Section 508 Fixes Without a Full RFP: Agency Procurement Guide

Most Section 508 remediation work never gets done for one reason: the team assumes they need a full RFP to hire outside help, and a full RFP takes months they don’t have.

The reality is that federal procurement law gives agencies several legitimate paths to get accessibility work moving fast, without going through a full competitive solicitation. Understanding which path fits which type of work is what separates agencies that make progress from agencies that stay stuck.

Here’s what contracting officers, program managers, and Section 508 coordinators need to know.

Why Do Agencies Wait So Long to Start Section 508 Remediation?

The answer is almost always the same: procurement friction. When a team discovers they have significant accessibility gaps, the instinct is to treat remediation as a major IT acquisition, which triggers the full procurement lifecycle. Market research, requirements definition, solicitation drafting, proposal evaluation, award. That process can take six to twelve months before any work begins.

Meanwhile, the annual Governmentwide Section 508 Assessment is measuring your conformance, your accessibility statement is sitting unfulfilled, and the violations you found in January are still live in December.

The good news is that most Section 508 remediation work doesn’t require a new RFP at all. Federal procurement regulations give agencies multiple faster options, and most agencies aren’t using them.

Option 1: Can You Use a Micro-Purchase?

What it is: A micro-purchase is an acquisition using simplified procedures where the total amount does not exceed the micro-purchase threshold. As of October 1, 2025, the maximum federal micro-purchase threshold under the FAR increased from $10,000 to $15,000.

What you can get done for under $15,000:

• Accessibility audit of your top 10 highest-traffic web pages
• Caption review and correction for a batch of agency videos
• PDF remediation for a set of high-priority documents
• A one-day training workshop for content creators
• An expert review of your agency’s accessibility statement for M-24-08 compliance

Micro-purchases require no competitive solicitation. The purchase card holder can acquire directly from a qualified vendor as long as the price is reasonable, documented, and purchases are distributed equitably among qualified suppliers.

What to watch for: Section 508 requirements still apply to micro-purchases. You’re not exempt from the accessibility standards simply because the dollar value is low. The FAR strongly encourages purchase card holders to comply with Section 508 standards even at micro-purchase levels. If you’re buying a software tool, a document template, or any ICT product under this threshold, it still needs to meet the standards.

Option 2: Do You Already Have a Contract That Covers This Work?

Before starting any procurement action, the first question should always be: does an existing contract already have scope for this?

Check your existing IT or web services contracts. Many agencies have active contracts for website maintenance, content management, or IT support services. If the statement of work includes language around “web content,” “digital services,” or “IT support,” there’s a reasonable chance that accessibility remediation falls within scope. Work with your contracting officer to evaluate whether a task order or delivery order under an existing contract can cover the work.

Check for accessibility language already in the contract. FAR 39.203 requires ICT acquisitions to meet the applicable accessibility standards unless an exception or exemption applies. The duty not to reduce the existing level of conformance, and repair or replacement at no cost to the agency, comes from the contract. Section508.gov publishes sample clauses for installation, maintenance, hosting, and non-compliance. If your contract includes that language, the contractor may already have to fix known violations. If it does not, the agency still holds the legal obligation. A conversation with the contracting officer costs nothing and sometimes produces results quickly.

Consider a contract modification. If the scope of your existing contract doesn’t currently include accessibility remediation, a contract modification within the general scope of the original contract may be possible. This avoids a new procurement while expanding what the contractor can do for you. The contracting officer will need to evaluate whether the modification is within scope, but this is a much faster path than a new solicitation.

Option 3: Use an Existing Government-Wide Contract Vehicle

If you need more than a micro-purchase but don’t have an existing contract that covers the work, government-wide contract vehicles let you place task orders without running a full competitive procurement from scratch. The competition happened when the vehicle was established. You’re buying off an already-competed contract.

GSA Multiple Award Schedule (MAS). The GSA Schedule is the most commonly used vehicle in federal procurement, covering billions in annual spending across technology, professional services, and more. Accessibility auditing, document remediation, web accessibility consulting, and Section 508 training services are all available through Schedule holders. Ordering under the Schedule requires getting quotes from multiple vendors but is far faster than a standalone RFP.

GSA GWACs (Government-Wide Acquisition Contracts). Vehicles like 8(a) STARS III, Polaris, and VETS 2 are pre-competed IDIQ contracts for IT services. If your agency’s accessibility work involves software remediation, web development, or broader IT modernization, these vehicles provide access to vetted vendors with established pricing. A warranted contracting officer needs a Delegation of Procurement Authority to issue task orders, but the solicitation work is already done.

NASA SEWP. SEWP V remains available through January 31, 2027. SEWP VI has been awarded, with an anticipated ordering period of November 1, 2026 through October 31, 2036. If your remediation needs involve technology tools, testing software, or combined product-and-services solutions, confirm which vehicle the order should use at sewp.nasa.gov before you write the acquisition.

NIH CIO-SP3, CIO-SP3 Small Business, and CIO-CS. As of October 19, 2026, do not treat these as open vehicles for new work. NITAAC’s notice sets October 29, 2026 as the last day to award new orders. Orders awarded on or after June 8, 2026 cannot run past December 31, 2028. CIO-SP4, the planned successor, was cancelled in early 2026 and was never awarded. NITAAC says future requirements go to vehicles in the GSA portfolio. For new Section 508 work, use the GSA Multiple Award Schedule or a GWAC GSA currently lists, including 8(a) STARS III (ordering period through July 1, 2029), Polaris, VETS 2, and Alliant 3. Confirm the pool, scope, and delegation with your contracting officer before you issue a task order.

The key advantage: When you use an existing GWAC or MAC, you’re issuing a task order against a pre-competed contract, not running a new competition. For accessibility work, this can compress months of procurement timeline into weeks.

Option 4: Use the Simplified Acquisition Threshold for Mid-Size Work

For acquisitions above the micro-purchase threshold but below the simplified acquisition threshold (now $350,000 as of October 1, 2025), agencies can use simplified acquisition procedures. This means:

• Fewer documentation requirements than a full RFP
• Ability to solicit price or rate quotations from an adequate number of qualified sources rather than running a full competitive procurement
• Faster award timelines

For many agencies, a comprehensive Section 508 audit, a multi-month document remediation project, or a training and capacity-building initiative can be scoped to fall within this threshold. Work with your contracting officer early to structure the requirement in a way that fits the simplified acquisition path where appropriate.

Option 5: Can Your Current Vendor Fix This Under Existing Obligations?

This one is underused and worth understanding clearly.

FAR 39.203 says ICT acquisitions must meet the applicable accessibility standards unless an exception or exemption applies. It does not, by itself, make every existing contractor remediate old work for free. That result depends on the contract. Section508.gov’s sample non-compliance clause says that if the contractor claimed conformance and the contracting officer finds the delivered ICT does not conform, the contractor repairs or replaces it at no cost to the agency.

If a contractor delivered a website or other ICT and the contract required Section 508 conformance, known violations may already be the contractor’s responsibility. A June 23, 2026 proposed rule would reorganize FAR Part 39. It is not a final rule. The live citation is still FAR subpart 39.2. Check acquisition.gov before you pin a section number in a solicitation.

This doesn’t mean every accessibility issue gets fixed for free. It depends on what the contract’s statement of work said, what standards were specified, and whether the agency accepted delivery without noting deficiencies. But for agencies with active IT or web development contracts, reviewing the contract’s accessibility language and opening a conversation with the contractor about known violations is a legitimate first step that costs nothing.

How Do You Scope Section 508 Remediation Work for a Quick Acquisition?

Scoping is where many agency teams get stuck. They know they have accessibility problems but can’t articulate what they’re buying. Here’s a practical framework:

Audit first, remediate second. Don’t try to procure remediation for problems you haven’t measured. Start with a scoped accessibility audit of your highest-priority assets. This is a discrete, bounded deliverable that’s easy to procure quickly, and the audit output becomes the basis for scoping remediation work.

Prioritize by risk and traffic. Your most-visited web pages, most-downloaded documents, and most-viewed videos carry the most risk and the most impact. A targeted remediation engagement focused on these assets delivers compliance value faster than a broad sweep of everything.

Break work into phases. A phased approach lets you start moving quickly under smaller procurement authorities while longer-term remediation work goes through a more complete acquisition process. Phase 1 might be an audit and quick-fix sprint under the simplified acquisition threshold. Phase 2 might be a longer-term document remediation program using a GWAC task order.

Use the Accessibility Requirements Tool (ART). GSA’s free ART tool (available at section508.gov) helps agencies determine which Section 508 standards apply to a specific procurement and generates appropriate contract language. This tool eliminates one of the most common causes of delay in 508-related acquisitions: not knowing what language to put in the solicitation.

What Should the Statement of Work Say?

Whether you’re issuing a task order, a simplified acquisition, or a micro-purchase, the statement of work needs to specify Section 508 requirements clearly. Section508.gov provides sample contract language that can be adapted for different acquisition types.

At minimum, for any accessibility remediation work, your statement of work should:

• Identify which ICT assets are in scope
• Specify the applicable Section 508 technical standards (Revised 508 Standards, WCAG 2.0 Level AA)
• Require the contractor to use a recognized testing methodology (DHS Trusted Tester or equivalent)
• Require delivery of test results and an Accessibility Conformance Report (ACR) upon completion
• Include a requirement that the contractor not reduce the existing level of conformance for any assets they touch
• Define acceptance criteria: what does “done” mean, and how will conformance be verified before acceptance?

Without clear acceptance criteria, you have no mechanism to enforce remediation quality or require rework.

Frequently Asked Questions About Section 508 Procurement

Do micro-purchases have to comply with Section 508? Yes. Section 508 requirements apply to all ICT acquisitions regardless of dollar value. While micropurchases use simplified procedures, the FAR strongly encourages compliance with accessibility standards even at this level. If you’re buying a tool, template, or service that involves ICT, the standards apply.

Can I use a GSA Schedule to buy Section 508 accessibility consulting? Yes. Accessibility auditing, document remediation, Section 508 training, and web accessibility consulting services are available through GSA Multiple Award Schedule vendors. Work with your contracting officer to identify vendors with relevant experience and get competitive quotes.

What is the current simplified acquisition threshold? As of October 1, 2025, the federal simplified acquisition threshold under the FAR increased from $250,000 to $350,000. Acquisitions at or below this threshold can use simplified acquisition procedures, which are significantly less burdensome than a full sealed bid or negotiated procurement.

What is the Accessibility Requirements Tool (ART) and should I use it? Yes. ART is a free tool on Section508.gov that walks acquisition professionals through the process of determining which Section 508 standards apply to a given procurement and generates customizable contract language. It’s the fastest way to produce a legally sound Section 508 requirements section for a statement of work.

If a contractor built our website and it has accessibility violations, who is responsible? It depends on what the contract required. If the statement of work specified Section 508 conformance and the delivered website does not conform, remediation is generally the contractor’s responsibility at their own expense. If the contract was silent on accessibility, the agency may have limited recourse through the contract, though the legal obligation to make the site accessible still rests with the agency. This is why accessibility requirements must be included in solicitations from the start.

Can we issue a task order for Section 508 work under an existing GWAC without running a new competition? Yes, on a vehicle that is still open for orders. As of October 19, 2026, that includes the GWACs GSA lists as current, such as 8(a) STARS III, Polaris, and VETS 2. Competition occurred at the vehicle level. Task orders are issued against the pre-competed contract, with competition among holders. A warranted contracting officer with a Delegation of Procurement Authority is required. NASA SEWP V runs through January 31, 2027, and SEWP VI is scheduled to open November 1, 2026. Do not award a new order on NIH CIO-SP3, CIO-SP3 Small Business, or CIO-CS after October 29, 2026.

Related Topics to Explore

• What Government Agencies Need to Know About Section 508 Compliance in 2026 (the full legal overview)
• The Most Common Section 508 Violations on Government Websites (And How to Fix Them Fast)
• Understanding and Evaluating VPATs - what to look for before accepting a vendor’s accessibility claim
• How to Build a Section 508 Testing Program from Scratch
• Section 508 and Procurement: What Contracting Officers Need to Know
• WCAG 2.0 vs. WCAG 2.2: What’s Changing and What It Means for Federal Agencies

The Bottom Line

Section 508 remediation doesn’t have to wait for a full RFP. Micro-purchases, existing contract vehicles, GWAC task orders, simplified acquisitions, and existing contractor obligations all give agencies legitimate ways to start moving faster.

The procurement path matters less than picking one and starting. The annual Section 508 Assessment is measuring your conformance right now. The people visiting your agency’s website and documents right now include people with disabilities who may not be able to access what you’ve published. Waiting another cycle for procurement paperwork to clear isn’t a neutral choice.

Talk to your contracting officer this week. Pull up your existing contracts and look at the statements of work. Check what’s available on the GSA Schedule. The path forward is almost always shorter than it looks.

For free acquisition tools and contract language templates, visit Section508.gov/buy. The Accessibility Requirements Tool (ART) is available at no cost and requires no account.