Guidance

Table of Contents

A. Purpose
B. Background
C. Scope
D. Process
Glossary
Appendix A
Appendix B

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Guidance for Requesting the Use of an Accommodation: Categorical Accommodation (PDF - 260KB )

A. Purpose

The purpose of this document is to document the process and criteria for requesting the Use of Categorical Accommodations for non-accessible Information Technology (IT).

B. Background

An accommodation is a means or method to assist users with disabilities in cases where the application of current Section 508 standards is not feasible or helpful. While it is generally expected that all EIT has been developed in accordance with accessibility standards, there are situations where the accessibility needs of all potential individual readers will not be met. In these cases (see NIH’s version of Guidelines and Examples for Determining the Suitability of an NIH Categorical Accommodation ), the government has a responsibility to ensure that an alternative approach is available to accommodate persons with disabilities that still need access tthe service or information that cannot be provided in a completely accessible manner.

The NIH has a formal process for determining if the Use of an Accommodation (in lieu of full accessibility) is appropriate. The Categorical Accommodation process has been developed to minimize the review/approval requirements for certain types of IT that can be categorized as a “typical” type of material and accessibility challenge that has been predetermined as appropriate for the Use of Accommodation allowance. This should never be misconstrued as a waiver from complying with Section 508 – this is merely an attempt to allow and support greater flexibility in how meaningful accessibility is provided in a responsive manner rather than purely integrated into the content prior to publication, for pre-approved and narrowly-defined circumstances.

For example, NIH-hosted conferences frequently have non-government presenters, whare not obligated to ensure their materials comply with Section 508. NIH, however, is required tensure materials are Section 508-conformant before posting them to their conference website. The Use of Accommodation would be a reasonable approach to allow materials to be posted until they can be reviewed and remediated to conform to 508 standards. Since this is a common situation, a Categorical Accommodation approach (Presentations from Non-Government Employees, see Appendix A) would save time and resources in reviewing and approving every NIH conference site’s request for Use of an Accommodation. The Use of an Accommodation approach would generally require the conference host to request an Accommodation allowance, and then to provide assistance to anyone with a disability that needs access to the materials in the interim if they are not all going to be remediated. This is further explained in the accompanying Guidelines and Examples.

C. Scope

This guidance applies to all NIH information technology systems and information subject to Section 508. The process described here is limited to those categories of IT described in Appendix A. This process may be used by NIH organizations that need to post, provide or otherwise make available information, systems or data that supports the NIH mission but where the application of Section 508 is either not feasible or not helpful to users with disabilities.

D. Process

  1. The system or information owner (Content Owner) and respective IC Section 508 Coordinator should work together on determining if the Use of a Categorical Accommodation is appropriate, and if so, how best to approach providing accommodation if required. The IC Section 508 Coordinator will submit the completed form to Section508Help1@mail.nih.gov. For additional instructions, see Appendix B.

  2. The NIH 508 Program staff will review the request to ensure that it is complete, appropriate, and justified. If there are any issues, the NIH 508 Program staff will work with the IC Section 508 Coordinator to resolve them.

  3. The NIH Section 508 Coordinator will review the request.

    • If the request is approved, a signed copy will be provided to the IC 508 Coordinator. All approved Categorical Accommodation Requests will be posted within (2) business days the NIH OCIO Section 508 SharePoint site, in the Accommodation Requests and Final Recommendation folder.

    • If the request does not receive approval/concurrence, the request will be returned tthe IC 508 Coordinator with an explanation.

    For any approved Use of Accommodation:

    1. For a Temporary Accommodations (Less than 1 year) – the NIH 508 Program will contact the IC Section 508 Coordinator prior to the expiration date to discuss if renewal is needed or confirm that material will no longer be available after the expiration date.

    2. For Permanent Accommodations – the IC Section 508 Coordinator will submit an annual report to Section508Help1@mail.nih.gov, describing the number of times that accommodation has been requested and an approximation of the resources required to respond.

Glossary

  • IC Section 508 Coordinator

    • Each NIH Institute/Center (IC) has a designated Section 508 Coordinator to represent their respective IC in the NIH-wide Section 508 effort. The Coordinator is a senior staff person in the IC with access to senior IC officials to assure proper coordination across the IC entities with a capacity to ensure effective Section 508 implementation within their IC. The Coordinator is the liaison to the OCIO on issues involving high level policy decisions, reporting, and coordinating on other NIH Section-508 related projects. The IC Section 508 Coordinator is designated by the OCIO to bring Accommodation Requests to their attention on behalf of their respective Institute or Center (IC).

  • Content Owner

    • For the purpose of the OCIO Section 508 Request for Use of an Accommodation, the Content owner shall be defined as anyone who has the responsibility to create or maintain information, content, or knowledge in an Electronic and Information Technology (EIT) format. It may be the department or branch head and/or designated individuals responsible for developing and maintaining the content of a web page or web site. This includes any parties that submit content to the Webmasters including electronic documents, videos, web application projects, pod casts, etc.

    • For non-web content, this may be the System or Information Owner, project officer, or program lead. Content owners are the individuals responsible for the content of web sites in their respective areas. Typically, this includes program managers, researchers and scientists, and their designees. Content owners typically designate maintenance of content to web contributors.

  • Electronic and Information Technology (EIT)

  • NIH Section 508 Team: the members of the NIH OCIO staff who handle Section 508-related matters, one or another of whom may be designated to manage Requests for the Use of an Accommodation which are submitted by NIH IC Section 508 Coordinators.

Appendix A

List of Categorical Accommodations

  1. Atypical Images and Chart Formats: Large or complex tables

  2. Complex and/or Dynamic Visualizations, including: medical diagnostic and research imaging technologies, 3D-models, CAD, virtual environments.

  3. Complex PDF Tables Complex math, physics, and chemical notations

  4. Complex Static Images, including static images and those supported and detailed narratives.

  5. Dynamic Simulations, Models, and Maps: Applications and Web-enabled software tools that manipulate data in a dynamic fashion or that simulate events or objects.

  6. Excel computational spreadsheets containing program modules and macros developed to perform automated analysis or to draw in data sets from external or legacy databases.

  7. Handwritten material or other material submitted by members of the public and then scanned and posted to a website (internet, intranet, or SharePoint site).

  8. Password-Protected Sites - the front page is accessible and Section 508-conformant but the pages encountered after the password are the basis of this request.

  9. Presentations from Non-Government Employees, e.g., researchers who are not obligated to comply with Section 508. (If the NIH re-distributes these files, they shall be remediated by the NIH.)

  10. Scanned Historical Materials that are hand-written or in poor quality such as historical publications/materials that are scanned to a digital archive.

  11. Third-party licensed PDF documents from medical and scientific journals and conference proceeding documents) (if no-cost accessible versions cannot be linked to elsewhere on the Web).

  12. Virtual Environments Sites and programs that model and simulate the manipulation of objects in virtual space are in another category of images best served as accommodations.

  13. Website under renovation or due tbe decommissioned within six (6) months of request.

Appendix B

Form Instructions:

  1. Select the appropriate accommodation type.

  2. Explain why the service or information cannot be made accessible or conform to 508 standards, what types of limitations (i.e., disabilities) will be excluded, and how it meets the criteria of the selected category(s).

  3. Describe how you will accommodate persons with disabilities that need access to this material. Details should include how a person will know who to contact and the timeframe they should expect to receive assistance.

  4. The Point of Contact Person, in the Contact Section, should include a named individual and his/her direct email and telephone number. However, the Accessibility Statement may include an organizational telephone number and email address, is acceptable as long as it is routinely monitored.

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