Recent GSA Efforts to Support Section 508 Compliance

The following describes GSA’s efforts to help entities collect and submit their Assessment data and related efforts to improve federal digital accessibility from December 29, 2023, to December 29, 2024.

Governmentwide Assessment-Related Actions

• OMB – in close coordination with GSA, the Access Board, and OSTP – refined the assessment criteria from FY23 to reduce technical assistance, improve terminology, question comprehension, data quality, and insights into reporting entity accessibility maturity and overall conformance. GSA actions included:

• Incorporating feedback on the criteria.

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

• Removing questions that did not derive much value.

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

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

• In tandem, GSA gathered feedback from federal Section 508 Program Managers (PMs) and assessment points of contact (POC) to refine context for understanding the assessment criteria, frequently asked questions, and definitions of terms to help reporting entities collect more accurate data.

• GSA also implemented improvements in the following related areas:

  • Office Hours: In collaboration with the Access Board, GSA hosted 11 office hours meetings between April and August to offer additional guidance to reporting entities preparing reports for this assessment.

  • Submission Tool Training: GSA responded to feedback from the assessment team regarding data validity and consistency issues. Recognizing the same submission tool would be used for FY24, GSA conducted three submission tool training sessions for assessment points of contact. This training aimed to improve data quality, reduce the need for office hours and technical assistance, and enhance the overall customer experience.

  • Independent Testing: GSA developed a framework for conducting limited independent testing of agency public websites and electronic documents. This framework enables the assessment team to validate reported data through “spot checks,” ensuring more consistent and reliable data for the Assessment. Independent testing will not replace reporting entity submitted data, but will be used in tandem with submitted data to inform data validation. The scope of independence testing will be dependent on resourcing in FY25.

Key Performance Indicators

In the beginning of FY25, GSA created a list of key performance indicators (KPIs) to help agencies create measurable targets for improving the maturity and conformance outcomes of their Section 508 Programs or equivalents. These indicators, once implemented, will serve as strategic specific, measurable, achievable, relevant and time-bound (SMART) goals for agencies to track progress across the enterprise with respect to accessibility considerations. These KPIs broadly cover business functions with the intent that agencies select which KPI to employ based on their current situation (i.e., overall maturity, testing capability, conformance outcomes, etc.). Not all KPIs will apply to all agencies, but all agencies should be able to take a few KPIs to help measure and track their progress.³⁷ See Table 13 below for a sample of these KPIs and visit Organizational IT Accessibility Key Performance Indicators (KPI) for the complete list.

Table 13: Sample KPIs

KPI Short Name	Draft KPI	Aligned Dimension
Role-Based Training	Content Creation: By Q3 FY27, 100% of the web content managers have completed the required, relevant Section 508 training. Developers: By Q4 FY26, 50% of agency designers, developers and testers have completed assigned Section 508 training.	General Information
PM Role Creation	By Q2 FY26, create a formal Section 508 Program Manager role and hire a qualified individual within 6 months of establishment.	IT Accessibility Program Office
Complaints Response Time	In FY26, respond to and resolve 75% of complaints within 60 calendar days.	Policies, Procedures, and Practices
Disability Group Engagement	In FY26, conduct outreach to at least three of disability-related affinity groups to garner feedback and incorporate into agency policies, process and standard procedures.	Human Capital, Culture, and Leadership
Automated Document testing	In FY26, conduct outreach to at least three of disability-related affinity groups to garner feedback and incorporate into agency policies, process and standard procedures.	Testing and Validation
Automated and Manual Web Page Testing	By Q4 FY24, test 15% of internet web pages using automated and manual testing.	Conformance Metrics

GSA Actions to Support Implementation of M-24-08:

• In consultation with the Access Board, GSA explored options for establishing a standardized accessibility conformance reporting (ACR) process for government procurement of ICT, including a central repository of vendor accessibility conformance reports.

  • In coordination with the Federal Chief Information Officers Council (CIOC) Accessibility Community of Practice (ACOP) leadership, the Access Board and GSA led the creation of “Basic Accessibility Conformance Report (ACR) Evaluation and User Guidance” to assist federal agencies and improve Section 508 implementation procedures for the procurement of ICT. This guidance presents a framework on how to obtain and evaluate ACRs. Following the completion of the guidance, they conducted multiple briefings to key stakeholder federal councils, including the CIO Council.

• During FY24 and moving forward into FY25, GSA has advised the Federal Acquisition Service (FAS) to help agencies acquire products and services related to the accessibility of ICT. FAS, with the support of GSA, has also explored solutions that enable Digital Accessibility as a Service, such as consulting, testing, training, and remediation. This would allow for smaller agencies to access accessibility tools and services through a newly established accessibility services purchasing schedule.

• With the Access Board and the Office of Personnel Management (OPM), GSA reviewed existing certifications to determine the potential use as a Section 508 professional certification programs for Section 508 PMs, identified opportunities to establish a professional Section 508 PM certification program with three tiers of trainings, and aligned where commercial certifications may be used to further Section 508 PM training and capabilities as part of the Section 508 PM certification.

• In consultation with the Access Board, GSA explored establishing a federal digital accessibility design and testing lab staffed with accessibility specialists who perform automated and manual testing and assessments of agency ICT, as well as provide user research and usability testing related to ICT accessibility.

Policy and Best Practices

• GSA regularly maintains and improves this web site, Section508.gov, as the central body of role-based information to help federal agencies incorporate accessibility into mission and IT-lifecycle activities. This governmentwide hub provides robust content, tools, best practices, and training to all stakeholders in ICT accessibility. Selected content focuses on:

  • Policy, Management, and General Information

  • Acquisition

  • Content Creation

  • Design and Development

  • ICT Accessibility Testing 

  • Training, Tools, and Accessibility Events 

  • Agency Section 508 PM List

  Specific updates include:

  • Best practices for creating and updating accessibility statements including examples

  • Best practices for establishing and maintaining a public feedback mechanism

  • Best practices for establishing and maintaining a formal Section 508 complaint process

  • Common PDF Tags and Their Usage

  • Considerations for Publishing a Page to the Web

  • Creating Accessible Email Messages

  • Designing Digital Content for Users With Cognitive Disabilities

• GSA conducted a “High Achiever Study’’ to enhance the Technology Accessibility Playbook, which is currently published on Section508.gov. GSA interviewed high-performing agencies on their FY23 Assessment responses to provide insights into how agencies may improve accessibility within their program. GSA is developing an addition to the playbook to create a model program. This addition will also include tools, templates, and other artifacts to assist agencies with implementing the plays from the playbook.

Strategic Engagement

• At the 2023 Government Information Technology Executive Council (GITEC) Emerging Technology Conference, the Advanced Technology Academic Research Center (ATARC) awarded the GSA Government-wide IT Accessibility Program in the category of Promoting Diversity, Equity, Inclusion, and Accessibility (DEIA) in the federal workforce. This award recognized the program for its exceptional leadership in addressing DEIA challenges, partnership with federal and outside organizations, and transformative impact on IT accessibility across the federal government.

• GSA participated in key government and external forums for ICT accessibility, including:

  • Hosting the FY24 Interagency Accessibility Forum (IAAF), a venue for federal accessibility professionals, developers, designers, project managers, leadership and many others to exchange best practices in managing and implementing digital accessibility imperatives including Section 508 of the Rehabilitation Act. GSA did this in partnership with other federal agencies with sponsorship by the CIOC ACOP.

  • In collaboration with the Access Board, presenting at the 2024 California State University, Northridge (CSUN) Assistive Technology Conference on the Section 508 ICT Testing Baseline Portfolio, OpenACR and the Future of Accessibility Conformance Reporting, the analytical approach to the Assessment, and an introduction to the ART, from March 19 to 21, 2024.

  • At the Government Innovation Exchange, participating in two panel discussions:

    • “CX in Government: Defining Digital Strategies,” which covered best practices for enhancing customer experience (CX) beyond 2024, shared insights from implementing CX initiatives, and highlighted the importance of accessibility for all citizens.

    • “The Way Forward for Government IT: Anticipating Future Considerations for Federal and State IT,” which explored technological factors, drew insights from the past five years of IT experiences, and addressed emerging threats.

  • At Government DX, participating in the fireside chat, “Accessing Accessibility: Going Beyond Section 508 Compliance in Digital Service Delivery,” in which they discussed how leaders can leverage accessibility and usability testing and the U.S. Web Design System to ensure equitable access.

  • To celebrate Global Accessibility Awareness Day, participating in a Digital Services Coalition panel event entitled Beyond Compliance: Building Inclusive Digital Experiences that focused on how to advance accessible digital services for all citizens.

  • Participating in the 2024 Defense Contract Management Agency (DCMA) Section 508 Fielding Awareness Conference on procurement tools. 

  • At the 2024 Equal Employment Opportunity Commission (EEOC) EXCEL Training Conference, providing an overview of the FY23 Governmentwide Section 508 Assessment to highlight relevance to employment law and noted resources available to Section508.gov to help organizations improve management and implementation of digital accessibility imperatives.

  • At the 2024 M-Enabling Summit, participating in three panel discussions related to the Annual Assessment, Standardizing the Federal Accessibility Conformance Reporting Process, and the New Rule for State and Local Government Web Content and Mobile Application Accessibility

• GSA conducted presentations to the governments of Canada and the United Kingdom and multiple federal agencies on the development and use of the IT Accessibility Policy Framework to improve incorporation of accessibility requirements throughout relevant organizational policies. 

• GSA created and launched the following two regularly distributed publications:

  • The bimonthly Digital Accessibility Newsletter, which shares announcements, news, online resource updates, and upcoming events designed to help digital accessibility practitioners improve the accessibility of the information, communications, and technology created for federal employees and the public.

  • The monthly Accessibility Bytes, which provides quick tips for digital accessibility practitioners to enhance the accessibility of the information, communications, and technology they create for federal employees and the public.

• GSA leads regular, recurring governmentwide meetings for collaboration, training and knowledge sharing of accessibility information and considerations. This includes:

  • Section 508 and IT Accessibility Community of Practice (SEC508ITAC CoP) meetings and email listserv of over 1,240 subscribers that facilitate collaboration and resource sharing across federal, state, and local governments, as well as with academia who are focused on building better digital experience in government. SEC508ITAC is one of 30 CoPs available at Digital.gov/communities.

  • Bimonthly Section 508 Program Manager Huddle, with support from the Access Board, provides federal Section 508 PMs an open, agenda-free forum to discuss and collaborate on building and maintaining effective Section 508 programs.

  • Bimonthly IT Accessibility Community Meetings provide information and guidance on Section 508 implementation to federal accessibility professionals, practitioners, and members of the SEC508ITAC. GSA conducted general awareness and “how-to” training sessions during the IT Accessibility Community Meetings that also included input and presentations from members of the community. 

• As GSA developed and conducted the Assessment, it also led the below engagements to improve digital accessibility within the past year:

  • In December 2023, GSA presented the FY23 Governmentwide Section 508 Assessment to the Federal Chief Information Officers Council and led discussion on strategies to improve digital accessibility.

  • In January 2024, GSA presented twice on the FY23 Governmentwide Section 508 Assessment, once in collaboration with the Access Board for the Section 508 webinar series run by the Accessibility Community of Practice and once at a public Access Board meeting with 474 attendees.

• GSA also presented to numerous other departments, agencies, and stakeholder councils on the outcomes of the FY23 Assessment. 

Technical Assistance, Tools, and Training

• GSA continued the following enhancements to two primary accessibility requirements acquisition tools: the Solicitations Review Tool (SRT) and the Accessibility Requirements Tool (ART):

  • Improvements to ART include adding additional ICT options, adding a delete button, allowing the user to modify inputs, improving the screen reader capabilities, and updating the flow to enhance user experience. New training videos were developed and posted on Section508.gov to help users understand how to use ART.  

  • The ART Application Programming Interface (ART-API) was developed as a solution for ART to integrate with other applications to provide the appropriate Section 508 language. It is highly customizable and can be adapted for any application. This is currently in the pilot phase.

  • Improvements to SRT include adding in GSA eBuy Open data, increasing the amount of data processing five-fold, and updating the user interface for an enhanced user experience.

  • GSA provided training to four federal agencies on the ART tool to facilitate their incorporation into procurement and contracting documentation. 

• GSA’s ACR Editor, which provides a web-based user interface for producing a machine-readable ACR, was migrated to Section508.gov to make it easier to find and navigate within the Section508.gov subdomain.

• The ICT Testing Baseline for Web standardizes and enhances web accessibility conformance tests across the federal government. Agencies now use this baseline as the foundation for evaluating relevant products for Section 508 conformance. In collaboration with strategic partners the Department of Homeland Security, Social Security Administration, Office of Personnel Management, and the Access Board, GSA has continued to develop and extend the ICT Baseline Portfolio: 

  • The Section 508 ICT Testing Baseline for Web version 3.1 was published. Notable changes include:

    • Image tests now rely more heavily on the author’s determination of meaningful or decorative images.

    • A new test covers Web Content Accessibility Guidelines (WCAG) Success Criterion 4.1.2 for user controls to improve accuracy.

    • The baseline incorporates WCAG 2.2 “Understanding” articles.

    • A single page view now contains all baseline tests.

  • In September 2024, the Section 508 ICT Testing Baseline for Electronic Documents version 1 was published. This new baseline utilizes the framework of the Baseline for Web with the goal of improving accessibility compliance for electronic documents. The Federal Accessible Electronic Documents Community of Practice (AED COP) and Baseline for Documents Technical Advisory Committee authored this baseline. Like the ICT Testing Baseline for Web, the ICT Testing Baseline for Electronic Documents is agnostic regarding testing tools. Each baseline test identifies the accessibility requirement being tested, the document content subject to evaluation, and step-by-step instructions for determining test outcomes. Agencies can employ any tools that align with this baseline to ensure consistent and reliable testing outcomes.

  • GSA continued to lead the development of the ICT Baseline Alignment Framework. Throughout FY24, GSA expanded test cases for the ICT Baseline for Web, further enhancing accessibility evaluation practices.

• GSA continued OpenACR Repository development, which will facilitate easier integration of accessibility conformance considerations in federal ICT acquisitions through a centralized, publicly-facing, and searchable repository of ACRs. GSA began developing the OpenACR Editor, which included determining business and technical requirements, back-end and user interface development, and an application programming interface (API).

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Reviewed/Updated: December 2024