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HHS Section 508 FAQ's

Last document update: July 3, 2007

508 Basics

Q: What does Section 508 Cover?

A: Almost everything electronic, from a fax machine to a sophisticated payroll management system.  There are exceptions, but all EIT is processed using OPDIV 508 procedures and any determined exceptions documented.

Q:  What is the purpose of Section 508?

A:  Section 508 states that when Federal agencies develop, procure, maintain, or use electronic and information technology (EIT), Federal employees with disabilities shall have access to and use of information and data that is comparable to the access and use by Federal employees who are not individuals with disabilities, unless compliance would impose an undue burden on the agency. It also includes individuals with disabilities, who are members of the public seeking information or services from a Federal agency have access to and use of information and data that is comparable to that is provided to the public who are not individuals with disabilities, unless compliance would impose an undue burden on the agency. 

Q: Is there a Section 508 Complaint Process?

A:  The Section 508 legislation passed in 1998 included enforceable and binding provisions that hold Federal agencies accountable when they procure EIT. The law places legal responsibility on the Federal agency to ensure that EIT purchases are accessible to persons with disabilities. Persons with disabilities (Federal employees and members of the public) can file civil action against the Federal agency that fail to purchase accessible EIT products and services. The civil action is filed against the Federal agency and not against an individual such as a web developer or requiring official. For true internally developed EIT, Federal employees should follow the administrative complaint procedures as stated in Section 504 of the Rehabilitation Act of 1973. See: Speak Out! - ITTATC

Q:  Our office does not employ any employees with disabilities. Would that make us exempt from complying with Section 508?

A: The number of people with disabilities is not relevant. If we procure, maintain, develop or use electronic and information technology, it must conform to the applicable provisions of the 508 standard.

Q:  What is Electronic and Information Technology?

A:  Electronic and Information Technology (EIT) are software and hardware products that people use everyday to obtain and retrieve information electronically. EIT includes computers (i.e., desktop and laptop), photocopy machines, fax machines, software applications (Word), operating systems (i.e., Windows), web sites and web pages, and telecommunication products (i.e., telephones and TTY's).

Q: What does Comparable Access mean?

A:  The intent of Section 508 is to ensure that Federal employees and members of the public have the ability to access the EIT information and data that is similar to the information and data that persons without disabilities have. The Section 508 requirements where created to guide Federal agencies in ensuring comparable access is provided. This does not require changing the format or the method of delivery of the information and data. Instead, the focus of 508 is to affect the way in which EIT is created so that the end product is accessible to persons using assistive technology. 

Q:  What is the difference between accessibility and accommodation?

A:  Accessibility is an approach to creating an environment that allows people to access the environment. An example includes building an office with a wheelchair ramp to allow persons using a wheelchair the ability to move around freely within the workplace.  Accommodation is modifying or adding a device to a workplace that allows a person the ability to work.  An example includes the use of screen reader software by a person with blindness to read information from their computer. 

Q:  What is the difference between alternative access and equivalent facilitation?

A:  Alternative access methods address the need to provide alternative ways to deliver information to a user in the event that a product is inaccessible as a result of an undue burden. Equivalent facilitation addresses the procurement of products that grant equal or greater accessibility even if they do not meet the specific provisions of the Section 508 standards. 

Q: What is the difference between Section 501, Section 504 and Section 508 of the Rehabilitation Act?


Q:  I need more information.  Where can I get it?

A:  There are several sources.  Start at the HHS Office on Disability web site.  Then check out the information and FAQ at  For technical questions on the standards, check out the Access Board at  If you still need assistance, call the HHS Office on Disability.

Internet / Intranet and Documents

Q:  How is it determined if software or a web site conforms to the provisions of Section 508?

A:  To determine if software or a web site conforms to the provisions of Section 508, use a test script, manual testing, automated testing, or checklists to evaluate internally developed and/or procured web or software applications.  Information regarding the standards can be found at GSA's Section 508 web site. under “About 508”. This section details the various requirements used in determining Section 508 compliance.

Q:  Do HHS videos and multimedia products need to be captioned or audio described?

A: The video and multimedia technical provisions (c) and (d) pertain specifically to HHS videos and multimedia products. They state that all training or informational video and multimedia productions, which support the agency’s mission, must be captioned for persons who are hard of hearing or deaf and audio described for persons who are blind or low vision. Also, if the informational video or multimedia production has audio or visual information that is necessary to comprehend the content, then they must be captioned or audio described. For example, CDC produced a videotape to convey its mission. The video was captioned (words appear on the screen) so that persons who are deaf or hard of hearing can see the content of the video. The tape also provided audio description (spoken words) so that persons who were blind or low vision could listen to the content. 

Q:  Do online Word documents and PowerPoint presentations need to meet the Section 508 web standards and provisions?

A:  Yes, any Word document or PowerPoint presentation that is going to be placed onto the Intranet or Internet needs to meet the applicable technical web provisions. The developer needs to look at the 16 web provisions and determine which of those provisions applies to the Word document or PowerPoint presentation. The developer will need to then follow the technical specifications in the applicable provisions to make the Word document or PowerPoint presentation accessible. For example, if the Word document contains images or graphics, then the images or graphics will need to have text descriptions provided describing their meaning. If a PowerPoint presentation contains images or graphics then those images or graphics will also need text descriptions provided describing their meaning. The intent is to make all documents, no matter their format, that will be placed on the Intranet or Internet compliant with the applicable web provisions.

Q:  Does Section 508 apply to print documents?

A:  No, unless the print document is support documentation for a software program or a description of accessibility features of EIT – in which case an alternative, accessible format must be available.  Otherwise, the requirements of Section 508 only apply to the use, development, maintenance or procurement of EIT products. If a document is going to be placed onto a Federal agency web site, then the content must comply with the applicable web-based technical provisions. 

Q:  How do web developers create web pages that are accessible for individuals who are color blind?

A:  The most common form of color blindness is red-green (the inability to distinguish between the color red and green). There is a wide range of variability within this group ranging from mild to extreme. The second most common form is blue-yellow, and a red-green deficit is almost always associated with this form. The colors blue, yellow, green and red are commonly used on Internet and Intranet web pages. It is the contrast of the colors that affect how individuals who are color blind view the web page. Color and Contrast Techniques

  1. Avoid using similar color combinations in the interface and graphics. Specifically, avoid using yellow/blue/red/green/brown/gray/purple next to, on top of, changing to yellow/blue/red/green/brown/gray/purple. It is how these colors are used, particularly if they are used against each other that result in problems.
  2. Use background patterns and colors that contrast well with lettering. Dark type and graphics against light, plain backgrounds are easiest to read and see.
  3. Avoid using colors by themselves to convey meaning or give directions to users.

Q:  Do automated web testing tools find and repair all 508-web compliance errors?

A:  No. While some automated web-testing tools on the market have the capability to find and repair web 508 compliance errors, none can find and repair all errors through a strictly automated process. There are web testing and repair tools that are free and available for download from the Internet. There are other web testing and repair tools that can only be purchased by a product vendor. AccMonitor (HiSoftware), which is available via MITS Web Services, is an automated web-testing tool that will find web compliance errors but will not repair them. The tool will test a web site for Section 508 web accessibility errors and will generate a report, which details the files that have failed. An accessibility checklist is also generated so the developer can see which of the 16 web provisions the web site failed to meet. AccMonitor will test the web site and generate accessibility and compliance reports but it is up to the web developer to code the changes required in order to meet each of the applicable web provisions. 

Q: Can Excel Spreadsheets or PowerPoint Presentations be put as files on a web site?

A:  Some Federal agency’s internal testing has determined that the free viewer programs for these types of files may not meet all of the Section 508 software criteria.  Therefore, files of these types deployed via the Internet should be converted to HTML, and then reviewed to ensure their compliance with the 508 standards for Web-based Internet and Intranet documents.  If placing Excel or PowerPoint (.ppt or .xls files) documents on an INTRANET site in original form is absolutely necessary – for example a group template, then it the responsibility of the author and the business unit manager to ensure that all persons needing access to the file have full working versions of the application, not just the viewers. 

Q:  Can I test my web site. with an automated tool and get my 508 status?

A:  Yes and no.Yes, automated tools can check for some of the provisions for web, and no they can not check for all of the provisions for web.To illustrate this point, let's consider automated spell checkers in word processing programs as an analogy. The spell checker can find words that are not in its dictionary, and even suggest replacements, but cannot identify a correctly spelled word used incorrectly. For example, if I type, "Did you loose you keys?" when I meant to write, "Did you lose your keys?", the automated spell checker will not detect this error. Similarly, while all accessibility checkers will identify missing "alt" text on images and other Web elements, none can check if the Alt text is "equivalent," as required by the guidelines.

Q:  How should I communicate the fact that my web site or software application is accessible?

A:  When communicating to the agency or members of the public about the accessibility of HHS products it is important to first talk about "people, or members of the public with disabilities", not one specific disability such as blindness. It is also important to talk about assistive technologies in general, not specific products like JAWS. Lastly, rather than saying that your product is accessible, you should be able to communicate that the product was developed to conform with the provisions of the Section 508 amendments to the Rehabilitation Act of 1973 and will provide individuals with disabilities, who may use assistive technology, equal access to and use of your product as provided to those without disabilities.


Q: Must EIT products meet all of the Section 508 technical provisions?

A:  Part of the Federal requiring officials’ responsibility in procuring an EIT product that is 508 compliant, is deciding which of the six categories of technical provisions applies to the EIT product. For example, if the Federal requiring official is looking to purchase a copier, then he or she needs to look at which of the six categories of technical provisions is applicable to the purchase of a copier. After the Federal requiring official becomes familiar with the differences between each of the six categories, he or she will know that the Self-Contained, Closed Products provisions apply to the purchase of a copier. These are the only provisions out of the six categories that apply to the purchase of a copier. Next, the Federal requiring official wants to buy a software application like the newest version of Word, and then he or she will determine that only the software applications and operating systems provisions apply. Now, if the Federal requiring official is looking for a more complex EIT product purchase like a web-based, software application that allows managers to monitor the customer calls that come into the call centers then he or she will need to look at multiple technical provisions to determine which apply. Most likely the software applications and operating systems, and the web-based information and applications technical provisions will both apply to the purchase of this EIT product. The software application will need to be accessible to users of assistive technology while interacting with the application on the Intranet, and the control functions and operating features will also need to be accessible to someone using a keyboard or the built-in accessibility functions of the Windows operating system. As previously stated, the determination of which of the six categories of technical provisions applies to an EIT procurement will depend on the functionality and intent of the EIT product. It will also depend on the requiring official’s understanding of each of the six categories of technical provisions. 

Q:  Does Section 508 require the provision of alternative formats?

A:  Yes, alternative formats of procured EIT product information, product instructions and user guides must be made available at no additional charge and only upon request. Alternate formats or methods of communication, can include Braille, cassette recordings, large print, electronic text, Internet postings, TTY access, and captioning and audio description for video materials. The EIT product materials are provided in an alternative format so that they meet the individual needs of the person with a disability. 

Q:  How do I determine which standards apply?

A:  If you are having trouble determining applicable provisions, GSA is introducing a tool called the “Section 508 Wizard” which will walk you through the process.  The Access Board web site. at also has excellent information, and can provide technical assistance with questions on the standards.

Q. Does this mean I have to test every piece of EIT I buy?

A:  Testing should be done by the vendor, reported via the VPAT and verified by the OPDIV (or OS) as meeting their needs.  Acceptance is a process of verification and awareness of any accessibility concerns, NOT setting up a Lab to ensure every disability can gain comparable access.  This is a requirements review process (again for risk management and compliance purposes) - not a detailed technical evaluation. A "determination and finding" will be made by the OPDIV that, based upon the information gathered, the product procured either meets all applicable 508 provisions, or it fails in identified provisions but is the most accessible product available.

Q:  How does Section 508 Apply to Information, Documentation and Support?

A:  When an EIT product is procured by a Federal agency, persons with disabilities need access to the information about the product, product instructions and user guides in a format that is usable and accessible. Section 508 also requires that persons with disabilities be provided with functionally equivalent access to support services. Support services include technical support hotlines and databases; call centers, service centers, access to repair services and billing services. For example, agencies acquiring help desk technical support must ensure that assistors are capable of accommodating the communication needs of persons with disabilities (communicate using a TTY).

Q:  How is assistive technology defined in terms of Section 508?

A:  Assistive technology, as defined in 36 CFR 1194.4, is any item, piece of equipment, or system that has been either customized, obtained commercially, or modified and is commonly used to enhance, maintain, or improve functional capabilities of people with disabilities. The intent of Section 508 is that EIT be compatible with assistive technology. In some cases, however, the technical provisions may require that EIT be readily usable without the need for assistive devices. For example, multimedia products that require captioning and descriptive video, must have these elements built in up front, as it is impractical to expect the user to add on these features. 

Q:  How is Functional Performance Criteria Determined?

A:  If there were no applicable technical provisions identified from Subpart B for an EIT product being procured, then the functional performance criteria provision, Subpart C would need to be applied. The functional performance criteria involve evaluating the overall product functionality and performance to ensure individual accessible components work together to create an accessible product. These provisions are structured to allow persons with sensory or physical disabilities to locate, identify, and operate input, to control mechanical functions, and to access to the information provided including text, icons, labels or operating cues. The intent is to ensure the EIT product is accessible for persons with disabilities on its own without requiring the use of assistive technology to make the product accessible. The EIT being procured must function in a method of operation and information retrieval that does not rely solely on any one of the following user abilities:

Motor Skills/Coordination or:

Q:  What are the Section 508 Technical Provisions?

A:  The technical provisions, Subpart B of the Section 508 standard are technical specifications and performance-based requirements, which focus on the functional capabilities covered by technologies. The provisions are organized into six technical categories:

When procuring EIT, requiring officials must determine and document which of these technical provisions are applicable to the EIT being purchased. For example, if the requiring official were procuring a software application like Windows XP, then the software applications and operating systems technical provisions would be applicable. If an HHS web developer is developing an internal HHS web site, then the developer is required to utilize the applicable web technical provisions to build a web site that is accessible. 

Q:  What is “market research” and how do I go about doing it?

A:  The Federal requiring official of a Federal agency is responsible for conducting market research to identify if any EIT products are available in the commercial marketplace that best meet the applicable technical provisions. Federal requiring officials can use a Voluntary Product Accessibility Template (VPAT) to assist in determining which of the technical provisions is the most applicable to the EIT product being procured. Some methods for conducting market research include using the Internet to review catalogs and other product literature published by manufacturers; obtain source lists from other agencies, trade associations and other sources; query government databases relevant to agency acquisitions; publish formal requests for information; and contact knowledgeable government agencies. 

Q:  Where can I find a list of Section 508 compliant software?

A:  The Federal Government will not maintain a list of "compliant" products due to potential legal implications. In no case should a requiring office ask a vendor to "certify their compliance with Section 508." The private sector does not have to comply with 508; the Government has the legal requirement to comply with Section 508. Instead, vendors are being asked to self-represent how their products conform to the provisions of the Section 508 standard. Ultimately, it is the responsibility of the requiring offices to do adequate market research. To assist with that research, GSA has worked with industry leaders to develop a template, the Voluntary Product Assurance Template (VPAT). GSA has created a "Buy Accessible" section of their Section 508 website ( with links to VPAT's of vendors who have represented the conformance of their products with 508. If a product is not found on GSA's web site or a manufacturer's web site, it is appropriate for a requiring office to ask vendors to complete a VPAT.

Q:  Who certifies EIT products as 508 compliant?

A: There is no Section 508 logo that signifies an EIT product meets all of the applicable technical provisions and requirements. The only one who can represent a product’s conformance is the product developer. This is however, only self-representation, not certification. The difference is that there is no legal process that can be used to derive a repeatable certification condition. Vendors are not required to self-represent EIT products as being 508 compliant unless they choose to respond to a solicitation, or are awarded a contract, that states they need to demonstrate how the products comply with the 508 applicable technical provisions. Vendors can submit a Voluntary Product Accessibility Template (VPAT) to document the applicable technical provisions and to demonstrate how the products are 508 compliant. The onus is on the procurement officials to determine if an EIT product best meets the applicable technical standards. Since it is the responsibility of Federal agencies to comply with the 508 regulations, even though a vendor may say that their product is 508 compliant, it is still up to the Federal agency procurement officials to determine whether they are buying an EIT product that best meets the technical standard. 

Contractors and Vendors

Q:  My vendor doesn't understand what I mean by Section 508, or isn’t giving me the answers I need to make a determination.

A:  Point them to the GSA’s, or to, an organization developed by the US Department of Education to provide accessibility information to States and Industry.

Q:  I told my vendor she must “certify” her IT products 508-compliant; she says she can’t.  Why?

A:  Two reasons, actually.  One, there is no official certifying body accepted by GSA, so any certification doesn’t mean anything.  Two, the vendor is responsible for making their products conform to the standards. Compliance is the responsibility of the agency deploying the IT – not the vendor!

Q:  Are Contractor’s required to meet Section 508 Compliance?

A:  Contractors are not required to develop products that meet the requirements of Section 508. Only Federal agencies are required to procure, develop, use or maintain compliant EIT products and to provide comparable access to employees and members of the public with disabilities. However, if the EIT product would come into Federal hands as part of a contract deliverable and the contract required Section 508 conformance then the contractor would be required to produce an EIT product that met the Section 508 requirements – this is called conformance. Contractors do not have to come into a contract with a Federal agency with 508 compliant products. The Federal agency would have to make Section 508 conformance a requirement of the contract and then the contractor is obligated to produce an EIT product that was 508 conformant. 

Q:  What’s a VPAT?

A:  The Voluntary Product Accessibility Template – designed by industry to report 508 conformance.  See for more details on VPAT's.

Existing Technologies

Q:  Do agencies have to retrofit EIT procured prior to June 21, 2001?

A:  Federal agencies are not required to “retrofit” existing technologies procured prior to June 21, 2001, unless the agency is maintaining or updating the technology. For example, software applications, printers or copiers purchased prior to June 21, 2001, do not have to be replaced. However, after June 21, 2001, all software applications, printers or copiers procured need to meet the applicable technical provisions. If a requiring official wanted to procure the newest version of the Microsoft Office suite, then he/she should ensure that the version met the applicable software applications technical provisions. Also, all changes to a web site made after this date would have to meet the applicable web-based technical provisions for the Intranet and Internet. Web sites are constantly changing so web developers’ need to be sure each of the changes meet the applicable web-based technical provision.


Q:  Who is responsible for implementing the Section 508 regulations?

A:  Section 508 applies to the use, procurement, development, and maintenance of EIT products and services by Federal agencies and not by the private sector. Before using  EIT products and services, business unit executives and developers should ensure that EIT products and services are accessible and usable by employees and members of the pubic with disabilities.  For procurement of EIT products and services, requiring and contracting officials are responsible for ensuring that that the EIT acquisitions meet the requirements of Section 508, as implemented in the Access Board’s standards and the Federal Acquisition Regulations, respectively. For the development and maintenance of EIT products and services, developers are responsible for ensuring that the upgrades and changes to software applications and web pages are compliant with the technical standard and applicable technical provisions. Each Federal agency has a Section 508 Coordinator who can offer additional information on agency procedures and the steps taken within the agency to implement Section 508.