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General Information - Government-wide Section 508 Assessment Criteria

Below is a list of the criteria agencies must use to evaluate the extent to which the information and communications technology (ICT) of the agency are accessible to and usable by individuals with disabilities.

These questions are broken down into eleven different criteria; nine focus on maturity, one focuses on Section 508 conformance metrics, and one focuses on general information. This is the final list of the questions that your agency will need to submit responses on by August 11, 2023.

Agency POCs will receive a link via email to the reporting tool no later than June 1st to submit the information. Feel free to use the following spreadsheet (XLSX) to help you collect the information; however, responses must be submitted using the reporting tool. You may also simply print the criteria questions directly from this page as a guide.

General Information

Questions in this section ask about information and metrics related to the activities of your agency's Section 508 Program (or equivalent) activities.

Question 1

Estimate the total number of federal full time equivalents (FTEs) your agency has in its Section 508 Program or equivalent as of FY 2023. (Expressed in whole or fraction of numbers of FTEs; e.g., 1.0 FTEs, 2.5 FTEs). (*Required)

Open response-number

Do not include contractors in this response.

Include only the federal employees working directly on your agency’s 508 program (e.g., there is formal designation to support the Section 508 program or equivalent).

If, over the course of the reporting period, your agency added federal staff or had a reduction in federal staff, report an average of federal FTEs.

For example, if your agency has:

  • A Section 508 Program Manager who is Full Time = 1 FTE for the 508 Program.
  • An administrative assistant who works 50-50 in both Section 508 and Section 504 areas = 0.5 FTE for the 508 Program.
  • An employee who works one day a week on Section 508 training for the 508 Program, and the rest of the week on other training for the agency = 0.2 FTE for the 508 program.

Question 2

Estimate the total number of contractor full time equivalents (FTEs) your agency has in its Section 508 Program or equivalent as of FY 2023. (Expressed in whole or fraction of numbers of FTEs; e.g., 1.0 FTEs, 2.5 FTEs). (*Required)

Open response-number

Do not include federal employees in this response.

Include only the contractors working directly on your agency’s 508 program (e.g., there is formal designation to support the Section 508 program or equivalent).

If, over the course of the reporting period, your agency added contractor staff or had a reduction in contractor staff, report an average of contractor FTEs.

Question 3

Indicate how many hours per week your agency's 508 Program Manager or equivalent are dedicated to supporting your agency's Section 508 Program or equivalent. (*Required)

Select one:

  1. Full time - I work 40 hours per week are dedicated to support the Section 508 Program
  2. Part time - I have additional duties and work less than 40 hours per week in support of the Section 508 Program [insert hours per week dedicated to Section 508 Program *required]
  3. N/A- my agency does not have a 508 program manager or equivalent

Only include the actual time spent by the 508 Program Manager or equivalent. This may be different from duties written into a job description or policy.

For example, an individual is hired to be the Section 508 Program Manager as well as your agency’s General IT Support Desk Manager, with a 50-50 time split in their job description. During the reporting period, the individual ends up spending 90% of their time on the IT Support Desk because of urgent issues. In this case, select option “b) Part time” and report “4” hours per week for this question.

Question 4

Where does your Section 508 program or equivalent reside within your agency? (*Required)

Select one:

  1. Head of agency's office or equivalent
  2. Agency’s CIO Office or equivalent
  3. Agency’s Equal Employment Office or equivalent
  4. Agency's Human Resource / Human Capital Office or equivalent
  5. General Counsel
  6. N/A - agency has not established a formal program/office to implement and comply with Section 508
  7. Other [input text field]

If your agency’s Section 508 program or equivalent is considered “cross-agency” or “multi-departmental”, use the department whose budget pays for the 508 Program Manager and their staff (or majority thereof).

Question 5

Estimate your agency’s total budget for its Section 508 Program or equivalent in FY 2023. Rounded to the nearest thousand (e.g., $345,000). If your budget is classified, please select "Classified" as your response. (*Required)

Select one:

  1. Open response-whole number
  2. Classified

Include the salary plus benefits for the number of federal FTEs (provided in Question 1) that support your agency’s Section 508 Program plus all other spending allocated to your agency’s Section 508 Program (e.g., contractor support, licensing, remediation services, tools, etc.)

If your agency is not sure how to estimate the salary plus benefits for each federal FTE, use the grade salary below that best align with each of your agency’s federal FTEs. Then, add each FTE staff salary and all other Section 508 program allocated spending to determine your agency’s estimated Section 508 program budget.

NOTE: The salaries listed below are the Washington, DC metro area locality pay rates for Grades 1-15, Step 1 multiplied by 1.31 to estimate the salary plus benefits (rounded up to the nearest dollar). If estimating, use these numbers even if the federal FTE is not located in the DC metro area.

  • Grade 1: $34,757
  • Grade 2: $39.083
  • Grade 3: $42,643
  • Grade 4: $47,870
  • Grade 5: $53,557
  • Grade 6: $59,702
  • Grade 7: $66,342
  • Grade 8: $73,473
  • Grade 9: $81,151
  • Grade 10: $89,364
  • Grade 11: $98,185
  • Grade 12: $117,683
  • Grade 13: $139,938
  • Grade 14: $165,365
  • Grade 15: $194,514

For example: Your agency Section 508 Program has 2 FTEs (one at Grade 12 and one at Grade 14) and an additional $500,000 for contractor support and accessibility tools. $117,683 + $165,365+ $500,000= $783,048. Round to nearest thousand and report $783,000.

Question 6

Indicate in what ways your agency consults with users with disabilities in acquisition and/or development of ICT. (*Required)

Select all that apply:

  1. Ad hoc/informal
  2. Disabilities are included in customer/user personas
  3. Individuals with disabilities are consulted when defining customer/user needs
  4. Individuals with disabilities are consulted in development of Section 508 conformance validation testing processes
  5. Individuals with disabilities are directly involved in Section 508 conformance validation testing
  6. Individuals with disabilities are directly involved in user acceptance testing
  7. None
  8. Other [input text field]

A description of each response option is provided below:

  1. Ad hoc/informal:

    If not all your ICT acquisitions considered the needs of users with disabilities, then select this item and any other items in this list as appropriate.

    If any acquisitions or developments used heuristic analysis (i.e., general design principles) of user needs, or other informal methods, select this item.

  2. Disabilities are included in customer/user personas:

    Like using heuristics, personas are used to hypothesize a set of user requirements based on general design principles and expert experience. This is not user testing, and it is not user consultation, but it is a way to consider the needs of end-users during acquisition and/or development projects.

  3. Individuals with disabilities are consulted when defining customer/user needs:

    This refers to direct consultation with end-users, either face-to-face, via phone or video conferencing. Direct consultation can involve interviewing end users, observing end users during tasks, holding focus groups with representative samples of end-users, and other methods.

  4. Individuals with disabilities are consulted in development of Section 508 conformance validation testing processes:

    If you are developing (and/or refining) your test processes, select this answer if the development process involves active consultation of individuals with disabilities (i.e., using the same kind of methods as in c, above).

  5. Individuals with disabilities are directly involved in Section 508 conformance validation testing:

    If your agency's testing team includes individuals with disabilities, select this item.

  6. Individuals with disabilities are directly involved in user acceptance testing:

    User Acceptance Testing (UAT) refers to implementation in a real-world setting. This might be part of a phased implementation of a prototype to be used in actual day to day business of the agency. If end-users with disabilities are involved with using the product or system as part of a UAT process, select this item.

  7. None:

    If none of your agency ICT acquisitions or ICT development considered the needs of users with disabilities, then select this item.

NOTE: Users with disabilities do not have to be personnel within your agency. For example, usability evaluations could be conducted by a contracting agency, recruiting members of the public, etc.

Question 7

Indicate how often your agency conducts web content user testing with people with disabilities prior to deployment to address all applicable Section 508 standards. (*Required)

Select one:

  1. Agency never conducts user testing with people with disabilities on web content for Section 508 conformance
  2. Agency sometimes conducts user testing with people with disabilities on web content for Section 508 conformance, but generally on an ad hoc basis
  3. Agency regularly conducts user testing with people with disabilities on web content for Section 508 conformance
  4. Agency frequently conducts user testing with people with disabilities on web content for Section 508 conformance prior to deployment
  5. Comprehensive user testing with people with disabilities is integrated into development and deployment, resulting in almost no accessibility issues deployed to production environments
  6. N/A - agency does not publish or maintain any web content

User testing may include users internal and/or external to your agency.

NOTE: See also Understanding for Question 6.


The following applies broadly to this question and to several other questions that employ the same frequency scale:

Frequency

  • Never: 0%
  • Sometimes/Some: Activities that are performed approximately 1%-24% of the time.
  • Regularly: Activities that are performed approximately 25%-59% of the time.
  • Frequently: Activities that are performed approximately 60%-89% of the time.
  • Almost always: Activities that are performed approximately 90% or more of the time.

NOTE that the scale of frequency is not an evenly distributed linear scale.

A specific range is provided for each response (e.g., “25% to 59%”); it is not expected that your agency tracks the exact percentage for every item in the assessment (e.g., “Yes, my agency does XYZ 59.75% of the time, so that’s ‘Frequently’”). Your agency can make an estimate based on your agency’s collective experience (e.g., “Yes, my agency does XYZ more than half the time – maybe even a bit more than half of the time. I think this is something my agency does ‘Frequently’”).

Subjectivity and Interpretation

Many of the question responses contain multiple items which may be difficult to assess as individual elements. For example, one of the responses for Question 55 is:

“d) Contract deliverables that are required to be Section 508 conformant are frequently verified prior to acceptance, including required remediation when necessary.”

There are two parts to this response option: verification, and remediation. Are both items done ‘Frequently’? Is verification ‘frequent’ and remediation is ‘almost always’? There may be cases where there is not an exact answer, but please provide your agency’s best estimation of what happens in practice.

Agency Goals versus Practice

Please select the most appropriate response for what happens in practice at your agency. For example, one of the responses for Question 46 is:

“c) Agency requires a standard Section 508 conformance validation test process in formal policy and web content testers regularly follow the required test process.”

If it is true that your agency includes this requirement in formal policy, but in actual practice web content testers sometimes follow the required test process, please select the response that aligns with your agency practice rather than the requirement. In this situation, your agency response will be b) (Sometimes) rather than c) (Regularly) because the former more accurately reflects day to day activities.

Question 8

Section 508 requires conformance to WCAG 2.0 Level A and AA. Does your agency’s accessibility policy include any other accessibility requirements? (Optional)

Select all that apply:

  1. All or some WCAG 2.0 Level AAA Criteria
  2. All or some WCAG 2.1 Level A Criteria
  3. All or some WCAG 2.1 Level AA Criteria
  4. All or some WCAG 2.1 Level AAA Criteria
  5. Other [input text field]

This question is specifically asking if your agency has implemented additional accessibility standards in agency policy. If your agency policy does not include any accessibility requirements beyond Section 508, please leave this question unanswered.

Each of the four response choices represents doing more than the minimum of WCAG 2.0 AA:

  1. All or some WCAG 2.0 Level AAA Criteria - This is increasing the Level from AA to AAA, but keeping to WCAG 2.0.
  2. All or some WCAG 2.1 Level A Criteria - This is increasing the Level A criteria from WCAG 2.0 to 2.1 while keeping WCAG 2.0 Level AA criteria.
  3. All or some WCAG 2.1 Level AA Criteria - This is increasing both Level A and AA from WCAG 2.0 to 2.1.
  4. All or some WCAG 2.1 Level AAA Criteria - This is doing c, above, plus increasing the Level from AA to AAA.

Question 9

Is Section 508 training mandatory for any of the following employees? (*Required)

Select all that apply:

  1. Required for all Employees
  2. Section 508 Program Managers
  3. Program Managers
  4. Contracting Officer's Technical Representative (COTR)/ Contracting Officer's Representative (COR)
  5. Contracting Officers
  6. Purchase Card Holders
  7. Developers
  8. Web Content Managers
  9. IT Help Desk
  10. Front line support staff
  11. Not Required for Employees

This question asks if any Section 508 training is mandatory for any of the listed employee groups.

NOTE: This question is not asking about which particular topic(s) are covered in Section 508 training, but in answering this question your agency may consider Section 508 training such as, but not limited to:

  • acquisitions,
  • internal development,
  • how to make electronic documents accessible,
  • accessibility testing, and/or
  • other training that provides specific direction on how to incorporate accessibility considerations into processes, policies, and/or procedures.

Question 10

Does your agency use an automated accessibility testing tool(s) for comprehensive, large-scale monitoring of web content? (*Required)

Select one:

  1. Yes
  2. No

An automated testing tool is one where the evaluation of Section 508 conformance requirements is determined solely by the tool. The automated tool(s) may be an application your agency developed, purchased from a vendor, or supplied by another government department.

“Your agency uses” includes tools even if they are used only by contractors to provide information to your agency.

Comprehensive, large-scale monitoring does not include browser plug-ins that only scan a single web page once (i.e., a user selects to run the manual testing tool(s), such as ANDI.)

Question 11

Please select the automated accessibility testing tools used for comprehensive, large-scale web content monitoring. (*Required)

Select all that apply:

  1. WebAIM WAVE
  2. Deque Axe tools (e.g., Axe Auditor/Axe Monitor)
  3. Siteimprove
  4. Google Lighthouse
  5. Level Access AMP
  6. Pa11y
  7. Other [input text response]

NOTE: This question is only required if Question 10 General Information is Yes.

An automated testing tool is one where the evaluation of Section 508 conformance requirements is determined solely by the tool.

Question 12

You indicated your agency uses an automated accessibility testing tool for comprehensive, large-scale monitoring of web content. Please indicate if your agency personnel who use the tool and interpret the results received training on the tool. (*Required)

Select one:

  1. Yes
  2. No, and no intention to do so
  3. No, but training is planned/scheduled
  4. Unknown

NOTE: This question is only required if Question 10 General Information is Yes.

This includes tools even if they are used only by contractors to provide information to your agency. If the training is only provided to contractors who are using the tools, select “Yes”.

Question 13

If your agency uses a manual and/or hybrid ICT accessibility test methodology for web content, which manual test methodology or methodologies does your agency use? (*Required)

Select all that apply:

  1. Trusted Tester 5.x
  2. Manual testing with guided developer tools (e.g. Axe DevTools, Siteimprove, Microsoft Accessibility Insights, AMP, etc.)
  3. Agency-specific test methodology
  4. Assistive Technology testing (e.g., screen reader)
  5. Manual code inspection
  6. N/A- agency does not use a manual and/or hybrid testing methodology
  7. Other and/or provide more details [input text field]

A manual or hybrid test methodology is one where the evaluation of Section 508 conformance requirements is wholly or partially determined by a human tester.

Question 14

Has your agency had to significantly delay an intern, detailee, or employee start date due to lack of ICT interoperability with assistive technology (Section 508, provision 502.1)? (*Required)

Select one:

  1. Yes [ # of significant delays during the reporting period (*required) ]
  2. No [ provide explanation (not required) ]
  3. Unknown

A delay of one month or longer is considered “significant”.

While an explanation for answering “No” is not required, please be encouraged to note if, within the reporting period:

  • an intern, detailee or new hire who uses assistive technology had no delays due to ICT interoperability, or
  • your agency had no new hires, detailees or interns, or
  • your agency had no new hires, detailees or interns who requested assistive technology.

Below are two examples of scenarios where a significant delay was caused by lack of ICT interoperability with assistive technology:

  • A project team regularly references a knowledge repository that has known accessibility issues, but it is used anyway because no current team members have a disability. The agency realizes that a detailee slated to join the team would be unable to perform their work duties due to the inaccessible repository. The agency decides to significantly delay the detailee’s start date until the accessibility issues in the repository are remediated.
  • A summer internship program where the protocol is to provide interns government furnished (GFE) laptops. A fully qualified intern makes a timely request for the JAWS screen-reader to be installed on their government furnished laptop. Due to lack of interoperability, this intern is not able to get JAWS working until 35 days after her peers have begun work, because a non-standard GFE laptop configuration must be approved and ordered to support her assistive technology.

Question 15

If inaccessible ICT was discovered during a detailee’s or intern’s service time, was your agency able to remediate the ICT accessibility issues within the service time to allow the detailee or intern to fully participate in projects and opportunities? (*Required)

Select one:

  1. No accessibility issues were identified during a detailee’s or intern’s service time
  2. Accessibility issues were identified and remediated during a detailee’s or intern’s service time
  3. Accessibility issues were identified and were not remediated during a detailee’s or intern’s service time
  4. Unknown
  5. N/A

Question 16

What services does your agency’s Section 508 program or equivalent offer to ensure compliance with Section 508? (*Required)

Select all that apply:

  1. Assist acquisition officials
  2. Assist developers in designing accessible ICT
  3. Evaluate web content, software, and/or hardware for Section 508 conformance
  4. Provide accessibility training
  5. Provide alternative formats
  6. Create or review documents for Section 508 conformance
  7. None

Services are different from simply providing static resources, such as how-to documents (e.g., how to create accessible PDFs, how to test Microsoft Word documents for accessibility, etc.). Services in this context refer to formal or informal hands-on support to perform a task.

Question 17

Estimate the total number of Fundamental Alteration Exceptions (36 CFR 1194 E202.6) authorized by your agency within the reporting period. (*Required)

Select one:

  1. Open response-whole number
  2. Unknown

Section 508 Exceptions are categorized and explained in https://www.access-board.gov/ict/#E202.6

In the Federal Acquisition Regulations, documentation is required for this exception. Count only those exceptions that have formal documentation. If your agency only has informal exceptions (meaning there is no formal documentation), do not include those in this total.

Question 18

Estimate the total number of Undue Burden Exceptions (36 CFR 1194 E202.6) authorized by your agency within the reporting period. (*Required)

Select one:

  1. Open response-whole number
  2. Unknown

Section 508 Exceptions are categorized and explained in https://www.access-board.gov/ict/#E202.6

In the Federal Acquisition Regulations, documentation is required for this exception. Count only those exceptions that have formal documentation. If your agency only has informal exceptions (meaning there is no formal documentation), do not include those in this total.

Question 19

Estimate the total number of Best Meets Exceptions (36 CFR 1194 E202.7) authorized by your agency within the reporting period. (*Required)

Select one:

  1. Open response-whole number
  2. Unknown

Section 508 Exceptions are categorized and explained in https://www.access-board.gov/ict/#E202.6

In the Federal Acquisition Regulations, documentation is required for this exception. Count only those exceptions that have formal documentation. If your agency only has informal exceptions (meaning there is no formal documentation), do not include those in this total.

Question 20

What are your primary challenges in implementing and complying with Section 508? (*Required)

Select all that apply:

  1. Lack of support from management
  2. Lack of resources
  3. Weak Section 508 policy and/or procedure
  4. Lack of general awareness
  5. Lack of or inadequate training
  6. Lack of or inadequate authoring, development, and/or testing tools
  7. Lack of or inadequate considerations at the early stage of the ICT life cycle management process
  8. Lack of or inadequate knowledge by acquisition officials
  9. Lack of or inadequate knowledge by web content managers
  10. Lack of or inadequate knowledge by developers
  11. Lack of or inadequate knowledge by vendors
  12. Poor quality of vendor’s ACRs
  13. Other [input text field]

Question 21

Of the following options, select the top five items that would be the most helpful in implementing Section 508 at your agency. (*Required)

Select five:

  1. Additional funding to aid Section 508 implementation
  2. More ICT accessibility subject matter experts
  3. More staff adequately trained to implement Section 508 requirements
  4. Stronger Section 508 policies and/or procedures
  5. Stronger Section 508 awareness across the agency
  6. Stronger Leadership support
  7. Increased implementation of established policies/procedures
  8. Agency-wide access to tools necessary to create accessible digital content
  9. Better access to ICT testing tools
  10. More government-wide ICT testing guidance
  11. Better guidance for buying/selecting accessible ICT
  12. More accountability for Section 508 implementation across the technology development lifecycle
  13. Other [text input field]

Reviewed/Updated: May 2023

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