Governmentwide Findings: Section 508 Program and Staff Analysis Summary

Section 508 Program Managers (PM)

The majority of reporting entities (128 reporting entities or 51%) reported their Section 508 PM or equivalent worked part time, with a governmentwide average of part-time PMs dedicating eight hours per week to the Section 508 Program or equivalent.¹³

As shown in Figure 10, 70 reporting entities (28%) reported having a full-time Section 508 PM dedicated to the reporting entity Section 508 Program, while 51 reporting entities (20%) reported having no Section 508 PM or equivalent.¹⁴

On average, Section 508 PMs across government spent 15.4 hours per week on Section 508.

A bar chart showing the percentages of governmentwide Section 508 PM or equivalent utilization Q3): 28.1% of reporting entities had a full-time Section 508 PM, 51.4% had a part-time Section 508 PM, and 20.5% had no Section 508 PM.

Figure 10. Percentages of governmentwide Section 508 PM or equivalent utilization (Q3)

In addition, regression analysis showed that the number of hours per week a Section 508 PM supported a Section 508 Program (Q3 (See FY23 Data Dictionary (XLSX))) predicted the status of the Section 508 Program (Q22). For every extra hour spent, the likelihood of a more mature Section 508 Program status increased by 0.048.¹⁵ This shows the more time Section 508 PMs invest results in a higher maturity of the Section 508 Program. Similarly, the number of hours per week a Section 508 PM supported a Section 508 Program (Q3) predicted the amount of resources and staffing within the Section 508 Program (Q26), highlighting the positive impact of increased dedication to Section 508 Program management on resource allocation within federal reporting entities. Every additional hour the Section 508 PM spent translated into a 0.023 governmentwide increase in resources and staffing.¹⁶

Table 4 depicts the average hours per week Section 508 PMs dedicate to their Section 508 Program by maturity bracket. This shows that as maturity increases, so does the average number of hours per week a Section 508 PM dedicates to the Section 508 Program; or vice versa, the more time a Section 508 PM dedicates to their Program, the more mature the Program is.

Table 4. Average Section 508 PM hours per week dedicated to their Section 508 Program by maturity bracket
Maturity Bracket	Average Section 508 PM hours spent per week
Very High	31 hours
High	26 hours
Moderate	19 hours
Low	10 hours
Very Low	3 hours

Section 508 FTEs

Varying levels of Section 508 Program resourcing were reported governmentwide. Ninety-three (93) respondents (37%) reported less than 1 Section 508 FTE, with 36 of those reporting entities reporting no Section 508 FTE.¹⁷ Governmentwide, the average number of Section 508 FTEs was reported at 4.3, comprising an average of 2.7 federal and 1.6 contractor Section 508 FTEs. Figure 11 below demonstrates the average of total Section 508 FTEs for all reporting entities that fell within each maturity bracket, regardless of their conformance bracket. More mature reporting entities tended to have larger Section 508 Program support staff.

In Figure 12 below, GSA determined the average of total Section 508 FTEs for all reporting entities that fell within each conformance bracket, regardless of their maturity bracket. As depicted, higher performing reporting entities tended to have larger Section 508 Program support staff. Similar to maturity, the more resources a reporting entity has at their disposal, the higher ICT conformance they tend to have.

A line graph shows that, as the maturity bracket increases, the average total FTE increases: The line graph data shows: 0.2 FTEs in the Very Low bracket, 2.5 FTEs in the Low bracket, 5.3 FTEs in the Moderate bracket, 6.1 FTEs in the High bracket, and 8.3 FTEs in the Very High bracket.

Figure 11. Average total Section 508 FTEs by maturity bracket

A line graph shows that, as the conformance bracket increases, the average total FTE generally increases:. The line graph data shows: 1.9 FTEs in the Very Low bracket, 6.1 FTEs in the Low bracket, 3.6 FTEs in the Moderate bracket, 4.9 FTEs in the High bracket, and 8.2 FTEs in the Very High bracket.

Figure 12. Average total Section 508 FTEs by conformance bracket

The numbers above only factored in Section 508 FTEs directly supporting the reporting entity Section 508 Program. For some respondents, this data may have underrepresented the number of Section 508s FTEs throughout the reporting entity. For example, excluding developer and testing staff embedded in other programs or resources utilized from parent or component-level reporting entities. To balance this, several questions highlighted the following competencies of all reporting entity staff involved in ICT conformance:

Only 65 respondents (26%) indicated they include Section 508 conformance in ICT-related leadership and management performance plans. Figure 13 below depicts the further breakdown of responses, noting that 68 reporting entities (27%) reported having no plans to do so, 33 reporting entities (13%) reported having a timetable to begin implementation, and 83 reporting entities (33%) did not know if Section 508 conformance was included in ICT-related leadership and management performance plans.
157 reporting entities (63%) responded that they do not integrate ICT accessibility into professional development plans for staff responsible for ensuring ICT conforms to Section 508 standards, with 84 of those reporting entities (34%) having no plans to do so and 73 reporting entities (29%) noting a plan to do so in the future.¹⁸
126 reporting entities (50%) responded that staff who are involved in technology development lifecycle activities either sometimes or never have sufficient knowledge and skill to ensure ICT is Section 508 conformant, with 17 reporting entities reporting they have no knowledgeable staff.
158 reporting entities (64%) said they had no or only some development and testing professionals trained in Section 508 web testing.

A bar graph shows the count of responses for inclusion of Section 508 conformance in ICT-related leadership/management performance plans (Q39): 68 respondents selected No, and have no plans to do so; 33 selected No, but reporting entity has a timetable to begin implementation; 42 selected Yes, for some ICT leadership and management performance plans; 7 selected Yes, for a majority of ICT leadership and management performance plans; 16 selected Yes, for all or almost all ICT leadership and management performance plans; and 83 selected Unknown.

Figure 13. Response count for inclusion of Section 508 conformance in ICT-related leadership and management performance plans (Q39)

Staff training emerged as a low scoring maturity dimension with only 56 of reporting entities (22%) implementing mandatory Section 508 training for all employees. Of those, a few reporting entities indicated that the required Section 508 awareness training was part of a one-time requirement while the majority of the reporting entities reported the training was required on a regular basis (e.g., annually).

A significant number of reporting entities (114 reporting entities or 46%) reported that Section 508 training is not required for employees. However, 79 reporting entities (32%) indicated the following roles for which Section 508 training was mandatory:

Table 5. Response count for employee roles and responsibilities for mandatory Section 508 Training
Employee Role and Responsibility	Number of Reporting Entities Who Require Section 508 Training for Role
Section 508 Program Managers	58 reporting entities (21%)
Web Content Managers	36 reporting entities (13%)
Developers	19 reporting entities (8%)
Contracting Officer’s Technical Representative (COTR)/Contracting Officer’s Representative (COR)	18 reporting entities (7%)
Contracting Officers	17 reporting entities (7%)
Program Managers	11 reporting entities (4%)
IT Help Desk	9 reporting entities (3%)
Purchase Card Holders	7 reporting entities (3%)
Front Line Support Staff	6 reporting entities (2%)

Additional Training dimension highlights include:

120 reporting entities (48%) reported offering an optional Section 508 awareness training that employees sometimes take, but generally on an ad-hoc basis.
150 reporting entities (60%) indicated they have limited to no capacity to provide ICT accessibility-related training for employees.
109 reporting entities (44%) lack any Section 508 training plan that defines training needs and training curriculum by ICT roles and responsibilities.
167 reporting entities (67%) reported their level of employee training on guidance, templates and tools used to create Section 508 conformant content ranges from none to some training, and generally on an ad hoc basis.

Section 508 Program

Across government, the state of Section 508 Programs also varied. Similar to reporting entity staffing, almost half of respondents (119 reporting entities or 48%) said they have no formal Section 508 Program or equivalent, or their formal Section 508 Program or equivalent is in development (as shown in the bottom two bars in Figure 14).

Figure 14. Response count for status of Section 508 Program or equivalent (Q22)

Almost half of respondents (114 reporting entities or 46%) reported that they do not have a published, detailed Section 508 policy. This is comprised of:

39 reporting entities (16%) who reported a policy does not exist.
30 reporting entities (12%) whose policy is in draft.
31 reporting entities (12%) who have a high-level Section 508/ICT accessibility policy signed but needs to be revised or more detail included.
14 reporting entities (6%) who did not know the status of their Section 508 policy.

A bar graph shows the count of responses for status of reporting entity Section 508 accessibility policy (Q27): 39 respondents selected that Section 508/ICT accessibility policy does not exist; 30 selected that Section 508/ICT accessibility policy in draft; 31 selected that High-level Section 508/ICT accessibility policy signed, but needs to be revised and/or more detail included; 73 selected that Signed, published Section 508/ICT accessibility policy that describes roles and responsibilities agency-wide for implementing and ensuring Section 508 requirements; 62 selected that Signed, published Section 508/ICT accessibility policy is appropriately referenced in other relevant agency policies and is regularly reviewed and updated; and 14 selected Unknown status of Section 508/ICT accessibility policy.

Figure 15. Response count for status of Section 508/ICT accessibility policy (Q27)

Data also shows that there is no correlation with overall Section 508 performance and where the Section 508 program resides within the organization. The majority of the respondents (166 reporting entities or 67%) reported they reside within the CIO Office or equivalent, with the remaining respondents noting the following:

39 respondents selected Other, with several noting a location in communications
30 respondents selected not applicable because there is no established formal program or office to implement and comply with Section 508
5 respondents selected head of agency’s office or equivalent
4 respondents selected General Counsel
3 respondents selected Equal Employment Office or equivalent
2 respondents selected Human Resource / Human Capital Office or equivalent

Conclusion

These findings underscore that resourcing for Section 508 Programs is lacking across government, including a dedicated and resourced Section 508 PM and sufficient staff to perform the work. Reporting entities largely do not mandate any Section 508 training for their employees, either as a one-time training or on a regular basis. They also lack sufficient resources to be able to offer ICT accessibility-related training to employees, including on guidance, templates and tools used to create Section 508 conformant content. Without knowledgeable senior staff to provide leadership and management, alongside appropriate staffing to perform the work, Section 508 compliance suffers.

< Previous Next >

Footnotes

Throughout this Assessment, Section 508 PM and Section 508 Program are used; reporting entities may have an equivalent (same function but a different name). When Section 508 PM/program are used, we also account for reporting entity equivalents, whatever that may be. ↩
Some reporting entities share a Section 508 PM across multiple reporting entities within a Department, leading to a part-time selection and less than full time hours noted. Conversely, some reporting entities noted duplication of Section 508 PM status/hours, leading to a possible overinflation of reporting for this question (Q3). ↩
Regression 3 was illustrated by the equation Q22 = 0.95 + 0.048 (Q3). This relationship was highly statistically significant (***), and <Q3 explained 39% of the variation in Q22. Asterisks refer statistical significance at the following levels: *** 0.01 ≥ p-value; ** 0.05 ≥ p-value; * 0.1 p-value > 0.05. ↩
Regression 4 was illustrated by the equation Q26 = 0.97 + 0.023 (Q3) represented this relationship, which was highly statistically significant (***). Furthermore, Q3 could predict 11% of variation in Q26. Asterisks refer statistical significance at the following levels: *** 0.01 ≥ p-value; ** 0.05 ≥ p-value; * 0.1 p-value > 0.05. ↩
FTEs include both federal and contractor staff directly supporting the reporting entity Section 508 Program. ↩
Reporting entity staff who are responsible for ensuring ICT is Section 508 conformant could be: Contracting Officers, Contracting Officers’ Representatives, Designers, Developers, Testers, IT Project Managers and leadership, Digital content managers, Communications professionals, Instructional designers, and/or Section 508 Program Managers. ↩

Reviewed/Updated: December 2023