Last year, the Office of Federal Contract Compliance Programs (OFCCP) began acting on Directive (DIR) 2018-04, placing an increased emphasis on disability inclusion in the workplace. In order to accomplish that goal, the agency said it will be conducting “focused reviews” of compliance with Section 503 of the Rehabilitation Act, which requires federal contractors to take affirmative action to recruit, hire, promote, and retain individuals with disabilities.
Focused reviews may include site visits to contractors’ headquarters, interviews with managers, a comprehensive review of policies and practices, collection of certain data related to employees with disabilities, and a review of contractors’ handling of accommodation requests, including the accessibility of websites, software products, and assistive technologies.
Now is a good time to review if your technology and digital content comply with Section 503 accessibility standards. The regulations set forth benchmarks for the recruitment and hiring of disabled individuals and contain many requirements for contractors. For example, the regulations require contractors to audit and attest whether known individuals with disabilities have had the opportunity to participate in all company-sponsored educational and training activities.
Ensuring your employee recruitment and retention processes are supporting individuals with disabilities often entails taking an independent look at your information and communication technologies level of compliance with accessibility standards. Reasonable accommodations may also be required in order to remove barriers to accessibility (for example, can digital documents or forms be navigated with the use of a screen reader or similar assistive technologies commonly required by blind users).
Steps to prepare for Section 503 reviews
To demonstrate your organization’s commitment to inclusion for employees with disabilities, some proactive measures concerning your technology stack might include:
Review your organization’s accessibility policies, including an adopted accessibility statement, which is a public commitment to following best practices and standards for accessibility of your website, intranet, and applications or platforms used by either your external clients or employees. If your organization does not currently have a formal accessibility statement, this checklist for creating one can be a good resource to begin.
Perform an independent accessibility audit of custom in-house applications or deployed SaaS solutions your employees are using, including processes in place to request accommodations for products or solutions not meeting accessibility standards. Best to prepare and identify any potential compliance issues in advance of a formal Section 503 audit, and work with accessibility specialists to develop a plan to mitigate and address and gaps that may exist in your current IT systems.
Under the Biden Administration, OFCCP continues to update its website landing page with information about its Section 503 focused reviews, in order to help federal contractors with this process. The page contains useful information on what to expect when your company is selected for a Section 503 focused review and best practices for compliance.
At Microassist, we understand navigating accessibility compliance requirements can be a challenge for those with limited or no in-house expertise. Microassist has been a government-contracted accessibility vendor for more than 20 years.
We can help Government contractors assess if their websites and digital assets comply with accessibility standards, test the accessibility and usability of employee training platforms, and consult on other accessibility concerns such as effective evaluation strategies for using a VPAT/ACR during the procurement process.
To stay up to date on digital accessibility issues, upcoming training opportunities and events, we encourage you to subscribe to our free weekly e-newsletter, “Accessibility in the News’, considered a ‘must-read’ by many in the digital accessibility community.
If you have any questions about preparing for Section 503 reviews and digital accessibility, feel free to share your question using this short form and a member of our government solutions team will schedule a Section 503 consult.
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