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Play 10: Conduct Information and Communication Technology Accessibility Testing

All Information and Communication Technology (ICT), including commercial-off-the-shelf (COTS), open-source, or custom-built products from your agency, a vendor, or another agency, requires comprehensive Section 508 conformance testing. While expert reviews of Section 508 conformance claims, such as Accessibility Conformance Reports, can offer some insight, comprehensive testing is essential to validate these claims.

Section 508 conformance can be intricate, and vendors and development teams may not fully grasp all requirements. Therefore, Section 508 conformance testing is crucial to mitigate the risk of inadvertently implementing inaccessible ICT.

Automated testing tools can be a great resource to supplement accessibility validation efforts and can dramatically reduce the overall effort to identify accessibility issues; however, they only provide partial coverage of the Section 508 Standards. Some Section 508 Standards are highly context-dependent and require human judgment to determine conformance. To fully validate conformance, manual testing using a repeatable, systematic methodology is necessary. Additionally, informal reviews by Section 508 experts throughout the design and development process can identify potential issues before the ICT is ready for complete Section 508 conformance testing.

While user testing with individuals with disabilities is valuable for assessing comprehensive user experience, assistive technologies (AT) like screen readers and voice input software may not fully measure code conformance. Testers might assume AT are the primary means to determine conformance, but AT often compensates for non-conformant technologies. Therefore, AT should not be the sole method for determining Section 508 conformance for digital services or technology solutions, despite their excellence for usability.

Key Questions:

These key questions help agencies assess whether their Section 508 Program Manager has the authority, expertise, time, and leadership support needed to effectively oversee accessibility compliance and manage legal and organizational risk.

  • Prior to deployment, how do you incorporate the use of ICT accessibility testing tools to inspect and validate digital services and ICT for Section 508 conformance?
  • After deployment, how do you monitor Section 508 conformance when components change or are updated?
  • When using agile processes, how do you ensure user stories include Section 508 conformance in each development iteration? Is Section 508 conformance part of the "definition of done?"
  • How do you obtain knowledgeable Section 508 developers and testers to conduct Section 508 conformance testing?

Checklists

This section provides checklists to guide systematic Section 508 conformance testing, planning, and process implementation for ICT throughout its lifecycle.

Table 1: Play 10 Basic Checklist
Item Actions
Build accessibility testing into the ICT lifecycle including pre-procurement evaluations.
Obtain management support to establish Section 508 conformance testing as a requirement prior to procurement or deployment. Alternatively, follow agency policy on ICT accessibility testing requirements.
Promote and use a consistent, repeatable, validated testing methodology based on a well-defined set of Section 508 test instructions, approved testing tools, and documentation processes. Please see the resources section below for testing methods.
Assess your agency’s current approach(es) to:
  • Validating ICT prior to procurement or deployment
  • Conducting accessibility audits using manual inspection and automated tools
Develop and document accessibility testing policy and procedures that define:
  • What level of testing is most appropriate and when? Levels of testing include automated only testing, spot checks, component testing, and comprehensive testing.
  • When accessibility testing is required? At minimum, test prior to deployment.
  • What qualifications are required to perform Section 508 conformance testing such as obtaining the DHS Trusted Tester certification for web developers.
  • Roles and responsibilities of each member of the project team including developers, testers, and management.
  • How Section 508 conformance testing will be conducted?
  • How will testing environments be configured?
  • What ICT accessibility testing tools and methodologies will be approved for use?
    Example: ICT Testing Baseline-aligned test processes, such as the DHS Trusted Tester testing methodology.
  • How testing results will be tracked and monitored? See Essential Elements of a Test Report.
Determine approach to using tools to support testing, including:
  • ICT Accessibility testing tools to assist with unit testing.
  • Audit tools capable of scanning large volumes of digital content for Section 508 conformance.
  • Monitoring tools to regularly scan digital content.
  • Tools to track, report, and monitor testing activities and results.
Develop or attain Section 508 testing expertise:
  • Determine whether the testers will be centralized or decentralized.
  • Identify training needs and, where warranted, certification procedures for individuals who will perform Section 508 conformance testing.
  • Develop a cadre of vetted Section 508 conformance testers and technical support resources.

Table 2: Play 10 Advanced Checklist
Task Resources
Develop a risk-based framework to inform the appropriate depth of ICT accessibility testing for the ICT product. Levels of testing range from automated only testing, spot check, component testing, or comprehensive testing.
Report Section 508 conformance results at the program, project, and organization level to your agency’s senior leadership team. Consider adding Section 508 data to current governance, risk, and compliance (GRC) tools used within your agency.
Audit testing activities to ensure agency employees follow accessibility testing policy and procedures and to identify areas for improvement.
Incorporate Section 508 conformance testing and monitoring into continuous integration/continuous deployment (CI/CD) pipelines.
Incorporate usability testing with users with disabilities into testing procedures, including testing with Assistive Technology.

Key Performance Indicators (KPI)

This section outlines Key Performance Indicators (KPIs) to track and measure accessibility testing, remediation, and overall Section 508 conformance across web, intranet, and enterprise ICT solutions.

Generic KPI: In FY2X, conduct user testing with users with disabilities on XX% of new user content before publishing and create a method for tracking this involvement.

Generic KPI: In FY2X, provide direct feedback through testing to XX% of the individuals who submitted content for review within 2 business days AND In FY2X, provide direct feedback through testing to XX+25% of the individuals who submitted content for review within 7 business days.

Generic KPI: In FY2X, conduct comprehensive manual testing on XX% of all new entity web content prior to content deployment.

Generic KPI: In FY2X, conduct comprehensive automated testing on XX% of all new entity web content prior to content deployment.

Generic KPI: In FY2X, conduct comprehensive automated testing on XX% of all new agency online documents prior to document distribution.

Generic KPI: In FY2X, test XX% of agency web pages for section 508 conformance.

Generic KPI: By QX FY2X, test XX% of internet web pages using automated and manual testing.

Generic KPI: By QX FY2X, test XX% of internet web pages using automated testing.

Generic KPI: By QX FY2X, test XX% of internet web pages using manual testing.

Generic KPI: In FY2X, test XX% of internal agency intranet web pages for Section 508 conformance.

Generic KPI: By QX FY2X, test XX% of internal intranet web pages using automated and manual testing.

Generic KPI: By QX FY2X, test XX% of internal intranet web pages of those that are testable using automated testing.

Generic KPI: By QX FY2X, test XX% of internal intranet web pages using manual testing.

Generic KPI: By QX FY2X, address at least XX% of the accessibility issues that were received through the public feedback mechanism during YY time period.

Generic KPI: By EOFY FY2X ensure all agency publicly used kiosks adhere to all relevant Section 508 standards.

Generic KPI: By QX FY2X ensure the agency's single sign-on application adheres to all relevant Section 508 standards.

Generic KPI: By QX FY2X ensure the agency's standard W-2 form adheres to all relevant Section 508 standards.

Resources

Reviewed/Updated: September 2025

Section508.gov

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