(U) NGAI 8400.4_Implementation of Electronic & Info Tech Accessibility Sec 508 Prog_Update_1.pdf

UNCLASSIFIED

National Geospatial-Intelligence Agency 1

INSTRUCTION 2

NUMBER 8400.4 4

05 July 2017 5

Administrative Update 1, 24 January 2020 6

CIO-T 8

SUBJECT: Implementation of Electronic and Information Technology 10

Accessibility/Section 508 Program 11

References: See Enclosure 1. 13

1. PURPOSE. This Instruction: 15

a. Establishes policy, assigns responsibilities, and provides procedures for the 17 implementation and governance of the Electronic and Information Technology (EIT) 18

Accessibility Program (also known as the Section 508 Program). 19

b. Rescinds NGA Instruction (NGAI) 8400.4, “Implementation of Section 508 of the 21

Rehabilitation Act,” 02 May 2013. 22

2. APPLICABILITY. This Instruction, hereinafter referred to as Section 508, applies to all 24

NGA civilian employees, military service members, other Government agency personnel 25 assigned to NGA, and contractors, hereinafter referred to as personnel. 26

3. DEFINITIONS. See Glossary. 28

4. POLICY. It is NGA policy to: 30

a. Ensure all EIT (i.e., computers or telephones) is accessible to people with 32 disabilities in accordance with (IAW) References (a) and (b). 33

b. Implement and manage an EIT Accessibility Program to ensure Section 508 35 compliance. 36

c. Ensure accessibility and universal usability to all EIT that is developed, procured, 38 maintained, or used by the Agency. 39

d. Certify EIT accessibility IAW References (a) and (b). 41

5. RESPONSIBILITIES. See Enclosure 2. 43

NGAI 8400.4

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6. PROCEDURES. See Enclosures 3-8. 48

7. EFFECTIVE DATE. This Instruction is effective on the date of signature. 51

Enclosures 55

1. References 56

2. Responsibilities 57

3. Procedures for Developing Accessible EIT 58

4. Procedures for Procuring Accessible EIT 59

5. Procedures for Maintaining Use of Accessible EIT 60

6. Procedures for Developing Accessibility Training 61

7. Procedures for Funding EIT Accessibility 62

8. Procedures for Initiating an Administrative Complaint 63

Glossary 64

UNCLASSIFIED

TABLE OF CONTENTS 66

CHANGE LOG ................................................................................................................ 4 68

ENCLOSURE 1: REFERENCES..................................................................................... 5 70

ENCLOSURE 2: RESPONSIBILITIES ............................................................................ 6 72

Director, NGA .................................................................................................................. 6 73

Director, Chief Information Officer (CIO) and Information Technology (IT) Services ........ 6 74

Component Acquisition Executive ................................................................................... 7 75

Director, Office of Diversity Management and Equal Employment Opportunity ................ 7 76

Director, Human Development ........................................................................................ 7 77

Director, Office of Contract Services ................................................................................ 7 78

Director, Office of Corporate Communications ................................................................. 7 79

General Counsel ............................................................................................................. 8 80

Director, Research........................................................................................................... 8 81

Director, Security and Installations .................................................................................. 8 82

Special Emphasis Program Leads, Equality Executives, and Senior Champions ............ 8 83

Component Directors, Agency Elements Leads, and Program Managers ........................ 9 84

Section 508 Coordinator .................................................................................................. 9 85

Electronic and Information Technology Accessibility Team, Lead .................................. 10 86

Requiring Officials ......................................................................................................... 10 87

Personnel ...................................................................................................................... 10 88

ENCLOSURE 3: Procedures for Developing Accessible EIT ........................................ 12 90

ENCLOSURE 4: Procedures for Procuring Accessible EIT ........................................... 13 92

ENCLOSURE 5: Procedures for Maintaining Use of Accessible EIT ............................ 15 94

ENCLOSURE 6: Procedures for Developing Accessibility Training .............................. 16 96

ENCLOSURE 7: Procedures for Funding EIT Accessibility ........................................... 17 98

ENCLOSURE 8: Procedures for Initiating an Administrative Complaint ........................ 18 100

GLOSSARY .................................................................................................................. 19 102

UNCLASSIFIED

CHANGE LOG 104

Change Change

Date Revised

By Pages

Affected Change Description

1 1/24/2020 CIO-T 13

Removed “CIO-T Official” for clarity.

The CIO-T Official is the Section 508 Coordinator.

2 1/24/2020 CIO-T 13

Clarified who signs the Form 5115-4 and for what purpose.

UNCLASSIFIED

ENCLOSURE 1 107

REFERENCES 109

(a) 29 United States Code (USC) Section 794d, “Workforce Investment Act of 1998,” 111

(Section 508 of the Rehabilitation Act of 1973, as amended) 112

(b) 40 USC Section 1452, Section 5142, Clinger-Cohen Act of 1996, 10 February 1996 113

(c) Title 36, Code of Federal Regulations Part 1194, “Electronic and Information 114

Technology Accessibility Standards,” 21 December 2000 115

(d) Office of Management and Budget Memorandum, “Strategic Plan for Improving 116

Management of Section 508 of the Rehabilitation Act,” 24 January 2013 117

(e) DoD Manual 8400.01-M, “Procedures for Ensuring the Accessibility of Electronic and 118

Information Technology (EIT) Procured by DoD Organizations,” 03 June 2011 119

(f) NGAI 1020.2, “Reasonable Accommodation,” 01 October 2005 120

(g) NGA Form 5115-4, “Section 508 Determination for Purchase Requests,” 121

01 May 2012 122

(h) NGAD 1405, “Employment and Placement,” 18 May 2015 123

(i) NGA Memorandum for Record, U-2016-02349, “Delegation of Authorities,” 124

13 September 2016 125

(j) Web Content Accessibility Guidelines 2.0 (WCAG 2.0), 126 https://www.w3.org/TR/WCAG20, 11 December 2008 127

UNCLASSIFIED

ENCLOSURE 2 129

RESPONSIBILITIES 131

1. Director, NGA (D/NGA). 133

a. Establishes the NGA EIT Accessibility Program IAW References (a), (d), and (e). 135

b. Designates the Chief Information Officer - Director, IT Services (D/CIO-T) as the 137

Senior Designated Officer for EIT who is responsible for ensuring compliance IAW 138

References (a) through (e). 139

2. D/CIO-T. 141

a. Oversees and maintains accountability for the EIT Accessibility Program. 143

b. Ensures the EIT Accessibility Program is established and implemented IAW 145

References (a), (d), and (e). 146

c. Ensures accessibility requirements are incorporated into the planning, operation, 148 and management of EIT that is developed, procured, maintained, or used by the 149

Agency. 150

d. Collaborates with the Component Acquisition Executive (CAE) and Director, 152

Office of Contract Services (D/OCS) to ensure that accessibility requirements are 153 included in EIT acquisition and procurement. 154

e. Provides a joint or coordinated transmittal memorandum with the CAE IAW 156

Reference (e) asserting that IT investments are consistent with Reference (a). 157

f. Appoints and assigns responsibility to a Section 508 Coordinator to provide 159 program leadership and management of the EIT Accessibility Program. 160

g. Maintains policies and guidebooks, disseminates best practices, and pursues 162 accessibility and universal usability in the development, procurement, and maintenance 163 of EIT. 164

h. Ensures that EIT acquisition processes and procedures are IAW References (c) 166 and (e). 167

i. Ensures the procurement and development of accessible EIT in collaboration with 169

Component Directors, Agency Element (AE) Leads, and Program Managers. 170

j. Facilitates staffing, funding, and implementation of EIT Accessibility Program 172 initiatives. 173

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3. CAE. 176

a. Ensures that EIT acquisition review processes include accessibility requirements. 178

b. Collaborates with D/OCS and D/CIO-T to ensure compliance with Reference (a) in 180 all EIT procurement request packages. 181

c. Collaborates with the D/OCS to ensure that accessibility requirements are 183 included in EIT acquisition and procurement. 184

d. Provides a joint or coordinated transmittal memorandum with the D/CIO-T IAW 186

Reference (e) asserting that IT investments are consistent with Reference (a). 187

4. Director, Office of Diversity Management and Equal Employment Opportunity 189

(D/ODE). 190

a. Assists in the development of user engagement programs in coordination with the 192

Section 508 Coordinator. 193

b. Ensures the Agency is responsive to the requests and complaints of personnel 195 with disabilities via the reasonable accommodation program IAW Reference (f). 196

c. Assists with the implementation and funding of accessibility in the workplace IAW 198

Reference (f). 199

d. Collaborates with the EIT Accessibility Team on recommendations from 201 employees, recruiters, and hiring events regarding how to make the Agency a more 202 accessible environment for personnel with disabilities. 203

5. Director, Human Development (D/HD). 205

a. Provides input on the Agency’s recruitment practices for people with disabilities. 207

b. Recruits and hires qualified people with disabilities IAW Reference (h). 209

c. Collaborates with the EIT Accessibility Team on recommendations from 211 employees, recruiters, and hiring events regarding making the Agency a more 212 accessible environment for personnel with disabilities. 213

d. Develops and maintains Section 508 awareness training in collaboration with the 215

Section 508 Coordinator. 216

e. Ensures that training provided by the NGA College is accessible to personnel with 218 disabilities. 219

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f. Provides guidance, subject-matter expertise, and advice on Section 508 training 221 and education initiatives to the EIT Accessibility Team. 222

6. D/OCS. 227

a. Provides guidance to contracting officers to ensure that acquisition strategies are 229 in compliance with Reference (a). 230

b. Assists with updating procurement policies and procedures to ensure consistency 232 with US Access Board standards IAW Reference (c). 233

c. Ensures that undue burden documentation is provided and included in the 235 contract file, when appropriate, IAW Reference (a). 236

d. Ensures that market research is performed during the acquisition planning phase. 238

7. Director, Office of Corporate Communications (D/OCC). 240

a. Ensures, in collaboration with all appropriate stakeholders, that all Agency public 242 and user-facing communications are accessible. 243

b. Collaborates with EIT Accessibility Team on the communication strategy for all 245 publications regarding accessibility-related topics including educational and training 246 materials. 247

c. Assists in the implementation and funding of workplace accessibility upon 249 availability of funds. 250

8. General Counsel (GC). 252

a. Determines legal compliance with Section 508. 254

b. Ensures an efficient and accessible method for handling Section 508 256 administrative complaints is established. 257

9. Director, Research (D/R). 259

a. Supports Agency efforts to build partnerships with the public sector, private 261 sector, and academia that add value to accessibility and usability efforts. 262

b. Assists the EIT Accessibility Team with developing solutions for unique 264 accessibility challenges on a discretionary basis. 265

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10. Director, Security and Installations (D/SI), with collaboration from all stakeholders, 267 provides input and subject matter expertise on environmental issues related to Section 268

508 accessibilities to the EIT Accessibility Team. 269

11. Special Emphasis Program Leads, Equality Executives, and Senior Champions. 271

a. Provide guidance to the Section 508 Coordinator and EIT Accessibility Team. 273

b. Identify and advocate solutions for EIT accessibility barriers throughout the 275

Agency. 276

c. Provide insight and advice on Agency culture and support for accessibility. 278

d. Assist with personnel engagement and outreach to provide information on 280 accessibility in the work environment. 281

12. Component Directors, AE Leads, and PMs. 283

a. Ensure compliance with Reference (a). 285

b. Ensure all applicable personnel are trained on compliance and accessibility IAW 287

Reference (a). 288

c. Provide the Section 508 Coordinator with feedback about the effectiveness of 290

Section 508 training courses. 291

d. Implement and fund Section 508 compliance for programs within their purview. 293

e. Ensure that compliance and accessibility performance goals are cascaded down 295 through second- and first-line supervisor performance plans. 296

13. Section 508 Coordinator. 298

a. Ensures EIT accessibility requirements are integrated into NGA’s strategic, 300 budget, and IT capital plans. 301

b. Develops and implements processes and procedures for monitoring Agency 303 adherence to Reference (a) IAW Reference (e). 304

c. Develops user engagement programs in coordination with D/ODE. 306

d. Manages EIT Accessibility Program staff and funding. 308

e. Establishes and leads an EIT Accessibility Team made up of points of 310 contact/participants from CIO-T, ODE, HD, OCS, OCC, GC, SI, R, Deaf and Hard of 311

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Hearing Council, People with Disabilities Council, other interested parties, and 312 stakeholders. 313

f. Develops a charter for the EIT Accessibility Team and assigns responsibilities to 315 team members according to their respective areas of expertise. 316

g. Responds to EIT accessibility complaints and issues and prepares reports 318 pertaining to those complaints and issues. 319

h. Promotes EIT accessibility awareness throughout the Agency and conducts 321 briefings for stakeholders. 322

i. Provides training content for EIT accessibility and collaborates with HD to develop 324 computer-based training. 325

j. Develops compliant and efficient procedures for the acquisition of accessible EIT, 327 approves exceptions, and provides guidance and recommendations to Component 328

Directors, AE Leads, and PMs who develop, procure, maintain, or use EIT. 329

k. Identifies needs for accessible systems, adaptive technology, and EIT deficiencies 331 in both current and prospective EIT systems that impact the performance of personnel 332 with disabilities. 333

l. Identifies NGA work environment accessibility issues, assists with writing problem 335 statements to describe issues, and coordinates with the stakeholders to find funding 336 and/or creative solutions for accessibility issues. 337

14. EIT Accessibility Team 339

a. Assists with the understanding and implementation of accessibility measures 341 throughout the Agency by leveraging the knowledge, perspective, and experience of 342 different Components, AEs, and PMs to resolve accessibility issues within NGA. 343

b. Supports the Section 508 Coordinator with integrating accessibility needs into 345

Agency strategic, budget, and IT capital plans. 346

c. Identifies Agency needs for accessible systems, adaptive technology, and EIT 348 deficiencies in both current and prospective EIT systems that impact the performance of 349 personnel with disabilities. 350

d. Participates in EIT accessibility monitoring, measurement, and disclosure 352 activities. 353

e. Supports the validation of accessible EIT system performance prior to 355 development. 356

UNCLASSIFIED

f. Provides recommendations and expertise to the Section 508 Coordinator 358 regarding implementation issues and solutions. 359

g. Supports the development of policies and procedures to ensure compliance with 361

Reference (a). 362

15. Requiring Officials. 364

a. Conduct market research to ensure procurement of the most accessible product 366 at best value. 367

b. Make EIT procurements on behalf of the Agency. 369

c. Track and document the Section 508 compliance status of each EIT procurement 371 made. 372

d. Ensure that Section 508 compliance records are made available to the Section 374

508 Coordinator upon request. 375

16. Personnel, if applicable, initiate a Section 508 administrative complaint IAW 377

Enclosure 8. 378

UNCLASSIFIED

ENCLOSURE 3 380

PROCEDURES FOR DEVELOPING ACCESSIBLE EIT 382

1. Requirements. Personnel involved in managing EIT development (e.g., Component 384

Directors, AE Leads, and PMs) ensure EIT is accessible by including accessibility 385 language in all service requests, contracts, performance work statements, and any 386 document that captures requirements relating to the EIT development. The language 387 must satisfy the requirement for contractors to ensure EIT compliance as directed in 388

Reference (a), specifically that vendors providing EIT may use Reference (c), 389

Reference (j), or use alternative designs or technologies that provide equal or greater 390 access to and use of the product for persons with disabilities. 391

2. Testing. Personnel involved in managing EIT development also ensure that EIT is 393 accessible by testing the products to confirm that the vendors have delivered the 394 requested service or system. PMs ensure vendors include requirements for accessibility 395 in EIT test cases. Accessibility compliance is identified in factory acceptance tests, initial 396 tests, and independent verification and validations. Accessibility results are published 397 with the general test results and are included in the production lifecycle of the product. 398

The Section 508 Coordinator tracks program progress on accessibility by requesting 399 accessibility results at different points in production. 400

UNCLASSIFIED

ENCLOSURE 4 402

PROCEDURES FOR PROCURING ACCESSIBLE EIT 404

1. Certification. The Section 508 Coordinator has the authority to certify compliance and 406 approve exemptions for EIT procurements. In practice, these decisions are made as a 407 result of a joint effort with other Components or AEs throughout the Agency. The 408

Requiring Officials complete NGA Form 5115-4 by answering the questions on the form 409 to the best of their knowledge while attempting to obtain missing or unknown 410 information. The Requiring Officials then sign and forward the form to the Section 508 411

Coordinator appropriate CIO-T official for certification. In addition, Requiring Officials 412 obtain a Section 508 Voluntary Product Assessment (VPAT) from the vendor to ensure 413

Section 508 compliance. Requiring Officials or the CIO-T official request guidance from 414 the Section 508 Coordinator for any questions about compliance concerning either NGA 415

Form 5115-4 or the VPAT. Requiring Officials then sign and forward the NGA Form 416

5115-4 to the Section 508 Coordinator and OCS. 417

2. Tracking of Compliance. The Requiring Officials track the compliance status of EIT by 419 including the VPAT and NGA Form 5115-4 in the procurement package that is sent to 420

OCS. Requiring Officials also maintain copies of the VPAT and NGA Form 5115-4 for 421 their records. The Section 508 Coordinator CIO-T official appointed for certification 422 retains a copy of NGA Form 5115-4 and. The Section 508 Coordinator can request 423 copies of NGA Form 5115-4 or the VPAT from Requiring Officials, CIO-T, or OCS. 424

3. Exemptions. While it is in the best interest of the Agency to pursue accessibility for 426 every EIT product developed, procured, maintained, or used by the Agency, there are 427 some exemptions. In the event of an exemption, the Requiring Official completes NGA 428

Form 5115-4, identifies the program, and provides an explanation that supports the 429 claim of exemption, and obtains the Section 508 Coordinator signature for exemption 430 approval. Even with an exemption, Requiring Officials request accessible products from 431 vendors, request a VPAT from the vendor, and document whether they can provide 432 one. The exemptions are: 433

a. National Security Systems for which the function, operation, or use involves 435 intelligence activities, cryptologic activities related to national security, command and 436 control of military forces, equipment that is an integral part of a weapon or weapon 437 system; or systems which are critical to the direct fulfillment of military or intelligence 438 missions. Systems that are critical to the direct fulfillment of military or intelligence 439 missions do not include a system that is to be used for routine administrative and 440 business applications (including payroll, finance, logistics, and personnel management 441 applications). (Reference (b)) 442

b. The EIT acquisition is: 444

(1) For service and/or service maintenance agreements (for technical support, 446 not software maintenance agreements). 447

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(2) Acquired by a contractor for use that is incidental to the contract. 449

(3) Located in spaces frequented only by service personnel for equipment 451 maintenance, repair, or occasional monitoring of equipment. 452

(4) Provided for telecommunications services and not contractor-provided 454 terminal equipment (telecommunications products). (Reference (a)) 455

c. An undue burden EIT acquisition exemption may be claimed IAW Reference (a). 457

The Requiring Official completes NGA Form 5115-4 and provides a justification for 458 undue burden and coordinates with the GC before submitting NGA Form 5115-4. All 459 undue burden exemption requests are forwarded to the Section 508 Coordinator for 460 final review. The justification includes: 461

(1) The products or services required. 463

(2) The dollar value of the acquisition. 465

(3) The otherwise applicable technical provision that cannot be met. 467

(4) The market research performed to locate commercial items that meet 469 applicable standards and the specific reasons why the technical provision cannot be 470 met. 471

(5) The significant difficulty or expense that would be incurred in order to comply 473 with the accessibility standard. If the expense is deemed prohibitive by the Requiring 474

Official, the estimation method for cost must be included. In addition, the insufficient 475

Agency resources available to the office or program for which the product or service is 476 being acquired must be described. 477

(6) The alternative means by which the Agency provides access to the data and 479 information to personnel with disabilities. 480

(7) If the justification is lacking any of the above elements, is incomplete, or is 482 unsupportable according to the GC, the request for exemption is denied by the Section 483

508 Coordinator. 484

UNCLASSIFIED

ENCLOSURE 5 486

PROCEDURES FOR MAINTAINING USE OF ACCESSIBLE EIT 488

1. User Engagement. The Section 508 Coordinator ensures that the Agency maintains 490 and uses accessible EIT by continuously monitoring the use of EIT throughout the 491

Agency. This is accomplished by working in collaboration with disability advocates such 492 as the Deaf and Hard of Hearing Council, People with Disabilities Council, Wounded 493

Warriors, and Component Equality Executives to gain information about the everyday 494 work experience of people with disabilities when they engage with EIT. The Section 508 495

Coordinator uses this information to assess the overall accessibility of the Agency, write 496 problem statements, and raise personnel awareness of areas for improvement. 497

2. Metrics. The Section 508 Coordinator uses information gained from user 499 engagement, accessibility testing, and accessibility procurement to create metrics that 500 illustrate the overall accessibility standing for EIT maintained and used by the Agency. 501

UNCLASSIFIED

ENCLOSURE 6 503

PROCEDURES FOR THE DEVELOPING ACCESSIBILITY TRAINING 505

The Section 508 Coordinator conducts research and collaborates with HD staff to 507 develop computer-based training for personnel that have various levels of engagement 508 with EIT and accessibility. Training covers topics that: 509

1. Teach general awareness of Section 508 and its requirement to ensure that all EIT is 511 accessible. 512

2. Illustrate the best way to ensure the procurement of accessible EIT including how to 514 determine exemptions, how to verify accessibility with vendors, and how to complete 515

NGA Form 5115-4. 516

3. Describe the best way to develop accessible EIT. 518

4. Recommend the best way to design software that is compatible with assistive 520 technology. 521

5. Show how to recognize barriers for disabilities such as hearing loss, color blindness, 523 and motor disabilities. 524

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ENCLOSURE 7 526

PROCEDURES FOR FUNDING EIT ACCESSIBILITY 528

1. Funding for Agency Initiatives. Component Directors, AE Leads, Portfolio Leads, and 530

PMs fund Section 508 needs by ensuring that vendors providing EIT fulfill accessibility 531 requirements as written in their statement of work and paying for accessible capabilities 532 as the vendor provides them. However, there are EIT projects associated with the 533 overall accessibility of the NGA work environment and not with the individual efforts of 534 any particular program, portfolio, AE, or Component. These initiatives are in response to 535 requests made by personnel with disabilities or are the result of an assessment by the 536

Section 508 Coordinator. If centralized funding is made available by the D/NGA and/or 537 the D/CIO-T to pay for accessibility initiatives, the Section 508 Coordinator may use the 538 funds to complete accessibility upgrades on behalf of the Agency. If centralized funding 539 is not available or funding has been depleted, funds may come directly from CIO-T in 540 satisfaction of a reasonable accommodation request filed through ODE pursuant to 541

Reference (f). 542

2. This guidance shall not be interpreted to rescind, revoke, or replace ODE’s role and 544 responsibility concerning Interpreting Services IAW Reference (f) or any other 545 responsibility ODE has to fund services concerning personnel with disabilities. 546

UNCLASSIFIED

ENCLOSURE 8 548

PROCEDURES FOR INITIATING AN ADMINISTRATIVE COMPLAINT 550

1. Initial Request. Personnel who have concerns about accessibility submit an 552 administrative complaint to the Section 508 Coordinator. The Section 508 Coordinator: 553

a. Creates a problem statement and makes an attempt to resolve the issue by 555 bringing it to the attention of CIO-T leadership. 556

b. Coordinates with stakeholders within CIO-T and other components, such as ODE, 558 to formulate a resolution. 559

c. Provides feedback and status updates to the requestor detailing progress toward 561 resolving the issue. 562

2. Lack of resolution. If the individual is dissatisfied with Agency efforts to resolve the 564 issue, the individual can file an informal Equal Employment Opportunity (EEO) 565 complaint with ODE. 566

3. If the informal complaint remains unresolved, the individual can file a formal EEO 568 complaint and have the complaint investigated IAW Reference (f). 569

4. The GC supports the formal complaint process by providing legal guidance and 571 assisting the parties to come to a satisfactory resolution. 572

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GLOSSARY 574

Accessibility The design of products, devices, services, or environments for people who experience disabilities. The concept of accessible design and practice of accessible development ensures both unassisted access and compatibility with assistive technology. (Reference (a))

Assistive Technology

Includes assistive, adaptive, and rehabilitative devices that promote greater independence by providing enhancements to or changing methods of interacting with technology to make it easier for people to perform tasks that they may have been unable to accomplish or have great difficulty in accomplishing. (Reference (c))

Electronic and Information Technology

(EIT)

Commonly referred to as IT but is an expansion upon the accepted definition of IT because it includes any equipment or interconnected system or subsystem of equipment that is used in the creation, conversion, or duplication of data or information. EIT includes IT products (such as computers, software, and ancillary equipment), telecommunications products (such as telephones), information kiosks, transaction machines, websites, multimedia, and office equipment (such as copiers and fax machines). (Reference (c))

Information Technology

(IT)

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. IT includes computers, ancillary equipment, software, firmware and similar procedures, services (including support services), and related resources. (Reference (c))

Requiring Official

Any Government official who is participating in the procurement of EIT.

Requiring Officials participate in the determination of Section 508 relevance, technical performance, and functional requirements. They also conduct market research and help to ensure that accessibility language is included in all requests for service, contracts, performance work statements, and/or any document that captures requirements related to EIT procurement. (Definition created by NGA for NGA purposes only)

Undue Burden

Significant difficulty or expense. In determining whether an action would cause an undue burden, an agency shall consider all agency resources available to the program or component for which the product is being developed, procured, maintained, or used. (Reference (c))

UNCLASSIFIED

Universal Usability

The broad spectrum of ideas meant to produce EIT that is inherently accessible to all people regardless of age or ability. A program that provides universal usability greatly increases the ease of use by which EIT can be leveraged to accomplish tasks with effectiveness, efficiency, and satisfaction. Universal usability ultimately drives and molds innovation. The goal of the EIT Accessibility Program is to move from Section 508 compliance, to accessibility, to universal usability. (Definition created by NGA for NGA purposes only)