Exception Request Mitigation Plan

Learn how to develop a Mitigation Plan as part of your Enterprise Digital Accessibility Exception Request.

Overview

A Mitigation Plan is a documented set of actions intended to remove or mitigate access barriers resulting from a Digital Asset’s noncompliance with the Digital Accessibility Standards. A Mitigation Plan must be included as part of an Enterprise Digital Accessibility Exception Request

What is Included in a Mitigation Plan?

A Mitigation Plan should include a combination of the following items:

  • Accessibility Support Measures.  Actions taken to mitigate potential barriers resulting from the noncompliance.
  • Remediation Plan. A roadmap with the goal of bringing the Digital Asset into compliance.
  • Replacement Plan. A plan to decommission and replace the inaccessible Digital Asset with a modern, more accessible digital experience. 

Examples of Accessibility Support Measures

The goal of providing accessibility support measures is to ensure equivalent access to Commonwealth programs, activities, and services. Accessibility support measures can take many forms. Because no one method may work for all users in each situation, a combination of approaches is recommended. Some examples of accessibility support measures include but are not limited to obtaining information or completing a task by phone, obtaining support via email or chat, posting additional instructions on how to complete a task, turning off inaccessible features in an application, creating accessible alternative pathways, or providing an alternative format of an electronic document in a timely manner upon request. Accessibility support measures should remain in place for as long as the Digital Asset is known to have Accessibility Violations that impact users.  

Creating a Mitigation Plan

Each applicable section of the Mitigation Plan should include the following information and related documentation.

Accessibility Support Measures

  • Name of person responsible for implementing accessibility support measures.
  • A list of measures taken to mitigate any access barriers resulting from the noncompliance.
  • A detailed description of actions taken including alternative accessible pathways to access information or complete a task.
  • If applicable, a documented process to remediate and deliver an electronic document in accessible format upon request including who will perform the remediation and expected turn-around time.

Remediation Plan

  • Name of person responsible for monitoring remediation progress.
  • An internal remediation roadmap that lists the specific Accessibility Violations and target dates for remediation of each violation.
  • If the noncompliance involves a third-party product, a Vendor Digital Accessibility Roadmap.  

Replacement Plan

  • Name of person overseeing Digital Asset replacement.
  • Target date for decommission and replacement.
  • Name of application scheduled to replace the inaccessible Digital Asset, if known.

How Do I Submit my Mitigation Plan?

A Mitigation Plan is submitted as part of an Enterprise Digital Accessibility Policy Exception Request. The online form will collect plan information and will be stored in Service Now. The Secretariat IT Accessibility Officer (SIAO) for your respective Agency will review your plan and may request additional information as needed. 

Mitigation Plan Requirements by Exception Type

the following table shows which sections of a Mitigation Plan are required for each Exception Type.

Exception TypeAccessibility Support MeasuresRemediation PlanReplacement Plan
Remediation in ProgressRequiredRequiredNone
Technical LimitationsRequiredRequired if not replacingRequired if not remediating
Minimal ImpactOptionalRequiredNone
Archived Web ContentRequiredNoneNone
Preexisting Electronic DocumentsRequiredNoneNone

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