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Play 11: Track and Resolve Accessibility Issues

How to test and validate Section 508 and ICT accessibility conformance is described in Play 10. Play 11 addresses what to do with the list of issues or defects found during testing. Agencies should systematically track, prioritize, and resolve defects within specified timelines. End users may also report ICT accessibility issues as part of public feedback or Section 508-related complaints. Agencies should also assess, track, prioritize, and resolve reported issues. Addressing the root cause of an issue may incur costs for the agency, regardless of its origin. If the defect stems from a lack of Section 508 conformance, the agency should take measures to prevent its recurrence in future development, upgrades, and procurements.

Key Questions:

  • How does your agency identify and track ICT accessibility issues from initial report through resolution?
  • How does your agency prioritize defects for remediation?
  • What process do you use to categorize, prioritize, troubleshoot, and identify root causes of accessibility issues?
  • Do you have a well-defined policy and procedure for Section 508-related complaints?
  • Do you have a mechanism and procedure to obtain and resolve public feedback?
  • Do you have a relationship with your agency's Equal Employment Office, or equivalent, and procedures to ensure complaint awareness and resolution?

Checklists

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

Table 1: Play 11 Basic Checklist
Item Actions
Develop a process to track and monitor Section 508 conformance:
  • For internal projects and software development, assess internal bug tracking systems for suitability in tracking accessibility defects.
  • Consider adding Section 508 data to current governance, risk, and compliance (GRC) tools used within your agency.
  • Assess your current help desk suitability for tracking and resolving accessibility issues reported by end-users.
  • Train Help Desk staff to recognize accessibility issues and alert the Section 508 Program or appropriate stakeholder for escalation and resolution.
Develop a process to assess and troubleshoot the issue:
  • Is the problem caused by the technology, third party components used by the product, the operating environment the product is deployed in, the assistive technology used to access the product, or some other source?
  • Is the problem caused by a lack of training or communications?
  • Is the problem caused by a usability issue?
  • Is the problem caused by non-conformance with the Section 508 Standards?
Develop a process to categorize accessibility issues. For example:
  • Issues cited in Section 508-related complaints: These items require formal, careful, expedited handling by the Section 508 Program, the IT department, general counsel, and possibly external Federal entities such as the Department of Justice (DOJ).
  • Technical conformance issues identified through testing or informal user reports: Agencies should address these items through risk mitigation processes as discussed in Play 10 and can include documented defects.
  • Deployment issues: These may result from challenges in how, where, and when agencies deploy ICT services and technologies.
  • Public feedback: Public submissions, whether or not directly related to Section 508 non-conformance, should be evaluated by knowledgeable employees who can determine how to direct the feedback. Agencies should document, address and communicate resolution of these issues to the submitters.
Develop a process to prioritize defects based on user impact or criticality. For example:
  • Critical issues may prevent an end user from accessing or using the technology.
  • Major issues may make it extremely difficult, but not impossible, for an end user to access or use the technology.
  • Minor issues do not materially affect the use of the product, but may represent a technical defect.
Develop an escalation process to set timelines and address the need for corrective action or remediation based on risk and impact on end users. Follow your agency’s acquisition processes for cure notice, show cause, or delinquency notices, where applicable.
Develop a process to evaluate and track corrective action and remediation plans.
Develop and implement a process for managing Section 508-related complaints.
Ensure that established Section 508-related complaint and feedback mechanisms, along with other required resources, are published on the agency's website accessibility statement, as required by OMB Memorandum.

Table 2: Play 10 Advanced Checklist
Task Resources
Establish a help desk dedicated to addressing accessibility issues, staffed by individuals specially trained to troubleshoot AT and accessibility issues.
Develop robust Section 508 reporting capabilities to aggregate and analyze accessibility issues across the agency, including custom developed and COTS ICT.
Integrate Section 508 conformance measures into the Authority to Operate (ATO) process or other pre-procurement or pre-deployment approval gates within your agency.

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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