Section 508 has been a requirement of federal government agencies since 1998, requiring agencies to provide accessible digital resources to all federal government employees and the general public. Enforcement of Section 508 has not always been consistent, despite its mandate.
In 2023, the Office of Management and Budget (OMB) enforced accessibility reporting required under Section 508, which had fallen by the wayside for decades. The results revealed that most federal government agencies’ digital content failed to meet Section 508 requirements. To demonstrate renewed commitment to digital accessibility, the Office of Management and Budget (OMB) has released updated guidance entitled M-24-08 Strengthening Digital Accessibility and the Management of Section 508 of the Rehabilitation Act. This Guidance is designed to help agencies manage and create sustainable accessibility best practices to achieve Section 508 compliance.
While this Guidance was created for federal government agencies, any organization can use these suggestions to build and maintain accessible digital resources to comply with Section 508 and the ADA. The following are the OMB requirements that you can apply to your organization:
Develop a comprehensive plan and ensure you have the necessary resources to make accessibility achievable. Each agency’s CIO must provide direction for the digital accessibility program, and a 508 program manager must be appointed. Section 508 program managers must provide the training, staff, and tools to successfully implement requirements. Agencies must also have clear and documented expectations about accessibility requirements and procedures for remediation, testing, and addressing complaints and issues. A digital accessibility statement must be posted to the website to communicate these initiatives to the public and provide a method for reporting complaints.
Buy Accessible Products and Services
Choose products and services that align with Section 508 standards by using the variety of tools developed for such assessment. Vendors may provide documentation demonstrating their product’s accessibility, which should be verified and validated during acquisition and after procurement if the product is updated.
Design and Develop Accessible Digital Experiences
Agencies should build accessibility into every digital environment from the very beginning of the design process. When building and developing new technology, agencies should consult and collaborate with end-users to suit a variety of accessibility needs. Technology should be built to be compatible with a variety of assistive technologies.
Once built and deployed, technology should be tested and retested often to ensure updates and edits do not compromise accessibility.
Create, Communicate, and Deliver Accessible Content
In addition to creating accessible digital platforms, agencies need to make sure their content is accessible as well. As the guidance points out, “Increasingly, government information and services are provided digitally, which means that agencies must intensify efforts to ensure that electronic information is accessible, regardless of the information’s specific electronic or digital format, medium, or content delivery channel.”
Agencies should develop formalized strategies and procedures to ensure all content is accessible from the beginning. That often includes providing text alternatives to non-text elements, such as adding captions to video or audio content, alt text to images, or tagging to PDFs.
PDFs are notoriously difficult to make accessible. If you’re not sure where to start, download our Guide to PDF accessibility or contact us. Equidox software is also capable of exporting tagged PDFs in HTML format, which is another recommendation of the guidance.
Evaluate, Monitor, Collect Feedback, and Remediate for Accessibility
Accessibility is not a “one and done” process. Every edit or change made to a website could impact accessibility. Have a process in place to continually monitor updates and new website additions to make sure the content and website functionality remain accessible. There’s always a chance something can slip through the cracks, unintentionally “breaking” the accessibility of a website. Make sure you have processes for when a person with a disability reaches out to your agency or organization with an accessibility issue. Respond and address the issue immediately to maintain website accessibility and also prevent lawsuits.
Cultivate a Positive Culture of Digital Accessibility
Getting everyone involved with accessibility means no single person is responsible for the accessibility of all content. The guidance recommends training all staff to make commonly created content accessible, and to make all staff familiar with digital accessibility policies. Beyond creating accessible documents, other groups should be trained on accessibility practices that align with their responsibilities.
- Training acquisition professionals to evaluate and procure accessible ICT
- Training help desk professionals to assist assistive technology users
- Training communications professionals to ensure the messages they distribute are accessible in the formats they produce
- Certification of those who are tasked with evaluating digital assets for accessibility through a Section 508 conformance training program
Finally, and perhaps most importantly, people with disabilities must be consulted to ensure the technology and content actually achieves its intended goal of accessibility. If people with disabilities cannot use the ICT, then it’s not accessible and does not meet the goals of Section 508.
Immediate Agency Actions
This guidance also enacts several immediate actions.
|Report the name of agency Section 508 program manager to the OMB.
|Ensure a digital accessibility statement is posted on their website
|Enact policies for receiving and addressing public feedback
|Assess policies and procedures to “ensure that ICT accessibility considerations are incorporated in all relevant agency functions”
|Make plans to update any policies and digital strategies to ensure they comply with Section 508 and this Guidance
Immediate Government-Wide Actions
|Review and update the resources on section508.gov
|Review and determine opportunities for expanded Section 508 training and certification opportunities
|Develop best practices and guidelines for hiring qualified accessibility staff
|Scale the comprehensive digital accessibility testing approach
|Establish a conformance reporting program for ICT procurement and establish a central repository for reporting documentation
|Establish a government-side service to help agencies procure accessible ICT and related accessibility services
|Explore opportunities to procure assistive technologies and related services to federal agencies
|Explore developing a Federal digital accessibility design and testing lab to provide research, data, and usability testing
Transferable Accessibility Best Practices
While this guidance was released for federal government agencies, all organizations can apply the recommendations to their own digital accessibility policies to avoid lawsuits under the ADA and include everyone.
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Nina comes to Equidox with years of sales and marketing experience from a variety of industries and holds a BS in Language Arts Education. Nina has a passion for words, storytelling, and information, which she believes everyone should have access to regardless of ability. After spending time as a teacher with a blind student, she became much more aware of the limitations and abilities of web accessibility, and how essential it is to those experiencing disabilities. “Being able to access information equally ensures that everyone has an equal opportunity for education, employment, and success in life.”