From 2013 to 2016, CTP provided Section 508 consulting services to the Department of Veterans Affairs (VA) leading day-to-day operations of the Commonwealth Trading Partners (CTP) team. In this capacity, Commonwealth Global Partners (CGP) worked closely with stakeholders at the VA Learning University (VALU) to institutionalize an early lifecycle audit process that was patterned after our own procedures. On behalf of VALU, CGP successfully engaged vendors early in their contract and reduced the volume and severity of 508 violations found in the vendor’s final deliverable when it was submitted to VA 508 for final certification.
High-Volume Audits and Vendor Coordination
CTP operated as a liaison between the VA 508 office and vendors contracted to deliver digital materials (e.g., e-learning, PDFs, websites, Etc.). Our 508 compliance team worked closely with vendors, from contract inception to delivery, to help internal development teams interpret and implement the requirements set forth by the VA’s Section 508 office. CGP was able to remove ambiguity early in the production process and minimize post-submission 508 violations.
Over the course of a project, CTP provided both consultative feedback and final audit results. When engaged early in the build-out phase, our 508 compliance team reviewed drafts, prototypes, or planning documents to furnish recommendations to the vendor that will impact subsequent production phases. Based on the development schedule, we frequently engage the vendor’s technical team to verify that the guidance is properly implemented. As needed, we work with the VA 508 office to clarify expectations and validate solutions.
As the development of a project nears completion, our team’s vendor interactions transition to a more traditional 508 audit approach. When the vendor has determined a product passes their internal 508 review, our team will perform a full audit using the same tools and evaluation criteria as the VA 508 office. Our results are recorded in an online software application called the Accessibility Management Platform (AMP), which is seamlessly shared with the VA 508 office.
Collaboration and a Revised Approach to 508
While every federal solicitation for digital products includes language requiring the vendor to meet 508 compliance guidelines, the requirement is typically included as a technical specification that does not describe how compliance will be evaluated or achieved. As a result, vendors must choose how they will interpret and implement 508 standards in their product. However, final audit and certification of a digital product is the responsibility of the Federal Agency for which the material was produced.
This was the case at VALU when our team began working with the VA—fully developed products were delivered for VA 508 review near the end of the vendor’s Period of Performance (PoP), with little time left to repair 508 violations. Although vendors generally believed that their products met the VA’s 508 requirements, specific implementation decisions frequently caused materials to be returned for substantial repairs. During the first six-months of the contract, CTP effectively diagnosed the situation and recommended changes that would proactively address 508 concerns.
In collaboration with stakeholders at VALU, we applied an early engagement model to create alignment between the vendor’s 508 evaluation criteria and those of VA 508. In support of this revised process, we educated project managers about the new process, created materials to help convey the message to vendors, and conducted outreach sessions to instruct practitioner-level staff. After an initial pilot period, our team provided subject matter expertise to help VALU create a new SOP that codified the approach.
The majority of 508 violations begin at the content creation level and are a byproduct of human error. The key to sustainable improvements in awareness, implementation, and conformance with Section 508 lies in continued outreach and education.
At VA, a continued goal of our outreach efforts has been the demystification of Section 508, with the aim of emphasizing real world accessibility. We have engaged content creators of all levels to share knowledge about how to create well-structured documents using methods that can also improve their overall workflow. For example, a Microsoft Word document that correctly employs styles can easily be converted to structured PDF that will function well with assistive technology (AT).
- Audited over 1,000 Digital Products (PDFs, Word Documents, PowerPoint files, Excel spreadsheets, Video Captions, email templates, eLearning, and HTML)
- Introduced an early life cycle audit methodology to reduce 508 failure rates
- Achieved Certification and Approval on 220 submission to VA 508
- Achieved 98% Certification rate for submitted materials