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Section III. Developing an Effective Accessibility Program

Explore how to build an effective accessibility program in this section of the Workplace Accommodation and Accessibility Policy Toolkit.

Having an effective accessibility program is critical to creating an inclusive workplace. Accessibility means making the workplace, equipment, and technology usable and functional to as many people as possible. Building in accessibility from the start sends the message that all are welcome.

Policy Assessment

1. What is an effective accessibility program?

An effective accessibility program creates an environment of universal accessibility, meaning access for all. An accessibility program must comply with standards, integrate user feedback, and facilitate decision-making in partnership with other organizational programs. There are two key elements of a whole-organization accessibility program that tie directly to accommodation services: physical and digital accessibility.

2. What is physical accessibility?

Physical accessibility ensures equal access to the workplace, including to parking lots, entrances, exits, emergency equipment, restrooms, and elevators. Steps, curbs, and doors are common structural obstacles in the workplace. Physical accessibility may also include clean air (PDF) and limited or no exposure to allergens such as mold, certain foods, and chemicals.

3. What is digital accessibility?

According to the Partnership on Employment & Accessible Technology, digital accessibility means that everyone can use the same technology—regardless of how they control a computer, how much vision they have, how many colors they can see, how much they can hear, or how they process information. Accessible technology is technology that can be used successfully by people with a wide range of functional abilities. Technology is directly accessible when usable without additional accessible technology (e.g., a mobile smartphone that is usable with a built-in screen reader). Technology is assistive technology–compatible when a tool is used for access (e.g., a website that is navigated effectively by people with vision loss using screen-reader software).

4. How does an organization develop an effective accessibility program?

Federal standards provide the starting point for an effective accessibility program. Various parts of the Americans with Disabilities Act (ADA) apply to physical accessibility. For example, an individualized assessment of physical accessibility needs for a particular employee with a disability must be considered under an employer’s Title I of the ADA (Title I) reasonable accommodation obligation. Titles II and III of the ADA have separate requirements under the 2010 ADA Standards for Accessible Design.

The 2010 Standards set minimum requirements for newly designed and constructed, or altered, state and local government facilities, public accommodations, and commercial facilities to be readily accessible to and usable by people with disabilities. For more information on these standards, see the U.S. Department of Justice 2010 Standards for State and Local Government Facilities (Title II) and 2010 Standards for Public Accommodations and Commercial Facilities (Title III). Facilities designed, built, altered, or leased with federal funds, including all federal buildings, must adhere to Architectural Barriers Act standards to ensure physical accessibility. The U.S. Access Board provides information on standards for the physical environment, including workplaces.

Ensuring that all employees can access the technology they need to perform their jobs is an important element of inclusion. The ADA and Rehabilitation Act (Rehab Act) mandate digital access for employees. Title I of the ADA requires the consideration of accommodations related to digital access for employees with disabilities on a case-by-case basis. Title II of the ADA (Title II) requires web content and mobile applications (apps) to be accessible to people with disabilities. This final rule (PDF) implementing Title II of the ADA establishes specific requirements for making accessible the services, programs, and activities offered by State and local government entities to the public through the web and mobile applications. It also mandates technical standards for state and local governments to help ensure the accessibility of programs and services provided through their web and mobile apps. 

Federal employers must also provide digital access as a form of reasonable accommodation under Section 501 of the Rehab Act. Federal employers (and federal contractors and subcontractors that provide information and communications technology products and services to them) also have an additional reason for paying attention to technological accessibility—Section 508 of the Rehab Act, which requires federal agencies’ technology to be accessible to people with disabilities, including members of the public and federal employees.

Developing an effective accessibility program requires that the accessibility team not work in isolation. In addition to meeting legal requirements, an organization can add elements to meet the unique needs of its workforce.

Policy Development

Questions to Ask

Develop an effective accessibility program by asking the following questions of your organization.

  • Sample Policy[1]

    [Organization Name] is committed to making its organization accessible to people with disabilities, both physically and digitally. To meet this commitment, we will:

    • Ensure that physical accessibility is provided equally throughout the workplace.
    • Create digital accessibility by making sure electronic products are directly accessible or compatible with accessible technology.
    • Collaborate with other teams to inform processes and manage innovations where applicable.

    If you have comments or questions related to accessibility, please reach out to the accessibility program by sending an email to [email address]. Where applicable, please include the following:

    • Nature of the accessibility problem encountered
    • Specific information sought
    • Email address for a response

    A member of the accessibility program will respond within 24 working hours and work with the responsible parties to remedy the situation. We will review this policy [review period] on or before [policy review date]. This policy was last reviewed on [last review date] by [Reviewer Name].

    [Signed by Name of Organization Head]

Policy in Practice

Prioritizing physical and digital accessibility ensures that all applicants, candidates, and employees can access the resources they need. Improved recruitment, employee retention, and operational cost reductions are just a few ways an organization will benefit.


Endnotes

  1. This Sample Policy does not necessarily represent legal obligations, but instead reflect topics that employers and employees may voluntarily choose to address. The Sample Policies do not constitute legal advice by the U.S. Department of Labor and do not reflect the full range of laws that may apply in every situation, including local and state laws that may provide additional protections and requirements. Employers should review local, state, and federal laws to ensure they are in compliance with the law that provides the most protections for employees and should include additional legal requirements as necessary.

    This publication is for general information to provide a voluntary resource for employers and is not considered in the same light as official statements of position. The contents of this Sample Policy do not have the force and effect of law and are not meant to bind the public in any way.
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