Every two years, the Attorney General is required by statute to issue a status report to Congress and the President regarding agencies' progress toward implementation of section 508 of the Rehabilitation Act, 29 U.S.C. § 794d. The next report is due August 7, 2001. All federal agencies are required by statute to cooperate with this effort by providing whatever information the Attorney General deems necessary to the preparation of this report. Your agency must complete its self-evaluation by April 6, 2001.
As a Designated Agency Official (DAO), your agency has chosen you as the person in charge of conducting your agency's self-evaluation. This memorandum summarizes your responsibilities, including answers to basic questions about how you can guide your agency to a quick and easy resolution of this project. If you have any questions, please contact us.
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Q1: What's different about this year's self-evaluation?
A: If you participated in your agency's 1999 self-evaluation, you will notice that the current survey is much less burdensome. We are asking agencies to conduct streamlined self-evaluations that address two specific topics, as well as some more general questions. The two specific topics include:
Q2: What are my responsibilities as a "Designated Agency Official?"
A: If you are your agency's Designated Agency Official (DAO), you are responsible for successful and timely completion of your agency's self-evaluation. You will also be the "point-of-contact" to whom the Department of Justice will correspond for all self-evaluation matters. You will coordinate responses by your agency's components and will answer all agency-level survey questions.
The Department of Justice will assign you a username and ask you to select a password for use on the data-collection website (http://www.508.org). You will be able to review and edit your submissions, including the web accessibility submissions from components within your agency, before they are transmitted to the Department of Justice. No one except DAO's will have this ability.
Q3: Can our agency have more than one DAO?
A: Yes. Some agencies may wish to designate two DAO's: one who will be responsible for the substance of agency submissions and another to handle administrative functions. To add or delete a DAO, your agency must contact the Department of Justice. Each DAO will be able to access and modify your agency's self-evaluation data before it is submitted to the Department of Justice on the www.508.org website.
Q4: What are the "components" of my agency and how do I choose the "Component Web Contacts"?
A: The Web Page Accessibility Questionnaire is designed to be filled out at the component level. For this purpose, each agency subdivision that maintains or develops its own web pages should respond as an independent component. There will also likely be an agency-wide response for agency-wide web pages that do not fall within the exclusive control of one subdivision or another. As your agency's DAO, it is your responsibility to identify the relevant components within your agency to respond to the web accessibility questionnaire designed for their use. For your own convenience, we strongly recommend that you work with each component to identify a single person or very small group of people to act as point-of-contact for each component (Component Web Contact). They will act as your team for completing the self-evaluation of your agency's web pages.
Once you have designated the Component Web Contacts, you will have the ability to create accounts (usernames and passwords) for each of them. These accounts will enable them to enter data onto the www.508.org website.
Q5: Can agency components have more than one contact per component?
A: Yes. Having more than one Component Web Contact per component, however, can increase the coordination responsibilities of DAO's. DAO's are responsible for ensuring that their agency does not submit duplicate entries. DAO's are also the only agency personnel with the ability to establish or delete accounts for Component Web Contacts.
Q6: How can Designated Agency Officials control access to and the content of their agency's submissions?
A: As a Designated Agency Official, you will assign usernames and passwords for each of your agency's Component Web Contacts. You will be able to review and edit their data before it is submitted to the Department of Justice.
Q7: Should each Component Web Contact answer all questions based on his or her knowledge of the agency as a whole?
A: No. As the Designated Agency Official, it is your responsibility to coordinate with all of your Component Web Contacts to ensure that they are submitting data only as it pertains to the limits of his or her authority or control within the agency or its component. You should try to ensure that your agency responds as fully as possible without generating overlapping responses. You will also determine which person(s) or office(s) in the agency will be responsible for evaluating agency-wide applications, such as agency-wide web pages.
Q8: Why is there greater focus on web sites than other technologies?
A: The Access Board (Architectural and Transportation Barriers Compliance Board) published standards implementing section 508 on December 21, 2000. Those standards are not enforceable until June 21, 2001. As the Department of Justice's report is due August 7, 2001, there is not enough time for agencies to conduct a comprehensive survey on all aspects of accessible technology. Instead, the Department of Justice has chosen the accessibility of federal agencies' web sites as the focus of this year's survey. This focus is consistent with a Presidential Memorandum issued July 26, 2000, requiring all agencies to "make all programs offered on their Internet and Intranet sites accessible to people with disabilities by July 27, 2001, consistent with the requirements of [sections 501, 504, and 508 of] the Act and subject to the availability of appropriations and technology," among other things.
Q9: Can we send in our data to the Department on paper instead of entering it on the www.508.org website?
A: No. You must submit your data electronically through the www.508.org website.
Q10: How will our information be used by the Attorney General?
A: On August 7, 2001, the Attorney General will send a report to the President and the Congress. This report will summarize the extent to which electronic and information technology used by the Federal government is accessible to and usable by persons with disabilities and the steps being taken by federal agencies as a whole for achieving compliance with Section 508. The report will reflect the limited topics of focus of the self-evaluation materials: how agencies are planning to handle complaints filed under section 508, the accessibility of their Internet and intranet pages for people with disabilities, and some general matters. Like the Attorney General's April 2000 report, Information Technology and People with Disabilities: The Current State of Federal Accessibility, the August 7, 2001 report will include data, analysis, and recommendations.
Q11: Can our agency bypass the self-evaluation process and provide the Attorney General with information about our 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.
Q12. We don't have any employees with disabilities. Do we still have to do a self-evaluation?
A: Yes. Section 508 applies to your agency whether or not you currently have any employees with disabilities. If you use electronic and information technology - and we all do - then you must comply with all parts of section 508, including the requirement to conduct regular self-evaluations under the guidance of the Department of Justice.