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Policy & Management
Play 2: Measure Your Section 508 Program’s Performance and Set Programmatic Goals
Some agencies have not yet established a formal Section 508 Program. Other agencies are just beginning to establish a Section 508 Program, and they must establish policies, procedures, training, and communications to build awareness of what is required and who is responsible for addressing compliance needs. Agencies further along may have dedicated resources to perform testing to validate Section 508 conformance claims, but do not have a systematic approach to perform testing.
Mature agencies demonstrate the ability to measure and monitor conformance to policies and actual compliance levels, and they use data to drive decision making to improve the effectiveness of their overall Section 508 Program. Section 508 activities appropriate for mature organizations may not be appropriate for less mature organizations that do not have an adequate foundation to build upon. Therefore, measuring your agency’s Section 508 Program performance is essential to gauge where you are, and to determine what steps are necessary to improve your program. After you have determined the current state of your agency’s ICT accessibility, then you can set goals to target areas of lower performance and create associated metrics to track progress on those goals.
Key Questions
What is the current performance of your agency’s Section 508 Program?
How is your program’s conformance to Section 508 standards enabling or inhibiting your agency’s ability to provide accessible digital services and technology solutions?
What Key Performance Indicators (KPIs) or targets are you using to assess your program or track progress on your agency’s ICT accessibility goals?
Accessibility Areas of Performance
Federal agencies can measure their performance in many ways including conformance of websites, documents, and software or by evaluating whether a Section 508 policy sufficiently covers an agency’s primary business functions. While it may make sense to assess organizations differently based on their size and mission, there are general areas of performance of Section 508 Programs and agency ICT accessibility activities that are more or less universally applicable. One exception to this applicability however, could be for very small agencies that simply may not perform some functions.
As a best practice, agencies should create and track 1-2 KPIs per category, where applicable, if significant improvement is required. More mature organizations may only have metrics in a few of the categories, with continuous monitoring for those they do not actively track. The areas of performance are:
IT Accessibility Program Office: Measures your agency’s program management, reporting, benchmarking, risk management, continuous process improvement, and other business-related functions that align to the development, implementation, and maintenance of the agency’s Section 508 Program or equivalent.
Policies, Procedures, and Practices: Measures the extent to which your agency develops, implements, and continuously improves digital accessibility-related policies, procedures, directives and standards, and includes digital accessibility into relevant policies across all business functions.
Communications: Measures the extent to which your agency considers accessibility in its internal and external communications. One example is leveraging a formal process or plan for creating Section 508 conformant agency official communications.
IT Accessibility Community Engagement: Consider how engaged you are within the IT Accessibility community. Activities may include attending events, hosting events or conferences, or participating in or providing shared accessibility services. Note that while participation in events does not automatically mean your program is mature, more mature organizations do tend to be more engaged in the IT Accessibility Community.
Content Creation: Measures the extent to which your agency develops, tests, remediates, and tracks conformance of digital content, including but not limited to documents, presentations, PDFs, spreadsheets, audio, video, multimedia, social media, and digital forms.
Human Capital, Culture, and Leadership: Measures the extent to which your agency embeds accessibility into its leadership and professional development practices and mission-related strategic planning.
Acquisition and Procurement: Measures the extent to which your agency conducts validation of procurement solicitations to ensure incorporation of Section 508 contract language into Statements of Work and Performance Work Statements.
When purchasing technology, you must ensure the acquisition process addresses Section 508 requirements. Solicitation language must clearly state what standards apply to the digital service or technology solution and require potential vendors to demonstrate they can meet those requirements.
Technology Lifecycle Activities: Measures the extent to which your agency conducts validation of Section 508 requirements to ensure incorporation into agency life cycle activities, including enterprise architecture, design, development, testing, deployment, and ongoing maintenance activities.
Enterprise life cycles are used to define the end-to-end approach to approving, building, deploying, and supporting agency technology. Section 508 requirements should be incorporated from the beginning of the enterprise life cycle, and included in all stages of the enterprise life cycle. The least effective and most expensive approach to supporting compliance is to treat Section 508 requirements as an afterthought in response to test results, or worse, in response to complaints from people with disabilities. The most effective and least expensive approach is to consider Section 508 requirements at all stages of the enterprise life cycle. This is analogous to the saying, “it’s cheaper and easier to use an eraser to modify an architectural drawing than a sledgehammer to tear down a wall.”
Testing and Validation: Measures the extent of your agency's testing and validation of Section 508 conformance including your testing framework and execution.
While a review of an Accessibility Conformance Report (ACR) based on the most current revision of the Voluntary Product Accessibility Template (VPAT) 2.0 or later developed by the Industry Technology Industry Council (ITIC) provided by a vendor or contractor is a starting point, sometimes testing may be required to validate Section 508 claims, to inform remediation planning, and to monitor agency progress with achieving Section 508 compliance. In addition, testing may be required on an ongoing basis to validate the technology developed, used, and maintained by an agency is conformant with the applicable Section 508 standards as components are updated or replaced.
Conformance Metrics: Measures the extent to which your agency’s ICT products and services conform to Section 508 standards. This also includes the capacity to and the effectiveness of tracking and resolving Section 508 complaints.
Agencies can measure conformance in many ways including conformance to standards of select electronic documents, the percentage of conformant documents versus all documents tested within a given time period, and percentage of required Section 508 standards to which a specific enterprise ICT conforms. See the full list of IT accessibility conformance KPIs for suggestions of conformance metrics to use within your organization.
Additionally, a clear process for addressing and tracking Section 508 complaints is necessary. This complaint process should provide effective communication with complainants, validate Section 508 non-conformance claims, support an appropriate agency response aimed at minimizing legal exposure, costs, and loss of administrative time, and serve as input into decisions related to resource and work planning.
Training: This category measures the extent of Section 508 compliance training opportunities that your agency offers or conducts for stakeholders within your agency.
Successful Section 508 programs rely on personnel with skills and expertise. Relevant resources need to be identified and trained. Mandatory training needs to be established and tracked. This includes, but is not limited to, training for web and software developers, acquisition professionals, human resource employees, and communications specialists.
Table 1: Play 2 Checklist
Item
Actions
Determine your agency’s performance related to ICT accessibility using accessibility Key Performance Indicators or other means.
Evaluate how existing agency policies, practices, and procedures support each mission area related to ICT accessibility (IT Program Office, Communications, Training, etc. as described above).
Identify strengths and weaknesses of the organization’s current accessibility processes.
Review Section 508 compliance challenges identified in previous complaints.
