Upcoming GSA Efforts to Support Section 508 Compliance

Governmentwide Accessibility Assessment Related Actions

GSA plans to do the following before and during the FY24 Assessment to hone criteria and address specific areas of improvement noted in feedback from reporting entities:

• Submission Tool Training: Given feedback the assessment team has received, observed issues with data validity and consistency, and the fact that the same tool will likely be used next year for submission, GSA will create and conduct submission tool training that all POCs can take and reference prior to responding. This will hopefully lead to better and more consistent data, less need for office hours and technical assistance, and an improved customer experience.³⁴

• Criteria Revision: GSA, in collaboration with the Access Board and OMB, will reassess and hone the Assessment criteria in order to reduce technical assistance, improve terminology, question comprehension, data quality, and insights into reporting entity accessibility maturity and overall conformance. Actions include:

  • Incorporate feedback on the criteria.

  • Include questions that will increase insight into governmentwide accessibility, such as expansion of hardware and software questions.

  • Remove questions that did not derive much value.

  • Consider asking specific questions cyclically instead of asking every question every year.

  • Develop trend-based assumptions, hypotheses, and questions to enable evaluation.

• Key Performance Indicators (KPI) Development: Creating optional KPIs will help reporting entities produce better benchmarks .

• Independent Testing: Create a framework to conduct limited independent testing of agency public websites and electronic documents. This will allow the assessment team to validate reported data through “spot checks” and promote more consistent data for the Assessment.

Policy and Best Practices

• Section508.gov is the primary resource for agencies to successfully manage and implement Section 508 requirements, including multiple citations within Federal Acquisition Regulation (FAR). GSA identifies and fills content gaps and stakeholder needs on Section508.gov through continuous analysis and outreach.³⁵

• In coordination with the ACOP, GSA plans to post best practices on how to obtain and evaluate ACRs to facilitate Section 508-conformant ICT procurements in the federal marketplace.

• Traditional ACRs have been the standard tool for documenting and verifying the accessibility of digital products, and most product vendors use the Voluntary Product Accessibility Template (VPAT)® to create an ACR. However, the static nature of these reports, often presented in Microsoft Word or PDF document formats, has posed challenges in real-time evaluation and comparison. GSA has led the development of OpenACR, a machine-readable ACR that hosts a description of the format and data schema and provides user instructions. GSA intends to provide recommendations to OMB around further development and adoption of this vital acquisition tool and encourage OpenACR Adoption. GSA will begin a more comprehensive promotion of this new tool that:

  • Allows users to easily share acquisition and product information.

  • Promotes repeatability of requirements gathering and solicitations in general.

  • Eases the burden of market research and ambiguity around product accessibility.

Strategic Engagement

• GSA will continue to lead the Interagency Accessibility Forum (IAAF) in FY24 and bimonthly Accessibility Community meetings.

• GSA will explore other opportunities to bring respondents of the Governmentwide Accessibility Assessment together for knowledge sharing, and to facilitate beneficial conversations to help agencies increase compliance.

• GSA will continue to submit presentations to leading conferences, such as the annual CSUN accessibility conference, Code for America, the M-Enabling Summit, ICT Testing Symposium, and DHS Accessibility Day.

• GSA will conduct other governmentwide and external engagements with federal partners and industry, as well as continue collaboration with the Access Board’s Section 508 Best Practices webinar series.

Technical Assistance, Tools, and Training

• In conjunction with promotion of the OpenACR Editor, GSA is developing the OpenACR Index – a central index of completed, vendor-provided machine readable ACRs. This tool will allow product vendors to list their product ACRs with other product-identifying information. Product buyers and users will be able to search, share, and compare product ACRs across government for repeatability, cost effectiveness, efficiency and ease of use, among other benefits. The OpenACR Index will also provide an API to make it easier for digital marketplaces – both within government and in the commercial marketplace – to obtain product accessibility information and display it alongside product descriptions and specifications. GSA expects to release the minimum viable product version within FY24.

• GSA will continue to lead the development of two primary accessibility requirements acquisition tools: the Solicitations Review Tool (SRT) and the Accessibility Requirements Tool (ART). This also includes software and usability updates as well as continuing the current plan of integration of the two tools. ART and SRT will allow users to determine which accessibility requirements should be included in solicitation documents (ART) and use a machine learning AI tool to review solicitations to ensure all applicable accessibility requirements are included (SRT).³⁶

• The ICT Testing Baseline for Web provides an approach to standardize and improve web accessibility conformance tests throughout the federal government. Agencies may use the web baseline as the foundation of their test methodology to evaluate relevant products for Section 508 conformance.

  The Access Board, in coordination with GSA and strategic partners, including DHS, SSA, and OPM, will continue to develop the ICT Baseline Portfolio – a collection of individual Baselines to cover specific ICT, current plans include electronic documents, software, hardware. Key revisions to the ICT Baseline for Web are expected to be published in FY24. Additionally, the ICT Baseline for Electronic Documents will allow agencies and users to ensure their review processes provide standard, accurate and trustworthy outputs. It is currently in final review and is expected to be published in FY24.

  GSA is leading the effort on the ICT Baseline Alignment Framework, which are test cases and instructions for aligning agency test processes to the ICT Baseline for Web. Expanded test cases for the ICT Baseline for Web will deploy throughout FY24.

• GSA intends to socialize the current draft of the Section 508 Program Manager Certification and gather feedback. The certification will provide development and training for agency Section 508 PMs as they transition into their role. If given the directive, GSA will also assist OPM in developing a process to identify qualified 508 PMs. This process could include several artifacts such as a skills list and assessment, pre-qualifications, and a targeted position description.

• In FY24, GSA intends to create new training courses while updating and modernizing several existing training courses. Depending on resource availability, GSA will also consider providing targeted live-training sessions for agencies and employees to help agencies bridge training gaps. These events would be in addition to the ongoing bimonthly Accessibility Community meetings that GSA facilitates. The needs and requests of the agencies, as well as feedback and outputs of the FY23 Assessment, would determine the training focus.

• GSA will continue to brief agencies on the Accessibility Policy Framework, revise the framework based on agency and other stakeholder feedback, and recruit potential agencies to help pilot the Assessment at their agency.

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Reviewed/Updated: December 2023