Agencies are dedicating more time and staff to digital accessibility efforts, but acquisition is still a key hurdle when it comes to Section 508 compliance.
The General Services Administration’s latest governmentwide Section 508 assessment shows agencies are still struggling to meet digital accessibility standards.
In fact, GSA’s fiscal 2024 assessment — its second annual report since last year’s landmark assessment — shows governmentwide conformance to Section 508 standards declined over the past year. Only 23% of the top-visited public websites fully conform with Section 508 standards, while 20% of intranet pages meet all the standards.
GSA officials had previewed the “stagnation on accessibility efforts” in a mid-November event, prior to the report’s release in December.
But Mike Gifford, a senior strategist at digital services firm CivicActions, said the 2024 assessment marks a key step in gauging year-over-year progress on Section 508.
“This has happened twice now,” Gifford said. “The only way we’re going to be able to make sure that accessibility is a priority for the departments delivering services to Americans is to make sure that those services are being at least evaluated, and there’s a process whereby you can compare agencies and how well they’re focusing their internal systems on looking at accessibility.”
So what does the 397-page report tell us about where agencies may have improved and why overall conformance remains low? Here are five key takeaways from the 2024 assessment:
While agencies backslid on conformance, there was a governmentwide increase in Section 508 “maturity.” That index is measured using several elements, including policies, acquisition, testing and training.
One of the top areas agencies focused over the past year was hiring or designation a Section 508 program manager. The White House Office of Management and Budget directed agencies to immediately hire Section 508 program leads in a December 2023 memo.
In fiscal 2024, 56% agencies reported having a part-time Section 508 PM, while 33% of agencies said they had a full-time PM. Only 11% of agencies reported having no Section 508 PM, down from 21% in fiscal 2023.
The assessment also found agencies were designating more staff and time overall to Section 508 efforts in fiscal 2024.
“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,” the report adds.
GSA’s latest assessment also shows many agencies are not checking whether the products and services they buy meet digital accessibility standards.
While most include accessibility requirements in solicitations for IT, 46.% of them reported “sometimes or never” verifying the accessibility of what was delivered. As GSA notes, “this is still a very high percentage of entities who are accepting contract deliverables without knowing if they meet the contractual requirements for digital accessibility.”
Gifford said agencies need to ensure their program and contracting offices have access to Section 508 expertise.
“You need to have accessibility subject matter experts there,” Gifford said. “You also need to have accessibility subject matter experts in the procurement team, so that if somebody has a question about what is the most accessible product for X, Y and Z, there’s somebody who could read a [Voluntary Product Accessibility Template] and understand what the vendors are claiming.”
The report recommends requiring Section 508 as a major factor in acquisition.
It also calls on Congress to target the accessibility of “high-use software,” as agencies often use the same or similar products for productivity, surveys, websites and other digital tools.
Gifford said it will be key for agencies to work together to demand better accessibility from IT vendors.
“There’s no other entity in the world that buys as much digital product as the U.S. government,” Gifford said. “There’s an opportunity to play a leading role, to go off and say, ‘We need to make sure that that our vendors and the vendors that serve governments around the world are building software that’s accessible.’ They haven’t been for the last 30 years.”
The Section 508 assessment found most agencies reported using automated and manual tools to test websites and other digital content for accessibility.
But planning for accessibility remains a key challenge — 41% of respondents said they sometimes or never integrated Section 508 conformance into their technology planning.
Agencies told GSA about numerous challenges, including “varied commitment to accessibility across programs, accessibility still being treated as an afterthought, digital accessibility conformance not being part of the technology lifecycle, limited or no testing tools, and lack of testing personnel.”
But overall, GSA noted Section 508 testing and integration into the technology lifecycle improved over the past year.
GSA’s assessment is based on self-reported data, meaning the data is ripe for misinterpretation and other quality challenges.
“Looking at the data both this year and last year, there’s been problems with the data quality in both cases,” Gifford said. “That happens anytime in government you have anyone filling in a form, it’s easy to make mistakes.”
GSA acknowledges as much in its report. It found 575 validation failures across all data submissions. Out of the 245 agency entities that reported to GSA, 182 had at least one validation failure.
“Since we continue to see a misunderstanding of questions and response options, GSA, OMB, and the Access Board will refine and reframe questions and response options for clarity, add content to the understanding section to explain the question intent and methods to gather information for response options, and continue to add to the definitions of terms,” the report states.
Beyond technical compliance and policy measures, GSA’s assessment also evaluates the commitment of leadership to accessibility. And for 58% of reporting entities, accessibility performance metrics were unknown or there were no such metrics in leadership performance plans.
“Agencies should develop accessibility related metrics to include in annual leadership performance plans. Increasing accountability may increase prioritization of digital accessibility, likely improving conformance of ICT,” the assessment states.
The Biden administration’s December 2023 memo on Section 508 — the first such directive in more than a decade — set the stage for agencies to pay more attention to accessibility requirements. It’s unclear whether the incoming Trump administration will follow through on those efforts.
Over the last 30 years, Gifford said the U.S. government has fallen behind many countries in Europe when it comes to digital accessibility.
“If the U.S. wants to regain its place as a leader for building inclusive and innovative digital environments, then there needs to be an investment to make sure that that people can get engaged,” he said.
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