Use of Accommodation as a Form of Section 508 Compliance 

Since 2001, Section 508 of the Rehabilitation Act of 1973 has required all Electronic and Information Technology (EIT) products and services in the Federal government to be accessible to persons with disabilities. As information technology has become a key part of how we communicate, the internet and multimedia have led to the creation of millions of pages, countless files, and sophisticated, interactive EIT.

Making all EIT meaningfully accessible is not always feasible or efficient. Documents or digital content that are heavy with images, multilevel charts and graphs, archives of historic handwritten laboratory notes, or computer-generated visualizations of scientific processes are just a few examples. Any one of these may require an inordinate investment of resources to make conformant. In some selected situations, it may be better to wait until a request is made to make the material accessible in a way that is meaningful to that person, and accommodate that person’s specific needs. 

An accommodation is a means or method outside of Section 508 standards designed to assist users with disabilities in cases where the application of current Section 508 standards is neither feasible nor helpful. HHS has developed a Standard​  to use in determining when it is appropriate to use an “accommodation” rather than try to achieve comparable accessibility. NIH’s “Accommodation Process” sets up a process to review and determine if the use of an accommodation is an appropriate solution.​

How is this different from “Reasonable Accommodations?”

An accommodation for inaccessible EIT should not be confused with “reasonable accommodations,” which are provided to an employee with a disability. A reasonable accommodation is any change in the workplace or the way things are customarily done that provides an equal employment opportunity to an individual with a disability. This may include provision of a sign language interpreter, videophones, screen-reading software to enable a blind or vision impaired person to access their computer, a Braille embosser or large-print materials, or physical changes in an office or lab to accommodate a wheelchair or scooter. If you need a reasonable accommodation as part of your work, speak with your supervisor, with the NIH Disability Employment Program Manager (EDI), or Computer/Electronic Accommodations Program (CAP) to request assistive technology.

What type of EIT can be included in an Accommodation request?

HHS allows the use of an accessibility accommodation with approval where the application of current Section 508 standards is not feasible, not helpful, and/or not practical. Typically, an “Accommodation” is approved for use in these cases. The types of EIT products that might be appropriate are described in the HHS Guidelines and Examples for Determining the Suitability of an Accessibility Accommodation. For further details about this approach to implementing Section 508, and HHS background, please visit.

In 2015, the NIH Office of the CIO implemented a “Categorical” approach for review and approval of these requests. 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. 

For further details about the Use of an Accommodation approach to implementing Section 508

For HHS background on the Use of an Accommodation approach please visit:​

For a list of NIH resources currently approved for the use of Accommodations, see:​

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