National Standards Perspectives: February 2017

April 6, 2017


Standards Perspectives

Healthcare regulations and policies are very complex and ever-evolving. It’s important for managers of health plans and state Medicaid agencies to understand what new legislation means and how it affects their programs. Standards Perspectives brings you the latest details on new policies and standards so you can quickly and clearly learn what’s important to make the right decisions.

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508 Final Rule is Here

On January 18, 2017 the Architectural and Transportation Barriers Compliance Board (Access Board) published a final rule updating accessibility requirements for the federal sector covered by Section 508 of the Rehabilitation Act. The Access Board is an independent agency of the United States government devoted to accessibility for people with disabilities. The goal of Section 508 is to enhance the access to government-funded systems by persons with disabilities. An overview of the final rule is available here.

The rule updates and reorganizes the Section 508 standards in response to market trends and innovations, such as the convergence of technologies. The refresh harmonizes these requirements with the Level A and Level AA Success Criteria and Conformance Requirements in the Web Content Accessibility Guidelines (WCAG) 2.0 and applies them not only to websites, but also to electronic documents and software. A customizable quick reference to the 508 WCAG 2.0 requirements and techniques is available here.

Major Changes

The Board updated the 508 Standards to ensure consistency in accessibility across the spectrum of information and communication technologies (ICT) covered. The final rule revises both the structure and substance of the ICT requirements to increase accessibility, facilitate compliance and make documents easier to use. Major changes include:

  • Restructuring provisions by functionality instead of product type due to the increasingly multi-functional capabilities of ICT
  • Incorporating the WCAG 2.0 by reference and applying Level A and Level AA Success Criteria and Conformance Requirements to websites, as well as to non-web electronic documents and software
  • Specifying the types of non-public facing electronic content that must comply
  • Requiring that operating systems provide certain accessibility features
  • Clarifying that software and operating systems must interoperate with assistive technology (such as screen magnification software and refreshable braille displays)
  • Addressing access for people with cognitive, language and learning disabilities
  • harmonizing the requirements with international standards

Like the original 508 standards, the updated 508 requirements apply to a full range of public-facing content, including websites, documents and media, blog posts and social media sites. The final rule also specifically lists the types of non-public-facing content that must comply. This includes electronic content used by an agency for official business to communicate:

  • Emergency notifications
  • Initial or final decisions adjudicating administrative claims or proceedings
  • Internal or external program or policy announcements
  • Notices of benefits, program eligibility, employment opportunities or personnel actions
  • Formal acknowledgements or receipts
  • Questionnaires or surveys
  • Templates or forms
  • Educational or training materials
  • Web-based intranets

Existing ICT content that meets the original 508 standards does not have to be upgraded to meet the refreshed standards unless it is modified. This “safe harbor” clause (E202.2) applies to any component or portion of ICT that complies with the existing 508 standards and is not modified. Any component or portion of existing, compliant ICT that is modified after the compliance date of January 18, 2018 must conform to the updated standards.

Updates to Documentation

The updated 508 rule also addresses access to support documentation and services. Product documentation must cover how to use the access and compatibility features required for hardware and software. Electronic documentation must comply with the requirements for electronic content. Alternate formats must be made available upon request for documentation provided. Support services, including help desks, call centers, training services, and automated technical support must accommodate the communication needs of customers with disabilities and include information on access and compatibility features.


Federal agencies and contractors covered by Section 508 are not required to comply with the updated 508 Standards immediately. The Rehabilitation Act gives the Federal Acquisition Regulatory Council (FAR Council) and federal agencies up to six months to incorporate the updated 508 standards into their respective acquisition regulations and procurement policies and directives. It will be up to the FAR Council to establish the date by which new and existing procurements for 508-covered ICT must meet the updated 508 Standards. For all other non-procured ICT, federal agencies and contractors must comply with the updated 508 standards beginning on January 18, 2018 (i.e., one year after publication of the final rule in the Federal Register). During the interim period before the updated 508 Standards take effect, the original 508 standards continue to serve as the accessibility standard for all 508-covered ICT.

What this Means for Medicaid

Because the new 508 standards cover a much broader array of systems and content than previous law, Medicaid systems will have to expand the scope of their compliance evaluation and testing. In addition to both internal and external web interfaces, Medicaid systems will need to evaluate the majority of publicly facing documentation (provider manuals, fee schedules, benefit information) as well as a wide range of non-public documents.

While there are some changes in the UI requirements that Medicaid Agencies must be aware of, the more significant change is incorporating the 508 requirements into internal and external electronically published documents. Technical writers and publication support will need to become aware of how to incorporate the 508 rules into their electronically available Microsoft Word and PDF documents.

You can read more Conduent insights about healthcare regulations in previous editions of Standards Perspectives.


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