It is clear that the current practices for digital accessibility are not working. The Department of Justice and the General Services Administration Section 508 Report to Congress and the President confirms this. From this we know that in the last decade, agencies have not made measurable progress toward Section 508.
“Current guidance does not stipulate testing methods nor sampling approaches, which decreases our confidence and ability to draw conclusions about government-wide accessibility performance,” the report stated.
Digital inclusion efforts in the federal government have not kept up with our digital society. Many countries are doing a better job of serving all of their citizens. Fortunately, there are global best practices that can be applied from outside the federal government. We aren’t going to have accessible customer experiences by scaling up decades-old government practices.
As an alternative, I would suggest that the Office of Management and Budget embrace the following strategic objectives.
OMB should adopt automated governmentwide accessibility monitoring much like the EU and the UK are doing. The EU’s Web Accessibility Directive required member states to implement accessibility monitoring. EU countries also must implement regular and detailed public reporting. The first set of reports was recently published.
Key results for OMB evaluations:
Conduct mandatory public annual agency level reporting. This should include access to the raw data for public sites (full automated test results, barriers reported by people with disabilities, accessibility conformance reports and results of 3rd party audits). The agency report should include information on publishing tools. Reporting should cover progress toward Authoring Tool Accessibility Guidelines (ATAG) 2.0. ATAG addresses both issues facing the federal workforce and supporting authors in creating better quality content.
Create a governmentwide dashboard of simple sitewide data. GSA should have a tool like analytics.usa.gov for accessibility. This would allow for a simple almost real-time comparisons of the accessibility of agency sites. Ireland and the Netherlands are already doing this. CivicActions is developing a scalable open source solution to meet this need. Evaluations can be made by looking at errors per page.
Provide specific reporting for PDFs. There should be a concerted effort to remove PDFs from government websites because of inherent problems with the format. This is a matter of removing technical debt in favor of modern semantic content publishing.
Feedback loops with people with disabilities
OMB should focus on building an accessible customer experience, rather than on compliance with a standard. Sites should meet the Web Content Accessibility Guidelines (WCAG), but this cannot be seen as the primary goal. The UK government provides a great example by building impactful accessibility statements. It has become meaningless for agencies to simply claim that they meet Section 508 requirements. Agencies need to build trust with citizens. It is also important that agencies build trust with their users by demonstrating perpetual progress. Authors, designers and developers need a feedback loop with real users. This is critical to ensuring that they can build inclusive experiences.
Provide documentation and clear examples for agencies to follow. The UK is again a terrific model.
Crawl agency sites to evaluate that accessibility statements are clearly in the footer. This scan can also check that it complies with the basic example format provided.
Ensure reports to the DOJ include accessibility feedback from people with disabilities (PwD). PwD should also be involved in user research as the service is being developed.
Clarify role of the Section 508 office
OMB should focus on ensuring that Section 508 offices are working to change the culture and practices of the agency. Currently, many Section 508 offices are primarily involved in the final evaluation. This is after all the critical decisions have already been made — making adjustments to meet WCAG is both expensive and brittle. Accessibility subject-matter experts should be coaching the adoption of inclusive digital services. Projects which fail to incorporate accessibility in the agile process should be assumed will not achieve Section 508.
Engage with agencywide accessibility monitoring efforts, and support contributions toward governmentwide reporting. The agency should use a combination of automated testing and testing using processes. The World Wide Web Consortium (W3C)’s WCAG Evaluation Methodology (WCAG-EM) provides a best practice for existing websites.
Support procurement teams to engage with vendors. The procurement process requires support to select which tools best meet criteria of Section 508. There are also post-contract evaluations which should be done to ensure accessibility fixes are implemented. Government should play a more active role in encouraging vendors to become more inclusive.
Keep accessibility evergreen
OMB should contribute to building global accessibility best practices. The web has been global for 30 years, and the internet even longer than that. We have to assume that most technology will be global. The internet has caused an acceleration of change. Governments need to collaborate to keep up with changing best practices.
Contribute to standards organizations like the W3C’s WAI. The W3C has a great collection of digital best practices, but all of these will need to be updated over time.
Support open accessibility initiatives. Popular open source solutions have become the infrastructure for our modern digital life.
Look for places to support accessibility within emergent technologies like extended reality (XR). Governments may not be early adopters, but it is so much easier if accessibility affordances are included early.
Support authors to create accessible content
OMB should focus on authors. One of the best ways to improve accessibility for websites is to give them the support they need to create more accessible content. Most content on government websites is not written by accessibility experts, nor should it be. The W3C’s WAI produced the Authoring Tools Accessibility Guidelines (ATAG) 2.0 to help provide guidelines for how authors can get the support they need.
Ensure that ATAG 2.0 and support for authors is included in procurement processes for government contracts. This is not currently fully covered in Section 508.
Recommend that all agencies deploy an open source accessibility checker. Accessibility Insights is a great tool which can be implemented on government distributions of Edge and Chrome.
Supported the next phase of the We4Authors Cluster project. There is more that can be done to develop better practices for authoring interfaces.
Support the development of open source tools which can extend existing publishing processes.
Make procurement prioritize accessibility
OMB should invest in improving procurement so that it accelerates inclusive digital services. Historically this has been attempted with accessibility conformance reports like the Voluntary Product Accessibility Template (VPAT). Working for the GSA, CivicActions built OpenACR. OpenACR provides a modern machine-readable approach to tracking vendor claims. This project includes an open source editing tool and open standard data format. OMB can make it a priority to rethink how Accessibility Conformance Reporting (ACR) was done and how that fits into an enterprisewide approach to accessibility.
Key results for OMB evaluations:
Actively encourage agencies to move to adopt OpenACR.
Develop better tools for agencywide multi-product evaluation of accessibility conformance reports.
PDFs are an ongoing problem with accessibility. In their PDF report, the DOJ indicates that two-thirds of PDFs evaluated had barriers for people with disabilities. It is too easy to publish PDFs, and too difficult to make them accessible. For people without accessibility expertise, it is still nearly impossible to distinguish between accessible and inaccessible PDFs. PDFs are a problem to assistive technology users, but also that they present a significant problem for anyone using a smartphone.
Key results for OMB evaluations:
Encourage agencies to actively discourage use of PDFs. This should be public, so that it is easy for people to refer to it.
Build on open source tools like Luxembourg’s simplA11y PDFCrawler. This simple tool can collect and evaluate PDFs for basic accessibility. Given the perpetual problems with PDFs, we should assume they are inaccessible.
Mike Gifford is a senior strategist at CivicActions and a thought leader on digital accessibility in the public sector. Gifford has spearheaded accessibility improvements in Drupal since 2008, and has served as a Drupal Core Accessibility Maintainer in 2012. Gifford has been engaged in the CivicTech community and provided support to governments around the world.