Investigation of Best Practices for

Maintaining Section 508 Compliancein

U.S. Federal Web Sites

Jonathan Lazar and Abiodun Olalere

Department of Computer and Information Sciences and

Universal Usability Laboratory

TowsonUniversity

8000 York Road

Towson, MD21252USA

;

To appear in the Proceedings of the

Human Computer Interaction International 2011 Conference

Abstract. The purpose of this paper is to discuss best practices in Web site compliance with Section 508 among Federal agencies. Individuals involved with 508 compliance at three different federal agencies were interviewed, to determine how their agencies meet 508 compliance requirements. The discussion includes specific evaluation methods used, such as how users with disabilities are involved, how often they perform usability testing, and what software tools are used on an ongoing basis for evaluation. It also examinesthe policies in place, such as the possibility of losing a content management system account for repeatedly posting non-compliantWeb content. We also compare the best practices in accessibility compliance from U.S. Federal agencies to approaches taken in other countries, such as Sweden and the United Kingdom.

Keywords: Section 508, accessibility, best practices, Web site, compliance, federal, government

1.Introduction

In the United States, Section 508 of the Rehabilitation Act was signed into law in August 1998. The main purpose of this law was to remove barriers in information technology that people with disabilities face, and to encourage the development of technologies that will make it possible and easy for people with disabilities to have equal access to technology the same as people without disabilities. An accessibleWeb site is a Web site designed in such a waythat people with disabilities can use it[9]. Section 508 specifically requires all Federal government agencies to develop, procure, maintain, and use electronic and information technology that will be accessible to everyone, including people with disabilities. As a part of Section 508 regulations, all federal agencies must have Web sites that are accessible for people with disabilities. Although these regulations have been in effect since 2001, compliance with the law is an ongoing challenge [12].

1.1Why Web Accessibility Problems Persist

Several papers have pointed out that compliance with the Section 508 law remains low among Federal government Web sites despite the fact that the law has been in effect for nearly 10 years [8,12,16] and various reasons, some of which are listed below, have been discussed as possible causes for low compliance.

Research hasshown that manyWeb developers do not see accessibility as a priority [10]. The goal of each agency often influencescompliance with Section 508 and the level of importance accorded to Web site accessibility. Some Web sites focus only on certain aspects of accessibility, and there areineffective communication channels between government Web sites and users, and a lack of a standardized approach to implementing Section 508[8]. Also, there is low involvement of users with disabilities in improving Web accessibility, and there is difficulty in integrating accessibility guidelines in existing developers’ workflow [3]. The current practices among Web developers are that both usability and accessibility issues are treated in a reactive rather than proactive manner. Akoumianakis and Stephanidis also noted that accessibility design guidelines are often seen as an afterthought [1]. Finally, some Webmasters outright object to the idea of making their Web sites accessible and believe that they would make their Web sites accessible only when the government forced them to do so [10].

1.2Solutions to Web Accessibility Problems

Recommendations have been presented by many other authors towards making the Web accessible. Savidis and Stephanidis discussed the need to have a systematic process for designing universally accessible interfaces [14]. Spinuzzi suggested using anopen-source content management system (CMS) in which accessibility guidelines are already programmed, for Webdevelopment [15].Bergel, Chadwick-Dias and Tullis found out that if Web developers are able to experience simulations of specific impairments, they would produce better designs that would be both usable and accessible[2]. Sometimes developers have good intentions to develop accessible content and also work towards building accessible Web sites, but Theofanos and Redish noted that a Web site may technically meet all Section 508 guidelines but still remain unusable [17]. This notion was also shared by Murphy, Malakhoffand Coon from the lessons learned in their evaluation of the usability and accessibility of an online form for census data collection for the US Census Bureau [11]. Some general suggestions from the research literature:

  • There is a need to consider accessibility very early in the development process
  • Content development must be guided by knowledge of users’ reading behavior on the Internet.
  • A life cycle approach that integrates usability and accessibility engineering processes with software engineering processes is needed.
  • More research is needed on ways to adapt user interfaces for successful use by people with hand tremors, low spatial ability, and other borderline disabilities, as well as for use by people with cognitive disabilities.
  • A requirement to design and test for accessibility needs to be stated clearly in requests for proposals from outside contractors; and submitted proposals need to be evaluated in terms of their understanding of and provision for achieving accessibility.
  • Agencies should require independent user testing with participants who have visual, cognitive, auditory, and motor disabilities as well as clusters of disabilities.

2.The Need for Best Practices

There is a growing effort among Web accessibility advocates to offer solutions to the existing Web accessibility problems. While it is worrisome that with guidelines and resources in place, so many Web interfaces continue to be inaccessible for people with disabilities [12], it is important to learn about HOWthose federal agencies which ARE in compliance with Section 508 regulations are keeping their Web sites compliant. There is a need to document what specific steps those agencies are taking and how they are incorporating Section 508 compliance into their development and management processes.The availability of best practices will assist others in not only making a Web site 508 compliant, but keeping a Web site compliant on an ongoing basis.

2.1Best Practices in Other Countries

Sweden

Swedish government Web sites are considered relatively accessible and there are reasons attributed to Sweden’s success. According to a survey carried out in 2007, 90% of individuals responsible for Swedish public administration Web sites are familiar with the country’s accessibility guidelines[18]; and in another study conducted on accessibility (compliance with WCAG) evaluation of government and parliament Web sites across EU member states, Sweden was ranked first in terms of accessibility compliance [7].

Sweden’sWeb accessibility success is attributed to regular evaluation, transparency,and understanding of Sweden’saccessibility guidelines by the Web administrators of the public administration Web sites. Gulliksen, von Axelson, and Persson et al.still advocate for both legislation (no existing legislation requires accessibility) and a process that emphasizes usability and accessibility to ensure that Web sites are very accessible. This shows that while regular evaluation and transparency are important, they will not take the place of adequate legislation, to encourage or enforce compliance [6].

United Kingdom

Recently, the British Standards Institution (BSI) launched a new Web accessibility code of practice, known as BS 8878, which is aimed at addressing the challenge of digital inclusion. Backed by the UK Equality Act 2010, which obligates all information providers to ensure that their Web products are accessible, the BS 8878 is to be followed by both public and private sectors. The guideline contains a comprehensive guide for Web production teams on how they can best build accessible Web sites and how the best practices can be integrated into their organizational and development process to ensure continuous accessibility. Included in the recommendation is the inclusion of people with disabilities in the development process, and using automated tools to assist with accessibility testing. The standard is prepared with the belief that if accessibility is built in, everyone wins [5].

The British government’s effort towards making the Web accessible, coupled with the increased public awareness effort by organizations such as Citizens Online’s “Fix the Web” campaign ( is a testament to the fact that there is a lot of momentum with a very positive outlook of improving access to the Web forpeople with disabilities.

Canada

In Canada, the government’s accessibility standards (Common Look and Feel for the Internet: Standards and Guidelines) have been in effect since 2001. They were developed to ensure that federal government Web sites are accessible to people with disabilities, but implementation was not effective. Following a suit brought by a blind Toronto woman concerning inaccessibility of some Federal government Web sites, on November 30, 2010, a Federal Judgeruled that the Canadian Federal government must make their Web sites accessible within 15 months. The court promised to monitor the implementation of this ruling [4]. Again, this scenario is proof that individual citizen action is what often leads to increased enforcement.

3.0Data Collection

The best practices in 508 Compliance were documented for three different USfederal entities: The Recovery Accountability and Transparency Board (“The Board”), the Food and Drug Administration (FDA), and the U.S. Census Bureau. One of the co-authors was personally involved with 508 compliance at “The Board,” and interviews took place with individuals involved with 508 compliance at FDA and Census Bureau. Table 1 provides a summary of the best practices at all three agencies.

3.1US Census Bureau

The US Census Bureau is a federal government agency under the Department of Commerce, responsible for conducting the decennial census, and other data collection, about the population of the United States. Several data outputs from the US Census Bureau serve as useful input into government, business, organizational and individual decision making.

To ensure compliance with the Section 508 regulations, the US Census Bureau has a Section 508 coordinator with the responsibility of planning, monitoring and follow-up on issues relating to compliance with Section 508. The US Census Bureau does not use a Content Management System (CMS), but instead encourages the use of page templates, which are built for accessibility.

A number of tools which include HiSoftware Compliance Sheriff, HiSoftware AccVerify, and JAWS are used by the agency to ensure compliance.HiSoftware Compliance Sheriff is run over on 90% of the Census Bureau Web sites on a monthly basis to check for Section 508 compliance, and the reports are forwarded to the content owners within the agency. A desktop version of HiSoftware AccVerify is readily available to all developers for validating Webcontent for compliance at the point of development.

Blind individuals who use JAWS regularly participate in usability tests. The usability lab staff, who often assist the 508 coordinator,perform expert reviews on Section 508 compliance. Contractors with the Census Bureau are also required to comply with Section 508, but when contractors do not comply (as has sometimes occurred), the usability lab staff usually inspects and makes specific suggestions to contractors on what must be fixed so that the Web pages areaccessible.

To ensure ongoing accessibility compliance and to promote accessibility among its employees, Section 508 news and tips are usually included in the Web site Services and Coordination Staff (WSCS) monthly Information Technology newsletter. The US Census Bureau also has an accessibility statement on its Web site. While most Web content is accessible, many older PDF files are not Section 508-compliant, as there is insufficient time and resources to go back and retrofit them.The Census Bureau also had previously posted someresearch reports documenting usability and accessibility testing involving usability lab staff on its Web site, but no longer seems to do so. Examples of such reports are “An Accessibility and Usability Review of the NotifyMe Web Application”, “An Accessibility and Usability Review of the Articulate and Captivate E-Learning Software Packages”, and “An Accessibility Evaluation of the Classification Analytical Processing System Application” [13]. When a specific application is thoroughly checked by the Census Bureau usability lab staff, PDFs are evaluated for 508 compliance at that time.

3.2US Food and Drug Administration (FDA)

The Food and Drug Administration (FDA) is an agency of the United States under the US Department of Health and Human Services (HHS). It is responsible for regulating, protecting and promoting public health in the US.

The FDA usesa Content Management System as a core strategy to ensure an accessible Web site. The FDA has more than 800 content contributors on their Web site and to properly manage the content and ensure compliance with Section 508, a Section 508 compliance group was formed and given the goal of ensuring and promoting Section 508 compliance among FDA employees. The group coordinates a panel of users (includingblind users) who are involved in ongoing usability testing to improve compliance.The group meetsbi-weekly via a conference call to perform usability and accessibility testing, discuss problems and provide feedback.Before creating a CMS account for each content contributor, the content contributor is required to sign a contract stating that they will only post 508-compliant materials and noting that users can lose accessto the CMS for repeatedly posting inaccessible content. In situations wherecontent contributors want to post non-508-compliant materials (for instance, due to the need to post emergency health information quickly), the content contributors must first get a waiver approved, and then must provide a phone number for people to call, and give an estimated timeline for when the non-508-compliant material will be repaired and made compliant(

The FDA holds a monthly meeting of all 508 compliance coordinators within the agency. Also, training modules for 508 compliance, including video-on-demand, are available to all FDA employees, and section 508 compliance is always presented to employeesin the context of overall usability. The 508 compliance team at FDA is currently working on getting Section 508 mentioned in the FDA new employee orientation, and working with HHS to get mandatory annual accessibility training for all employees.

3.3Recovery Accountability and Transparency Board (Recovery.gov)

The American Recovery and Reinvestment Act (the Act) became law on February 17, 2009. The Act required the establishment of a user-friendly Web site, Recovery.gov, to provide the public with information on the progress of the economic recovery effort. Therefore, an important requirement of Recovery.gov was to make the Web site accessible to users with disabilities, such as visual, hearing, and motor impairments. While a small Web site (called Recovery.gov 1.0) was launched by the GSA and the Office of Management and Budgeton February 17,2009, the day the Act was signed into law, this was a placeholder until a full Web site (called Recovery.gov 2.0) was launched on September 28, 2009.

After the initial stage of eliciting requirements from potential users, prototypes of the Recovery.gov 2.0 Web site were created. A user-centered design approach was used during the design and development stages. This includedten two-hour focus groups(including users with visual impairments) conducted in 5 cities with a total of 105 participants, among which 4 had low vision, 3had hearing impairment and 5 had motor impairment. The output of this research was used for determining optimal layout, design and nomenclature for the site. This was followed by a series of expert reviews of the design.

Usability testing involving 72 remote one-on-one interviews wasconducted with a diverse user population (including users with disabilities) across 50 states in the US.This was followed by a formal usability critique of design, layout, navigation, functionality, content and terminology to determine the appropriateness of content and layout.Usability testing for compliance with Section 508 was also conducted with 11 participants of which 3 were blind (using the JAWS screen reader), 5 had low vision (using ZoomText), 1 had hearing impairment, and 2 had motor impairment. In addition, the staff of Recovery.gov evaluated the Web siteusing Jaws, Watchfire XM, and a head-pointing device frequently used by individuals with dexterity limitations.

To ensure ongoing accessibility compliance, all content providers, editors, and approvers receive accessibility training, and Web managers are always checking for 508 compliance inWeb content, including PDFs. Any content that is found not to be compliant with Section 508 is fixed by Web managers if they are small changes, or are returned to content creators for correction and resubmission if large changes are needed.

Table 1.Summary of Findings

The Board / FDA / Census Bureau
Uses a Content Management System (CMS)? / Yes, Microsoft SharePoint Designer / Yes / No CMS, but page templates are used
Uses automated tools for accessibility testing? / Uses Watchfire WebXM.
Contrast and color schemes are tested using and / No / 1. HiSoftware Compliance Sheriff to test 90% of Web sites monthly.
2. HiSoftware AccVerify for content accessibility validation.
Involvesusers with disabilities in evaluation of Web sites? / Yes / Yes / Yes
Performs expert testing? / Yes / Yes / Yes
Ongoing accessibility meeting/training for staff? / Yes / Yes, biweekly meeting. Mandatory Webcast course must be taken by staff. / Yes, monthly newsletter
Posts accessibility statement on its Web site? / Yes / Yes / Yes
Core administrative strategy to ensure compliance? / Review process for all content posted to the Web site / Employees sign agreement to post only accessible content, if violated, employees may lose their CMS account / Monitoring of Web content by section 508 coordinator, and inclusion of 508 information in WSCS Information Technology monthly newsletter.
PDF files accessible? / Yes, process in place to monitor all PDF files / Individual content contributors have the responsibility to check their individual PDF files / Few PDF files are periodically evaluated, but when a specific application or Web site undergoes a thorough accessibility review, all PDF files in that site are checked

4.0Conclusion