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General Information - Government-wide Section 508 Assessment Criteria

Below is a list of the criteria reporting entities must use to evaluate the extent to which the information and communications technology (ICT) of the reporting entity is accessible to and usable by individuals with disabilities.

These questions are broken down into eleven different criteria; one focuses on general information, nine focus on maturity, and one focuses on Section 508 conformance metrics. This is the final list of the questions that your reporting entity will need to submit responses on by July 31,2024.

Reporting entity POCs will receive a link via email to the reporting tool no later than June 1st to submit the information. Feel free to use the following spreadsheet (XLSX) to help you collect the information; however, responses must be submitted using the reporting tool. You may also simply print the criteria questions directly from this page as a guide.

General Information

Questions in this section ask about information and metrics related to the activities of your reporting entity's Section 508 Program (or equivalent) activities.

Question 1

Estimate the number of federal employees onboarded to date within your reporting entity. (*Required)

Select one:

  1. Open response-number
  2. Classified
  3. Unknown

Estimate how many federal employees are currently employed and receiving a paycheck.

Only include federal employees for the reporting entity. Parent agencies should not include other reporting entity federal staff when answering this question.

Exclude contractors from the total number of onboarded federal employees. Only include civilian federal employees (for military reporting entities).

Question 2

Estimate the total number of federal full time equivalents (FTEs) the reporting entity has directly supporting its Section 508 Program or equivalent to date. (Expressed in whole or fraction of numbers of FTEs; e.g., 1.0 FTEs, 2.5 FTEs) (*Required)

Open response-number

Only include the federal employees working directly on the reporting entity’s Section 508 program or where there is formal designation to support the Section 508 program or equivalent.

Do not include contractors in this response.

For example, if the reporting entity has:

  • A Section 508 Program Manager who is full time = 1 FTE for the 508 Program.
  • An administrative assistant who works 50-50 in both Section 508 and Section 504 areas = 0.5 FTE for the 508 Program.
  • An employee who works one day a week on Section 508 training for the 508 Program and the rest of the week on other training for the agency = 0.2 FTE for the 508 program.

Question 3

Estimate the total number of contractor full time equivalents (FTEs) the reporting entity has directly supporting its Section 508 Program or equivalent to date. (Expressed in whole or fraction of numbers of FTEs; e.g., 1.0 FTEs, 2.5 FTEs) (*Required)

Open response-number

Only include the contractors directly supporting the reporting entity’s Section 508 program.

Do not include federal employees in this response.

Question 4

Indicate how many hours per week the Section 508 Program Manager or equivalent is dedicated to supporting the reporting entity's Section 508 Program or equivalent. (*Required)

Select one:

  1. Full time - Section 508 Program Manager works 40 hours per week fully dedicated to supporting the reporting entity's Section 508 Program
  2. Part time - Section 508 Program Manager has additional duties and work less than 40 hours per week supporting the reporting entity's Section 508 Program [insert hours per week dedicated to Section 508 Program *required]
  3. N/A - reporting entity does not have a Section 508 Program Manager or equivalent

Only include the time spent by the 508 Program Manager or equivalent specifically on the Section 508 Program or equivalent. The actual time spent may differ from the estimated time written into a job description or policy.

For example, an individual is hired to be the Section 508 Program Manager as well as the reporting entity’s General IT Support Desk Manager, with a 50-50 time split in their job description. The individual ends up spending 90% of their time on the IT Support Desk because of urgent issues. In this case, select option “b) Part time” and report “4” hours per week for this question.

Question 5

Where does the reporting entity's Section 508 program or equivalent reside? (*Required)

Select one:

  1. Head of reporting entity office or equivalent
  2. CIO Office or equivalent
  3. Equal Employment Office or equivalent
  4. Human Resource or Human Capital Office or equivalent
  5. Communications Office
  6. General Counsel
  7. N/A - reporting entity has not established a formal program or office to implement and comply with Section 508
  8. Other [input text field]

If the reporting entity’s Section 508 program or equivalent is considered “cross-agency” or “multi departmental,” use the department whose budget pays for the 508 Program Manager and their staff, or majority thereof.

Question 6

Indicate how the reporting entity uses its Section 508 program to implement and comply with Section 508. (*Required)

Select Yes or No for a-i

For each of the following, select yes or no (will be shown in table format in reporting tool)
  1. Develops and maintains Section 508 or ICT accessibility policies
  2. Supports efforts to create an accessible and inclusive ICT environment
  3. Coordinates with other responsible staff for Rehabilitation Act compliance including the provision of reasonable accommodations
  4. Ensures ICT activities integrate Section 508 compliance across the IT and acquisition lifecycle
  5. Assists acquisition officials and developers in procuring or building accessible ICT
  6. Manages and coordinates evaluation of ICT for Section 508 conformance
  7. Manages and coordinates Section 508 training
  8. Manages and coordinates creation and review of electronic documents for Section 508 conformance
  9. Manages and coordinates provision of alternative formats

This question is specifically asking about actions and activities performed by the Section 508 program. Do not select an answer if the reporting entity Section 508 program does not perform the task.

Question 7

Estimate the total budget for the reporting entity's Section 508 Program or equivalent in FY24. Round to the nearest thousand (e.g., $345,000). If your budget is classified, please select "Classified" as the response. (*Required)

Select one:

  1. Open response-whole number
  2. Classified Note: OMB will follow up with entities that submit "Classified" to confirm.
  3. Unknown

Note: OMB will follow up with entities that submit “Classified” to confirm.

Please only include budget information for the reporting entity; parent agencies should not include other reporting entity budgets when answering this question. To retrieve budget information, work with the reporting entity Budget Office or Chief Financial Officer Office.

Question 8

Section 508 requires conformance to WCAG 2.0 Level A and AA. Does the reporting entity's accessibility policy include any other accessibility requirements? (*Required)

Select all that apply:

  1. No additional criteria implemented beyond Section 508 (WCAG 2.0 Level A and AA)
  2. All or some WCAG 2.0 Level AAA Criteria
  3. All or some WCAG 2.1 Level A Criteria
  4. All or some WCAG 2.1 Level AA Criteria
  5. All or some WCAG 2.1 Level AAA Criteria
  6. All or some WCAG 2.2 Level A Criteria
  7. All or some WCAG 2.2 Level AA Criteria
  8. All or some WCAG 2.2 Level AAA Criteria
  9. Reporting entity specific standards
  10. Unknown

This question is specifically asking if the reporting entity has implemented additional accessibility standards in policy. If the reporting entity accessibility policy does not include any accessibility requirements beyond Section 508, select “a) No additional criteria implemented beyond Section 508 (WCAG 2.0 Level A and AA).”

Question 9

Which of the following ICT types does the reporting entity evaluate with a Section 508 conformance test process? (*Required)

Select all that apply

  1. Hardware
  2. Software
  3. Mobile applications
  4. Electronic Documents
  5. Kiosks
  6. Web content
  7. None of the above

Only select the ICT type(s) for which the reporting entity uses a Section 508 conformance test process. It is acceptable if the test process used was developed by a vendor or another reporting entity.

Question 10

Is an automated accessibility testing tool(s) for comprehensive, large-scale monitoring of web content used on the reporting entity's web content? (*Required)

Select one:

  1. Yes
  2. No
  3. Unknown

An automated accessibility testing tool is one where the evaluation of Section 508 conformance requirements is determined solely by the tool. The automated tool may be an application the reporting entity developed, purchased from a vendor, or supplied by another government department or reporting entity.

Comprehensive, large-scale monitoring does not include browser plug-ins that only scan a single web page once such as when a user selects to run the manual testing tool such as ANDI.

This question is asking whether any automated accessibility testing tool is used to test reporting entity web content, even if the reporting entity itself does not run, or own a license for, the tool. If a contractor or another reporting entity such as a parent agency performs comprehensive, large-scale monitoring of the reporting entity’s web content, please answer affirmatively.

Question 11

Please select the automated accessibility testing tool(s) used for comprehensive, large-scale web content monitoring. (*Required)

Select all that apply:

  1. accessiBe
  2. Compliance Guardian
  3. Compliance Sheriff
  4. Deque Axe tools (e.g., Axe Auditor or Axe Monitor)
  5. Google Lighthouse
  6. Koa11y
  7. Level Access AMP
  8. Monsido
  9. Pa11y
  10. Pope Tech
  11. Siteimprove
  12. SortSite
  13. WebAIM WAVE
  14. Other [input text response]

NOTE: This question is only required if Question 10 General Information is Yes.

An automated accessibility testing tool assesses Section 508 conformance requirements solely through tool usage, without any human testing.

Comprehensive, large-scale monitoring does not include browser plug-ins that only scan a single web page once (i.e., a user selects to run the manual testing tool such as ANDI.)

Question 12

You indicated the reporting entity's web pages are tested with an automated accessibility testing tool for comprehensive, large-scale monitoring of web content. Have the personnel who use the tool(s) and interpret the results received training on the tool(s)? (*Required)

Select one:

  1. No and no intention to do so
  2. No but training is planned or scheduled
  3. Yes but only some personnel received training
  4. Yes, all personnel received training
  5. Unknown

NOTE: This question is only required if Question 10 General Information is Yes.

This question is interested in automated accessibility testing tools, even if they are only used by contractors to provide information to the reporting entity. If training is only provided to contractors who are the only personnel using the tools, select the appropriate “Yes” answer.

Question 13

Which manual test methodology(ies) does the reporting entity use for manual and/or hybrid Section 508 testing? (*Required)

Select all that apply:

  1. Trusted Tester 5.x
  2. Manual testing with guided developer tools (e.g. Axe DevTools, Siteimprove, Microsoft Accessibility Insights, AMP, etc.)
  3. Reporting entity-specific test methodology
  4. Assistive Technology testing (e.g., screen reader)
  5. Manual code inspection
  6. N/A- reporting entity does not use a manual and/or hybrid testing methodology

A manual or hybrid testing approach involves the evaluation of Section 508 conformance requirements, either entirely or partially, through human testers.

Question 14

Between June 1, 2023 and May 31, 2024, did the reporting entity delay an intern, detailee, or employee start date for 30 calendar days or longer due to lack of ICT interoperability with assistive technology (Section 508, provision 502.1)? (*Required)

Select one:

  1. Yes [# of delays 30 calendar days or longer during the reporting period (*required)]
  2. No [provide explanation (not required)]
  3. Unknown

While an explanation for answering “No” is not required, feel free to note if:

  • An intern, detailee, or new hire who uses assistive technology had no delays due to ICT interoperability, or

  • The reporting entity had no new hires, detailees, or interns, or

  • The reporting entity had no new hires, detailees, or interns who requested assistive technology.

Below are two examples of scenarios where a significant delay was caused by the lack of ICT interoperability with assistive technology:

  • A project team regularly references a knowledge repository that has known accessibility issues, but it is used anyway because no current team members have a disability. The reporting entity realizes a detailee slated to join the team would be unable to perform his work duties due to the inaccessible repository. The reporting entity decides to delay the detailee’s start date for 75 days until the accessibility issues in the repository are remediated.

  • A summer internship program where the protocol is to provide interns with government-furnished (GFE) laptops. A fully qualified intern makes a timely request for the JAWS screen reader to be installed on her GFE laptop. Due to a lack of interoperability, this intern is not able to get JAWS working until 35 calendar days after her peers have begun work because a non-standard GFE laptop configuration must be approved and ordered to support her assistive technology.

Question 15

If inaccessible ICT was discovered during a detailee’s or intern’s service time, was the reporting entity able to remediate the ICT accessibility issues within the service time to allow the detailee or intern to fully participate in projects and opportunities? (*Required)

Select one:

  1. No ICT accessibility issues were identified during a detailee’s or intern’s service time
  2. Accessibility issues were identified and remediated during a detailee’s or intern’s service time
  3. Accessibility issues were identified but were not remediated during a detailee’s or intern’s service time
  4. Unknown
  5. N/A

Question 16

Estimate the total number of Fundamental Alteration Exceptions (36 CFR 1194 E202.6) authorized by the reporting entity between June 1, 2023 and May 31, 2024. (*Required)

Select one:

  1. Open response-whole number
  2. Unknown

In accordance with the Federal Acquisition Regulation (FAR)(39.205), documentation is required for this exception. Section 508 Exceptions are categorized and explained in E202.6 Undue Burden or Fundamental Alteration.

Only count exceptions that have formal documentation. If the reporting entity only has informal exceptions, meaning exceptions for which there is no formal documentation, do not include those in this total.

Question 17

Estimate the total number of Undue Burden Exceptions (36 CFR 1194 E202.6) authorized by the reporting entity between June 1, 2023 and May 31, 2024. (*Required)

Select one:

  1. Open response-whole number
  2. Unknown

In accordance with the Federal Acquisition Regulation (FAR)(39.205), documentation is required for this exception. Section 508 Exceptions are categorized and explained in E202.6 Undue Burden or Fundamental Alteration.

Only count exceptions that have formal documentation. If the reporting entity only has informal exceptions, meaning exceptions for which there is no formal documentation, do not include those in this total.

Question 18

Estimate the total number of Best Meets Exceptions (36 CFR 1194 E202.7) authorized by the reporting entity between June 1, 2023 and May 31, 2024. (*Required)

Select one:

  1. Open response-whole number
  2. Unknown

In accordance with the Federal Acquisition Regulation (FAR) (39.205), documentation is required for this exception. Section 508 Exceptions are categorized and explained in E202.7 Best Meets.

Only count exceptions that have formal documentation. If the reporting entity only has informal exceptions, meaning exceptions for which there is no formal documentation, do not include those in this total.

Question 19

Does the reporting entity have a defined process for reviewing and approving Best Meets Exceptions? (*Required)

Select one:

  1. Yes
  2. No
  3. Unknown
  4. N/A - reporting entity does not procure ICT

A defined process means there is a repeatable framework for reviewing and approving this exception. The Best Meets exception may only be applied to procurement of commercially available ICT. This process may be followed by acquisitions professionals, Section 508 SMEs, or anyone else who has a role in this procurement exception process within the reporting entity.

Question 20

Who has authority to sign off on Best Meets Exceptions? (*Required)

Select all that apply:

  1. Section 508 Program Manager
  2. Contracting Officer's Technical Representative (COTR) or Contracting Officer's Representative (COR)
  3. Contracting Officers
  4. Reporting Entity CIO or designee
  5. Chief Acquisition Officer or designee
  6. Sign off is not required
  7. Other [text input field]

Question 21

Does the reporting entity have a defined process for reviewing and approving Fundamental Alteration and Undue Burden Exceptions? (*Required)

Select one:

  1. Yes
  2. No
  3. Unknown
  4. N/A - reporting entity does not procure ICT

A defined process means there is a repeatable framework for reviewing and approving these exceptions. The Fundamental Alternation and Undue Burden exceptions may be applied to ICT that is developed, used, maintained, or procured. This process may be followed by acquisitions professionals, Section 508 SMEs, or anyone else who has a role in the exceptions process within the reporting entity.

Question 22

Who has authority to sign off on Fundamental Alteration and Undue Burden Exceptions? (*Required)

Select all that apply:

  1. Section 508 Program Manager
  2. Contracting Officer's Technical Representative (COTR) or Contracting Officer's Representative (COR)
  3. Contracting Officers
  4. Reporting Entity CIO or designee
  5. Chief Acquisition Officer or designee
  6. Sign off is not required
  7. Other [text input field]

Sign off includes approval and overruling a previous decision.

Question 23

How does the reporting entity research and evaluate contractors in order to select the most capable of delivering ICT development services that meet applicable Section 508 requirements? Examples of ICT development services include ICT design and development, creation of electronic content, multimedia creation, and facilitation of technology-reliant meetings or conferences. (*Required)

Select all that apply:

  1. Interview potential vendors
  2. Review Past Performances
  3. Review Contractor Capability Statements
  4. Request and review vendor ICT samples for Section 508 conformance
  5. Review of contractor submitted solicitations or equivalent by Section 508 Subject Matter Expert
  6. Other [text input field]
  7. None

This question seeks to understand how reporting entities research and evaluate contractors who provide ICT development services, whether during the market research or evaluation stage of the acquisition process. When buying ICT development services, there may be no upfront ICT products to assess for accessibility. In these cases, the market research should focus on identifying potential vendors with experience and maturity in developing accessible solutions.

Question 24

Indicate how the reporting entity engages users with disabilities. (*Required)

Select all that apply:

  1. Creation of user personas
  2. Defining user needs
  3. Development of Section 508 conformance validation testing processes
  4. Section 508 conformance validation testing
  5. User acceptance testing
  6. Interoperability testing with Assistive Technology
  7. No engagement
  8. Unknown
  9. Other [input text field]

Users with disabilities do not have to be personnel within the reporting entity. For example, interoperability testing with Assistive Technology could be conducted by a firm hired to perform this function.

Engagement broadly refers to how real users contribute input, expertise, or feedback. Answer selection should reflect the reporting entity’s honest assessment of how they engage users with disabilities to inform creation of user personas, defining user needs, etc.

Question 25

Select all employee roles and responsibilities that require mandatory Section 508 training either as a one time requirement or on a repetitive basis. (*Required)

Select all that apply:

  1. Required for All Employees
  2. Section 508 Program Manager
  3. Program Managers
  4. Contracting Officer's Technical Representative (COTR) or Contracting Officer's Representative (COR)
  5. Contracting Officers
  6. Purchase Card Holders
  7. Developers
  8. Document Authors
  9. Web Content Managers
  10. IT Help Desk
  11. Front line Support Staff
  12. Not Required for Employees
  13. Other [input text field]
  14. Unknown

Section 508 training may cover a range of topics pertinent to the employee roles and responsibilities listed here, for example:

  • acquisitions,
  • internal development,
  • electronic documents accessibility,
  • accessibility testing, and
  • other training that provides specific direction on how to incorporate accessibility considerations into processes, policies, or procedures.

NOTE: This question is not asking which particular topics are covered in Section 508 training.

Question 26

Indicate what measures are taken by the reporting entity to ensure content generation and other collaborative activities (e.g., draft documents, presentations, wireframes, and other non-agency official communication) allow colleagues with disabilities to fully participate. (*Required)

Select all that apply:

  1. Fosters a culture of "accessible by default"
  2. Specifically targets training for teams with known employees with disabilities
  3. Internal communication highlights the importance of accessibility for all electronic content
  4. Includes accessible content generation and other collaborative activities in policies, processes, or procedures
  5. Implements accessible templates for content creation
  6. Unknown
  7. Other [input text field]
  8. No measures taken

This question aims to understand how reporting entities handle the accessibility of electronic content generation such as draft or working electronic documents, other collaborative electronic activities amongst colleagues, and electronic content that is not considered Agency Official Communication. This may involve considerations from Section 501, Section 504, and Section 508 to ensure colleagues with disabilities can fully participate. Please note that this question is not asking about final content.

Question 27

What are the reporting entity's primary challenges in implementing and complying with Section 508? (*Required)

Select all that apply:

  1. Lack of support from management
  2. Lack of staffing resources
  3. Weak Section 508 policy or procedure
  4. Lack of general awareness
  5. Lack of or inadequate training
  6. Lack of or inadequate authoring, development, or testing tools
  7. Lack of or inadequate considerations at the early stage of the ICT life cycle management process
  8. Lack of or inadequate knowledge by acquisition officials
  9. Lack of or inadequate knowledge by web content managers
  10. Lack of or inadequate knowledge by developers
  11. Lack of or inadequate knowledge by vendors
  12. Poor quality of vendor’s ACRs
  13. Section 508 is not prioritized
  14. Platform choices are not evaluated for Section 508 conformance
  15. Lack of Section 508 conformant options available on the market
  16. Vendor misrepresenting accessibility of product
  17. Lack of funding or budget
  18. Other [input text field]
  19. None

Question 28

Of the following options, select (up to) the top five items that would be the most helpful in implementing Section 508 in the reporting entity. (*Required)

Select five:

  1. Additional funding to aid Section 508 implementation
  2. More ICT accessibility subject matter experts
  3. More staff adequately trained to implement Section 508 requirements
  4. Stronger Section 508 policies or procedures
  5. Stronger Section 508 awareness across the reporting entity
  6. Stronger Leadership support
  7. Increased implementation of established policies or procedures
  8. Better access to tools necessary to create accessible digital content
  9. Better access to ICT testing tools
  10. More government-wide ICT testing guidance
  11. Better guidance for buying or selecting accessible ICT
  12. More accountability for Section 508 implementation across the technology development lifecycle
  13. Industry awareness and generation of Section 508 conformant ICT
  14. Inter-agency Section 508 shared services
  15. Access to Section 508 training
  16. Stronger action or enforcement of accessibility violations for vendors
  17. Other [text input field]
  18. None

Reviewed/Updated: June 2024

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