On December 21, 2023, the Office of Management and Budget (OMB) published memorandum M-24-08 Strengthening Digital Accessibility and the Management of Section 508 of the Rehabilitation Act. The memo gives recommendations and direct instructions to agencies on building stronger accessibility programs. The first action must be completed within 30 days, followed by more tight deadlines that will make accessibility a focus area for many agencies in 2024.
This new memo is perhaps the biggest shift in the federal government’s accessibility landscape since the Section 508 refresh in 2017. Ad Hoc’s Accessibility Beyond Compliance Playbook is a great resource for building a strong and sustainable approach to accessibility. But for an agency that needs to significantly level up to meet OMB’s new guidelines, just figuring out where to start may feel daunting.
Here are some best practices for setting up your digital accessibility program.
Empower your Section 508 program manager
The new OMB guidelines state that agencies must identify an agency-wide Section 508 program manager within 30 days. Choosing a program manager and ensuring that they have the tools they need to be successful is the first big step toward building your accessibility program. That means:
- Choose someone with a solid background in accessibility. They need a good understanding of how users with disabilities interact with their devices.
- Involve them in procurement decisions. The OMB memo highlights the importance of acquisitions, and your program manager should be actively involved. You can do a lot to improve accessibility just through contract language.
- Give them the authority to block products from launching. When a critical accessibility barrier makes it into production, it impacts real people – and it will take more effort to fix.
Who you select as your program manager and what kind of influence they have in your organization will go a long way toward setting your accessibility culture.
Start thinking about policy
OMB instructs agencies to take several immediate actions with some aggressive deadlines:
- Create or update an accessibility statement on all agency websites within 90 days. Here’s a solid example from the Department of Veterans Affairs. W3C also provides some guidance on their website.
- Create a mechanism for receiving accessibility feedback, and begin tracking issues generated from that feedback, within 90 days.
- Conduct a “comprehensive assessment of agency policies” and make a plan to update those policies and the agency’s digital strategy to reflect strengthened accessibility requirements within 180 days.
- Set up an annual reporting process to track progress and compliance.
Several other policy considerations are also highlighted by OMB, but as you develop your accessibility policies, here are some good places to start:
- Create an accessibility roadmap for your agency. Your roadmap will be unique to your agency, but consider landmarks like writing your accessibility statement, auditing all existing products, resolving critical defects, and conducting research with disabled users.
- Adopt the Web Content Accessibility Guidelines (WCAG) version 2.2 level AA as your minimum conformance level. This exceeds Section 508 (currently aligned to WCAG 2.0 AA), but it’s consistent with OMB’s guidance on implementing 21st Century IDEA. This might seem overwhelming, but adopting higher standards of accessibility is a powerful statement that your agency sees the importance of accessibility beyond basic compliance and wants to create a sustainable, inclusive community for everyone. Not only that, it’s a great way to ‘future proof’ your work as accessibility standards evolve and adopt new levels of compliance over time.
- Set a schedule for auditing existing digital products. Your review cadence depends on your organizational needs and your staffing, but it’s important to establish that accessibility audits are an important part of ongoing maintenance.
- Create a defect severity/prioritization rubric. Issues that could trigger health conditions or put users at immediate risk should be identified as priorities, followed by issues that make task completion impossible, and finally followed by issues that make task completion difficult.
- Adopt semantic HTML as your preferred document format. HTML is readable by every web browser, extendable with CSS and JavaScript, and (most importantly) accessible out of the box. Providing users with the option to export to PDF or other formats is fine, but your agency should commit to an HTML-first policy.
It’s important to remember that these should apply to all products that your agency relies on — public-facing and internal, in-house, and purchased from a vendor.
Identify missing processes and personnel
Your accessibility program should be built to identify barriers and resolve them in both new and existing digital products. Assess whether your agency has:
- A full inventory of existing digital products, PDFs, and other assets for testing and remediation
- A system to track and prioritize accessibility defects
- Communication channels for sharing accessibility defects with stakeholders, product teams, and vendors
- A way to assess vendor VPATs for accuracy
- A way to provide course corrections for new products as they are built
- An escalation path for resolving disagreements about defect severity and proposed solutions
If you don’t have processes for each of these, start building them now. Many are closely tied to your broader digital governance program. If you have strong governance already, adding accessibility to the mix will be comparatively easy. If you don’t already have a strong governance program, consider using accessibility as an excuse to build that program. Adopt the US Web Design System, implement robust QA standards, and conduct a comprehensive information architecture review.
As you consider changes to your processes, identify the personnel who will be responsible for accessibility and the new roles that will need to be created. Consider defining specific roles like accessibility strategist, accessibility researcher, accessibility designer, accessibility engineer, and accessibility tester. Each of these roles interacts with a team differently, and you’re unlikely to find one person who can do everything for everyone. As you review bids or plan your direct staff hiring, make sure all of your accessibility needs are covered.
One more thing to remember: There’s a growing demand for accessibility expertise in both the public and private sectors. Budget for a competitive job market.
Engage your disabled users
One of the challenging parts of digital accessibility is that you don’t get to decide whether your digital presence is accessible — your users do. Even if you’re following WCAG to the letter, you might end up with experiences that are technically accessible but still introduce practical barriers to actual disabled users.
Getting feedback from real live humans is critical. This can be accomplished in multiple ways:
- Invite people who complete your accessibility feedback form to participate in follow-up interviews or focus groups
- Conduct user research studies with assistive technology users
- Co-design with users with disabilities
- Invite representatives from disability advocacy organizations to participate as advisors or stakeholders
This will all take time and budget to achieve, so it’s okay to start slow. But it can’t be emphasized enough: people with disabilities know what works for them and what doesn’t. Listening to them is a critical part of building an accessibility program.
Shift left in small ways (and then big ways)
OMB instructs agencies to cultivate a positive culture of digital accessibility, creating “a sustainable and disability-inclusive agency workplace culture that aids in establishing and maintaining digital accessibility.” The shorthand for that in the accessibility world is “shift left.”
Imagine your product lifecycle as a timeline. Toward the right are all the things that happen later (product launch, press release, pizza party). Toward the left are the things that happen earlier (problem statements, determining scope). Somewhere in the middle is all of the research, design work, and coding that goes into building a digital product.
If you start thinking about accessibility when the product is already in production, you’re about as far to the right on that timeline as you can get. Shifting left could mean:
- Working with disabled users to create an inclusive product roadmap and definition of done
- Adjusting wireframes or prototypes based on anticipated assistive technology interactions
- Fixing accessibility issues while still actively coding the product
Each time you shift left you save a lot of effort downstream. Accessibility is easier when it’s baked in from the beginning.
But when you’re starting your accessibility program, this might be a big cultural shift at your agency. Start by shifting left in small ways:
- Complete an accessibility audit before each product launches
- Use automated accessibility testing tools as part of your deployment process
- Require front-end engineers to complete an accessibility self-evaluation before launch
- Require designers to annotate their prototypes with accessibility information
- Add plain language guidelines to your content style guide
As your product teams build these habits, you can start shifting left in bigger ways:
- Embed accessibility specialists with product teams to help define accessibility goals, conduct design reviews, and provide immediate feedback to engineers
- Conduct user research sessions with assistive technology users
- Provide accessibility training for your teams, plus licenses for assistive technologies
- Conduct accessibility-informed performance testing
- Recruit and hire people with disabilities into technology roles
Your agency may not be ready to shift left in big ways – not yet! But finding incremental ways to ‘shift left’ helps create that positive culture of digital accessibility. And by creating products with an accessibility-first mindset, you’ll mitigate potential risks, and provide meaningful access to people who depend on your services every day.
