OMB issues digital accessibility guidelines, tells agencies to set up public feedback mechanism

The White House is putting a renewed emphasis on accessibility requirements for federal technology under an Office of Management and Budget memo that directs a bevy of agency-specific and government-wide actions.

The memo, “Strengthening Digital Accessibility and the Management of Section 508 of the Rehabilitation Act,” was signed out Dec. 21 by OMB Director Shalanda Young. It’s intended to ensure agencies meet Section 508 standards set by the U.S. Access Board.

“Members of the public and federal employees should have equitable access to government, regardless of ability,” Young writes. “The prevalence of information technology and the growing necessity of it in daily life make digital accessibility a continuing imperative for federal agencies.”

Accessibility is an “operational imperative,” the memo states, considering about 25% of U.S. adults – approximately 61 million people – live with a disability. And 17% of the federal workforce reported having a disability in 2022.

“Accessibility is an essential part of federal government modernization that utilizes digital technologies to effectively serve the public as well as the employees who need tools to do their jobs effectively,” the memo continues. “Continuous accessibility improvements lead to better, higher-quality software and employee engagement, which can improve agency operations and reduce long-term operating costs.”

The OMB memo is the first White House action on Section 508 compliance in more than a decade. It comes after agencies have been criticized for not tracking and evaluating their adherence to Section 508 requirements in recent years.

And recent testing shows more than half of all government websites have at least one accessibility issue, according to data collected by OMB and the General Services Administration

“This is something that I think the accessibility community working with government has been looking for, for a long time,” Mike Gifford, a senior strategist at the digital services firm CivicActions, said in an interview. “Having this direct guidance trying to eliminate the fuzzy barriers about what the expectations are for government agencies,”

The memo directs agencies to provide OMB with the name and contact information for an “agency-wide Section 508 program manager” within the next 30 days.

OMB also tells agencies to regularly evaluate their accessibility efforts and establish feedback mechanisms to remediate any issues. The memo highlights the importance of using automated tools to routinely scan their websites for any accessibility issues, as well as regular manual tests like the “Trusted Tester Conformance Test Process for the Web.”

Within 90 days, OMB directs agencies to post an accessibility statement on their websites and establish a “public feedback mechanism for receiving complaints or reports about accessibility issues with agency websites and digital services and begin to track, review, and address feedback.”

Gifford said the feedback mechanism should help agencies more quickly uncover and fix accessibility issues.

“Having that feedback loop so that it’s not getting routed through the Section 508 office of the agency, but it’s making sure that that feedback can get back to the people who are building the website, not to launch a grievance, but in order to fix the problem,” Gifford said. “And the shorter that feedback loop is, the more effective it will be to address the accessibility issues that come up.”

The White House wants agencies to design and develop “accessible digital experiences.” The memo says accessibility is critical to improving customer experience and public-facing services, while also an essential element of supporting the federal workforce through internal technology improvements.

The guidance specifically addresses all information and communications (ICT) technology used by agencies.

“Accessibility must be incorporated, unless an exception applies, from the very beginning of the design and development of any digital experience and integrated throughout every step of the ICT lifecycle, including qualitative and inclusive research, feature prioritization, testing, deployment, enhancements, and maintenance activities,” the memo states.

Within 180 days, OMB directs agencies to conduct a “comprehensive assessment of agency policies to ensure that ICT accessibility considerations are incorporated in all relevant agency functions.”

Meanwhile, the memo tells GSA to work with the Access Board to review and update any government-wide Section 508 resources, such as best practices and playbooks. OMB specifically anticipates updating Section 508.gov with sample accessibility statements, best practices for the public feedback mechanism, and how agencies can maintain a formal Section 508 complaint process.

Section 508 ‘buy accessible’ initiative

GSA is also being tasked with multiple new efforts aimed at helping agencies “buy accessible” under the OMB memo.

For instance, GSA will work with the Access Board over the next year to explore options for establishing a standard reporting process for accessible technologies, including a “central repository of vendor accessibility conformance reports.”

OMB also directs GSA to establish a government-wide service to help agencies acquire products and services that could help them comply with accessibility standards, such as product accessibility testing services, Accessibility Conformance Report evaluations, and website and document remediation.

Furthermore, GSA, the Access Board and the Office of Personnel Management are directed to expand Section 508 certifications and training. The Chief Information Officers Council will also work with the Chief Human Capitol Officers Council to “improve the hiring and development of effective and qualified Section 508 program managers, digital accessibility testers, and related positions.”

Gifford said it’s critical for agency procurement units to understand accessible technology requirements.

“Making sure that they have the skills and the information that they need, making sure they have access to those subject matter experts, so that they can help to provide clear instructions to vendors who are looking to win government contracts in the future,” he said.

Meanwhile, the CIO Council will work with agencies over the next year to “explore opportunities” to establish a government-wide program for providing assistive technology devices and services, OMB’s memo continues.

And GSA will work with the Access Board in 2024 to explore establishing a “federal digital accessibility design and testing lab staffed with accessibility specialists who can perform automated and manual testing and assessments of agency ICT, as well as provide user research and usability testing related to the accessibility of ICT.”

The memo also comes as OMB is expected to wrap up a government-wide Section 508 assessment that was mandated by the fiscal 2023 spending bill. Federal CIO Claire Martorana recently said the results of the assessment — due Dec. 29 —will “enable agencies to demonstrate their progress and advocate for additional resources dedicated to improving accessibility.”

“I cannot stress enough how big a step this is. This assessment is holding our federal government accountable for providing an accessible technology to the public and to our federal employees,” Martorana said Nov. 8 at the Interagency Accessibility Forum (IAAF) in Arlington, Virginia.

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