Governmentwide Findings: Section 508 Program and Staff Analysis Summary

Section 508 Program Managers (PM)

As shown in Figure 10, 33% of reporting entities reported a full-time Section 508 PM or equivalent, improving from 28% in FY23. Only 11% of respondents reported no Section 508 PM or equivalent, down from 21% in FY23.

On average, Section 508 PMs across government spent 17.9 hours per week on Section 508, improving from 15.4 hours in FY23 and resulting in a 16.2% increase in time spent by Section 508 PMs (WSRT: extremely statistically significant).

Figure 10. Comparison of governmentwide Section 508 PM or equivalent utilization (Q4)

Although there has been a reported rise in staffing and utilization for Section 508 PMs, further efforts are needed to clearly define the roles and responsibilities associated with this position. One recommendation from the FY23 Assessment was to ensure sufficient Section 508 PM utilization that includes authority that is proportionate for the Section 508 program. When entities were asked about the status of the reporting entity’s Section 508 PM or equivalent position, varying responses showed about one-third of all reporting entities or 76 respondents lacked any formal Section 508 PM to perform digital accessibility duties. However, entities showed a small, meaningful increase (WRST: extremely statistically significant), with well over half of all entities now having a Section 508 PM with clearly defined roles, responsibilities, and Section 508-aligned performance measures.²¹ Additional results show:

• 65 entities or 26.7% reported no formal position or duties assigned to perform the Section 508 PM role.

• 11 entities or 4.5% reported the Section 508 PM has clearly defined roles and responsibilities but no personnel are currently performing the duties.

• 96 entities or 39.3% reported that the Section 508 PM is currently staffed with clearly defined roles and aligned performance measures.

• 32 entities or 13.1% reported the Section 508 PM is currently staffed with clearly defined roles and meets or exceeds aligned performance measures and has sufficient authority.

• 40 entities or 16.4% reported the Section 508 PM is currently staffed with clearly defined roles and meets or exceeds aligned performance measures and has sufficient authority and uses feedback loops to continually make program improvements.²²

Table 9 depicts the average hours per week Section 508 PMs dedicate to their Section 508 Program, by maturity bracket, with a comparison to FY23. This continues to show that as maturity increases so does the average number of hours per week a Section 508 PM dedicated to the Section 508 Program; or vice versa, the more time a Section 508 PM dedicates to their program, the more mature the program. For the Very High and High Maturity brackets, we see a decrease in overall hours per week but we see an average increase for the Very Low, Low and Moderate maturity. ²³

The FY23 Assessment recommended agencies ensure sufficient Section 508 PM utilization because the greater the utilization of the Section 508 PM, generally the better the reporting entity’s conformance outcomes. Although some progress has been made and respondents are starting to prioritize Section 508 Program Managers more effectively, there is still work to be done.

Section 508 Full Time Equivalents (FTEs)

While some entities reported increasing Section 508 staffing and contractor resources over the past year, many entities noted that resourcing as a whole was – and remains – a challenge. Reporting entities continue to report varying levels of Section 508 FTEs but entities overall reported slightly more FTEs on average compared to FY23. The data shows:

• In FY24, 75 reporting entities reported less than one Section 508 FTE, which is a 19% improvement since FY23. Only 19 entities reported no FTEs, which is a 47% improvement since FY23.

• Governmentwide, the FY24 average number of Section 508 FTEs was at 5.5 compared to 4.3 in FY23, comprising an average of 3.7 federal Section 508 FTEs versus 2.7 in FY23 and 1.8 contractor Section 508 FTEs versus 1.6 in FY23.²⁴

Figure 11. Average reporting entity FTE by maturity bracket.

As Figure 11 shows, there is a positive correlation between the total number of FTEs and the maturity outcomes for that reporting entity. More well-resourced organizations tend to be more mature with respect to accessibility considerations across the business landscape. The reverse is also true: less mature organizations tend to be those that are not well resourced.

Figure 12. Average reporting entity FTE by conformance bracket.

Similar to maturity, as shown in Figure 12, FTE by conformance shows a positive relationship between the number of resources and the conformance outcomes. However, as opposed to maturity, the relationship between FTEs and conformance outcomes is slight. In fact, although there is a positive trend, Low and Moderate performing entities reported slightly more FTEs on average than High or Very High performing entities.

Section 508 Competencies, Leadership, and Management

In the Assessment, FTE only factors in Section 508 FTEs directly supporting the reporting entity Section 508 Program. While many entities have Section 508 Subject Matter Experts (SMEs) embedded throughout the entire lifecycle – from business requirements development to deployment and operations and maintenance – being able to reliably estimate all personnel who perform digital accessibility-related activities is challenging, if not impossible. We expect the overall number of FTEs who perform digital accessibility-related activities throughout the reporting entity is much higher than the above count reflects. To address this, several questions emphasized the key competencies of all staff involved in ICT conformance. Like last year, leadership participation was seen to be a hindrance to implementation of accessibility efforts across the enterprise. As leadership engagement is key to advancing accessibility, entities should continue to work to promote accessibility as a priority.

Data shows a 60% increase YOY in the number of entities who indicated they include Section 508 conformance in ICT-related leadership and management performance plans, with 26% of respondents selecting this option in FY23 and 42% of respondents or 104 entities selecting this in FY24. This indicates a small, meaningful increase (WRST: extremely statistically significant) YOY to include Section 508 conformance in ICT-related leadership and management performance plans, with half of the reporting entities now indicating a timetable to begin its implementation. In FY24, 32% of respondents or 78 entities reported not including Section 508 compliance in any ICT-related leadership and management performance plans, which is a decrease from 40% overall in FY23. Additionally, 19% of respondents or 47 of those entities noted they have no plans to do so, down from 27% in FY23, showing a 30% decrease YOY. Figure 13 below depicts the further breakdown of responses in comparison to FY23, showing an overall increase in the number of entities who responded affirmatively to inclusion of Section 508 in ICT-related management performance plans.

Although the Human Capital, Culture, and Leadership Dimension improved from 1.63 in FY23 to 1.93 in FY24 – about an 18% increase YOY across the government – there is still room for improvement. This remains one of the lowest performing dimensions. In fact, in FY24, it is the lowest dimension. While improvements were reported, digital accessibility remains deprioritized for some reporting entities.

Figure 13. YOY response count for inclusion of Section 508 conformance in ICT-related leadership and management performance plans (Q44).

Other digital accessibility competency, skills, and knowledge response highlights include:

• Entities noted substantially improving how often ICT accessibility skills and capabilities are integrated into competency and professional development planning for staff who are responsible for ensuring ICT is accessible. There was a 79% improvement YOY in the number of entities who said they do not integrate ICT accessibility into professional development plans, with 13.5% of respondents or 33 entities in FY24 selecting this response compared to 63% in FY23.

• 35% of respondents or 86 entities in FY24 noted regularly, frequently, or almost always integrating ICT accessibility skills and capabilities into competency and professional development planning for staff responsible for accessible ICT.

• In FY24, 40% of entities 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, compared to 50% in FY23, resulting in a 20% decrease YOY. However, in FY24, 32 of those reporting entities said they have no knowledgeable staff compared to 17 entities in FY23, resulting in an 88% increase YOY.

• In FY23, 64% of entities reported they had no or only some development and testing professionals trained in Section 508 web testing. There is a slight improvement in FY24, with 60% of respondents or 146 entities still saying they have no or only some development and testing professionals trained in Section 508 web testing. This high percentage may suggest that staff responsible for ICT conformance testing may not have sufficient skills nor training to accurately test for Section 508 requirements.

• Only 22% of entities reported they require specific training curriculum or certification in Section 508 web testing for accessibility web testers.

Staff Training

Training was the lowest performing dimension last year and informed a FY23 Assessment recommendation that agencies should require mandatory annual Section 508 training for specific roles and responsibilities. In FY24, training is the second lowest dimension, however entities noted increased investments in training over the last year, which is reflected in this year’s data. Last year, only 22% of entities implemented a mandatory Section 508 training for all employees. In FY24, 34% of entities reported requiring a Section 508 training for employees, with the majority of those requiring training on a regular basis such as annually, leading to a 51% increase YOY.

Mandatory Section 508 training by roles and responsibilities substantially increased YOY, with all roles and responsibilities noting an increase in mandatory Section 508 training and 68% fewer entities reporting Section 508 training is not required for employees. The largest increase in required mandatory Section 508 training was for purchase card holders and front line staff, both of which increased 300% YOY. Table 10 further details the response count YOY for employee roles and responsibilities with mandatory Section 508 training.

Additionally, M-24-08 stated, “[a]gencies should develop an accessibility training plan that identifies appropriate training requirements for specific staff and the frequency at which it must be completed to maintain understanding of and the ability to apply Section 508 standards.” Last year, 44% of entities lacked any Section 508 training plan. In FY24, this number decreased by 17%, with 37% of respondents or 91 entities selecting they have no Section 508 training plan defined, representing a small, meaningful change (WRST: extremely statistically significant). Additionally, for FY24, 23% of entities reported that their training plan identifies training needs and training curriculum for most or almost all ICT roles and responsibilities.

Additional FY24 training highlights include: Only 39 entities or 16% report no Section 508 training is offered. 91 entities or 37% reported that an optional Section 508 training is offered that employees sometimes take. 53 entities or 22% responded that they never offer ICT accessibility-related training to employees, including training on guidance, templates, and tools for creating accessible content. 74 entities or 30% responded that they offer ICT accessibility-related training to employees, including training on guidance, templates, and tools for creating accessible content 7 or more times a year. 78 entities or 32% indicated they distribute communication with employees and contractors about digital accessibility approximately 6 or more times a year, with 109 entities or 44% selecting they distribute communication no more than 2 times a year.²⁵

Reporting entities have made substantial progress in enhancing the training, responsibilities, and capabilities of staff supporting Section 508 compliance. However, there is still room for improvement. Although the Human Capital, Culture, and Leadership Dimension improved from 1.63 in FY23 to 1.93 in FY24 – about an 18% increase YOY across the government – it remains one of the lowest performing dimensions. In fact, in FY24 it is the lowest dimension.

Following a FY23 Assessment recommendation for agencies to require mandatory annual Section 508 training for specific roles and responsibilities, entities invested significantly in training. Entities reported a 51% increase in mandatory Section 508 training adoption and notable growth in role-specific requirements, especially for purchase card holders and front-line staff – both of which saw a 300% increase. Another FY23 recommendation suggested agencies should ensure sufficient Section 508 Program Manager utilization. Although reporting entities improved staffing of the Section 508 PM, about one-third of entities still reported lacking formal Section 508 PM staffing. Additionally, there was an improvement in efforts to incorporate ICT accessibility skills into professional development, with only 13.5% of entities excluding these skills from planning in FY24, down from 63% in FY23. Together, these advancements signal an increased awareness of the demand for skilled Section 508 staffing and the need for investment in ongoing training and professional development. Continued efforts to prioritize digital accessibility will also ensure downstream impacts on more conformant ICT.

Reviewed/Updated: December 2024