Compliance

Compliance with accessibility per Section 508 of the Rehabilitation Act of 1973 is mandatory. The Department is required by law to make its digital media accessible to all audiences. VA itself has employees with visual, auditory, motor and other disabilities. VA builds accessibility from the start into its digital media.

This policy applies to all VA entities procuring, designing, maintaining, or providing oversight to VA digital internet and intranet assets and content (such as websites, web applications, mobile apps, videos and online documents). Section 508 compliance includes materials produced for VA on behalf of full- and part-time employees, contractors, interns and volunteers. Everyone is responsible for making digital content accessible.  

VA Web Registry requires annual certification by VA business owners that their digital content meets requirements in VA Directive 6102 and Section 508.  

The Assistant Secretary for Information Technology and Chief Information Officer delegate responsibility to VA administration Web Communications Offices and the VA Central Office Digital Media Engagement Office to ensure VA digital content is accessible to all audiences.  

Under secretaries, assistant secretaries and other key officials ensure all systems and applications developed, procured, maintained or used by VA have been evaluated for accessibility. This evaluation happens in conjunction with the Chief Information Officer and Section 508 Office.  

Individual program offices, VA facilities and business content owners with published digital content are responsible for complying with Section 508 law. These offices are responsible for requesting annual audits from the Section 508 Office through the content’s lifecycle.  

Digital assets may outlive the office which built them. All published digital content must be transferred to a new VA office.  

VA uses automated tools to review websites and other publications for accessibility issues prior to first-time launch, and later in the product lifecycle after editing and further development.  

The VA Section 508 Office is staffed with experts who advise on making content accessible. They manage the scanning tool and provide reports about website and content accessibility deficiencies to VA administrations and staff offices that own digital assets. Content owners may request an annual Section 508 office audit as needed.  

It is the content owner’s responsibility to remediate digital content compliance issues throughout its lifecycle. When major changes occur (such as a redesign or change in content, platform or template) owners must retest to assure accessibility.  

Content owners must maintain and certify Web Registry (vaww.va.gov/webregistry) entries annually or as changes occur for each asset with an assigned Uniform Resource Locator (URL) on the va.gov domain, and other domains that have received permission from the AS/OIT to operate on VA’s behalf or with VA funding.

Business content owner(s) will submit a memorandum signed by their undersecretary annually that web registry has been certified and their web item meets Section 508 law and VA Directive 6102 requirements.

1. All requests for new or substantially changed public-facing items must be
   submitted to the WCO for development and production approval, and a
   maintenance and sustainment plan must be incorporated.
2. VA Business Owners/Content Owners will collaborate with the WCO by
   submitting the acquisition documentation and including the WCO as part of
   the acquisition IPT. Acquisition documents may include a Performance Work
   Statement (PWS), Statement of Work (SOW), or other items the Business
   Owner (BO), Program Manager (PM), or Contracting Officer’s Representative
   (COR) may develop.
   1. WCO will review acquisition documents to ensure Section 508
      requirements for websites are incorporated into the acquisition
      language. Questions regarding Section 508 requirements will be
      referred to the VA Section 508 Office for final determination.
3. Acquisition documents received by the WCO will be reviewed using track
   changes and returned to the VA employee who submitted the initial
   documents.
4. WCO recommendations focus on public-facing web items, including but not
   limited to:
   • VA Directive 6102
   • VA Directive 6221
   • VA Graphic Standards
   • VA Tier 1 Graphic Style Guide requirements
5. WCO recommendations are intended to assist the program office in obtaining
   approval through the VA OIT CIO and VA Web Governance Board processes for
   modernization efforts or new public-facing web items before release to
   production.
6. NCA Program Office(s) may choose to collaborate with the WCO from project
   initiation and throughout the entire project lifecycle.
7. The goal of the WCO is to assist and collaborate with program offices in
   identifying potential issues that could prevent approval by the VA OIT CIO
   or VA Web Governance Board for production release. However, the NCA
   Program Office, as the product content owner, remains solely responsible
   for ensuring compliance with all applicable VA policies and requirements
   necessary to obtain VA WGB approval.
8. NCA Business Owners, Product Owners, or CORs may submit acquisition
   documents and other potential requirements documentation to their
   administration WCO.
9. NCA Business Owners, Product Owners, and CORs should follow VA Office of
   Section 508 processes to satisfy Recommendation 3 (effective July 1,
   2025) by obtaining a statement of relative compliance from the VA Office
   of Section 508 based on the documentation they provide.
10. NCA Business Owners, Product Owners, and CORs will continue following the
    VA Office of Section 508 processes to meet all applicable Section 508
    compliance requirements and any procedures established by the VA Office of
    Section 508.