The Ins & Outs of 508: Compliance in Instructional Technology

Jeffrey Wessmiller
Training Specialist, GW Alumnus

If you work for the federal government or create e-learning products for it, you should be familiar with Section 508 standards. Section 508 is named after a 1998 amendment to the United States Workforce Rehabilitation Act requiring federal agencies to make electronic information technology (EIT) accessible to those with disabilities. As recently as this year, the United States Access Board (charged with interpreting accessibility requirements) “refreshed” 508 standards to incorporate additional international and other commonly accepted guidelines.

The E-Learning Dilemma
As technology continues to advance, an issue identified as the e-learning dilemma has surfaced. The perceived conflict is that the same interactivity that leads to successful learning also inhibits accessibility. This has unfortunately led to some agencies avoiding the best-suited learning solutions or even abandoning e-learning entirely out of fear of violation (United Stated Access Board, 2017). This is similar to what occurred when the deadline approached to comply with the original 1998 amendment: “Some program managers began to shut down their websites rather than risk being sued while their webmasters tried to assess and implement the applicable compliance standards” (McLawhorn, 2001, p. 74).

To avoid this confusion and potential reduction in accessibility, the e-Training Best Practices Committee advocated primary focus on learning requirements, objectives, and needs prior to 508 standards (United States Access Board, 2017). This approach is especially applicable when procuring commercial off-the-shelf items; the Federal Acquisition Regulation (2017) provides limited flexibility based on what is available at the time and delivery requirements. The most accessible option possible is encouraged, the intent being to influence the private sector into eventual full compliance.

Exceptions and Requirements
Exceptions that don’t require Section 508 compliance are rare for in-house EIT. Examples include EIT relevant to intelligence, weapon systems, or national security, EIT where compliance would require alteration of the nature of the project itself, and EIT that creates an undue burden (in which case the organization is required to provide an explanation and make the EIT available by alternate means). A common misconception is that compliance with Section 508 is not required if the e-learning’s target audience isn’t disabled. Although the Rehabilitation Act does initially identify its purpose as providing equal access to federal employees with disabilities, it further requires that members of the public seeking information or services from the government be provided comparable access as well. This has particularly presented challenges with Freedom of Information Act requests, a topic still being discussed by many federal organizations today.

Some of the Section 508 standards particularly relevant to e-learning include guidance on navigation, color, animation, readability, links, timing, and captioning. The 2017 refresh incorporated twelve Web Content Accessibility Guidelines (WCAG) to make products more perceivable, operable, understandable, and robust. The requirements in their entirety can be viewed on and (although it can be tricky to identify what applies to e-learning and what doesn’t).

A developer can quickly find themselves in violation of these standards when trying to incorporate gamification in e-learning. Especially when asynchronous, competition and challenge are often based on timing or reflexes. If a lesson incorporated a trivia-type game which awards points based on response speed for example, it may be in violation of WCAG 2.0 Guideline 2.2 which requires options to turn off, adjust, or extend timed elements (World Wide Web Consortium, 2017).

Luckily, there are many resources to assist developers in becoming compliant with 508 standards. Many federal organizations already have a 508 office that should be consulted and included as a stakeholder in any e-learning product. Designing a checklist and ensuring a policy is in place are good starting points to making an organization’s e-learning more accessible. Additional government resources for this topic include:

Although sometimes intimidating, the main purpose of Section 508 should always be kept in mind: Improving accessibility to those that otherwise wouldn’t have it.

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Federal Acquisition Regulation, 48 C.F.R. § 39.203(c)(2) (2017).

McLawhorn, L. (2001). Recent development: Leveling the accessibility playing field: Section
508 of the Rehabilitation Act. North Carolina Journal of Law and Technology, 3(1), 63-100.

Rehabilitation Act of 1973, 29 U.S.C. § 794(d) (2011).

United States Access Board. (2017). E-Learning: Conforming to Section 508. Retrieved from

World Wide Web Consortium (W3C). (2017). Web Content Accessibility Guidelines (WCAG)
. Retrieved from