Section 508 of the Rehabilitation Act - Frequently Asked Questions

B.3.iii. - What is the difference between "equivalent facilitation" and "alternative means of access"?

Equivalent facilitation focuses on whether an EIT product provides access that is equal to or greater than that required in the technical provisions in Subpart B of the Access Board’s standards. By contrast, an alternative means of access focuses on the accessibility of the information and data, rather than the technology. Under Section 508, agencies have a statutory obligation to make information and data available by an "alternative means of access" when acquiring EIT that meets the applicable technical provisions of the Access Board’s standards would impose an undue burden. (See 36 CFR 1194.4 and section B.6.ii below)

Agencies have additional obligations under Sections 501 and 504 of the Rehabilitation Act, including the obligation to provide employees with disabilities "reasonable accommodations." "Reasonable accommodation" focuses on the needs of a particular individual with a disability. "Equivalent facilitation," instead, focuses on whether the technology itself is designed to afford a specific degree of accessibility – e.g., that which would have been provided if the product or service strictly adhered to the specific technical provisions of Subpart B.