Validation Process for Applications, Website & Hardware

Any newly purchased or developed electronic and information technology (EIT) including new versions or releases, must be validated for 508 Compliance. This includes the following:

• Commercial Off the Shelf (COTS) software
• Hardware (scanners, printers)
• Applications and systems developed for use by CMS
• Websites  including Portals, Exchanges, secure websites, the CMS Intranet, and public facing websites

Validation

The validation process is as follows:

1. The Application Owner requests a PAT (Product Assessment Template) from the EIT developer or a VPAT (Voluntary Product Accessibility Template) from an EIT vendor or contractor.
2. Application Owner submits PAT/VPAT to the Section 508 Coordinator (cms_section508@cms.hhs.gov).
3. Section 508 Coordinator will review.
   • If approved, the 508 Coordinator forwards the PAT/VPAT to the Testing Team to determine whether the software is compatible with CMS infrastructure. 
   • If additional information is needed, the 508 Coordinator will contact the application owner.
4. The Testing Team contacts the Application Owner to complete a Testing Plan.
5. The Application Owner completes a Testing Plan and sends to the Testing Team.
6. The Testing Team will schedule a 508 validation test with the Application Owner, 508 Coordinator, and a 508 Accessibility Tester.
7. Once the test is completed, the 508 Coordinator completes the Test Summary Report and provides to the Application owner.
8. If next steps are required, the 508 Coordinator will reach out to the Application Owner.

For more information refer to the CMS Validation Process and Procedure document.  

Exceptions

In rare cases, 508 exceptions may be granted for COTS software. The exception granting process begins with the component’s 508 Clearance Officer.  In order to be granted, an exception must fall within the following categories:

• National Security System
• Acquired by a Contractor Incidental to a Contract
• Back-office Equipment
• Undue Burden for CMS (e.g., extreme costs)
• Commercial Non-Availability

EIT exceptions are only valid for one release.  All subsequent releases must be re-evaluated for an exception.

Contact your 508 Clearance Officer for more information on obtaining an exception. To apply for a Section 508 exception, please complete the appropriate certification form.  The form must be submitted with a thorough justification to the Section 508 Clearance Officer.  The Section 508 Clearance Officer will submit it for further reviews and approvals.

For more information refer to the "Procedure: Section 508 Exceptions" document.