Note: This article was updated Nov. 4.

“Health information technology solutions are developed for people who need to manage their care. Depending on the medical diagnosis and the prescribed regimen, this may impact the patient’s sight, hearing, cognition, and mobility, which are essential for performing any computer-related tasks,” said Ameenah Ghoston, the Defense Health Agency’s Section 508 Program Office manager.

“So, when you think about the intersection of health IT and being healthy—the Section 508 law and digital accessibility are essential for a successful patient outcome. It enables a segment of the user population experiencing temporary or permanent limitations to independently manage their care, [and] to communicate with their health care team to ensure they receive the necessary quality of care.”

The Section 508 Law of the Rehabilitation Act of 1973, amended in 1998 and refreshed in 2018, requires federal agencies to make any information and communications technology obtained, developed, maintained, and sustained, accessible to people with disabilities. Information and communications technology includes agency digital communications such as documents, websites and social media posts, and hardware and software.

The DHA Section 508 Program Office “is here to work with you on any aspect of Section 508 compliance, whether you are creating a document, whether they be contracts, [or you] have general questions on how you yourself get started,” said Ghoston. She discussed Section 508 at a session called “Equal Access to Health IT for Disabled and Aging Populations” during the Defense Health Information Technology Symposium 2024, in Dallas, Texas, this past August.

“Anything that is information technology or electronic content is covered under the Section 508 law, which outlines what you need to look for … to ensure these various categories of information technology are compliant,” Ghoston said. 

Supporting 508 compliance 

Ghoston said the Program Executive Office for Medical Systems/Chief Information Officer (J-6), within which the DHA Section 508 Program Office resides, “recognizes that 508 is a daunting task.” The law allows for exceptions and exemptions from meeting legal compliance standards.

As Ghoston explained: “We will walk you through putting together the documentation that you need in your contract files to ensure that vendors are providing compliant products and to hold them accountable when such products are not compliant.” 

Digital accessibility for all 

“Section 508 conformance can improve the overall usefulness, functionality, and usability of information and communications technology for all individuals,” said Ghoston.

The Section 508 law requires the government to leverage digital accessibility standards, specifically the Web Content Accessibility Guidelines 2.0, or higher. “Digital accessibility is for everyone,” she declared. “Yes, it primarily benefits people with disabilities, but everyone benefits from it, and it makes for a better, usable, user-friendly product, and provides a flexible user interface to be accessed on a mobile device or desktop or whatever device … [we] need to have in our technology entourage for accessing and interacting with digital content,” she explained.

“In addition to digital accessibility standards, Section 508 requires that the information and communications technology is interoperable with assistive technology,” Ghoston told DHITS. Assistive technology is a general term that describes tools used by people with disabilities to accomplish tasks, such as specialized keyboards. Within the context of the Section 508 law and digital accessibility, assistive technology refers to software and hardware that enables people with mobility, hearing, speech, vision, or learning disabilities to use computing devices. 

Under Section 504 of the Rehabilitation Act of 1973, agencies are required to provide assistive technology as a reasonable accommodation to employees. Part of the DHA Section 508 Program office’s role is to “facilitate the coordination between the DHA Disability Program Management Office that oversees reasonable accommodations, and J-6 organizational processes,” Ghoston said. For example, the office must ensure that “the requested assistive technology has gone through cyber security processes and [is] coordinated with the global service center for installation.”

“Assistive technology is dependent upon digital content and products being developed with digital accessibility considerations early in the lifecycle, not as an afterthought,” said Ghoston. 

Next steps 

One of the office’s goals is for the majority of documents posted on TRICARE.mil to be 100% compliant with the Section 508 law by November 2024, Ghoston said, adding: “We're on a very good path to meet that objective.”

Technology is an enabler, not an end state for the future of health care in the market and on the battlefield, said U.S. Army Lt. Gen. Telita Crosland, director of the DHA, at the opening plenary of DHITS. 

One of Crosland’s DHA advancement goals is speeding up the pace of digitization as part of the agency’s acceleration to the next level of patient-centered health care for its customer base of service members, beneficiaries, veterans, and providers worldwide.

“DHA is transitioning to virtual care and will apply best practices to leading-edge technologies to support our worldwide population,” Ghoston told her DHITS audience. 

Remediation: the interface of accessibility and usability 

The DHA Section 508 Program Office has developed a draft 508 policy. One of the many areas the policy addresses is remediating public-facing content “because it is considered high-risk content, and we're working on some other initiatives to bring up our outcomes” in the public domain.

There is legal risk to an agency when information and communications technology is not compliant with Section 508 requirements. To check for accessibility, Ghoston recommended health information computer technology developers use the Department of Homeland Security’s Trusted Tester process.

The Trusted Tester process provides a code-inspection-based-test approach for determining web content conformance to the Section 508 standards. “It will show you what and how to test your digital product against the WCAG [guideline] standards, and help you understand how assistive technology interacts with digital content,” said Ghoston. 

If you believe you are experiencing a Section 508 noncompliance matter at DHA or with DHA content and would like to report it, go to Accessibility.

To learn more about the DHA Section 508 Program Office, view its annual report.