Executive Summary

Over the past five decades, federal law and policy concerning the accessibility of information and communications technology (ICT) have undergone significant advances to ensure equitable access for persons with disabilities (PWD). Crucial governmentwide initiatives and resources have emerged as a result of collaborative efforts by the legislative and executive branches to advance ICT accessibility within the federal government. Federal agencies including the Office of Management and Budget (OMB), the Department of Justice (DOJ), the General Services Administration (GSA), the White House Office of Science and Technology Policy (OSTP), and the U.S. Access Board (Access Board) have continued advancing digital accessibility along with many partnering agencies throughout the government.

The Governmentwide Section 508 Assessment (referred to hereafter as the “Assessment”) aligns with the reporting requirements of the Consolidated Appropriations Act, 2023. The Assessment serves a twofold purpose:

• To improve transparency, accountability, and trust regarding Section 508 compliance, fulfilling specific reporting requirements under the Consolidated Appropriations Act, 2023.

• To address the critical need for accessible ICT in the federal government, particularly recognizing its impact on PWD.

Highlighted Findings

Assessment of compliance with Section 508 requirements is a complex issue that requires context and framing. As such, methods to produce the Assessment included the criteria development, data collection, data validation, descriptive statistical analysis, and the creation of indices for maturity and conformance. Conformance questions focused on outcomes of the respondents’ accessibility related activities, such as conformance of the respondent’s top 10 web pages and documents or regularly testing web pages and accessibility of their time and attendance system.

Maturity, in the context of this Assessment, is not based on a holistic maturity model. It is solely based on the respondent’s self-assessed responses to the Assessment’s maturity-related questions that address processes, policies, procedures, testing, training and other inputs of a Section 508 program. In this sense, maturity is determined by how well a program is set up to succeed while conformance is the accumulation of accessibility-related outcomes of an organization. GSA conducted additional analysis to identify factors contributing to Section 508 compliance and assess the strength and significance of relationships between factors relating to accessibility. Throughout this Assessment, GSA analyzed both conformance outcomes and maturity inputs to holistically evaluate Section 508 compliance and better understand where deficiencies exist and why. Not all criteria were statistically significant for this inaugural year, but we expect to see trends in future years. As a result, the Findings section does not summarize every data point; however, all response data is publicly available in the Assessment Data section.

Based only on self-reported data from 249 reporting entities from June 1, 2022, to May 31, 2023, the Assessment revealed several key findings¹: Overall compliance to Section 508 is well below expectations given the federal government has had over 20 years to implement programs capable of achieving and maintaining modern ICT Standards. More than 75% of respondents are at or below average with respect to Section 508 compliance. Findings show:

• Compliance Can Be Improved Across Government: The majority of reporting entities (76%) fall within the lower maturity and conformance categories, signifying performance well below the statutory requirement of Section 508.

• The Majority of Top-Viewed ICT Tested Does Not Fully Conform to Section 508 standards: Of the self-reported top ten viewed intranet and internet pages, top ten viewed electronic documents, and top five viewed videos, on average, less than 30% fully conform to Section 508 standards.

• Technology Lifecycle and Policies Activities Need Improvement: Despite reporting entities, on average, faring the best in Technology Lifecycle Activities and Policies, Procedures and Practices, low compliance of ICT governmentwide demonstrates established policies, procedures and practices lack requirements and accountability sufficient to build, buy, maintain, and use Section 508-conformant ICT.

• Section 508 Program Maturity Drives Conformance: More mature, well-established Section 508 Programs tended to report better conformance to Section 508 requirements.

• Resources Are Important: Reporting entities with more Full Time Equivalents (FTEs) tend to be more mature and have higher conformance with Section 508 standards.

• Section 508 Program Manager (PM) Time Is Well-Utilized: The more time the Section 508 PM was involved in the program, the better or more mature that program tended to be, irrespective of program size

• Section 508 Program Resources Are Low Across Government: Many reporting entities lack Section 508 FTEs, hindering Section 508-related work.

• Testing Is Prevalent, but Immature: A substantial number of reporting entities employ manual or hybrid ICT accessibility testing, yet low compliance of ICT governmentwide indicates room for improvement in the use of these methodologies.

• Training and Human Capital Activities Require the Most Investment: Training and Human Capital, Culture, and Leadership are the least mature aspects of reporting entity accessibility capabilities.

Highlighted Recommendations

The Assessment combines data analysis and findings with contextual considerations to provide recommendations aimed at enhancing Section 508 activities across the federal government and increasing Section 508 compliance. Selected recommendations include²:

• Congress should consider updating Section 508 of the Rehabilitation Act (29 U.S.C. 794(d) - Electronic and Information Technology) to include:

  • Definition of Agencies Subject to Section 508 to clearly define who should follow Section 508 standards and respond to this Assessment.

  • Updated Language, Terminology, and Scope to harmonize and strengthen the language for applicability to the current and future digital landscape.

• Proactive Section 508 Compliance Enforcement: Congress should explore options to proactively enforce Section 508 compliance across the Federal Government, likely leading to less reactionary measures and more conformant ICT.

• Target Accessibility of High-Use Software: Congress may consider conducting oversight efforts into major providers of ICT to the federal government to determine the best course(s) of action for improving accessibility of high-use products. As office productivity applications, survey tools and other programs are used by all agencies, a push for more “out of the box” Section 508 conformant products would help improve ICT accessibility across government.

• Increased Agency Oversight of Section 508: Relevant oversight and accountability bodies should consider increasing internal agency oversight of Section 508 compliance, leading to improved self-enforcement of Section 508.

• Strengthen Leadership Accountability: Relevant management entities and councils should consider strengthening management activities to improve accessibility metrics in leadership performance reporting on an annual basis. Leadership accountability, tangible accessibility accountability, and conformance metrics would directly lead to improved accessibility compliance across government.

• Increased Conformance Validation and Testing: Agencies should increase automated and manual Section 508 conformance testing, validation, and defect remediation before deployment. Agencies should also hold vendors accountable for conformant deliverables prior to acceptance, likely creating significant positive downstream impacts as more conformant products and services deploy.

• Require Section 508 Training: Agencies should require mandatory annual Section 508 training for specific roles and responsibilities, particularly for those who regularly create electronic content and digital products or have influence in procurement and development of ICT. Mandatory training would increase knowledge and understanding of accessibility considerations across government, provide a baseline set of skills with respect to content creation, and introduce users to tools and information on how to address accessibility issues in ICT.

• Improve Accessibility Requirements in Procurement: Agencies should use the Solicitation Review Tool (SRT) and the Acquisition Requirements Tool (ART), or similar tools to help incorporate sufficient accessibility requirements in procurement and contracting documentation. The tools would also help establish policy and procedures for when inaccessible ICT is procured, which includes holding vendors responsible for remediating ICT to be Section 508 conformant. This will likely lead to better procurement outcomes and improved accessibility across government products and services.

• Ensure Sufficient Section 508 Program Resourcing: Agencies should consider including information about Section 508 program capacity in its annual budget requests to highlight necessary resources to improve ICT accessibility, likely leading to better Section 508 conformance.

Overall, while some reporting entities perform well with respect to meeting accessibility requirements and are well-positioned to do so with mature programs and accessibility related-business functions, there is significant room for improvement. As will be shown throughout this report, many reporting entities rarely or only sometimes address accessibility considerations when executing their mission or conducting related support activities, such as communicating, training or acquiring products. This first iteration of the Governmentwide Section 508 Accessibility Assessment will provide a baseline picture of how well we, as the federal government, are meeting our digital accessibility obligations.

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Reviewed/Updated: December 2023