements for each year; OPDIVS are encouraged to plan a more aggressive schedule of compliance if it is possible to achieve.
  4. Analyzing and rectifying business processes that result in documents or files that will be posted on the Web. Section 508 compliance can be facilitated by addressing accessibility issues from project conception through all stages instead of at project completion.
  5. Estimating and identifying resources that will be needed to complete each Phase of the Plan. Reallocating resources from current budgets to achieve the first year goals and planning for succeeding years related to funding needed. Proposed new sites and site redesigns should be weighed against the need to fund Section 508 compliance and site (broken link) maintenance.
  6. Completing Plans for Phases One through Five that meet the goals below. These Plans will remain dynamic, and can be adjusted by reporting major changes in implementation to WCD. Each Phase of the Plan is likely to be several pages long when the detail is added. OPDIVs should be as specific as possible so that the Plan is a guide for use in implementation.

OPDIVs will each name a Senior Manager by April 30, 2008 who will be responsible for coordinating the development and implementation of their Division’s Compliance and Remediation Plan. The Senior Manager named will work closely with the Web Council Members and 508 Official in preparing and managing 508 implementation. Standards will be incorporated into Performance Plans for SES managers, Public Affairs Directors, Web content and technical staff, and contract and project officers.

WCD’s day-to-day coordination will be with OPDIV Representatives to the HHS Web Council and OPDIV Section 508 Officials and Coordinators (lists attached).

Phase One – First Year (06-01-08 through 9-30-08):

  • Web infrastructure: Top 7% (of non-compliant pages) remediated
    (Section 508 and broken links)
  • Web files: Top 3% (of non-compliant) made compliant
  • Web cleanup: Combined Web page and file inventory reduced by 10% Department-wide
  • Web forms: Top 20% of HTML/PDF inventory made compliant

Phase Two – Second Year (10-01-08 through 09-30-09):

  • Web infrastructure: Next 28% remediated
    (Total: 35% compliant/fixed)
  • Web files: Next 27% made compliant
    (Total: 30% compliant)
  • Web cleanup: Web and file inventory reduced by 5% or more (OPDIV goals)
  • Web forms: Remaining 80% made compliant

Phase Three – Third year (10-01-09 through 09-30-10):

  • Web infrastructure: Next 25% remediated
    (Total 60% compliant/fixed)
  • Web files: Next 30% made compliant or removed
    (Total 60% compliant)

Phase Four – Fourth Year (10-01-10 through 09-30-11):

  • Web infrastructure: Next 25% remediated
    (Total: 85% compliant/fixed)
  • Web files: Next 25% made compliant or removed
    (Total: 85% compliant)

Phase Five – Fifth Year (10-01-11 through 05-31-13)*:
* This date has been extended

  • Web infrastructure: Remaining 15% remediated or removed
    (Total: at least 90% compliant/fixed)
  • Web files: Remaining 15% made compliant or removed
    (Total: at least 90% compliant)

Project Completion:

  • HHS Web sites and associated files are fully Section 508 compliant by the end of the fifth year.
  • Broken link percentage is held below 2%.
  • Web page and file inventory are reduced by 25% Department-wide.
  • Tools, resources, and culture are in place to ensure continuing compliance.

Action Items:

Please reply with the name of the senior manager who will coordinate and manage the development and implementation of your 508 Compliance and Remediation Plan by April 30, 2008. Your Plan is due to WCD June 30, 2008. All replies, your Plan and any questions should be sent to: prudence.goforth@hhs.gov and richard.stapleton@hhs.gov.