Government-wide Section 508 Assessment Frequently Asked Questions

All Federal departments or agencies covered by Section 508 of the Rehabilitation Act of 1973 (29 U.S.C. 794d) are required to fill out the Annual Section 508 Assessment.

The majority of the questions are required but there are several optional questions. Some questions are dependent on previous answers and will not be provided if they do not apply to your agency. For example, if you select that your agency does not use automated testing tools, you will not be presented additional questions about automated testing tools in your agency.

Agencies may use the following spreadsheet (XLSX) to help collect the information; however, responses must be submitted using the reporting tool. You may also simply print the criteria questions directly from Assessment Criteria pages.

If an agency is unable to provide the requested information because it is currently unavailable, the agency should select “Unknown” or “N/A”. In rare instances, you may need to input “0” into a text field. Agencies will have opportunities to collect any unavailable information during future reporting periods of the annual assessment.

If your agency does not have 10 web pages (intranet/internet), 10 electronic documents, or 5 videos, please test the number of web pages, documents, and/or videos you do have and report on those. Please select N/A when additional web pages, electronic documents, or videos do not exist.

If you do not have resources available to complete the requested testing of ICT products prior to the submission deadline, please test what you can. If you cannot test anything, please select “Unavailable- agency does not have resources to test”. For Question 40 regarding ICT solicitations, if you are unable to review any of the previous 10 solicitations, please select “Unknown”.

Please reach out to the GSA Government-wide IT Accessibility team at Section.508@gsa.gov in order to verify point of contact for your agency and resolve access issues.

The reporting tool will close on August 11, 2023 at 11:59 pm Eastern Standard Time. No responses can be submitted or altered after that date.

Yes, you may use a vendor’s ACR to report whether or not the ICT product(s) referenced in Conformance questions 82, 83, 84, 85, 86, 88, and 90 fully conforms to all applicable Section 508 standards.

Yes. The GSA Government-wide IT Accessibility team will host office hours starting April 11th. Please check the Support page and Events page for all sessions and how to register. The GSA Government-wide IT Accessibility team will also use the May and July Section 508 Program Manager huddles will dedicate time to answering questions on the report.

Agency components (e.g., bureaus, sub-agencies, or major organizational divisions as determined by the agency) must be reported independently of their “parent” agency. “Parent” agencies must limit reporting to that of the parent agency and not include reporting from component agencies.

Yes, component level data will be shared with the parent agency upon submittal.

GSA, in consultation with OMB, will prepare and submit to Congress a comprehensive assessment that includes information identifying the metrics and data collected, compliance by each agency, and by the federal government generally, a detailed description of the actions, activities, and other efforts made by GSA over the year preceding to support compliance at agencies and any planned efforts in the coming year to improve compliance at agencies, and a list of recommendations that agencies or Congress may take to help support that compliance.

The goals of GSA’s analysis are to:

1. Gain a deeper understanding of the state of ICT accessibility across the federal Government
2. Identify opportunities to educate the workforce, and reduce redundancies, remediation, and waste
3. Improve collaboration across agencies, develop common solutions, and enable future shared services; and
4. Inform recommendations that improve the implementation and management of Section 508 across the federal government to ensure that people with disabilities have equitable access to information and data.

GSA and OMB will evaluate and approximate agency maturity across the following core dimensions:

1. IT Accessibility Program Office - Measuring how well program governance, risk management, and compliance is managed.
2. Policies, Procedures, and Standards - Measuring the extent to which agencies establish, integrate, and comply with policies, procedures, and standards that support ICT accessibility.
3. Communications - Measuring how well agencies communicate and monitor all ICT accessibility program activities, including tracking and resolving non-compliance issues.
4. Content Creation - Measuring the extent to which agencies make their digital content (e.g., websites, documents, video and other media, social media, electronic forms, and digital signatures) accessible.
5. Human Capital, Culture, and Leadership - Measuring your agency's leadership and professional development and how ICT accessibility is integrated into mission-related strategic planning.
6. Technology Lifecycle Activities - Measuring the extent to which agencies incorporate ICT accessibility requirements into enterprise architecture, design, development, testing, deployment, operations, and maintenance.
7. Testing and Validation - Measuring the extent to which agencies conduct testing and validation of ICT accessibility and Section 508 conformance claims.
8. Acquisition and Procurement - Measuring the extent to which agencies include, review, and validate contracts for ICT accessibility compliance requirements.
9. Training - Measuring the extent to which agencies train stakeholders on roles and responsibilities related to compliance with Section 508 practices and requirements.

The report will be submitted to Congress no later than December 29. The report will also be made available on a public website.

Submitted agency data will be maintained in a publicly available, machine readable format (i.e. as a 44 U.S.C 3502 (20) open Government data asset). Other organizations may choose to use this data for their own purposes.

When reporting the total number of full-time equivalents (FTEs) your agency has in its Section 508 Program office or equivalent, this number should reflect the FTEs of individuals who directly support the activities of the Section 508 Program office or equivalent, and not individuals responsible for accessibility as a matter of practice within their regular duties in other organizational business units.

When it is not possible to ascertain the number of employee or contractor hours being spent on the agency Section 508 Program office or equivalent, please estimate. Determine the percentage of 508 work being performed on the contract, then apply this percentage to the total cost of the contract, and divide that dollar value by the average cost of each FTE.

This is a self-report assessment with 11 dimensions which are categorized as:

1. General Information questions ask about information and metrics related to the activities of your agency's Section 508 Program’s (or equivalent) activities.
2. IT Accessibility Program Office - Measuring how well program governance, risk management, and compliance is managed.
3. Policies, Procedures, and Standards - Measuring the extent to which agencies establish, integrate, and comply with policies, procedures, and standards that support ICT accessibility.
4. Communications - Measuring how well agencies communicate and monitor all ICT accessibility program activities, including tracking and resolving non-compliance issues.
5. Content Creation - Measuring the extent to which agencies make their digital content (e.g., websites, documents, video and other media, social media, electronic forms, and digital signatures) accessible.
6. Human Capital, Culture, and Leadership - Measuring your agency's leadership and professional development and how ICT accessibility is integrated into mission-related strategic planning.
7. Technology Lifecycle Activities - Measuring the extent to which agencies incorporate ICT accessibility requirements into enterprise architecture, design, development, testing, deployment, operations, and maintenance.
8. Testing and Validation - Measuring the extent to which agencies conduct testing and validation of ICT accessibility and Section 508 conformance claims.
9. Acquisition and Procurement - Measuring the extent to which agencies include, review, and validate contracts for ICT accessibility compliance requirements.
10. Training - Measuring the extent to which agencies train stakeholders on roles and responsibilities related to compliance with Section 508 practices and requirements.
11. Conformance Metrics that measure how well your agency’s ICT meets technical standards for accessibility, including websites, electronic documents, and multimedia

1. Never: 0%
2. Sometimes/Some: Activities that are performed approximately 1%-24% of the time.
3. Regularly: Activities that are performed approximately 25%-59% of the time.
4. Frequently: Activities that are performed approximately 60%-89% of the time.
5. 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.

Yes. At the end of the assessment tool, there will be an open-ended question (see Question 105 General Information) where you may write any additional details about your program, answer selections, etc. Please use this form field to provide any additional narrative you would like. When referencing a specific question, please put the Dimension (e.g., Conformance Metrics) and the question number (e.g., Question 76).

Registered POCs will recieve, on or about June 1st, an email from “Section.508@gsa.gov” with instructions to access to tool. If you do not receive this email, check your email’s junk folder.

NOTE: Since the email is sent from a collection tool, the email sender may appear as “ogpsurveysupport@research.gsa.gov”.

No. While this data collection asks some similar questions, it is more robust in its scope.

Section 752 is referencing a specific section of the Consolidated Appropriations Act of 2023 which stipulates timelines and requirements for OMB, GSA, and USAB to collect data on government-wide accessibility.

To update the list of agency/component dropdowns within the designee registration tool, please contact Section.508@gsa.gov. You may also select “Other” in the registration link for your agency POC/designee; a text field is presented on the next page for you to input the appropriate agency/component.

Yes. The same POC can register for multiple agencies but each agency will have its own specific link to the online response tool. The designated POC will need to ensure the correct link is used to report agency-specific responses.

Agencies that fail to complete the assessment by the deadline will be listed as non-responsive; which will be conveyed to Congress in the summary report.

Please limit agency registration to one POC per agency. Once your agency POC has submitted thier information in the POC registration tool, they will receive a unique link for your agency’s report submission. Once the response tool link is opened, the tool will lock to that specific user. To unlock the response tool for a different user, you must contact GSA at Section.508@gsa.gov for a manual unlock.

GSA has not yet drafted an outline. GSA anticipates similarities to the most recent DOJ/GSA report but with additional narrative text. GSA anticipates the report will include data visualizations, diagrams, and narrative analysis to accompany recommendations.

When responses are submitted, GSA will receive notice from the online response tool. GSA will then package those responses to provide parent agencies on a yet-to-be-determined regular basis.

No, the reporting tool will not have the functionality to be able to portion out different sections of questions for other individuals to submit responses. Each agency should coordinate information gathering outside of the response tool for the agency point of contact to submit on behalf of their agency.

Yes, GSA anticipates having office hours through early August, though the frequency may vary. Please continue to check the Events page page as office hours are scheduled.

Select the best response that is most representative of your agency’s current status in that area with respect to disability.

It is acceptable if an agency utilizes parent agency processes, policies, and/or services and each agency should answer appropriately for how they utilize or implement the parent agency process/policy/service, etc. For example, it is acceptable to answer that an agency has a complaint process even if that agency relies on the complaint process of the parent agency.

Where agency-specific data should be reported are for questions such as FTEs and budget; an agency should not report parent agency budget/resources but instead give an honest report of their specific agency. Agency-specific data should also be reported for Conformance Metrics and most of the General Information questions; agencies should submit their own data without duplication of the parent agency when answering specific outcome-related questions.

Your agency’s responses cannot be edited after submission without manual steps to unlock your response. If edits are necessary after submission, email GSA’s Government-wide IT Accessibility Program at section.508@gsa.gov. Edits or submissions will not be permitted after the submission period closes on August 11, 2023. Please note that unlocking your agency’s assessment may not be immediate; please carefully review your answers prior to submission to avoid any additional delay.

Office Hours are not recorded and transcripts are not available for distribution. However, based on these sessions, our team regularly updates these FAQs and the “Understanding Question [X]” content associated with assessment criteria to help agencies better understand each question. Please note that not all criteria have additional Understanding content.

We recommend gathering all responses prior to accessing and entering data into the submission tool. This will facilitate your agency’s ability to start at the beginning of the submission tool and answer questions in order. We encourage agencies to use the assessment spreadsheet (XLSX) to gather responses.

The submission tool does not have a Back button, however, the Table of Contents allows you to move between sections of the assessment once all required questions on the current screen have been completed. Use the Table of Contents to navigate between sections to ensure complete and accurate responses for each applicable question.

“Partially supports” denotes that there is at least one component of the ICT product that fails that criterion, thus the ICT does not fully conform to Section 508 requirements. Report “no” for any question that asks if that ICT is fully conformant.