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Enabling a Commitment to Accessibility through Transformative 508 Compliance Remediation 

Background   

The U.S. Healthcare System is one of the most complex in the world with multiple stakeholders, regulatory complexity, varied payment systems, a mix of public and private funding, and lack of data standardization and interoperability. The Centers for Medicare & Medicaid Services (CMS) plays a central and crucial role in working to alleviate many of these complexities by aiming to simplify processes, improve healthcare quality, enhance access to care, and promote a more patient-centered and efficient healthcare system to more than 100 million beneficiaries, many of whom have some type of disability. 

Within CMS, The Center for Medicaid and the Children’s Health Insurance Program (CHIP) Services (CMCS) leads the formulation, coordination, integration, and implementation of all national program policies and operations relating to Medicaid, the Children’s Health Insurance Program (CHIP), and the Basic Health Program (BHP). As part of that responsibility, various groups and divisions within CMSC produce and publish documents and other materials on the Medicaid.gov website that beneficiaries rely on for guidance and benefit attainment. These documents and materials are required by law to comply with Section 508 prior to being made available to the public. 

While CMS and all underlying offices and departments to include CMCS, are required to adhere to Section 508, their commitment to accessibility transcends regulatory compliance. CMS aspires to be a model employer of people with disabilities and seeks to ensure equally effective access to its programs and services, as required by Section 504 of the Rehabilitation Act of 1973. Additionally, CMS is committed to providing the absolute best user experience to all beneficiaries, of which accessibility is a core component. 

Context and Challenge 

CMCS produces and shares literally thousands of documents each year, both directly with beneficiaries and on the CMCS-managed websites. These documents are critical to the ability of beneficiaries to understand and utilize their benefits. Several of these documents date back decades and have posed an ongoing challenge to CMCS’s goal of not only ensuring 508 compliance but also access equality and the best possible user experience for all beneficiaries, especially those with disabilities. Additionally, as beneficiary needs continue to grow and evolve, requirements around document creation and sharing have also continued to grow and evolve. As an example, CMCS faces increasingly stringent deadlines, often needing to submit documents to other government agencies (e.g. White House) within a mere 3 hours. With an existing backlog of noncompliant legacy documents and a growing backlog of new documentation that also needed 508 compliance remediation, CMCS lacked the resources, process, and expertise to meet their accessibility commitments. 

Solutions    

Building on our extensive background in 508 compliance and remediation, Sky Solutions’ Human-Centered Design Center of Excellence (CoE) has undertaken 508 remediation initiatives with several Federal agencies. These efforts have produced results that are significantly meaningful to the accessibility goals of these agencies and have helped to establish modernized processes and frameworks that will ensure compliance and enhanced user experience for the foreseeable future. For CMCS, Sky leveraged extensive expertise in both Section 508 Standards and Web Content Accessibility Guidelines (WCAG) 2.0, a deep understanding of Medicaid policies and processes, and a Digital-First approach to modernization and process improvement, as the basis to ensure successful 508 compliance remediation in alignment with expectations and requirements.  

Sky assessed potential alternative solutions from an accessibility perspective and selected appropriate Section 508 automated testing tools designed to deliver timely and quality-compliant products. Sky then developed an easy-to-follow and time-saving document remediation process for CMCS to submit and retrieve documents. The modernized process, in conjunction with our expertise and tools, ensured a timely mitigation of the legacy document backlog but more importantly, provided a framework to ensure that moving forward, CMCS would be able to account for growing remediation demands and tightening time constraints, and ensure alignment with CMS’s overall commitment to accessibility. 

Our Approach 

Sky Solutions, which holds the CMMI Maturity Level 3 for Development and Services, applies best practices for timely and high-quality delivery of Section 508 Compliance and Remediation Services. Additionally, Sky’s approach follows both a Digital-First methodology and the central tenets of Human Centered Design. At CMCS, this ensured continuity of existing efforts, effective leveraging of the success and experience of existing CMCS team members, the development of a modernized compliance remediation process, and aligned with user experience expectations for both internal and external stakeholders. Key focus areas included providing seamless 508 support across CMCS, increasing consistency through standard operating procedures, boosting confidence in deliverables through test result transparency, improving quality via proven control practices, and reducing timelines and program risks through automation tools and project management techniques. 

Outcomes

The new, streamlined Section 508 compliance process significantly enhanced consistency, bolstered confidence in deliverables, and elevated the quality of all documents and templates. Accessibility barriers were eliminated, making content readily available to the public and to those beneficiaries with disabilities. Sky Solutions achieved a remarkable reduction in document remediation time, from 12 hours to a mere 2 hours, even amidst pressing requests. 

Sky successfully provided seamless Section 508 remediation support across CMCS, spanning both the Operations Services Group (OSG) and the State Demonstrations Group (SDG). By establishing standardized operating procedures for Section 508 compliance and remediation activities, Sky significantly increased consistency in our deliverables. Our commitment to quality was demonstrated through the inclusion of artifact test results and enhanced confidence in the products we delivered. Leveraging proven quality control practices, we elevated the overall quality of our deliverables and documents. Additionally, our strategic use of automation tools and effective project management techniques played a pivotal role in reducing timelines, mitigating program risks, and ensuring a smooth and efficient workflow. 

This case study exemplifies how Sky Solutions not only met and exceeded the specific requirements of the CMCS 508 remediation initiative, but also exemplifies our appreciation of the significance of CMS’s broader commitment to ensuring those with disabilities have the access they need and deserve to the critical benefits they rely on. 


About Sky Solutions

Sky Solutions is a Digital-First enablement partner that believes in using a human-centered approach to address the most complex and rapidly evolving business process challenges facing public sector clients. Our core capabilities include Low-Code / No-Code Development, Cloud Services, Digital Process Automation & Robotics Process Automation (DPA/RPA), Human Centered Design (HCD), Artificial Intelligence & Machine Learning Services (AI / ML), and Agile DevSecOps. Additionally, we’re partnered with several leading-edge Business Process Management (BPM), Automation, and Low-Code Platforms.  For more information on how Sky Solutions is helping to enable the Digital-First enterprise, visit www.skysolutions.com. Follow Sky’s LinkedIn for news and updates.

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