Five reasons to get excited about governmentwide Section 508 assessment criteria

This is the first part of a two-part article.

In July 1990, the Americans with Disabilities Act (ADA) was signed into law, yet it is understandable that people are concerned about the lack of progress over the last 33 years. Far too often, accessibility has become just a checklist item that agencies cross off without understanding it. That said, under the Biden administration, there has been a renewed effort to address accessibility.

Recently, I was impressed by the General information — Governmentwide section 508 assessment criteria pages published on As Tim Springer wrote in his article, In pursuit of digital accessibility: Navigating the impact of Section 752 on federal agencies, this “signals a new chapter in pursuing digital accessibility for federal agencies.” Looking at the 105 questions that agencies are required to answer, I think he’s right.

I believe it is worth highlighting the key reasons these questions are valuable in measuring government progress towards its ADA goals. There are a lot of questions, so I will be breaking this into two articles, the first focused on people and process.

Accessibility starts with leadership

Effective government requires having a skilled workforce that is trained and given a mandate to implement projects effectively. This can be through employees or contractors, but the direction needs to come from government leadership. Asking agencies to identify how digital accessibility fits into their leadership and management performance plans is a brilliant step.

Many in the public and private sectors are familiar with the phrase “culture eats strategy for breakfast,” but people forget that incentives drives culture. Ensuring that management understands that this is a priority for the government on which they will be evaluated on will help drive change.

Ensuring that there is clear integration of accessibility in the professional planning and development is also critical. CivicActions has incorporated accessibility into our onboarding for all staff, and also include it with our project onboarding when working with our government clients. We find it makes a huge difference in how we talk about Section 508 requirements. We would like to have confidence that our clients have a similar level of basic training.

Training government employees is key, but unfortunately, many training opportunities are presently inaccessible. The questionnaire suggests that agencies start with the most popular training course and ensure that is fully compliant. All government training should be accessible. Unfortunately, in talking to accessibility advocates inside government, accessible courses are rare. Training courses, like other projects, find it easier to conform to Section 508 while being built, rather than as a retrofit.

A call to engage people with disabilities

I loved that there were several specific questions that prioritized people with disabilities as being part of this process. “Nothing about us, without us” is a critical part of the movement which led to the ADA. We simply cannot forget that the goal of the ADA is not to meet Section 508 criteria, but to see that people with disabilities are able to engage meaningfully with the economic, political and social life of the nation. Section 508 is essentially a consolidation of digital best practices to help move us to that goal.

There are two questions that encourage agencies to consult with users with disabilities. This needs to be done in the acquisition and development process. It also needs to happen after the site is launched as part of ongoing user research.

This administration has put a big focus on intentionally adding accessibility into current diversity, equity and inclusion (DEI) initiatives. It would have been nice if this had been assumed from the start, but unfortunately, it was not. Agencies are now being asked to demonstrate how they are addressing diversity, equity, inclusion and accessibility (DEIA) in their strategic planning. Going further, disability-related affinity groups have expertise, and should to be consulted to inform an agency about the effectiveness of their accessibility efforts.

There are many advantages to the government being able to support employees with disabilities. The big one is just access to talent. In the context of this questionnaire, though, it will also help to have the in-house expertise to better inform agencies about how many Americans engage with their services.

Procurement must include accessibility

Procurement is a critical part of ensuring that government is accessible. Agency contracting often involves a complex team of professionals.

Historically, Section 508 made some terrific strides in seeing that accessibility was included as part of the procurement process. Governments have a great deal of influence when they are trying to buy products and services. Ensuring that the most accessible vendors win contracts with government will go a long way to make America more inclusive.

Many in procurement will be familiar with the voluntary procurement accessibility template (VPAT). VPAT was really innovative 20 years ago, but has simply not kept up with the times. CivicActions worked with the General Services Administration to build a pilot to modernize this in the form of OpenACR — a machine-readable accessibility conformance report, so we have gotten very familiar with those reports.

Not everything can be accessible to everyone. The Section 508 process provides some exceptions for what products must comply with Section 508. The questions requiring agencies to estimate how many fundamental alteration exceptions and undue burden exceptions are allowed by an agency will be very useful. There are some agencies which over-use these exceptions.

The Department of Labor’s PEAT Buy It does a great job outlining the procurement process and how accessibility fits in. Buy It demonstrates communication with contractors is key. To ensure consistent messaging, government employees also need to be strategically involved. Having messaging with vendors post-procurement about the importance of accessibility is important. We also see the importance of some third-party evaluation so that vendor claims can be tested. Documenting communications to employees and contractors addresses some of this.

The questions don’t skip the difficult situation where vendors deliver inaccessible information and communications technology (ICT). There clearly needs to be disincentives put in place for when vendors fail to deliver. As a contractor, it is also important to note that most often the priorities are set by the client. If the client doesn’t make accessibility a priority, it won’t be well executed in the deliverables.

I am an accessibility maintainer of Drupal, a popular open source content management system that has prioritized accessibility. Drupal is used to produce some of the most accessible websites in government. Still, Drupal Core is not 100% accessible. Having ICT that has no accessibility issues is going to be very rare, because it is difficult if not impossible to do. Section 508 requires agencies to do a market survey, and then pick the tools that are the most accessible. This is the “best meets exceptions,” and tracking these across government will provide real insights on how technology is being evaluated.

Government has a role in understanding accessibility. It is not something which can be simply delegated to the vendor. Responsibility must be shared. Vendors need to hear consistent communications from agencies about the importance of accessibility.

Monitor the data for progress

Finally, Congress mandated this reporting, and the intention is to make it public. The results of the survey should be available for the public to review, analyze and draw their own inferences. The General Services Administration and the Justice Department will gather the information they collect from agencies to create annual and biennial reports to Congress. This will include a public data file that contains all agency responses which should allow people to identify trends over time.

This is so important for building trust in government. We need to focus not on achieving perfection, but being able to measure progress. Moreover, making the data publicly available will allow for competitive pressure between departments, projects, and the vendors that they work with.

A great example to follow

This is an excellent model for other governments to emulate. By collecting rich data on the complex process of building inclusive digital interfaces, publishing the results and allowing for comparisons between them, governments can more effectively measure and grow their accessibility initiatives.

This is an impressive questionnaire. It will be quite difficult for most agencies to complete it, as it is an unprecedented level of reporting. Should agencies complete these with due diligence, there will be an opportunity for considerable government-wide learning. I do hope that the full results become public, as I do think that there is value in self assessments if they are properly constructed.

Mike Gifford is a senior strategist for CivicActions, a digital services firm that pairs expertise in free and open source (FOSS), Drupal, and accessibility to help the government deliver high-impact public services. He also is an invited expert with the World Wide Web Consortium (W3C).  

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