Existing and commercially available information technology services might not meet all of the IT Accessibility Standards in the Enterprise Information Technology Accessibility Policy for a variety of reasons. Examples include: no vendor produces suitably accessible services, the implementation of certain accessibility features would necessarily compromise effective government operations or citizen security, or new accessibility technologies remove former accessibility barriers.
Mitigation plans document the minimum actions necessary to address accessibility deficiencies. They should be updated on an as-needed basis, for example, to remove known issues which have been remedied, to modify accommodations, and to address newly-discovered issues.
An agency should create a mitigation plan when an information technology product or service does not fully comply with the IT Accessibility Standards. Defects should be identified, and analyzed to determine the impact they have on usability.
The mitigation plan should outline strategies, specific activities, emergent technologies, or other actions needed to minimize accessibility defects. This may include planned remediation, configuration, customization, and reasonable accommodations agencies will need to provide until accessibility deficiencies have been addressed. Mitigation plans should be shared with the agency’s ADA Coordinator and may also be distributed to other subject matter experts as necessary, such as technical specialists.