Increase Font Size | Decrease Font Size
ADA.gov United States Department of Justice, Civil Rights Division
Information and Technical Assistance on the Americans with Disabilities Act
2010 Regulations
2010 Design Standards
Technical Assistance Materials
Enforcement

Section 508 Report to the President and Congress:  
Accessibility of Federal Electronic and Information Technology

September 2012

I.       Executive Summary and Recommendations

A.     Background

1.       Information Technology

2.       Section 508 of the Rehabilitation Act

B.     Department of Justice’s Survey

C.     Department of Justice’s Report

1.       General Processes for Section 508 Implementation

2.       Procurement

3.       Administrative Complaints and Civil Actions

4.       Website Compliance

5.       Inter- and Intra-Agency Coordination

II.      General Processes for Section 508 Implementation

A.     Section 508 Policy

B.     Section 508 Office or Program

C.     Spending on IT and Section 508

D.     Software and Other EIT

E.     Section 508 Technical Requirements

F.      Section 508 Functional Performance Requirements

G.     Section 508 Information and Documentation Requirements

H.     Section 508 Training

I.       Section 508 Challenges

J.      Other Rehabilitation Act Issues

III.          Procurement

A.     Contract Requirements

B.     Market Research

C.     Decision Documentation

D.     Exceptions and Commercial Non-Availability Determinations

E.     Pre or Post Award Protests

IV.         Administrative Complaints and Civil Actions

A.     Policies and Procedures for Processing Section 508 Complaints

B.     Number of Complaints and Civil Actions

V.          Website Compliance

A.     Web Policies and Practices

B.     Four Representative Web Pages

1.       External Internet Home Page

2.       Internal Intranet Home Page

3.       Web-Based Form

4.       Web-Based Application

VI.         Appendices

A.     Section 508 Statutory Language

B.     Section 508 EIT Accessibility Standards

C.     The Attorney General's Memorandum to Heads of All Federal Agencies

D.     Section 508 Survey Questions

E.     Agencies Listed by Size Categories

I. Executive Summary and Recommendations

Over 20 years ago, Congress enacted the Americans with Disabilities Act (ADA), which was signed into law on July 26, 1990.  42 U.S.C. §§ 12101-12213.  The ADA made it a violation of federal law to discriminate against a person with a disability in private sector and state and local government employment, in the provision of state and local government services, and in the provision of goods and services by places of public accommodation.  The ADA is a mandate for equality for persons with disabilities, many of whom throughout our country’s history have been constrained by societal, cultural, and structural barriers that limited opportunities for them to achieve their potential, live independently, obtain gainful employment, and participate meaningfully in our shared American life.  The ADA’s implementation has rendered much of our society more open and inclusive; considerations of accessibility feature more prominently today than in the past in the implementation of state and local government programs, as well as the provision of private sector services and facilities.  These changes have empowered people with disabilities to participate in American society to an extent never before possible.

In the federal sector, government agencies have long been subject to the accessible design requirements of the Architectural Barriers Act of 1968, 42 U.S.C. §§ 4151-4156, and the employment nondiscrimination requirements of Section 501 of the Rehabilitation Act of 1973, 29 U.S.C. § 791.  In 1978, Congress amended Section 504 of the Rehabilitation Act of 1973 (Section 504) to extend the disability nondiscrimination obligations imposed on recipients of federal financial assistance to the programs and activities of federal agencies.  29 U.S.C. § 794.  And, in 1998, Congress amended Section 508 of the Rehabilitation Act (Section 508) to require federal agencies to ensure that the electronic and information technology (EIT) they procure, develop, maintain, and use is accessible to people with disabilities.  29 U.S.C. § 794d.  Section 508 is designed to fulfill the promise inherent in information technology to enhance the lives of persons with and without disabilities. 

In April 2000 the Department of Justice issued its first report pursuant to Section 508, which described the state of accessibility of the federal government’s EIT for people with disabilities.  The 2000 report included detailed findings of fact based on the results of a 1999 self-evaluation by federal agencies.  The report also included recommendations, for example, to increase coordination among federal agencies, including establishing an interagency technical assistance support center, to form intra-agency voluntary advisory committees comprised of persons with disabilities to assist in the identification and resolution of accessibility issues, to develop agency-wide guidelines for web-page development, and to develop systemic procedures to ensure procurement of accessible EIT products.

On the tenth anniversary of the ADA, on July 26, 2000, then President Clinton called upon the heads of the executive departments and agencies to renew their commitment to ensuring that federal programs were free of disability-based discrimination, including all programs offered on government Internet and Intranet sites, and he encouraged coordination among government agencies to ensure the success of their efforts to make EIT accessible to persons with disabilities pursuant to Section 508.  The memorandum emphasized that an “important goal of the [Rehabilitation] Act for the Federal Government is to set an example for the rest of the country by . . . providing exemplary service to its customers with disabilities.”  President‘s Memorandum for the Heads of Executive Departments and Agencies on Renewing the Commitment to Ensure that Federal Programs are Free from Disability-Based Discrimination, 36 Weekly Comp. Pres. Doc. 1688 (July 31, 2000).

EIT Accessibility Standards implementing Section 508 were published by the U.S. Architectural and Transportation Compliance Board (Access Board) in late 2000 and the Federal Acquisition Regulation was amended to incorporate the Access Board’s Section 508 Standards in 2001.  Section 508 became enforceable in June 2001.

In recognition of the important role that technology can play in advancing opportunities for workplace and community participation by persons with disabilities, then President Bush on February 1, 2001, embarked on a number of efforts designed to promote the development of assistive and universally designed technologies for individuals with disabilities.  For example, under the Assistive Technology Act, matching grants to States were awarded to help people with disabilities purchase assistive technology.  A new website, www.DisabilityInfo.gov (now www.Disability.gov), was launched by the government to provide information in an accessible format to persons with disabilities concerning programs and activities of interest across the government.  And, to facilitate a common understanding among federal agencies of Section 508 requirements, an interagency Section 508 Steering Committee and Coordinators’ Working Group were formed to work closely with federal agencies responsible for Section 508 and coordinate technical guidance and training.

In 2001 and 2004 the Department of Justice surveyed federal agencies regarding the status of their efforts to comply with Section 508.  In mid-2004, the Department published on its website at www.usdoj.gov/crt/508/report2/index.php a report based on the results of the 2001 Survey [1].  The report included findings and offered recommendations regarding web accessibility, the processing of Section 508 administrative complaints, agency policies and practices concerning telecommunications devices and information transaction machines, and it offered some guidance on the interplay of Sections 501 and 504 of the Rehabilitation Act on the federal government’s obligations under Section 508.

On President Obama’s second day in office, on January 21, 2009, he issued a call for openness and transparency in the manner in which the federal government interacts with citizens and provides information about government programs and activities.  President’s Memorandum for the Heads of Executive Agencies on Transparency and Open Government, 74 Fed. Reg. 4685 (January 26, 2009).  More recently, on May 23, 2012, the President issued a directive entitled “Building a 21st Century Digital Government,” which launched a comprehensive Digital Government Strategy aimed at delivering better digital services to the American people.  President’s Memorandum for the Heads of Executive Departments and Agencies on Building a 21st Century Digital Government, 77 Fed. Reg. 106 (June 1, 2012).  These mandates can only be fully realized, however, when persons with disabilities have comparable access to government information and data.  Federal agencies operate today in a more dynamic information environment than ever before and vigilance is required to make sure that the requirements of Section 508 continue to guide the procurement, development, maintenance, and use of EIT in all of its various forms.  With recent advancements in technology, opportunities for communicating with the public have grown exponentially to include not only the Internet as traditionally used to provide information, but also new Internet-based social networking communities where people can respond to information provided to them, such as Facebook, Twitter, MySpace and YouTube.  These expansions in technology hold the promise of increased participation for all, but present challenges for the full inclusion of persons with disabilities.

President Obama is committed to removing those barriers that remain in our society and that exclude people with disabilities, depriving them of true equality of opportunity and independence. In seeking to do more for Americans with disabilities, he is motivated by the principles of improving health care, increasing employment opportunities, expanding educational opportunities, protecting civil rights, promoting community living, supporting accessible technology, and supporting international disability rights.  Compliance with Section 508 can facilitate achievement of the President’s objectives by removing many of the barriers to EIT that impede persons with disabilities’ access.  For example, accessible EIT can open up to persons with disabilities information about government assistance for education and training programs, housing, and other government services and benefits, much of which is available on agency websites or is communicated to the public using agency telecommunication services, agency information kiosks, and transaction machines.  Accessible EIT can also facilitate achievement of the federal government’s goal of increased federal hiring, promotion, retention, and success of people with disabilities, as illustrated by Executive Order Number 13548, Increasing Federal Employment of Individuals with Disabilities, 75 Fed. Reg. 45,039 (July 26, 2010).  Executive Order 13548 calls for the heads of executive agencies to take steps to increase the employment of persons with disabilities.  The executive order emphasized that agencies should implement strategies for hiring and retaining workers with disabilities, including by “increasing access to appropriate accessible technologies, and ensuring the accessibility of physical and virtual workspaces.”

This report examines the state of federal agencies’ compliance with Section 508 during fiscal year 2010 (FY2010).  The survey was administered to federal agencies in early 2011.  It is hoped that the report’s findings can serve as a benchmark against which progress towards an even more open, transparent, and inclusive EIT environment within federal agencies can be assessed in the future.

A. Background

1. Information Technology

Changes in technology continue at an extremely rapid pace, increasing the amount of EIT available to the American people, both with and without disabilities.  Today, meaningful participation in American society requires access to a full range of EIT, including computers, office equipment, cellular telephones, software, and the Internet.  Technological devices are increasingly portable, connected, and multifunctional, allowing a person to make a phone call, type a document, search the Internet, and send and receive e-mail from virtually anywhere in the country.  The technological convergence of various modes of communication and information is continually evolving, changing the way the American people learn, work, consume goods and services, and communicate with each other.

People with disabilities have been among the greatest beneficiaries of the technological advancement of EIT.  However, people with disabilities also are at significant risk of being excluded if the technological innovations are designed without considering accessibility.  Section 508 of the Rehabilitation Act ensures that federal agencies address these needs when they develop, procure, maintain, or use EIT. [2]

2. Section 508 of the Rehabilitation Act

Section 508 of the Rehabilitation Act, as amended by the Workforce Investment Act of 1998, requires federal agencies to ensure that EIT is accessible to people with disabilities, unless certain exceptions apply.  Specifically, Section 508 requires federal agencies to ensure that EIT they develop, procure, maintain, or use allows employees with disabilities and members of the public seeking information or services to have access to and use of information and data that is comparable to that available to employees and members of the public without disabilities.

To implement Section 508, the Access Board published final EIT Accessibility Standards on December 21, 2000, 36 C.F.R. pt. 1194.  On April 25, 2001, the General Services Administration, the Department of Defense, and the National Aeronautics and Space Administration published a final rule to amend the Federal Acquisition Regulation (FAR) to incorporate the Access Board’s EIT Accessibility Standards.  66 Fed. Reg. 20894 et seq. (April 25, 2001).  Section 508 became enforceable and the FAR amendments went into effect in late June 2001.

Because of the rapid changes in technology, in 2006, the Access Board began the process to update the Section 508 EIT Accessibility Standards by establishing an advisory committee.  The advisory committee was composed of representatives from industry, disability groups, standard setting bodies in the United States and abroad, and government agencies.  On April 3, 2008, the advisory committee presented its report and recommendations to the Access Board, and on March 22, 2010, the Access Board issued an advance notice of proposed rulemaking (ANPRM) to update and revise the Section 508 EIT Accessibility Standards.  In response to comments, the Access Board made significant changes to the 2010 ANPRM and issued a second ANPRM on December 8, 2011.  The comment period for the second ANPRM ended on March 7, 2012.  The Access Board anticipates publishing a notice of proposed rulemaking in early 2013.

B. Department of Justice’s Survey

Section 508 requires the Attorney General to submit to the President and Congress reports containing information on and recommendations regarding the state of federal department and agency compliance with Section 508, including actions regarding individual complaints.  29 U.S.C. § 794d(d)(2).  Section 508 requires federal agencies to cooperate with and to provide information to the Attorney General necessary to assist with the reports.  29 U.S.C. § 794d(e). 

Pursuant to this directive, in 2010-2011, the Department of Justice created survey instruments and solicited answers from federal agencies regarding their implementation of Section 508 in FY 2010.[3] The survey questions were based on prior survey efforts and finalized after consultation with participants from various federal agencies, including the Access Board, General Services Administration, Social Security Administration, and the Department of Homeland Security.  The Department also consulted with many participants from federal government organizations including the Section 508 Coordinators, Federal Web Managers Council, and the Federal Chief Information Officers Council.

The survey requested data in four important areas:  general processes for implementing Section 508, procurement, administrative complaints and civil actions, and website compliance.  In order to obtain the most comprehensive and reliable data possible, the survey asked the federal agencies to identify components within each agency that were responsible for each category of duties referenced in each section of the survey.  These agency components completed the survey and submitted the survey responses to their parent agency.  The parent agency collected and provided the combined survey responses from all of their components to the Department.  For purposes of the report, the survey responses were grouped according to their agency size category using the following breakdown:

  • Very Small        100 or fewer employees
  • Small                101 to 1,000 employees
  • Mid-Size            1,001 to 10,000 employees
  • Large                10,001 to 25,000 employees
  • Very Large        25,001 or more employees

A total of 89 federal agencies, including Cabinet level agencies, independent agencies, and boards, commissions, and committees, participated in the Department of Justice's survey [4]. Twenty-six were very small agencies, 26 were small agencies, 18 were mid-size agencies, 6 were large agencies, and 13 were very large agencies. The 89 federal agencies identified a total of 318 components that provided the responses to the survey. This report provides the Department's findings and recommendations. The report also provides the data reported by the federal agency components and includes an analysis by agency size category.

C. Department of Justice’s Report and Recommendations

Almost 15 years ago, Congress amended Section 508 of the Rehabilitation Act to require federal agencies to ensure that the EIT they procure, develop, maintain, and use is accessible to people with disabilities.  Some agencies have achieved substantial success in implementing and complying with Section 508.  However, many agencies continue to face significant challenges in adopting appropriate policies and procedures, establishing a Section 508 office or program, providing training, coordinating efforts, and establishing accountability.

1. General Processes for Section 508 Implementation

The first section of the Department’s survey focused on general processes for implementing Section 508 within the agencies and their components.  Specifically, this section sought information regarding policies, processes, and procedures that agencies used to ensure their components comply with the requirements of Section 508.  In addition, agencies were asked questions regarding their budgets for information technology (IT), development of software and web applications, and training.  Also, agencies were asked several questions regarding Section 504 of the Rehabilitation Act (Section 504).

Agencies reported mixed levels of success.  Slightly more than fifty percent of agency components had established a general policy to implement and comply with Section 508.  However, only about forty percent of agency components that developed software had included a process to ensure the accessibility of software, and only about thirty percent of agency components that developed videos or multimedia productions had included a process to ensure the accessibility of training or informational videos or multimedia productions.  Additionally, nearly seventy percent of agency components had appointed a Section 508 coordinator, but only thirty-five percent of agency components had established a Section 508 office or program.  Among the agency components that had established a Section 508 office or program, they assigned on average 2.5 full time equivalents (FTEs) and allocated a median budget of $35,000 to their Section 508 office or program.[5]

Agency components experienced difficulty in providing Section 508 training to their personnel - only forty percent of agency components provided Section 508 training, and these agency components provided only a small number of hours of training to their agency acquisition workforce (less than one hour) or EIT developers (a little more than one hour).  Agency components also experienced difficulty establishing a mechanism to ensure EIT used in a program or activity receiving federal financial assistance is accessible to persons with disabilities .

The Department recommends the following:

  • Establish Section 508 Policies and Procedures.  Agencies that have not already done so should establish policies and procedures to ensure that their development, procurement, maintenance, and use of EIT (web, software, office equipment, and other EIT) are accessible.  The policies and procedures should identify the person in charge and define roles and responsibilities, especially for the agency’s personnel involved in the procurement process and web and software developers.  The policies and procedures should include a process to regularly report on the status of Section 508 compliance and implementation to agency’s leadership.  The policies and procedures should also include the technical requirements of Section 508 EIT Accessibility Standards, including the accessibility requirements for all live or recorded training and multimedia production (e.g., closed captioning, open captioning, and audio description). 
  • Appoint Coordinators and Establish Section 508 Offices or Programs.  Agencies that have not already done so should appoint a Section 508 coordinator and establish a Section 508 office or program.  The Section 508 coordinator and the Section 508 office or program should reside in the office that plans and oversees the implementation of the agency’s information technology (e.g., Office of the Chief Information Officer or Chief Technology Officer).  The Section 508 coordinator should have the authority to implement the agency’s Section 508 policy.  The coordinator should also have the authority to facilitate and develop partnerships with agency components that are responsible for information technology, procurement, and enforcement of equal employment opportunity (EEO) or civil rights laws.  The agency’s Section 508 office or program should support Section 508 compliance within the agency’s information technology governance activities to ensure that decisions regarding technology include the needs of employees and members of the public with disabilities.  Additionally, the agency’s Section 508 office or program should provide support to agency personnel who are responsible for ensuring the accessibility of EIT that is developed, procured, maintained, or used.  The Section 508 office or program should also provide support for accessibility testing and remediation of EIT.
  • Provide More Training to Agency Personnel.  Agencies should provide and/or facilitate the provision of more training to Section 508 coordinators, agency personnel involved in the procurement process, software developers, website developers, and video and multimedia developers.  Agencies should also provide training to equal employment opportunity, human resources, civil rights, and Section 508 offices and personnel.  To provide more effective training, agencies should utilize the Section 508 expertise of the Access Board and the General Services Administration, which have statutory authority for providing technical assistance under Section 508.  Agencies also should encourage the sharing of interagency training opportunities and take advantage of the existing Section 508 training opportunities, including the Section 508 Coordinators’ Conference and the Interagency Disability Educational Awareness Showcase.
  • Ensure Accessibility of EIT Used in Programs or Activities Receiving Federal Financial Assistance.  Section 504 prohibits recipients from discriminating against persons with disabilities in any program or activity receiving federal financial assistance. Under this statute, recipients have an obligation to ensure that persons with disabilities are not excluded from, denied the benefits of, or subjected to discrimination under any program or activity receiving federal financial assistance, including instances when the program or activity is offered through the use of EIT (e.g., through websites). Agencies should inform recipients that they are required to ensure the accessibility of their websites and other EITs and that they may meet this statutory obligation by using the standards described under the Section 508 EIT Accessibility Standards.[6]

2. Procurement

The second section of the survey focused on procurement practices and procedures within the federal agencies.  Specifically, this section analyzed contract requirements, market research, documentation of decisions, exceptions and commercial non-availability, and pre or post award protests.

A majority of the agency components currently incorporate accessibility provisions into their EIT procurements.  However, less than fifty percent of agency components incorporated specific applicable Section 508 Accessibility Standards as requirements in each procurement solicitations.  A majority of the agency components only provided standardized compliance language or clauses in their solicitations.  Additionally, instead of relying on actual product testing to validate Section 508 compliance, agency components most often relied on reviewing the materials submitted by the contractor or vender to evaluate whether the deliverables met the Section 508 requirements.  Some agency components conducted no evaluation at all.

The Department recommends the following:

  • Develop Procurement Policies for Section 508 Compliance.  As mentioned previously, slightly more than fifty percent of agency components had established a general policy to implement and comply with Section 508.  Agencies that have not already done so should review all of their procurement practices and policies, formal and informal, and develop systematic ways to ensure that they are procuring EIT that meets the Section 508 EIT Accessibility Standards.
  • Use Specific Language of the Section 508 Requirements in All Solicitations.  Rather than rely on general Section 508 standardized language, whenever possible, agencies should incorporate specific applicable Section 508 requirements that are appropriate for the procurement of the EIT product.
  • Perform Actual Product Testing.  Instead of solely relying on reviewing the materials submitted by the contractor or vendor, agencies should evaluate Section 508 compliance by conducting actual product testing throughout the acquisition process, particularly for products that will be heavily used by agency employees or members of the public.  When product testing reveals noncompliance, an effective plan should be developed to correct or remediate the problem in a timely manner.
  • Establish Procedures to Document Section 508 Procurement Decisions.  Only about forty percent of agency components had established a formal policy to document any Section 508 exceptions claimed on procurements of EIT.  Agencies that have not already done so should establish formalized systems to document their Section 508 procurement decisions (e.g. , non-availability determination, undue burden exceptions, National Security exceptions).

3. Administrative Complaints and Civil Actions

The third section of the survey examined policies and procedures for handling Section 508 complaints and requested statistics on the number of complaints and judicial actions involving the federal agencies.  Agency components reported 140 administrative complaints and seven civil actions since June 21, 2001, the effective date of the Section 508 EIT Accessibility Standards.  However, most of the administrative complaints and civil actions were filed against componets in very large agencies.  Also, only slightly more than thirty percent of agency components had already established set of policies and procedures specifically to process Section 508 complaints.  Fifty-seven percent of the agency components were either using existing Section 504 complaint processes or some other process.

The Department recommends the following:

  • Establish Procedures Specifically to Process Section 508 Complaints.  Rather than rely solely on the Section 504 complaint process, agencies should consider augmenting the Section 504 complaint process, where appropriate, so as to include specific policies and procedures targeted to the processing of Section 508 complaints. [7]  The complaint policies and procedures should also include a method for tracking the complaints and ensure a timely response and resolution.
  • Incorporate Alternative Dispute Resolution Into Section 508 Complaint Process.  Almost seventy percent of agency components reported providing Section 508 complainants a choice of using an Alternative Dispute Resolution (ADR) option to attempt resolution of their complaints.  Those agencies that have not done so should consider offering to Section 508 complainants a carefully designed ADR option within the context of the agencies’ Section 508 administrative complaint resolution process.
  • Disseminate Widely Information About the Section 508 Complaint Process.  Agencies should widely distribute information about their Section 508 administrative complaint process.  For example, agencies should publish the complaint process on the agencies’ Internet and Intranet websites, as well as publish information prominently in equal employment opportunity handbooks and other appropriate publications.

4. Website Compliance

The fourth section of the Department’s survey inquired about general policies and practices for developing accessible web pages within the federal agencies.  Agencies also were asked to evaluate the accessibility of their external Internet home pages, internal Intranet home pages, web-based forms, and web-based applications.  Seventy percent of agency components reported having accessibility policies in place for website development and that their web pages, web-based forms, and web-based applications were generally accessible.  Also, nearly fifty-eight percent of agency components reported performing routine automated and/or manual evaluation and remediation on their websites.  Specifically, twenty-eight percent of agency components performed both automated and manual evaluation, while twenty-four percent of agency components performed only manual evaluation, and six percent of agency components performed only automated evaluation.  Agency components reported some difficulty, however, with providing captioning and audio description for multimedia content and providing keyboard accessibility.

The Department recommends the following:

  • Establish Web Accessibility Policies and Procedures.  Agencies that have not already done so should establish web accessibility policies and procedures to ensure that web developers follow the requirements of the Section 508 EIT Accessibility Standards so as to ensure that their web pages (both public and private) are accessible to people with disabilities.
  • Ensure that Web Accessibility Policies and Procedures Include Special Topics.  Agencies should ensure that their web accessibility policies and procedures include guidance to ensure that frequently used elements on their websites are accessible.  Guidance should include, among other things, Adobe Acrobat files (.pdfs), video and audio multimedia content (closed captioning, open captioning, and audio description), JavaScript or other scripting languages, word processing files, data tables, skip navigation links, and online electronic forms.
  • Test Accessibility of Agency Web Pages.  Agencies should include in their web accessibility policies and procedures a process to routinely and consistently test their web pages for accessibility.  The most effective way to determine whether a web page is accessible to people with disabilities is to use both automated and manual testing.  Manual testing should be based on a consistent test process and should rely primarily on code inspection to ensure that the web page is consistent with the Section 508 EIT Accessibility Standards.  Also, agencies can improve accessibility and usabilty of a web page by including people with disabilities in the testing process using screen readers and other assistive technologies prior to posting.  Agencies should establish policies and procedures that require both methods of testing web pages.
  • Publish Web Accessibility Statements.  Agencies should develop and publish web accessibility statements on their websites to provide transparency and information regarding the website’s accessibility.  The web accessibility statements should address the agency’s web accessibility policy, availability of accessible features, and testing and remediation process.
  • Publish E-Mail Addresses.  Agencies should designate and advertise e-mail addresses on their websites to allow persons with disabilities to inform the agencies of accessibility problems encountered on their websites.  Agencies can also use e-mail addresses to accept requests from persons with disabilities for information and documentation in alternate formats.

5. Inter - and Intra-Agency Coordination

One significant challenge posed by Section 508 is the need for coordination between those with technological expertise and those with knowledge of disability access issues.  Agencies should improve inter- and intra-agency coordination and collaboration among information technology personnel, procurement officials, EEO or civil rights professionals, end users with disabilities, and the private sector.

In 2010, the U.S. Chief Information Officers Council (CIOC) formed an Accessibility Committee to serve as an interagency forum to improve the federal government’s implementation of Section 508.  Working in conjunction with the U.S. Access Board, the Department of Justice, and the General Services Administration, the Accessibility Committee hopes to provide a forum for federal agencies, disability advocacy groups, industry, and academic stakeholders to enable and support the federal government’s implementation of Section 508.  The Accessibility Committee has begun to develop and share best practices that address, among other things, Section 508 governance, procurement, testing, and training.

The formation of the CIOC Accessibility Committee is a positive step forward in promoting increased inter-agency coordination and awareness.  At the same time, agencies will need to improve intra-agency coordination and collaboration among agency components that are responsible for information technology, procurement, and enforcement of EEO or civil rights laws.  The participation of the agency’s EEO or civil rights office is especially important.  For most agencies, Section 508 implementation has been the province of components that are responsible for the agency’s information technology or procurement.  Today, some agencies view Section 508 as a set of technical requirements that they must comply with when developing, procuring, maintaining and using EIT.  Section 508 is a federal civil rights law but agencies’ EEO or civil rights offices have been mostly absent from the implementation process.

The Department recommends the following to increase coordination and cooperation:

  • Revive the Interagency Disability Coordinating Council.  The Department should revive the Interagency Disability Coordinating Council (IDCC), as set forth in 29 U.S.C. §794c, with the Attorney General as Chair, consistent with Executive Order 12250, 29 U.S.C. §2000d-1.
  • Issue Section 508 Model Complaint Resolution Policies and Procedures.  The Department, in consultation with the IDCC after it is reconvened, should review agencies’ complaint resolution policies and procedures for Section 508 and recommend improvements and best practices.
  • Issue Guidance Clarifying the Relationship Among Sections 501, 504, and 508 of the Rehabilitation Act.  The IDCC should issue guidance clarifying the relationship among Sections 501, 504, and 508 of the Rehabilitation Act.

II. General Processes for Section 508 Implementation

This section of the survey focused on general processes for implementing Section 508 within the agencies and their components.  Specifically, this section sought information regarding policies, processes, and procedures that agencies used to ensure compliance with the full requirements of Section 508, including EIT that is procured, developed, maintained or used by federal agencies.  In addition, agencies were asked questions regarding their budget or spending on information technology (IT), development of software and web applications, and training.  Also, agencies were asked several questions regarding Section 504 of the Rehabilitation Act (Section 504).

The general processes section focused on ten specific areas:

  • Section 508 Policy
  • Section 508 Office or Program
  • Spending on IT and Section 508
  • Software and Other EIT
  • Section 508 Technical Requirements
  • Section 508 Functional Performance Requirements
  • Section 508 Information and Documentation Requirements
  • Section 508 Training
  • Section 508 Challenges
  • Other Rehabilitation Act Issues

The following provides a brief summary of findings for each of the ten subsections of Section II – General Processes for Section 508 Implementation.

  • Section 508 Policy.  Slightly more than fifty percent of agency components established a formal, written policy to implement and comply with Section 508.  The head of an agency or the agency’s office of the chief information officer established the majority of the agency components’ Section 508 policies.  Most Section 508 policies identified the office or person responsible, and defined some roles and responsibilities for Section 508 coordinators, requiring officials, contracting officers, application developers, and web content managers and authors.
  • Section 508 Office or Program.  Nearly seventy percent of agency components appointed a Section 508 coordinator.  Also, nearly thirty-five percent of agency components established a Section 508 office or program.  On average, agency components assigned 2.5 full time equivalents (FTEs) and allocated a budget of $413,497 to their Section 508 office or program. [8]  However, it is important to note that the average budget for larger agency components was significantly higher than the average budget for smaller agency components, which has an effect of skewing the figure.  Across all agency size categories, the median budget was $35,000 for their Section 508 office or program.  In addition, the most common service provided by agency components that had established a Section 508 office or program was to evaluate the accessibility of websites, and the least common service provided was to evaluate the accessibility of hardware.
  • Spending on IT and Section 508.  Agency components reported an average IT budget of $390,024,414.  However, it is important to note that the average IT budget for larger agency components is significantly higher than the average IT budget for smaller agency components, which has the effect of skewing the figure.  Also, nearly seventy percent of agency components reported allocating or using resources to implement and comply with Section 508.  However, eighty-five percent of agency components did not track their spending to implement and comply with Section 508.  Those agency components that tracked their spending, reported an average budget or spending of $5,785,963 to implement and comply with Section 508. [9]  However, again, it is important to note that the average budget for larger agency components was significantly higher than the average budget for smaller agency components, which has the effect of skewing the figure.  Across all agency size categories, the median spending was $140,000 to implement and comply with Section 508.  The most common service provided by agency components, regardless of whether they had established a Section 508 office or program, was to evaluate the accessibility of websites, and the least common service provided was to evaluate the accessibility of hardware.
  • Software and Other EIT.  Seventy-five percent of agency components reported developing software or web applications. About forty percent of these agency components reported establishing a policy to ensure the accessibility of software, including testing developed software for Section 508 compliance.  Nearly seventy-one percent of agency components reported developing training or informational videos or multimedia productions. About thirty percent of these agency components reported establishing a policy to ensure the accessibility of videos or multimedia productions, including testing developed videos or multimedia production for Section 508 compliance.
  • Section 508 Technical Requirements.  The percentage of agency components or parts of their components establishing policies to comply with each of the six subparts of the technical requirements of the Section 508 EIT Accessibility Standards varied from forty-three percent for self-contained, closed products to sixty percent for websites.
  • Section 508 Functional Performance Requirements.  Nearly fifty percent of agency components or parts of their components established formal, written policies to comply with the functional performance requirements in Section 508 EIT Accessibility Standards.  Thirty-three percent of agency components reported not establishing a policy and had no plans to establish a policy to comply with the functional performance requirements.
  • Section 508 Information and Documentation Requirements.  Website, E-mail, and large print were the most common alternate formats used by agency components to provide individuals with disabilities access to information and documentation for EIT products.  Braille was the least common alternate formats used by agency components.  Similarly, website, E-mail, TTY, and sign language were the most common alternate methods used by agency components.  Mobile texting was the least common alternate method used by agency components.
  • Section 508 Training.  Nearly sixty percent of agency components reported not providing Section 508 training to their employees.  Slightly more than forty percent of agency components reported providing Section 508 training.  Agency components reported providing the most average hours of training to Section 508 coordinators (a little more than four hours) and the fewest average hours of training to IT help desk staff (less than one hour).  Very small agency components reported the highest number of average hours of Section 508 training for many of the available types of employees.  A majority of agency components that offered training reported online training as the most common method for providing Section 508 training.  By contrast, mid-size agency components reported classroom instruction and conferences as their most common method for providing Section 508 training.
  • Section 508 Challenges.  Many agency components reported lack of resources, lack of general awareness, and lack of training as the three most common challenges in implementing and complying with Section 508.  By contrast, lack of management support was the least common challenge.  Interestingly, fifteen percent of agency components could not identify any challenges in implementing and complying with Section 508.
  • Other Rehabilitation Act Issues.  Nearly forty percent of agency components that provided federal financial assistance reported not having any knowledge whether recipients of federal financial assistance were required to ensure accessibility of websites and other EITs.  Another twenty-four percent of agency components did not require recipients to ensure accessibility of websites and other EITs.  Thirty-five percent of agency components or parts of their components reported requiring recipients of federal financial assistance to ensure accessibility of websites and other EITs.  Among these agency components, a majority reported establishing an EIT accessibility policy or parts of their components establishing an EIT accessibility policy for recipients of federal financial assistance.

A. Section 508 Policy

Agencies and their components were asked questions relating to their policies and procedures to implement Section 508.  A total of 318 agency components participated in this section. 

The following provides a summary description of the agency components’ responses:

  • Slightly more than fifty percent of agency components reported they established a formal, written policy to implement and comply with Section 508.
  • The majority of the Section 508 policies were established by the head of the agency or the agency’s office of the chief information officer.
  • Most agency components reported that their Section 508 policy identified the office or person responsible for implementing and complying with Section 508.
  • A majority of the agency components reported that their Section 508 policy defined some roles and responsibilities for Section 508 coordinators, requiring officials, contracting officers, application developers, and web content managers and authors.

Question 1 asked whether agency components established a formal, written policy to implement and comply with Section 508.  Those agency components that did not establish a formal, written policy were asked to skip the remaining questions in this section and proceed to the next section regarding the Section 508 Office or Program.  In general, a majority of agency components (51.3%) established a Section 508 policy.  More components of larger agencies established a Section 508 policy compared to components of smaller agencies.  Seventy-seven agency components (24.2%) reported not establishing a Section 508 policy but established a schedule to develop a policy.  Surprisingly, 76 agency components (23.9%) reported not establishing a Section 508 policy and had no plan to develop a policy.

The following table provides the specific responses by the agency components:

Section 508 Policy by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes, a formal, written policy was established 163 (51.3%) 103 (57.9%) 36 (52.9%) 7 (38.9%) 8 (28.6%) 9 (34.6%)
(b) No, but a timetable was established to do so 77 (24.2%) 34 (19.1%) 9 (13.2%) 9 (50.0%) 13 (46.4%) 12 (46.2%)
(c) No, and there were no plans to do so 76 (23.9%) 41 (23.0%) 23 (33.8%) 2 (11.1%) 7 (25.0%) 3 (11.5%)
(d) Don’t know 2 (0.6%) 0 (0.0%) 0 (0.0%) 0 (0.0%) 0 (0.0%) 2 (7.7%)

Question 2 asked agency components to identify the highest office within the agency that established the Section 508 policy.  A total of 163 agency components that established a Section 508 policy responded to this survey question.  Overall, a majority of the agency components reported that either the head of the agency or the agency’s office of the chief information officer established the Section 508 policy.  Specifically, 65 agency components (39.9%) reported that the agency’s office of the chief information officer established the Section 508 policy.  Forty-eight agency components (29.4%) reported that the head of the agency established the Section 508 policy.  Twenty-seven agency components (16.6%) reported that the agency’s Section 508 office or coordinator established the Section 508 policy.  Only 1 agency component (0.6%) reported that the agency’s civil rights office established the Section 508 policy.

The agency components’ responses are summarized in the table below:

Section 508 Policy by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Head of the agency 48 (29.4%) 29 (28.2%) 10 (27.8%) 2 (28.6%) 1 (12.5%) 6 (66.7%)
(b) CIO office 65 (39.9%) 47 (45.6%) 7 (19.4%) 3 (42.9%) 6 (75.0%) 2 (22.2%)
(c) Civil rights office 1 (0.6%) 1 (1.0%) 0 (0.0%) 0 (0.0%) 0 (0.0%) 0 (0.0%)
(d) Section 508 office or coordinator 27 (16.6%) 16 (15.5%) 9 (25.0%) 1 (14.3%) 0 (0.0%) 1 (11.1%)
(e) Other 22 (13.5%) 10 (9.7%) 10 (27.8%) 1 (14.3%) 1 (12.5%) 0 (0.0%)

Question 3 asked agency components whether their Section 508 policy identified the office or person responsible for implementing and complying with Section 508.  Overall, most of the agency components (85.9%) reported that their Section 508 policy identified the office or person responsible for implementing and complying with Section 508.  Eleven agency components (6.7%) reported that their Section 508 policy did not identify the office or person responsible for implementing Section 508 but established a schedule to identify the office or person.  Twelve agency components (7.4%) reported that their Section 508 policy did not identify the office or person responsible for implementing Section 508 and had no plan to identify the office or person.

The following table provides the agency components’ responses:

Section 508 Policy – Office or Person in Charge by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes, the policy identifies the office or person who is responsible 140 (85.9%) 88 (85.4%) 30 (83.3%) 7 (100.0%) 7 (87.5%) 8 (88.9%)
(b) No, but a timetable was established to do so 11 (6.7%) 4 (3.9%) 5 (13.9%) 0 (0.0%) 1 (12.5%) 1 (11.1%)
(c) No, and there were no plans to do so 12 (7.4%) 11 (10.7%) 1 (2.8%) 0 (0.0%) 0 (0.0%) 0 (0.0%)

Question 4 asked agency components whether their Section 508 policy defined roles and responsibilities for Section 508 coordinators, requiring officials, contracting officers, application developers, and web content managers and authors.  Overall, a majority of agency components (58.3%) reported that their Section 508 policy defined some roles and responsibilities.  Another 50 agency components (30.7%) reported that their Section 508 policy defined all roles and responsibilities.  Ten agency components (6.1%) reported that their Section 508 policy did not define any roles and responsibilities and had no plan to define roles and responsibilities.

The agency components reported the following:

Section 508 Policy on Roles and Responsibilities by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes, roles and responsibilities were defined 50 (30.7%) 31 (30.1%) 13 (36.1%) 3 (42.9%) 1 (12.5%) 2 (22.2%)
(b) Yes and no, some roles and responsibilities were defined, while others were not 95 (58.3%) 63 (61.2%) 18 (50.0%) 3 (42.9%) 5 (62.5%) 6 (66.7%)
(c) No, but a timetable was established to do so 8 (4.9%) 1 (1.0%) 4 (11.1%) 0 (0.0%) 2 (25%) 1 (11%)
(d) No, and there were no plans to do so 10 (6.1%) 8 (7.8%) 1 (2.8%) 1 (14.3%) 0 (0.0%) 0 (0.0%)

B. Section 508 Office or Program

Agencies and their components were asked questions relating to their Section 508 office or program.  A total of 318 agency components participated in this section.  However, 81 agency components did not complete this section because they have not established a Section 508 office or program.

The following provides a summary description of the agency components’ responses:

  • Nearly seventy percent of agency components had appointed a Section 508 coordinator.
  • Nearly thirty-five percent of agency components had established a Section 508 office or program. Another twenty-five percent of components did not establish an office or program, but utilized their parent agency’s Section 508 office or program.
  • Agency components that established a Section 508 office or program reported assigning 2.5 average number of FTEs and allocated an average budget of $413,497 for their Section 508 office or program. [10]  However, it is important to note that the average budget for larger agency components was significantly higher than the average budget for smaller agency components, which has the effect of skewing the figure.  Across all agency size categories, the median budget was $35,000 for their Section 508 office or program.
  • Agency components reported that the most common service provided by their Section 508 office or program was to evaluate the accessibility of websites.  By contrast, the least common service provided by agency components’ Section 508 office or program was to evaluate the accessibility of hardware.

Question 1 asked whether agency components selected a Section 508 coordinator.  A majority of the agency components (69.8%) reported that they selected a Section 508 coordinator.  Thirty-four agency components (10.7%) reported not having a Section 508 coordinator but established a schedule to select a coordinator.  Interestingly, 61 agency components (19.2%) reported not having a Section 508 coordinator and had no plan to select a coordinator.

The following table provides the specific responses by the agency components:

Section 508 Coordinator by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes, a coordinator was selected 222 (69.8%) 127 (71.3%) 45 (66.2%) 15 (83.3%) 18 (64.3%) 17 (65.4%)
(b) No, but a timetable was established to do so 34 (10.7%) 19 (10.7%) 4 (5.9%) 2 (11.1%) 6 (21.4%) 3 (11.5%)
(c) No, and there were no plans to do so 61 (19.2%) 32 (18.0%) 19 (27.9%) 1 (5.6%) 4 (14.3%) 5 (19.2%)
(d) Don't know 1 (0.3%) 0 (0.0%) 0 (0.0%) 0 (0.0%) 0 (0.0%) 1 (3.8%)

Question 2 asked whether agency components established an office or program to ensure their compliance with Section 508.  Those agency components that did not establish a Section 508 office or program were asked to skip the remaining questions in this section and proceed to the next section regarding the Spending on Information Technology and Section 508.  A majority of the agency components (60.1%) either established a Section 508 office or program, or relied on their parent agency’s Section 508 office or program.  Surprisingly, 78 agency components (24.5%) reported not establishing a Section 508 office or program and had no plan to establish an office or program.  A significantly higher number of very large agency components reported establishing a Section 508 office or program.

The agency components’ responses are summarized in the table below:

Section 508 Office or Program by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes, an office or a program was established 110 (34.6%) 74 (41.6%) 15 (22.1%) 5 (27.8%) 6 (21.4%) 10 (38.5%)
(b) No, but we utilize our agency’s Section 508 office or program 81 (25.5%) 48 (26.9%) 33 (48.5%) 0 (0.0%) 0 (0.0%) 0 (0.0%)
(c) No, but a timetable was established to do so 46 (14.5%) 16 (9.0%) 4 (5.9%) 6 (33.3%) 13 (46.4%) 7 (26.9%)
(d) No, and there were no plans to do so 78 (24.5%) 40 (22.5%) 16 (23.5%) 7 (38.9%) 8 (28.6%) 7 (26.9%)
(e) Don't know 3 (0.9%) 0 (0.0%) 0 (0.0%) 0 (0.0%) 1 (3.6%) 2 (7.7%)

Question 3 asked agency components the number of FTEs assigned to their Section 508 office or program.  A total of 110 agency components that established a Section 508 office or program responded to this survey question.  Across all agency size categories, agency components reported assigning 2.5 average number of FTEs to a Section 508 office or program. [11]  Interestingly, the mid-size agency components reported the largest number of average FTEs, 5.4.  The small and very small agency components reported the smallest number of average FTEs, 0.4 and 1.1, respectively.

The following table provides the agency components’ responses:

Section 508 Office or Program FTEs by Number of FTEs Among Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
Question 3: How many FTEs does your agency component have in its Section 508 office or program? 2.5 2.5 3.3 5.4 0.4 1.1

Question 4 asked agency components that established a Section 508 office or program to estimate their budget.  Overall, agency components reported an average budget of $413,497 for their Section 508 office or program. [12]  However, it is important to note that the average budget for larger agency components is significantly higher than the average budget for smaller agency components, which has the effect of skewing the figure.  Across all agency size categories, the median budget was $35,000 for their Section 508 office or program.

The following table provides the agency components’ responses:

Section 508 Office or Program Budget by Average Number of Dollars Among Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
Question 4: What was your agency component's budget for its Section 508 office or program? $413,497 $557,584 $208,305 $76,000 $13,698 $0

Question 5 asked agency components that had established a Section 508 office or program to identify the types of services offered to implement and comply with Section 508.  A total of 110 agency components responded to this survey question.  In this question, agency components were allowed to select any number of available options.  Thus, the total of percentages within each column of the table may exceed 100%.

Overall, the most common services provided by an agency component’s Section 508 office or program were to evaluate website accessibility (74.5%), provide training (69.1%), and assist acquisition officials prepare Section 508 language in EIT contracts (65.5%).  By contrast, the least common service provided by an agency component was to evaluate hardware accessibility (40.0%).  Interestingly, a higher percentage of large (73.3%) and small (83.3%) agency components assisted developers to design software that complies with Section 508 than very large, mid-size, or very small agency components.  Also, a higher percentage of small (83.3%) and very small (70.0%) agency components created or repaired electronic documents to comply with Section 508 than very large, large, or mid-size agency components.

The agency components reported the following:

Section 508 Services Provided by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Assist acquisition officials prepare Section 508 language in EIT contracts. 72 (65.5%) 51 (68.9%) 11 (73.3%) 3 (60.0%) 4 (66.7%) 3 (30.0%)
(b) Assist developers to design software that complies with Section 508 64 (58.2%) 42 (56.8%) 11 (73.3%) 2 (40.0%) 5 (83.3%) 4 (40.0%)
(c) Create or repair electronic documents to comply with Section 508 73 (66.4%) 49 (66.2%) 9 (60.0%) 3 (60.0%) 5 (83.3%) 7 (70.0%)
(d) Evaluate websites 82 (74.5%) 55 (74.3%) 9 (60.0%) 5 (100.0%) 6 (100.0%) 7 (70.0%)
(e) Evaluate software 59 (53.6%) 40 (54.1%) 7 (46.7%) 2 (40.0%) 3 (50.0%) 7 (70.0%)
(f) Evaluate hardware 44 (40.0%) 29 (39.2%) 5 (33.3%) 1 (20.0%) 3 (50.0%) 6 (60.0%)
(g) Provide training 76 (69.1%) 54 (73.0%) 11 (73.3%) 4 (80.0%) 3 (50.0%) 4 (40.0%)
(h) Provide alternate formats 51 (46.4%) 33 (44.6%) 9 (60.0%) 1 (20.0%) 3 (50.0%) 5 (50.0%)

C. Spending on IT and Section 508

Agencies and their components were asked questions relating to their investments in IT and Section 508.  A total of 318 agency components participated in this section.  However, 35 agency components did not complete this section because the information was classified.

The following is a summary of agency components’ responses:

  • Agency components reported an average IT budget or spending of $390,024,414.  However, it is important to note that the average IT budget for larger agency components is significantly higher than the average IT budget for smaller agency components, which has the effect of skewing the figure.  The amount of the IT budget or spending was generally relative to the agency size categories:  the larger the agency, the larger the IT budget or spending.  There was one exception to this trend, mid-size agencies reported an average IT budget or spending of $129,835,018, which was more than double the average IT budget or spending of large agencies.
  • Nearly seventy percent of agency components reported allocating or using resources to implement and comply with Section 508.
  • Eighty-five percent of agency components reported not tracking their spending to implement and comply with Section 508.  About fifteen percent of agency components reported tracking their spending.
  • Agency components that tracked their spending reported an average budget or spending of $5,785,963 to implement and comply with Section 508. [13]  However, it is important to note that the average budget for larger agency components was significantly higher than the average budget for smaller agency components, which has the effect of skewing the figure.  Across all agency size categories, the median budget or spending was $140,000 to implement and comply with Section 508.
  • Agency components, regardless of whether they established a Section 508 office or program, reported that the most common service provided was to evaluate websites for Section 508 compliance.  By contrast, the least common service provided was to evaluate hardware.

Question 1 asked agency components to estimate their total budget or spending for information technology (IT).  Those agency components that could not provide their IT budget or spending were asked to skip the remaining questions in this section and proceed to the next section regarding Software and Other EIT.  Overall, agency components reported an average IT budget or spending of $390,024,414.  However, it is important to note that the average IT budget for larger agency components is significantly higher than the average IT budget for smaller agency components, which has the effect of skewing the figure.  Generally, the amount of the IT budget or spending was relative to the agency size category:  larger the agency, larger the IT budget or spending.  There was one exception to this trend, mid-size agencies reported an average IT budget or spending of $129,835,018, which was more than double the average IT budget or spending of large agencies.

The following table provides the specific responses by the agency components:

IT Budget or Spending by Average Number of Dollars Among Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
Question 1: What was your agency component's IT budget or spending? $390,024,414 $694,837,407 $58,446,353 $129,835,018 $9,438,433 $274,800

Question 2 asked whether agency components track their spending to implement and comply with Section 508.  A total of 283 agency components that estimated their IT budget or spending responded to this survey question.  Overall, a majority of agency components (85.2%) reported not tracking their spending to implement and comply with Section 508.  Only 42 agency components (14.8%) reported tracking their spending.

The agency components’ responses are summarized in the table below:

Section 508 Spending Tracking System by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes, a tracking system is in place 42 (14.8%) 23 (15.3%) 8 (12.7%) 1 (5.9%) 5 (18.5%) 5 (19.2%)
(b) No, but a timetable was established to do so 46 (16.3%) 18 (12.0%) 12 (19.0%) 4 (23.5%) 5 (18.5%) 7 (26.9%)
(c) No, and there were no plans to do so 158 (55.8%) 86 (57.3%) 34 (54.0%) 11 (64.7%) 14 (51.9%) 13 (50.0%)
(d) Don't know 37 (13.1%) 23 (15.3%) 9 (14.3%) 1 (5.9%) 3 (11.1%) 1 (3.8%)

Question 3 asked agency components to estimate their budget or spending to implement and comply with Section 508.  A total of 42 agency components that tracked their budget or spending responded to this survey question.  Overall, agency components reported an average budget or spending of $5,785,963 to implement and comply with Section 508. [14]  However, it is important to note that the average budget for larger agency components was significantly higher than the average budget for smaller agency components, which has the effect of skewing the figure.  Across all agency size categories, the median budget or spending was $140,000 to implement and comply with Section 508.

The following table provides the agency components’ responses:

Section 508 Spending by Average Number of Dollars Among Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
Question 3: What was your agency component's budget or spending to comply with Section 508? $5,785,963 $5,066,678 $15,708,157 $300,000 $36,314 $66,000

Question 4 asked whether agency components allocated or used resources to implement and comply with Section 508.  A total of 283 agency components responded to this survey question.  Overall, most agency components (67.8%) reported allocating or using resources to implement and comply with Section 508.  Surprisingly, 18.8% of agency components reported not allocating or using resources, and 13.4% of agency components reported not knowing whether they allocated or used resources to comply with Section 508.

The agency components reported the following:

Section 508 Spending by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes, resources were used to comply with Section 508 192 (67.8%) 98 (65.3%) 44 (69.8%) 15 (88.2%) 20 (74.1%) 15 (57.7%)
(b) No, but a timetable was established to do so 18 (6.4%) 9 (6.0%) 2 (3.2%) 0 (0.0%) 3 (11.1%) 4 (15.4%)
(c) No, and there were no plans to do so 35 (12.4%) 16 (10.7%) 10 (15.9%) 2 (11.8%) 2 (7.4%) 5 (19.2%)
(d) Don't know 38 (13.4%) 27 (18.0%) 7 (11.1%) 0 (0.0%) 2 (7.4%) 2 (7.7%)

Question 5 asked whether agency components’ budget or spending to implement and comply with Section 508 include spending to comply with Section 504.  A total of 192 agency components that allocated or used resources to comply with Section 508 responded to this survey question.  Across all agency size categories, 77 agency components (40.1%) reported that resources for Section 508 compliance did not include resources to comply with Section 504.  Sixty-five agency components (33.9%) reported that resources to comply with Section 508 included resources to comply with Section 504.  Fifty agency components (26.0%) selected the option “Don’t know.”

The following table summarizes the responses provided by the agency components:

Section 508 Spending by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes, resources for Section 508 compliance include resources to comply with Section 504 65 (33.9%) 39 (39.8%) 9 (20.5%) 7 (46.7%) 5 (25.0%) 5 (33.3%)
(b) No 77 (40.1%) 37 (37.8%) 14 (31.8%) 7 (46.7%) 12 (60.0%) 7 (46.7%)
(c) Don't know 50 (26.0%) 22 (22.4%) 21 (47.7%) 1 (6.7%) 3 (15.0%) 3 (20.0%)

Question 6 asked agency components, regardless of whether they had established a Section 508 office or program, to identify the types of services offered to implement and comply with Section 508.  A total of 192 agency components that allocated or used resources to comply with Section 508 responded to this survey question.  This question permitted agency components to select any number of available options.  Thus, the total of percentages within each column of the table may exceed 100%.

Across all agency size categories, the most common services provided by agency components were to evaluate websites (81.3%), create or repair electronic documents (70.3%), assist developers to design software (66.1%), evaluate software (64.6%), and assist acquisition officials prepare Section 508 language in EIT contracts (64.6%).  By contrast, the least common service provided by an agency component was to evaluate hardware (40.6%).  Interestingly, a higher percentage of mid-size agency components provided more of the following services than agency components in all other size categories:  assist acquisition officials prepare EIT contracts, assist developers design accessible software, remediate electronic documents, and evaluate websites.

The following table provides the specific responses by the agency components:

Section 508 Services Provided by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Assist acquisition officials prepare Section 508 language in EIT contracts 124 (64.6%) 62 (63.3%) 29 (65.9%) 12 (80.0%) 15 (75.0%) 6 (40.0%)
(b) Assist developers to design software that complies with Section 508 127 (66.1%) 66 (67.3%) 29 (65.9%) 13 (86.7%) 13 (65.0%) 6 (40.0%)
(c) Create or repair electronic documents to comply with Section 508 135 (70.3%) 70 (71.4%) 28 (63.6%) 12 (80.0%) 18 (90.0%) 7 (46.7%)
(d) Evaluate websites 156 (81.3%) 78 (79.6%) 36 (81.8%) 13 (86.7%) 17 (85.0%) 12 (80.0%)
(e) Evaluate software 124 (64.6%) 67 (68.4%) 30 (68.2%) 8 (53.3%) 10 (50.0%) 9 (60.0%)
(f) Evaluate hardware 78 (40.6%) 42 (42.9%) 16 (36.4%) 5 (33.3%) 7 (35.0%) 8 (53.3%)
(g) Provide training 100 (52.1%) 57 (58.2%) 22 (50.0%) 11 (73.3%) 4 (20.0%) 6 (40.0%)
(h) Provide alternate formats 95 (49.5%) 43 (43.9%) 24 (54.5%) 10 (66.7%) 12 (60.0%) 6 (40.0%)

D. Software and Other EIT

Agencies and their components were asked questions relating to their development of software and web applications.  A total of 318 agency components participated in this section.  However, 79 agency components did not complete this section because they did not develop software or web applications.

The following provides a brief summary of the agency components’ responses:

  • Seventy-five percent of agency components reported developing software or web applications either in-house or by contractors.  But only about forty percent of these agency components reported establishing a policy to ensure the accessibility of software, including testing developed software for Section 508 compliance.
  • Nearly seventy-one percent of agency components reported developing training or informational videos or multimedia productions either in-house or by contractors.  But only about thirty percent of these agency components reported establishing a policy to ensure the accessibility of videos or multimedia productions, including testing developed videos or multimedia production for Section 508 compliance.

Question 1 asked whether agency components developed their own software or web applications other than informational web pages.  Those agency components that did not develop software or web applications were asked to skip the remaining questions in this section and proceed to the next section regarding the Section 508 Standards.  For all but very small agency components, the majority of agency components in all size categories reported developing software or web applications either in-house (51.9%) or by contractors (23.3%).  Most of the very small agency components (80.8%) reported that they do not develop software or web applications.

The agency components’ responses are summarized in the table below:

Software or Application Development by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes, software was developed in-house 165 (51.9%) 96 (53.9%) 38 (55.9%) 11 (61.1%) 18 (64.3%) 2 (7.7%)
(b) Yes, but development was limited to contractors 74 (23.3%) 44 (24.7%) 16 (23.5%) 6 (33.3%) 5 (17.9%) 3 (11.5%)
(c) No 79 (24.8%) 38 (21.3%) 14 (20.6%) 1 (5.6%) 5 (17.9%) 21 (80.8%)

Question 2 asked whether agency components established a formal, written policy to ensure that software or web application complies with Section 508.  A total of 239 agency components that developed software responded to this survey question.  Overall, 92 agency components (38.5%) reported establishing a policy to ensure accessibility of software.  Another 62 agency components (25.9%) reported that only parts of their components had established a software policy.  Surprisingly, 55 agency components (23.0%) reported not establishing a policy and had no plan to establish a policy to ensure accessibility of software.

The following table provides the agency components’ responses:

Software or Application Development Policy by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes, a formal, written policy was established to ensure that software development complies with Section 508 92 (38.5%) 62 (44.3%) 14 (10.0%) 8 (47.1%) 6 (26.1%) 2 (40.0%)
(b) Yes and no, parts of our components have done this, while others have not 62 (25.9%) 34 (24.3%) 20 (37.0%) 3 (17.6%) 5 (21.7%) 0 (0.0%)
(c) No, but a timetable was established to do so 30 (12.6%) 15 (10.7%) 2 (3.7%) 3 (17.6%) 7 (30.4%) 3 (60.0%)
(d) No, and there were no plans to do so 55 (23.0%) 29 (20.7%) 18 (33.3%) 3 (17.6%) 5 (21.7%) 0 (0.0%)

Question 3 asked whether an agency component’s policy to ensure accessibility of software included a process to review or evaluate developed software or web applications for Section 508 compliance.  A total of 154 agency components that established a software policy responded to this survey question.  In general, 77 agency components (50.0%) reported that their software policy included testing for Section 508 compliance.  Another 58 agency components (37.7%) reported that only parts of their components included testing.  Thirteen agency components (8.4%) reported that their software policy does not include testing and had no plan to include testing for Section 508 compliance.

The agency components reported the following:

Software or Application Testing Policy by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes, a formal, written policy was established to evaluate developed software 77 (50.0%) 52 (54.2%) 14 (41.2%) 5 (45.5%) 4 (36.4%) 2 (100.0%)
(b) Yes and no, parts of our components have done this, while others have not 58 (37.7%) 30 (31.3%) 17 (50.0%) 6 (54.5%) 5 (45.5%) 0 (0.0%)
(c) No, but a timetable was established to do so 6 (3.9%) 3 (3.1%) 2 (5.9%) 0 (0.0%) 1 (9.1%) 0 (0.0%)
(d) No, and there were no plans to do so 13 (8.4%) 11 (11.5%) 1 (2.9%) 0 (0.0%) 1 (9.1%) 0 (0.0%)

Question 4 asked whether agency components developed training or informational videos or multimedia productions.  Those agency components that did not develop videos or multimedia productions were asked to skip the remaining questions in this section and proceed to the next section regarding the Section 508 Standards.  A total of 239 agency components responded to this survey question.  Overall, a majority of agency components reported developing videos or multimedia productions either in-house (52.3%) or by contractors (18.4%).  Seventy agency components (29.3%) reported that they did not develop videos or multimedia productions or all productions were purchased.

The following table summarizes the responses provided by the agency components:

Video or Multimedia Production by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes, video or multimedia production was developed in-house 125 (52.3%) 76 (54.3%) 23 (42.6%) 10 (58.8%) 15 (65.2%) 1 (20.0%)
(b) Yes, but the production was limited to contractors 44 (18.4%) 23 (16.4%) 12 (22.2%) 5 (29.4%) 2 (8.7%) 2 (40.0%)
(c) No, all productions were procured or we do not create any video or multimedia productions 70 (29.3%) 41 (29.3%) 19 (35.2%) 2 (11.8%) 6 (26.1%) 2 (40.0%)

Question 5 asked whether agency components established a formal, written policy to ensure that training or informational videos or multimedia productions comply with Section 508.  Those agency components that did not establish a policy to develop accessible videos or multimedia productions were asked to skip the remaining questions in this section and proceed to the next section regarding the Section 508 Standards.  A total of 169 agency components that developed videos or multimedia productions responded to this survey question.  For all but small agency components, a majority of agency components in all size categories reported establishing a policy (31.4%) or parts of their components establishing a policy (33.1%) to ensure that videos or multimedia productions comply with Section 508.  The majority of small agency components (64.7%) reported they did not establish a policy to ensure accessible training or informational videos or multimedia productions.

The following table provides the specific responses by the agency components:

Video or Multimedia Production Policy by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes, a formal, written policy was established to ensure that video or multimedia production complies with Section 508 53 (31.4%) 35 (35.4%) 9 (25.7%) 3 (20.0%) 3 (17.6%) 3 (100.0%)
(b) Yes and no, parts of our components have done this, while others have not 56 (33.1%) 30 (30.3%) 16 (45.7%) 7 (46.7%) 3 (17.6%) 0 (0.0%)
(c) No, but a timetable was established to do so 27 (16.0%) 14 (14.1%) 3 (8.6%) 2 (13.3%) 8 (47.1%) 0 (0.0%)
(d) No, and there were no plans to do so 33 (19.5%) 20 (20.2%) 7 (20.0%) 3 (20.0%) 3 (17.6%) 0 (0.0%)

Question 6 asked whether an agency component’s policy to ensure accessibility of training or informational videos or multimedia productions included a process to review or evaluate developed videos or multimedia productions for Section 508 compliance.  A total of 109 agency components that established a policy to ensure accessibility of videos or multimedia productions responded to this survey question.  Overall, 49 agency components (45.0%) reported that their video or multimedia production policy included testing for Section 508 compliance.  Another 47 agency components (43.1%) reported that only parts of their components included testing.  Nine agency components (8.3%) reported that their video or multimedia production policy does not include testing and had no plan to include testing for Section 508 compliance.

The following table provides the specific responses by the agency components:

Video or Multimedia Production Testing Policy by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes, a formal, written policy was established to evaluate video or multimedia productions 49 (45.0%) 34 (52.3%) 9 (36.0%) 1 (10.0%) 2 (33.3%) 3 (100.0%)
(b) Yes and no, parts of our components have done this, while others have not 47 (43.1%) 23 (35.4%) 13 (52.0%) 8 (80.0%) 3 (50.0%) 0 (0.0%)
(c) No, but a timetable was established to do so 4 (3.7%) 2 (3.1%) 1 (4.0%) 0 (0.0%) 1 (16.7%) 0 (0.0%)
(d) No, and there were no plans to do so 9 (8.3%) 6 (9.2%) 2 (8.0%) 1 (10.0%) 0 (0.0%) 0 (0.0%)

E. Section 508 Technical Requirements

The Section 508 EIT Accessibility Standards contain technical requirements for six specific technology areas:  software applications and operating systems, web-based information or applications, telecommunication products, video and multimedia products, self contained, closed products (e.g. , information kiosks, calculators, and fax machines), and desktop and portable computers.  In this section, agencies and their components were asked questions relating to their policies and procedures to comply with the technical requirements of the Section 508 EIT Accessibility Standards.  A total of 318 agency components participated in this section.

The following provides a summary description of the agency components’ responses:

  • Software.  Nearly fifty-four percent of agency components reported establishing a policy or parts of their components establishing a policy to comply with the technical requirements for software.  Twenty-four percent of agency components reported not establishing a policy and had no plans to establish a policy to comply with the technical requirements for software.
  • Websites.  Nearly sixty percent of agency components reported establishing a policy or parts of their components establishing a policy to comply with the technical requirements for websites.  Twenty-three percent of agency components reported not establishing a policy and had no plans to establish a policy to comply with the technical requirements for websites.
  • Telecommunication Products.  Forty-eight percent of agency components reported establishing a policy or parts of their components establishing a policy to comply with the technical requirements for telecommunication products.  Nearly twenty-four percent of agency components reported not establishing a policy and had no plans to establish a policy to comply with the technical requirements for telecommunication products.
  • Video and Multimedia Products.  Nearly forty-six percent of agency components reported establishing a policy or parts of their components establishing a policy to comply with the technical requirements for video and multimedia products.  Twenty-four percent of agency components reported not establishing a policy and had no plans to establish a policy to comply with the technical requirements for video and multimedia products.
  • Self Contained, Closed Products.  Forty-three percent of agency components reported establishing a policy or parts of their components establishing a policy to comply with the technical requirements for self contained, closed products.  Twenty-one percent of agency components reported not establishing a policy and had no plans to establish a policy to comply with the technical requirements for self contained, closed products.
  • Desktop and Portable Computers.  Fifty percent of agency components reported establishing a policy or parts of their components establishing a policy to comply with the technical requirements for desktop and portable computers.  Twenty-seven percent of agency components reported not establishing a policy and had no plans to establish a policy to comply with the technical requirements for desktop and portable computers.

Question 1(a) asked whether agency components established policies and procedures to comply with the technical requirements for software applications and operating systems in the Section 508 EIT Accessibility Standards.  Overall, agency components reported establishing a policy (32.1%) or parts of their components establishing a policy (21.4%) to comply with the technical requirements for software.  Another 78 agency components (24.5%) reported not establishing a policy and had no plans to establish a policy to comply with the technical requirements for software.  A higher percentage of very small agency components (30.8%) did not establish a policy because they did not buy or develop software.  The following tables provide the agency components’ responses:

Section 508 Standards on Software by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes, a formal, written policy was established to comply with the software standards 102 (32.1%) 66 (37.1%) 19 (27.9%) 7 (38.9%) 6 (21.4%) 4 (15.4%)
(b) Yes and no, parts of our components have done this, while others have not 68 (21.4%) 40 (22.5%) 18 (26.5%) 5 (27.8%) 4 (14.3%) 1 (3.8%)
(c) No, but a timetable was established to do so 45 (14.2%) 19 (10.7%) 6 (8.8%) 3 (16.7%) 8 (28.6%) 9 (34.6%)
(d) No, and there were no plans to do so 78 (24.5%) 39 (21.9%) 23 (33.8%) 3 (16.7%) 9 (32.1%) 4 (15.4%)
(e) No, we don't buy or develop software 25 (7.9%) 14 (7.9%) 2 (2.9%) 0 (0.0%) 1 (3.6%) 8 (30.8%)

Question 1(b) asked whether agency components established policies and procedures to comply with the technical requirements for web-based information or applications in the Section 508 EIT Accessibility Standards.  Overall, agency components reported establishing a policy (36.5%) or parts of their components establishing a policy (23.0%) to comply with the technical requirements for websites.  Another 77 agency components (24.2%) reported not establishing a policy and had no plans to establish a policy to comply with the technical requirements for websites.  A higher percentage of very small agency components (23.1%) did not establish a policy because they did not buy, create, or maintain websites.

The agency components reported the following:

Section 508 Standards on Websites by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes, a formal, written policy was established to comply with the web standards 116 (36.5%) 74 (41.6%) 23 (33.8%) 8 (44.4%) 4 (14.3%) 7 (26.9%)
(b) Yes and no, parts of our components have done this, while others have not 73 (23.0%) 42 (23.6%) 16 (23.5%) 6 (33.3%) 8 (28.6%) 1 (3.8%)
(c) No, but a timetable was established to do so 37 (11.6%) 17 (9.6%) 4 (5.9%) 2 (11.1%) 6 (21.4%) 8 (30.8%)
(d) No, and there were no plans to do so 77 (24.2%) 39 (21.9%) 23 (33.8%) 2 (11.1%) 9 (32.1%) 4 (15.4%)
(e) No, we don't buy, create or maintain websites 15 (4.7%) 6 (3.4%) 2 (2.9%) 0 (0.0%) 1 (3.6%) 6 (23.1%)

Question 1(c) asked whether agency components established policies and procedures to comply with the technical requirements for telecommunication products in the Section 508 EIT Accessibility Standards.  Overall, agency components reported establishing a policy (28.3%) or parts of their components establishing a policy (19.8%) to comply with the technical requirements for telecommunication products.  Another 76 agency components (23.9%) reported not establishing a policy and had no plans to establish a policy to comply with the technical requirements for telecommunication products.  A higher percentage of very small agency components (42.3%) did not establish a policy because they did not buy or develop telecommunication products.

The following table summarizes the responses provided by the agency components:

Section 508 Standards on Telecommunication Products by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes, a formal, written policy was established to comply with the telecommunication product standards 90 (28.3%) 61 (34.3%) 13 (19.1%) 7 (38.9%) 5 (17.9%) 4 (15.4%)
(b) Yes and no, parts of our components have done this, while others have not 63 (19.8%) 35 (19.7%) 16 (23.5%) 5 (27.8%) 6 (21.4%) 1 (3.8%)
(c) No, but a timetable was established to do so 41 (12.9%) 18 (10.1%) 5 (7.4%) 3 (16.7%) 7 (25.0%) 8 (30.8%)
(d) No, and there were no plans to do so 76 (23.9%) 42 (23.6%) 20 (29.4%) 3 (16.7%) 9 (32.1%) 2 (7.7%)
(e) No, we don't buy or develop telecommunications products 48 (15.1%) 22 (12.4%) 14 (20.6%) 0 (0.0%) 1 (3.6%) 11 (42.3%)

Question 1(d) asked whether agency components established policies and procedures to comply with the technical requirements for video and multimedia products in the Section 508 EIT Accessibility Standards.  Overall, agency components reported establishing a policy (26.4%) or parts of their components establishing a policy (19.2%) to comply with the technical requirements for video and multimedia products.  Another 77 agency components (24.2%) reported not establishing a policy and had no plans to establish a policy to comply with the technical requirements for video and multimedia products.  A higher percentage of very small agency components (46.2%) did not establish a policy because they did not buy or develop video and multimedia products.

The following table provides the specific responses by the agency components:

Section 508 Standards on Video/Multimedia Products by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes, a formal, written policy was established to comply with the video/multimedia product standards 84 (26.4%) 57 (32.0%) 13 (19.1%) 6 (33.3%) 4 (14.3%) 4 (15.4%)
(b) Yes and no, parts of our components have done this, while others have not 61 (19.2%) 36 (20.2%) 16 (23.5%) 6 (33.3%) 3 (10.7%) 0 (0.0%)
(c) No, but a timetable was established to do so 43 (13.5%) 19 (10.7%) 3 (4.4%) 3 (16.7%) 10 (35.7%) 8 (30.8%)
(d) No, and there were no plans to do so 77 (24.2%) 40 (22.5%) 22 (32.4%) 3 (16.7%) 10 (35.7%) 2 (7.7%)
(e) No, we don't buy or develop video/multimedia products 53 (16.7%) 26 (14.6%) 14 (32.4%) 0 (0.0%) 1 (3.6%) 12 (46.2%)

Question 1(e) asked whether agency components established policies and procedures to comply with the technical requirements for self contained, closed products in the Section 508 EIT Accessibility Standards.  Overall, agency components reported establishing a policy (24.5%) or parts of their components establishing a policy (18.9%) to comply with the technical requirements for self contained, closed products.  Another 68 agency components (21.4%) reported not establishing a policy and had no plans to establish a policy to comply with the technical requirements for self contained, closed products.  A higher percentage of very small agency components (50.0%) did not establish a policy because they did not buy or develop self contained, closed products.

The agency components’ responses are summarized in the table below:

Section 508 Standards on Self Contained, Closed Products by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes, a formal, written policy was established to comply with the self contained, closed product standards 78 (24.5%) 52 (29.2%) 12 (17.7%) 6 (33.3%) 4 (14.3%) 4 (15.4%)
(b) Yes and no, parts of our components have done this, while others have not 60 (18.9%) 36 (20.2%) 16 (23.5%) 5 (27.8%) 2 (7.1%) 1 (3.8%)
(c) No, but a timetable was established to do so 35 (11.0%) 13 (7.3%) 6 (8.8%) 3 (16.7%) 8 (28.6%) 5 (19.2%)
(d) No, and there were no plans to do so 68 (21.4%) 36 (20.2%) 17 (25.0%) 3 (16.7%) 9 (32.1%) 3 (11.5%)
(e) No, we don't buy or develop self contained, closed products 77 (24.2%) 41 (23.0%) 17 (25.0%) 1 (5.6%) 5 (17.9%) 13 (50.0%)

Question 1(f) asked whether agency components established policies and procedures to comply with the technical requirements for desktop and portable computers in the Section 508 EIT Accessibility Standards.  Overall, agency components reported establishing a policy (35.5%) or parts of their components establishing a policy (14.5%) to comply with the technical requirements for desktop and portable computers.  Another 87 agency components (27.4%) reported not establishing a policy and had no plans to establish a policy to comply with the technical requirements for desktop and portable computers.

The following table provides the agency components’ responses:

Section 508 Standards on Computers by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes, a formal, written policy was established to comply with the desktop/portable computer standards 113 (35.5%) 73 (64.6%) 19 (27.9%) 7 (38.9%) 7 (25.0%) 7 (26.9%)
(b) Yes and no, parts of our components have done this, while others have not 46 (14.5%) 29 (16.3%) 11 (16.2%) 4 (22.2%) 1 (3.6%) 1 (3.8%)
(c) No, but a timetable was established to do so 38 (11.9%) 14 (7.9%) 4 (5.9%) 3 (16.7%) 10 (35.7%) 7 (26.9%)
(d) No, and there were no plans to do so 87 (27.4%) 45 (25.3%) 22 (32.4%) 3 (16.7%) 10 (35.7%) 7 (26.9%)
(e) No, we don't buy or develop computers 34 (10.7%) 17 (9.6%) 12 (17.6%) 1 (5.6%) 0 (0.0%) 4 (15.4%)

F. Section 508 Functional Performance Requirements

The Section 508 EIT Accessibility Standards contain functional performance requirements that are intended for overall product evaluation and for technologies or components for which there is no specific requirement under the technical requirements.  In this section, agencies and their components were asked a question relating to their policies and procedures to comply with the functional performance requirements of the Section 508 EIT Accessibility Standards.  A total of 318 agency components participated in this section.

Question 1 asked whether agency components established policies and procedures to comply with the functional performance requirements of the Section 508 EIT Accessibility Standards.  Overall, 155 agency components reported establishing a policy (28.3%) or parts of their components establishing a policy (20.4%) to comply with the functional performance requirements.  Another 106 agency components (33.3%) reported not establishing a policy and had no plans to establish a policy to comply with the functional performance requirements.  The agency components reported the following:

Functional Performance Criteria by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes, a formal, written policy was established to comply with the functional performance criteria standards 90 (28.3%) 62 (34.8%) 12 (17.6%) 5 (27.8%) 5 (17.9%) 6 (23.1%)
(b) Yes and no, parts of our components have done this, while others have not 65 (20.4%) 38 (21.3%) 17 (25.0%) 6 (33.3%) 3 (10.7%) 1 (3.8%)
(c) No, but a timetable was established to do so 57 (17.9%) 24 (13.5%) 9 (13.2%) 4 (22.2%) 11 (39.3%) 9 (34.6%)
(d) No, and there were no plans to do so 106 (33.3%) 54 (30.3%) 30 (44.1%) 3 (16.7%) 9 (32.1%) 10 (38.5%)

G. Section 508 Information and Documentation Requirements

Section 508 EIT Accessibility Standards require agency components to use alternate formats and alternate methods in providing individuals with disabilities access to information and documentation for EIT products.  Agencies and their components were asked to identify the alternate formats and alternate methods used by their components.  In this section, agency components were allowed to select any number of available options.  Thus, the total of percentages within each column of the tables may exceed 100%.  A total of 318 agency components participated in this section.

In general, agency components identified varying demand for each of the available alternate formats and alternate methods. [15]  Overall, website, E-mail, and large print were the most common alternate formats used by agency components.  Braille was the least common alternate formats used by agency components.  Similarly, website, E-mail, TTY, and sign language were the most common alternate methods used by agency components.  Mobile texting was the least common alternate methods used by agency components.

Question 1 explained that Section 508 EIT Accessibility Standards require agency components to provide product support documentation for EIT products to end users in alternate formats upon request.  Agency components were asked to identify the alternate formats used by their components.

A total of 122 agency components (38.4%) were unable to identify any alternate formats used because they did not track this information.  Another 113 agency components (35.5%) could not identify any alternate formats used because they reported that no requests were received.  In addition, 38 agency components (11.9%) could not identify any alternate formats used because the components were not responsible for providing EIT product support.  In general, agency components reported different demand for each of the available alternate formats.  Overall, website (21.1%), E-mail (17.3%), and large print (15.1%) were the most popular alternate formats used by agency components for EIT product support documentation.  By contrast, Braille (8.5%) was the least popular alternate format used by an agency component.

The following table summarizes the responses provided by the agency components:

Product Support Documentation Provided in Alternate Formats  by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Braille 27 (8.5%) 16 (9.0%) 3 (4.4%) 5 (27.8%) 1 (3.6%) 2 (7.7%)
(b) ASCII text 36 (11.3%) 23 (12.9%) 7 (10.3%) 2 (11.1%) 3 (10.7%) 1 (3.8%)
(c) Large print 48 (15.1%) 32 (18.0%) 9 (13.2%) 1 (5.6%) 4 (14.3%) 2 (7.7%)
(d) Website 67 (21.1%) 39 (21.9%) 16 (23.5%) 3 (16.7%) 3 (10.7%) 6 (23.1%)
(e) E-mail 55 (17.3%) 31 (17.4%) 13 (19.1%) 3 (16.7%) 3 (10.7%) 5 (19.2%)
(f) CD-ROM/DVD 34 (10.7%) 21 (11.8%) 7 (10.3%) 2 (11.1%) 1 (3.6%) 3 (11.5%)
(g) Recorded Audio 36 (11.3%) 21 (11.8%) 9 (13.2%) 1 (5.6%) 4 (14.3%) 1 (3.8%)
(h) Other 26 (8.2%) 15 (8.4%) 4 (5.9%) 1 (5.6%) 4 (14.3%) 2 (7.7%)
(i) We did not receive any requests 113 (35.5%) 58 (32.6%) 19 (27.9%) 8 (44.4%) 4 (14.3%) 13 (50.0%)
(j) We did not track this data 122 (38.4%) 73 (41.0%) 28 (27.9%) 6 (33.3%) 4 (14.3%) 4 (15.4%)
(k) N/A, we were not responsible for our own EIT product support 38 (11.9%) 21 (11.8%) 12 (17.6%) 0 (0.0%) 0 (0.0%) 13 (50.0%)

Question 2 explained that Section 508 EIT Accessibility Standards require agency components to provide access to descriptions of the accessibility and compatibility features of EIT products to end users in alternate formats or alternate methods upon request.  Agency components were asked to identify the alternate formats and alternate methods used by their components.

A total of 128 agency components (40.3%) were unable to identify any alternate formats used because they did not track this information.  Another 119 agency components (37.4%) could not identify any alternate formats used because they reported that no requests were received.  In addition, 35 agency components (11.0%) could not identify any alternate formats used because the components were not responsible for providing EIT product support.  Agency components’ responses to this question were very similar to the responses in Question 1.  Again, website (18.9%), E-mail (17.3%), and large print (13.5%) were the most common alternate formats used by agency components for descriptions of EIT accessibility features.  Braille (7.2%) was the least common alternate format used by an agency component.  The following table provides the specific responses by the agency components:

Accessibility/Compatibility Descriptions Provided in Alternate Formats

by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Braille 23 (7.2%) 16 (9.0%) 3 (4.4%) 3 (16.7%) 0 (0.0%) 1 (3.8%)
(b) ASCII text 29 (9.1%) 19 (10.7%) 7 (10.3%) 1 (5.6%) 1 (3.6%) 1 (3.8%)
(c) Large print 43 (13.5%) 30 (16.9%) 8 (11.8%) 2 (11.1%) 2 (7.1%) 1 (3.8%)
(d) Website 60 (18.9%) 36 (20.2%) 16 (23.5%) 3 (16.7%) 1 (3.6%) 4 (15.4%)
(e) E-mail 51 (16.0%) 30 (16.9%) 13 (19.1%) 3 (16.7%) 1 (3.6%) 4 (15.4%)
(f) CD-ROM/DVD 34 (10.7%) 21 (11.8%) 8 (11.8%) 3 (16.7%) 0 (0.0%) 2 (7.7%)
(g) Recorded Audio 31 (9.7%) 19 (10.7%) 7 (10.3%) 1 (5.6%) 3 (10.7%) 1 (3.8%)
(h) Other 24 (7.5%) 14 (7.9%) 7 (10.3%) 0 (0.0%) 2 (7.1%) 1 (3.8%)
(i) We did not receive any requests 119 (37.4%) 58 (32.6%) 22 (32.4%) 9 (50.0%) 3 (10.7%) 14 (53.8%)
(j) We did not track this data 128 (40.3%) 79 (44.4%) 30 (32.4%) 6 (33.3%) 3 (10.7%) 4 (15.4%)
(k) N/A, we were not responsible for our own EIT product support 35 (11.0%) 20 (11.2%) 10 (14.7%) 0 (0.0%) 0 (0.0%) 5 (19.2%)

In addition, a total of 120 agency components (37.7%) were unable to identify any alternate methods used because they did not track this information.  Another 102 agency components (32.1%) could not identify any alternate methods used because they reported that no requests were received.  Thirty-five agency components (11.0%) could not identify any alternate methods used because the components were not responsible for providing EIT product support.  In general, while reported responses varied among agency size categories, providing information by website (19.8%), E-mail (18.2%), TTY (17.0%), sign language (17.0%), and voice (15.1%) were reported to be the most popular options.  By contrast, mobile texting (5.7%) was the least popular alternate method used by an agency component.

The agency components’ responses are summarized in the table below:

Accessibility/Compatibility Descriptions Provided in Alternate Methods

by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Voice 48 (15.1%) 26 (14.6%) 11 (16.2%) 5 (27.8%) 1 (3.6%) 5 (19.2%)
(b) Fax 24 (7.5%) 12 (6.7%) 6 (8.8%) 3 (16.7%) 0 (0.0%) 3 (11.5%)
(c) Relay Service 43 (13.5%) 24 (13.5%) 7 (10.3%) 5 (27.8%) 5 (17.9%) 2 (7.7%)
(d) TTY 54 (17.0%) 30 (16.9%) 13 (19.1%) 5 (27.8%) 4 (14.3%) 2 (7.7%)
(e) Website 63 (19.8%) 34 (19.1%) 16 (23.5%) 5 (27.8%) 2 (7.1%) 6 (23.1%)
(f) E-mail 58 (18.2%) 29 (16.3%) 15 (22.1%) 7 (38.9%) 2 (7.1%) 5 (19.2%)
(g) Sign language 54 (17.0%) 33 (18.5%) 13 (19.1%) 4 (22.2%) 3 (10.7%) 1 (3.8%)
(h) Instant messaging 28 (8.8%) 18 (10.1%) 7 (10.3%) 0 (0.0%) 2 (7.1%) 1 (3.8%)
(i) Mobile texting 18 (5.7%) 13 (7.3%) 3 (4.4%) 1 (5.6%) 3 (10.7%) 1 (3.8%)
(j) Captioning 58 (18.2%) 31 (17.4%) 15 (4.4%) 5 (27.8%) 3 (10.71%) 1 (3.85%)
(k) Audio description 24 (7.5%) 15 (8.4%) 4 (5.9%) 2 (11.1%) 3 (10.7%) 0 (0.0%)
(l) Text to speech synthesis 39 (12.3%) 23 (12.9%) 9 (13.2%) 4 (22.2%) 3 (10.7%) 0 (0.0%)
(m) Other 13 (4.1%) 10 (5.6%) 1 (1.5%) 0 (0.0%) 1 (3.6%) 1 (3.8%)
(n) We did not receive any requests 102 (32.1%) 50 (28.1%) 18 (26.5%) 8 (44.4%) 12 (42.9%) 14 (53.8%)
(o) We did not track this data 120 (37.7%) 76 (42.7%) 29 (42.6%) 6 (33.3%) 8 (28.6%) 1 (3.8%)
(p) N/A, we were not responsible for our own EIT product support 35 (11.0%) 20 (11.2%) 10 (14.7%) 0 (0.0%) 0 (0.0%) 5 (19.2%)

Question 3 explained that Section 508 EIT Accessibility Standards require agency components to accommodate the communication needs of end users with disabilities when providing support services for EIT products.  Agency components were asked to identify the types of accommodations used by their components.

A total of 111 agency components (34.9%) were unable to identify any types of accommodations used because they did not track this information.  Another 89 agency components (28.0%) could not identify any types of accommodations used because they reported that no requests were received.  In addition, 31 agency components (9.7%) could not identify any types of accommodations used because the components were not responsible for providing EIT product support.  In general, agency components reported different demand for each of the available types of accommodations.  Overall, E-mail (28.9%), website (28.0%), and voice (26.1%) were the most common types of accommodations used by agency components.  By contrast, mobile texting (7.2%) was the least common type of accommodation used by an agency component.

The following table provides the agency components’ responses:

Communication Accommodations Provided in Alternate Methods

by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Voice 83 (26.1%) 44 (24.7%) 19 (27.9%) 10 (55.6%) 4 (14.3%) 6 (23.1%)
(b) Fax 37 (11.6%) 22 (12.4%) 8 (11.8%) 3 (16.7%) 1 (3.6%) 3 (11.5%)
(c) Relay Service 57 (17.9%) 30 (16.9%) 10 (14.7%) 9 (50.0%) 6 (21.4%) 2 (7.7%)
(d) TTY 68 (21.4%) 42 (23.6%) 13 (19.1%) 7 (38.9%) 3 (10.7%) 3 (11.5%)
(e) Website 89 (28.0%) 50 (28.1%) 22 (32.4%) 8 (44.4%) 4 (14.3%) 5 (19.2%)
(f) E-mail 92 (28.9%) 51 (28.7%) 20 (29.4%) 10 (55.6%) 6 (21.4%) 5 (19.2%)
(g) Sign language 67 (21.1%) 38 (21.3%) 16 (23.5%) 8 (44.4%) 4 (14.3%) 1 (3.8%)
(h) Instant messaging 34 (10.7%) 21 (11.8%) 9 (13.2%) 1 (5.6%) 2 (7.1%) 1 (3.8%)
(i) Mobile texting 23 (7.2%) 15 (8.4%) 3 (4.4%) 0 (0.0%) 4 (14.3%) 1 (3.8%)
(j) Captioning 56 (17.6%) 32 (18.0%) 10 (4.4%) 6 (33.3%) 4 (14.3%) 1 (3.8%)
(k) Audio description 27 (8.5%) 17 (9.6%) 4 (5.9%) 2 (11.1%) 3 (10.7%) 1 (3.8%)
(l) Text to speech synthesis 39 (12.3%) 24 (13.5%) 8 (11.8%) 3 (16.7%) 4 (14.3%) 0 (0.0%)
(m) Other 19 (6.0%) 12 (6.7%) 4 (5.9%) 0 (0.0%) 2 (7.1%) 1 (3.8%)
(n) We did not receive any requests 89 (28.0%) 43 (24.2%) 18 (26.5%) 5 (27.8%) 12 (42.9%) 11 (42.3%)
(o) We did not track this data 111 (34.9%) 70 (39.3%) 28 (41.2%) 5 (27.8%) 6 (21.4%) 2 (7.7%)
(p) N/A, we were not responsible for our own EIT product support 31 (9.7%) 18 (10.1%) 7 (10.3%) 0 (0.0%) 0 (0.0%) 6 (23.1%)

H. Section 508 Training

Agencies and their components were asked questions regarding the Section 508 training of various employees in their workforce.  A total of 318 agency components participated in this section.  However, 187 agency components did not complete this section because they did not offer Section 508 training to their employees.

The following provides a brief summary of the agency components’ responses:

  • Nearly sixty percent of agency components reported not providing Section 508 training to their employees.  Slightly more than forty percent of agency components reported providing Section 508 training.
  • Agency components that offered training reported that Section 508 coordinators, purchase card holders, and website developers were the three most often identified employees to receive mandatory Section 508 training.
  • Agency components that offered training reported providing the most average hours of training to Section 508 coordinators (a little more than four hours) and the fewest average hours of training to IT help desk staff (less than one hour).  Very small agency components reported the highest number of average hours of Section 508 training for many of the available types of employees.
  • Sixty-seven percent of agency components that offered training reported online training as the most common method for providing Section 508 training.  By contrast, mid-size agency components reported classroom instruction and conferences as their most common method for providing Section 508 training.
  • A majority of agency components that offered training reported Section 508 statute, Section 508 EIT Accessibility Standards, and procurement of accessible EIT among the three most common subject areas covered by their Section 508 training.  Captioning was the least common subject area covered by agency components’ Section 508 training.

Question 1 asked whether agency components provided Section 508 training to their employees.  Those agency components that did not offer Section 508 training to their employees were asked to skip the remaining questions in this section and proceed to the next section regarding the Section 508 Challenges.  Across all agency size categories, a majority of agency components (58.8%) reported not providing Section 508 training to their employees.  A higher percentage of small (82.1%) and very small agency components (80.8%) reported not providing Section 508 training.  A total of 131 agency components (41.2%) reported providing Section 508 training to their employees.

The agency components reported the following:

Section 508 Training Provided by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes, Section 508 training was provided 131 (41.2%) 84 (47.2%) 26 (38.2%) 11 (61.1%) 5 (17.9%) 5 (19.2%)
(b) No 187 (58.8%) 94 (52.8%) 42 (61.8%) 7 (38.9%) 23 (82.1%) 21 (80.8%)

Question 2 asked whether Section 508 training was mandatory for any employees in the agency components’ workforce.  This question permitted agency components to select any number of available options.  Thus, the total of percentages within each column of the tables may exceed 100%.  A total of 131 agency components that offered Section 508 training responded to this survey question.  Overall, agency components reported that Section 508 coordinators (42.0%), purchase card holders (27.5%), and website developers (26.0%) were the three most often identified employees to receive mandatory Section 508 training.  By contrast, IT help desk staff (8.4%), video and multimedia developers (9.9%), and program managers (9.9%) were the three least often identified employees to receive mandatory Section 508 training.  Interestingly, 10 agency components (7.6%) reported providing mandatory Section 508 training to all of their employees, and 40 agency components (30.5%) reported not requiring Section 508 training for any of their employees.

The following table summarizes the responses provided by the agency components:

Mandatory Section 508 Training by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Section 508 coordinators 55 (42.0%) 40 (47.6%) 9 (34.6%) 2 (18.2%) 2 (40.0%) 2 (40.0%)
(b) Requiring officials 19 (14.5%) 14 (16.7%) 4 (15.4%) 1 (9.1%) 0 (0.0%) 0 (0.0%)
(c) Program managers 13 (9.9%) 11 (13.1%) 2 (7.7%) 0 (0.0%) 0 (0.0%) 0 (0.0%)
(d) COTR/COR 26 (19.8%) 18 (21.4%) 5 (19.2%) 2 (18.2%) 0 (0.0%) 1 (20.0%)
(e) Contracting officers 28 (21.4%) 21 (25.0%) 4 (15.4%) 2 (18.2%) 0 (0.0%) 1 (20.0%)
(f) Purchase cardholders 36 (27.5%) 29 (34.5%) 3 (11.5%) 3 (27.3%) 0 (0.0%) 1 (20.0%)
(g) Software developers 18 (13.7%) 12 (14.3%) 5 (19.2%) 1 (9.1%) 0 (0.0%) 0 (0.0%)
(h) Website developers 34 (26.0%) 20 (23.8%) 8 (30.8%) 4 (36.4%) 0 (0.0%) 2 (40.0%)
(i) Video and multimedia developers 13 (9.9%) 9 (10.7%) 3 (11.5%) 0 (0.0%) 0 (0.0%) 1 (20.0%)
(j) IT help desk staff 11 (8.4%) 8 (9.5%) 2 (11.5%) 1 (9.1%) 0 (0.0%) 0 (0.0%)
(k) Other employees 14 (10.7%) 7 (8.3%) 3 (11.5%) 4 (36.4%) 0 (0.0%) 1 (20.0%)
(l) All employees 10 (7.6%) 6 (7.1%) 1 (3.8%) 0 (0.0%) 0 (0.0%) 3 (60.0%)
(m) No employees 40 (30.5%) 20 (23.8%) 12 (46.2%) 4 (36.4%) 3 (60.0%) 1 (20.0%)

Questions 3 - 10 asked agency components for information on Section 508 training for various employees in their workforce.  Specifically, agency components were requested to provide the number of hours of annual Section 508 training for various employees.  Agency components reported providing the most average hours of training to Section 508 coordinators (4.2 hours).  By contrast, agency components reported providing the fewest average hours of training to IT help desk staff (0.6 hours).  For most agency components, with the exception of Section 508 coordinators, the average hours of Section 508 training for all available types of employees was slightly below or slightly above one hour.  Surprisingly, very small agency components reported the highest number of average hours of Section 508 training for many of the available types of employees.  For example, very small agency components reported providing 5.2 average hours of training to website developers, which was more than three times the average hours provided by all agency components.

The following table provides the specific responses by the agency components:

Section 508 Training Provided to Personnel by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
Question 3: Section 508 coordinators 4.2 4.2 3.2 5.1 5.2 5.2
Question 4: Requiring officials (program managers, contracting officer's technical representatives, etc. ) 0.8 0.8 0.9 0.2 1.8 1.2
Question 5: Acquisition workforce (contracting officers, contract specialists, etc. ) 0.9 0.8 0.9 1.1 1.0 0.8
Question 6: Purchase cardholders 0.8 0.9 0.7 0.2 1.0 1.2
Question 7: Website developers 1.6 1.5 1.6 1.4 1.4 5.2
Question 8: Video and multimedia developers 1.0 0.8 1.3 0.5 0.0 3.4
Question 9: IT help desk staff 0.6 0.5 1.1 0.2 0.0 2.0
Question 10: Other employees 0.7 0.6 0.8 0.8 0.2 1.0

Question 11 asked agency components to identify their methods for providing Section 508 training.  In this question, agency components were allowed to select any number of available options.  Thus, the total of percentages within each column of the tables may exceed 100%.  In general, agency components identified various methods for providing Section 508 training.  With the exception of small agencies, components reported online training (67.2%) as the most common method for providing Section 508 training to their employees.  Mid-size agency components reported classroom instruction (81.8%) and conferences (72.7%) as their most common method for providing Section 508 training.

The agency components’ responses are summarized in the table below:

Section 508 Training Methods by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Section 508 universe (www.section508.gov) 68 (51.9%) 41 (48.8%) 14 (53.8%) 7 (63.6%) 3 (60.0%) 3 (60.0%)
(b) Other online training 88 (67.2%) 60 (71.4%) 17 (65.4%) 7 (63.6%) 1 (20.0%) 3 (60.0%)
(c) Classroom instruction 71 (54.2%) 42 (50.0%) 16 (61.5%) 9 (81.8%) 2 (40.0%) 2 (40.0%)
(d) Conferences and seminars 72 (55.0%) 44 (52.4%) 14 (53.8%) 8 (72.7%) 3 (60.0%) 3 (60.0%)
(e) Other 54 (41.2%) 32 (38.1%) 15 (57.7%) 3 (27.3%) 2 (40.0%) 2 (40.0%)

Question 12 asked agency components to identify specific subject areas covered by their Section 508 training.  This question permitted agency components to select any number of available options.  Thus, the total of percentages within each column of the tables may exceed 100%.  Overall, a majority of agency components reported Section 508 statute (80.2%), Section 508 EIT Accessibility Standards (79.4%), and procurement of accessible EIT (60.3%) as the three most common subject areas covered by their Section 508 training.  Captioning was the least common subject area covered by agency components’ Section 508 training.

The agency components’ responses are summarized in the table below:

Section 508 Training Subject Matter by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Section 508 law 105 (80.2%) 66 (78.6%) 23 (88.5%) 9 (81.8%) 3 (60.0%) 4 (80.0%)
(b) Section 508 EIT Accessibility Standards 104 (79.4%) 66 (78.6%) 23 (88.5%) 9 (81.8%) 3 (60.0%) 3 (60.0%)
(c) How to buy accessible EIT 79 (60.3%) 52 (61.9%) 17 (65.4%) 5 (45.5%) 1 (20.0%) 4 (80.0%)
(d) How to create accessible software 55 (42.0%) 37 (44.0%) 11 (42.3%) 4 (36.4%) 2 (40.0%) 1 (20.0%)
(e) How to create accessible website 70 (53.4%) 43 (51.2%) 14 (53.8%) 7 (63.6%) 2 (40.0%) 4 (80.0%)
(f) How to create accessible electronic forms 65 (49.6%) 38 (45.2%) 14 (53.8%) 6 (54.5%) 3 (60.0%) 4 (80.0%)
(g) How to create accessible electronic documents 73 (55.7%) 44 (52.4%) 16 (61.5%) 7 (63.6%) 3 (60.0%) 3 (60.0%)
(h) How to create accessible .pdfs 75 (57.3%) 44 (52.4%) 15 (57.7%) 7 (63.6%) 5 (100.0%) 4 (80.0%)
(i) How to caption video or multimedia 45 (34.4%) 29 (34.5%) 10 (38.5%) 2 (18.2%) 3 (60.0%) 2 (40.0%)
(j) How to evaluate software, websites, or documents for accessibility 68 (51.9%) 46 (54.8%) 16 (38.5%) 2 (18.2%) 3 (60.0%) 2 (40.0%)
(k) Other 44 (33.6%) 26 (31.0%) 12 (46.2%) 3 (27.3%) 1 (20.0%) 2 (40.0%)

I. Section 508 Challenges

Agencies and their components were asked a question regarding challenges in implementing and complying with Section 508.  A total of 318 agency components participated in this section.

Question 1 asked agency components to identify challenges in implementing and complying with Section 508.  In this question, agency components were allowed to select any number of available options.  Thus, the total of percentages within each column of the tables may exceed 100%.  In general, many agency components reported lack of resources (58.2%), lack of general awareness (50.0%), and lack of training (43.4%) as the three most common challenges in implementing and complying with Section 508.  By contrast, lack of management support (17.9%) was the least common challenge.  Interestingly, 49 agency components (15.4%) could not identify any challenges in implementing and complying with Section 508.

The following table provides the agency components’ responses:

Section 508 Challenges by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Lack of management support 57 (17.9%) 36 (20.2%) 17 (25.0%) 1 (5.6%) 2 (7.1%) 1 (3.8%)
(b) Lack of resources 185 (58.2%) 103 (57.9%) 42 (61.8%) 12 (66.7%) 17 (60.7%) 11 (42.3%)
(c) Weak Section 508 policy and/or procedure 86 (27.0%) 54 (30.3%) 15 (22.1%) 6 (33.3%) 9 (32.1%) 2 (7.7%)
(d) Lack of general awareness 159 (50.0%) 104 (58.4%) 29 (42.6%) 13 (72.2%) 9 (32.1%) 4 (15.4%)
(e) Lack of or inadequate training 138 (43.4%) 83 (46.6%) 31 (45.6%) 11 (61.1%) 9 (32.1%) 4 (15.4%)
(f) Lack of or inadequate authoring, development, and/or testing tools 97 (30.5%) 59 (33.1%) 22 (32.4%) 7 (38.9%) 8 (28.6%) 1 (3.8%)
(g) Lack of or inadequate considerations at the early stage of the EIT life cycle management process 101 (31.8%) 71 (39.9%) 22 (32.4%) 4 (22.2%) 3 (10.7%) 1 (3.8%)
(h) Lack of or inadequate knowledge by acquisition officials 82 (25.8%) 57 (32.0%) 17 (25.0%) 4 (22.2%) 3 (10.7%) 1 (3.8%)
(i) Lack of or inadequate knowledge by web content managers 73 (23.0%) 53 (29.8%) 12 (17.6%) 4 (22.2%) 3 (10.7%) 0 (0.0%)
(j) Lack of or inadequate knowledge by developers 83 (26.1%) 63 (35.4%) 14 (17.6%) 3 (16.7%) 3 (10.7%) 0 (0.0%)
(k) Lack of or inadequate knowledge by vendors 95 (29.9%) 58 (32.6%) 26 (38.2%) 6 (33.3%) 2 (7.1%) 0 (0.0%)
(l) Poor quality of vendor's VPATs 71 (22.3%) 42 (23.6%) 15 (22.1%) 9 (50.0%) 2 (7.1%) 3 (11.5%)
(m) Other 51 (16.0%) 22 (12.4%) 13 (19.1%) 1 (5.6%) 8 (28.6%) 7 (26.9%)
(n) No challenges 49 (15.4%) 26 (14.6%) 12 (17.6%) 0 (0.0%) 2 (7.1%) 9 (34.6%)

J. Other Rehabilitation Act Issues

Section 504 of the Rehabilitation Act prohibits discrimination on the basis of disability in any program or activity that receives financial assistance from any federal agency.  This means recipients of federal financial assistance must provide individuals with disabilities an opportunity to participate in and benefit from aids, benefits and services that are equal to and as effective as that provided to individuals without disabilities.  Today, due to advances in technology, recipients of federal financial assistance may provide benefits and services via websites and other EITs.  In this section, agencies and their components were asked questions regarding their policies of requiring recipients of federal financial assistance to ensure accessibility of their websites and other EITs.  A total of 318 agency components participated in this section.  However, 195 agency components did not complete this section because they did not provide any federal financial assistance to recipients.

The following provides a brief summary of the agency components’ responses:

  • Nearly forty percent of agency components that provided federal financial assistance reported not having any knowledge whether recipients of federal financial assistance were required to ensure accessibility of websites and other EITs.  Another twenty-four percent of agency components did not require recipients to ensure accessibility of websites and other EITs.  Thirty-five percent of agency components required recipients or parts of their components required recipients to ensure accessibility of websites and other EITs.
  • Among the agency components that required recipients to ensure accessibility of EITs, a majority reported that they used the Section 508 EIT Accessibility Standards as the standard for compliance by recipients of federal financial assistance.
  • Among the agency components that required recipients to ensure accessibility of EITs, a majority reported that they had established an EIT accessibility policy or parts of their components had established an EIT accessibility policy for recipients of federal financial assistance.

Question 1 asked whether agency components required recipients of federal financial assistance to ensure accessibility of websites and other EITs.  Those agency components that did not require recipients to ensure accessibility of EITs were asked to skip the remaining questions in this section and proceed to the next section regarding Procurement.  Overall, 22 agency components (39.8%) reported not having any knowledge whether recipients of federal financial assistance were required to ensure accessibility of EITs.  Another 44 agency components reported requiring recipients (17.9%) or parts of their components requiring recipients (17.9%) to ensure accessibility of EITs.  Twenty-five agency components (20.3%) did not require and had no plans to require recipients of federal financial assistance to ensure accessibility of EITs.

The agency components reported the following:

EIT Accessibility Under Section 504 by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes, recipients of federal financial assistance were required to provide accessible websites and other EITs 22 (17.9%) 9 (12.7%) 5 (19.2%) 4 (57.1%) 0 (0.0%) 4 (36.4%)
(b) Yes and no, parts of our components have done this, while others have not 22 (17.9%) 14 (19.7%) 4 (15.4%) 2 (28.6%) 2 (25.0%) 0 (0.0%)
(d) No, but a timetable was established to do so 5 (4.1%) 3 (4.2%) 0 (0.0%) 0 (0.0%) 1 (12.5%) 1 (9.1%)
(e) No, and there were no plans to do so 25 (20.3%) 14 (19.7%) 4 (15.4%) 0 (0.0%) 2 (25.0%) 5 (45.5%)
(c) Don't know 49 (39.8%) 31 (43.7%) 13 (50.0%) 1 (14.3%) 3 (37.5%) 1 (9.1%)

Question 2 asked agency components to identify EIT standards or guidelines used by recipients of federal financial assistance to ensure accessibility of their websites and other EITs.  A total of 44 agency components that required recipients to ensure accessibility of their EITs responded to this survey question.  Overall, 29 agency components (65.9%) reported the Section 508 EIT Accessibility Standards as the most common standard used by recipients of federal financial assistance.  Another 10 agency components (22.7%) reported the Web Content Accessibility Guidelines as the second most common standard used by recipients of federal financial assistance.  The following table summarizes the responses provided by the agency components:

EIT Standards Used Under Section 504 by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Section 508 EIT Accessibility Standards 29 (65.9%) 18 (78.3%) 4 (44.4%) 2 (33.3%) 2 (100.0%) 3 (75.0%)
(b) Web Content Accessibility Guidelines 10 (22.7%) 4 (17.4%) 3 (33.3%) 2 (33.3%) 0 (0.0%) 1 (25.0%)
(c) Other 3 (6.8%) 1 (4.3%) 1 (11.1%) 1 (16.7%) 0 (0.0%) 0 (0.0%)
(d) None 1 (2.3%) 0 (0.0%) 0 (0.0%) 1 (16.7%) 0 (0.0%) 0 (0.0%)
(e) Don't know 1 (2.3%) 0 (0.0%) 1 (11.1%) 0 (0.0%) 0 (0.0%) 0 (0.0%)

Question 3 inquired whether agency components established a formal, written policy to require recipients of federal financial assistance to ensure accessibility of their websites and other EITs.  Again, 44 agency components that required recipients to ensure accessibility of their EITs responded to this survey question.  Overall, 20 agency components (45.5%) reported establishing an EIT accessibility policy for recipients of federal financial assistance.  Another 14 agency components (31.8%) reported parts of their components establishing an EIT accessibility policy for recipients.  By contrast, 8 agency components (18.2%) reported not establishing an EIT accessibility policy for recipients.

The following table provides the specific responses by the agency components:

Section 504 EIT Accessibility Policy by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes, a formal, written policy was established to require recipients of federal financial assistance to provide accessible websites and other EITs 20 (45.5%) 12 (52.2%) 4 (44.4%) 1 (16.7%) 0 (0.0%) 3 (75.0%)
(b) Yes and no, parts of our components have done this, while others have not 14 (31.8%) 9 (39.1%) 2 (22.2%) 1 (16.7%) 1 (50.0%) 1 (25.0%)
(c) No, but a timetable was established to do so 5 (11.4%) 1 (4.3%) 0 (0.0%) 3 (50.0%) 1 (50.0%) 0 (0.0%)
(d) No, and there were no plans to do so 3 (6.8%) 1 (4.3%) 1 (11.1%) 1 (16.7%) 0 (0.0%) 0 (0.0%)
(e) Don't know 2 (4.5%) 0 (0.0%) 2 (22.2%) 0 (0.0%) 0 (0.0%) 0 (0.0%)

III. Procurement

Procurement policies and practices are critically important to an agency component’s compliance with Section 508 for two reasons.  First, Section 508 authorizes civil actions and administrative complaints by persons with disabilities when federal departments and agencies procure electronic and information technology that is not compliant with the Section 508 EIT Accessibility Standards. [16]  Second, the Federal Acquisition Regulation (FAR) was amended to incorporate the Section 508 EIT Accessibility Standards, and the amendment became effective on June 25, 2001.

The procurement section of the survey focused on five areas:

  • Contract Requirements
  • Market Research
  • Decision Documentation
  • Exceptions and Commercial Non-Availability Determinations
  • Pre or Post Award Protests

The following provides a brief summary of findings for each of the five subsections of Section III – Procurement.

  • Contract Requirements.  Agency components most often relied on basic contract requirements (such as general language requiring Section 508 compliance).  Also, agency components most often relied on reviewing the materials the vendor submitted rather than actual product testing to validate Section 508 compliance.
  • Market Research.  Agency components reported that the two most popular means of conducting market research were via internet research and vendor information (e.g., Voluntary Product Accessibility Template[17] or Government Product Accessibility Template).
  • Decision Documentation.  Agency components most often conveyed their decisions regarding Section 508 applicability or exceptions on EIT procurements in writing.  However, only a small number of agency components have established formalized systems for tracking and documenting Section 508 decisions.
  • Exceptions and Commercial Non-Availability Determinations.  Nearly forty percent of agency components reported establishing a formal, written policy to document Section 508 exceptions claimed on EIT procurements.  Many of these agency components reported that their EIT procurements met the Section 508 requirements and that reliance on an exception was unnecessary.  Agencies made occasional use of the available exceptions and reported most frequently using the exception for products located in non-occupiable locations. [18]  Where an undue burden determination was necessary, forty-six percent of agency components required approval at the top agency or top component level, while nearly twenty percent of agency components allowed the contracting official to make undue burden determinations without higher approval.
  • Pre or Post Award Protests.  One component in a very large agency reported receiving and sustaining one procurement protest based on Section 508.

A. Contract Requirements

Agencies and their components were asked questions relating to how Section 508 requirements were met in their EIT procurements.  This section included specific questions covering the initial contract process through the assessment of deliverables.  A total of 318 agency components participated in this section.  However, 57 agency components did not complete this section because they were not responsible for EIT procurements.

In general, agency components reported reliance on simple Section 508 tools, such as standard clauses and basic conformance materials from vendors.  Seventy percent of agency components reported using general language requiring Section 508 compliance as the most common means of incorporating Section 508 requirements in their solicitations.  Sixty percent of agency components reported reviewing the materials vendor submitted as the most common means of evaluating EIT related deliverables.  Surprisingly, a small number of agency components reported not incorporating Section 508 requirements in their solicitations, and not conducting any evaluation before accepting EIT related deliverables.

Question 1 asked how agency components incorporated Section 508 requirements in their solicitations that contained EIT related deliverables.  Those agency components that did not incorporate Section 508 requirements in their solicitations were asked to skip the remaining questions in this section and proceed to the next section regarding Market Research.  This question permitted agency components to select any number of available options.  Thus, the total of percentages within each column of the tables may exceed 100%. 

Across all agency size categories, general language requiring Section 508 compliance was the most common means of incorporating Section 508 requirements in their solicitations, used by 184 agency components (70.5%).  Specific applicable requirements from Section 508 EIT Accessibility Standards were the second most common means of incorporating Section 508 requirements in their solicitations, used by 125 agency components (47.9%).  VPATs were the least common method of incorporating Section 508 requirements in their solicitations, used by 75 agency components (28.7%).  Surprisingly, 20 agency components (7.7%) did not incorporate Section 508 requirements in their solicitations for EIT procurements.

The agency components’ responses are summarized in the table below:

Section 508 Incorporation Methods by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Used specific applicable requirements from Section 508 EIT Accessibility Standards 125 (47.9%) 78 (53.4%) 22 (41.5%) 9 (50.0%) 10 (40.0%) 6 (31.6%)
(b) Used general language stating comply with Section 508 184 (70.5%) 104 (71.2%) 38 (71.7%) 13 (72.2%) 17 (68.0%) 12 (63.2%)
(c) Used GSA Buy Accessible Wizard 79 (30.3%) 40 (27.4%) 19 (35.8%) 6 (33.3%) 7 (28.0%) 7 (36.8%)
(d) Used VPAT 75 (28.7%) 45 (30.8%) 17 (32.1%) 7 (38.9%) 4 (16.0%) 2 (10.5%)
(e) Other 40 (15.3%) 25 (17.1%) 8 (15.1%) 1 (5.6%) 5 (20.0%) 1 (5.3%)
(f) Did not incorporate Section 508 requirements 20 (7.7%) 9 (6.2%) 4 (7.5%) 1 (5.6%) 3 (12.0%) 3 (15.8%)

Question 2 inquired whether agency components included Section 508 requirements into their source selection criteria for procurements that contain EIT related deliverables.  A total of 241 agency components responded to this survey question.  Overall, a majority of agency components (78.0%) reported incorporating Section 508 requirements into their source selection criteria.  By contrast, 53 agency components (22.0%) reported not incorporating Section 508 requirements into their source selection criteria.

The following table provides the agency components’ responses:

Section 508 Requirements in Source Selection Criteria by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes, Section 508 requirements were incorporated into the source selection criteria 188 (78.0%) 105 (76.6%) 38 (77.6%) 13 (76.5%) 18 (81.8%) 14 (87.5%)
(b) No 53 (22.0%) 32 (23.4%) 11 (22.4%) 4 (23.5%) 4 (18.2%) 2 (12.5%)

Question 3 asked agency components how they identified contract requirements for test and acceptance of EIT related deliverables of applicable Section 508 EIT Accessibility Standards.  This question permitted agency components to select any number of available options.  Thus, the total of percentages within each column of the tables may exceed 100%.  A total of 241 agency components responded to this survey question.  Results varied between agency components regarding their reported use of testing.  Overall, the option most often selected by agency components across all size categories was to review the materials submitted.  Surprisingly, 43 agency components (17.8%) reported that they conducted no evaluation at all.

The agency components reported the following:

Testing Methods by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Testing done in-house 111 (46.1%) 62 (45.3%) 25 (51.0%) 6 (35.3%) 10 (45.5%) 8 (50.0%)
(b) Testing done by a third party 61 (25.3%) 36 (26.3%) 13 (26.5%) 2 (11.8%) 4 (18.2%) 6 (37.5%)
(c) Review of material submitted 145 (60.2%) 73 (53.3%) 35 (71.4%) 10 (58.8%) 18 (81.8%) 9 (56.3%)
(d) Special acceptance provisions 28 (11.6%) 17 (12.4%) 5 (10.2%) 1 (5.9%) 3 (13.6%) 2 (12.5%)
(e) No evaluation 43 (17.8%) 24 (17.5%) 9 (20.9%) 6 (35.3%) 2 (9.1%) 2 (12.5%)
(f) Other 31 (12.9%) 20 (14.6%) 6 (12.2%) 1 (5.9%) 2 (9.1%) 2 (12.5%)

B. Market Research

Agencies and their components were asked a question relating to market research in complying with Section 508 for EIT procurements.  A total of 318 agency components participated in this section.  However, 57 agency components did not complete this section because they were not responsible for EIT procurements.

Question 1 asked agency components how they performed market research for procurements that contain EIT related deliverables.  This question permitted agency components to select any number of available options.  Thus, the total of percentages within each column of the tables may exceed 100%.  In general, there was little variation among agency size categories regarding their choices.  A majority of agency components (75.5%) reported that internet research was the most common method of performing market research.  A total of 171 agency components (65.5%) reported vendor information as the second most common method of performing market research.  By contrast, internal database of products was the least common method of performing market research.  Twenty-eight agency components (10.7%) reported that they performed no market research at all when procuring EIT products.  The following table summarizes the responses provided by the agency components:

Market Research Source by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) GSA Buy Accessible Wizard 126 (48.3%) 71 (48.6%) 27 (50.9%) 8 (44.4%) 11 (44.0%) 9 (47.4%)
(b) Internet research 197 (75.5%) 114 (78.1%) 37 (69.8%) 14 (77.8%) 21 (84.0%) 11 (57.9%)
(c) Internal database of products 67 (25.7%) 39 (26.7%) 15 (28.3%) 4 (22.2%) 6 (24.0%) 3 (15.8%)
(d) Vendor information (VPAT or GPAT) 171 (65.5%) 96 (65.8%) 35 (66.0%) 12 (66.7%) 19 (76.0%) 9 (47.4%)
(e) Other agencies 91 (34.9%) 50 (34.2%) 19 (20.9%) 5 (27.8%) 9 (36.0%) 8 (42.1%)
(f) Other 53 (20.3%) 32 (21.9%) 11 (20.8%) 3 (16.7%) 6 (24.0%) 1 (5.3%)
(g) No market research performed 28 (10.7%) 15 (10.3%) 5 (9.4%) 2 (11.1%) 3 (12.0%) 3 (15.8%)

C. Decision Documentation

Agencies and their components were asked questions relating to their methods to document decisions regarding Section 508 applicability or exceptions on EIT procurements.  A total of 318 agency components participated in this section.  However, 57 agency components did not complete this section because they were not responsible for EIT procurements.

In general, a majority of agency components reported that requiring officials convey their decisions regarding Section 508 applicability or exceptions on EIT procurements in writing.  However, twenty-one percent of agency components reported that they did not document decisions at all.  In addition, a small number of agency components reported using an electronic system for tracking and documenting Section 508 decisions.

Question 1 asked agency components how their requiring officials document decisions when determining Section 508 applicability or exceptions on EIT procurements.  This question permitted agency components to select any number of available options.  Thus, the total of percentages within each column of the tables may exceed 100%.  Overall, a majority of agency components (74.7%) reported that requiring officials convey their decisions regarding Section 508 in writing.  This was particularly true within larger agency components.  Small and very small agency components reported using oral communications more frequently than larger agency components.  Fifty-seven agency components (21.8%) reported that they did not document any decisions when determining Section 508 applicability or exceptions on EIT procurements.

The following table provides the specific responses by the agency components:

Decision Documentation Methods by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) By written notice (specific form required) 96 (36.8%) 71 (48.6%) 14 (26.4%) 4 (22.2%) 4 (16.0%) 3 (15.8%)
(b) By written notice (form not required) 99 (37.9%) 46 (31.5%) 26 (49.1%) 9 (50.0%) 10 (40.0%) 8 (42.1%)
(c) By oral communication 47 (18.0%) 21 (14.4%) 9 (17.0%) 3 (16.7%) 9 (36.0%) 5 (26.3%)
(d) Other 42 (16.1%) 27 (18.5%) 9 (17.0%) 2 (11.1%) 4 (16.0%) 0 (0.0%)
(e) Did not document decisions 57 (21.8%) 27 (18.5%) 13 (22.8%) 4 (22.2%) 6 (24.0%) 7 (36.8%)

Question 2 inquired whether agency components were required to document decisions regarding Section 508 applicability or exceptions for EIT purchases of $3,000 or less (i.e. , micro-purchases).  A total of 204 agency components that documented decisions on EIT procurements responded to this survey question.  In general, a slight majority of agency components (51.0%) reported requiring decision documentation for EIT micro-purchases.

The agency components’ responses are summarized in the table below:

Decision Documentation for Micro-Purchases by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes, we document decisions for EIT micro-purchases 104 (51.0%) 68 (57.1%) 16 (40.0%) 6 (42.9%) 9 (47.4%) 5 (41.7%)
(b) No 100 (49.0%) 51 (42.9%) 24 (60.0%) 8 (57.1%) 10 (52.6%) 7 (58.3%)

Question 3 asked whether agency components track their decision documentation regarding Section 508 applicability or exceptions for EIT procurements.  Those agency components that did not track their decision documentation were asked to skip the remaining questions in this section and proceed to the next section regarding Exceptions and Commercial Non-Availability Determinations.  Overall, a majority of agency components (56.9%) reported that they did not track their decision documentation regarding Section 508 applicability or exceptions for EIT procurements.  A higher percentage of small agency components (78.9%) did not track their decision documentation.

The following table provides the agency components’ responses:

Decision Documentation Tracking by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes, we track document decisions for EIT purchases 88 (43.1%) 56 (47.1%) 18 (45.0%) 5 (35.7%) 4 (21.1%) 5 (41.7%)
(b) No 116 (56.9%) 63 (52.9%) 22 (55.0%) 9 (64.3%) 15 (78.9%) 7 (58.3%)

Question 4 inquired whether agency components established an automated system for tracking and documenting decisions regarding Section 508 applicability or exceptions for EIT procurements.  A total of 88 agency components that tracked their decision documentation responded to this survey question.  In general, a majority of agencies (59.1%) reported that they did not have an automated system available for specifically tracking Section 508 applicability or exceptions for EIT procurements.  Only 36 agency components (40.9%) reported having an electronic system for tracking and documenting Section 508 decisions.

The agency components reported the following:

Automated Decision Documentation Tracking System by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes, an automated tracking system was in place 36 (40.9%) 28 (50.0%) 6 (33.3%) 1 (20.0%) 1 (25.0%) 0 (0.0%)
(b) No 52 (59.1%) 28 (50.0%) 12 (66.7%) 4 (80.0%) 3 (75.0%) 5 (100.0%)

D. Exceptions and Commercial Non-Availability Determinations

Agencies and their components were asked questions relating to their use of Section 508 exceptions on EIT procurements.  A total of 318 agency components participated in this section.  However, 57 agency components did not complete this section because they were not responsible for EIT procurements.

In general, nearly forty percent of agency components established a formal, written policy to document Section 508 exceptions claimed on EIT procurements.  Many of these agency components reported EIT products they procured fully met the Section 508 requirements and that reliance on an exception was unnecessary.  Where an exception was used, the exception most frequently claimed by agency components was the exception for product located in non-occupiable locations. [19]  The exception least frequently claimed by agency components was the exception for undue burden.  In addition, with regard to the level of review required for undue burden determinations – forty-six percent of agency components required approval at the top agency or top component level, while nearly twenty percent of agency components allowed the requiring or procurement official to make undue burden determinations without higher approval.

Question 1 asked whether agency components established a formal, written policy to document any Section 508 exceptions claimed on EIT procurements.  Those agency components that did not establish a policy were asked to skip the remaining questions in this section and proceed to the next section regarding Administrative Complaints and Civil Actions.  Overall, a majority of agency components (60.9%) reported that they did not establish a policy to document Section 508 exceptions claimed on EIT procurements.

The following table summarizes the responses provided by the agency components:

Decision Documentation Policy by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes, a formal, written policy was established 102 (39.1%) 73 (50.0%) 14 (26.4%) 6 (33.3%) 5 (20.0%) 4 (21.1%)
(b) No 159 (60.9%) 73 (50.0%) 39 (73.6%) 12 (66.7%) 20 (80.0%) 15 (78.9%)

Question 2 asked agency components to identify the types of Section 508 exceptions claimed on EIT procurements.  This question permitted agency components to select any number of available options.  Thus, the total of percentages within each column of the tables may exceed 100%.  A total of 102 agency components that established a policy to document Section 508 exceptions responded to this survey question.  In general, 38 agency components (37.3%) reported that EIT products they procured fully met the Section 508 requirements and that reliance on an exception was unnecessary.  The exception most frequently claimed by agency components (32.4%) was the exception for product located in non-occupiable locations.  The exception least frequently claimed by agency components (10.8%) was the exception for undue burden.

The following table provides the specific responses by the agency components:

Exceptions Used by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Undue burden 11 (10.8%) 8 (11.0%) 3 (21.4%) 0 (0.0%) 0 (0.0%) 0 (0.0%)
(b) Determination of commercial non-availability 32 (31.4%) 24 (32.9%) 6 (42.9%) 0 (0.0%) 0 (0.0%) 2 (50.0%)
(c) National security 14 (13.7%) 14 (19.2%) 0 (0.0%) 0 (0.0%) 0 (0.0%) 0 (0.0%)
(d) Product was to be acquired by a contractor incidental to a contract 15 (14.7%) 13 (17.8%) 2 (14.3%) 0 (0.0%) 0 (0.0%) 0 (0.0%)
(e) Fundamental alteration 19 (18.6%) 15 (20.5%) 4 (21.1%) 0 (0.0%) 0 (0.0%) 0 (0.0%)
(f) Product to be located in space frequented only by service personnel for maintenance, repair, or occasional monitoring 33 (32.4%) 26 (35.6%) 2 (14.3%) 1 (16.7%) 2 (40.0%) 2 (50.0%)
(g) No exception used 38 (37.3%) 24 (32.9%) 7 (50.0%) 4 (66.7%) 3 (60.0%) 0 (0.0%)
(h) Don't know 18 (17.6%) 15 (20.5%) 1 (7.1%) 1 (16.7%) 0 (0.0%) 1 (25.0%)

Question 3 asked agency components to identify the minimal level of administrative approval for an undue burden exception on EIT procurements.  Overall, 47 agency components (46.0%)[20] reported requiring approval at the top agency or top component level.  Twenty agency components (19.6%) reported that the requiring or procurement official could make the undue burden determination without additional approval.

Specifically, the agency components’ provided the following responses:

Minimal Level of Approval for Undue Burden Exception by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) An approving official or board at the agency level 23 (22.5%) 18 (24.7%) 2 (14.3%) 0 (0.0%) 1 (20.0%) 2 (50.0%)
(b) An approving official or board at each component of the agency 24 (23.5%) 18 (24.7%) 4 (28.6%) 1 (16.7%) 1 (20.0%) 0 (0.0%)
(c) An approving official or board below the component level 7 (6.9%) 5 (6.8%) 1 (7.1%) 0 (0.0%) 0 (0.0%) 1 (25.0%)
(d) Requiring or procurement official without additional approval 20 (19.6%) 13 (17.8%) 2 (14.3%) 3 (50.0%) 1 (20.0%) 1 (25.0%)
(e) Section 508 coordinator 16 (15.7%) 10 (13.7%) 4 (28.6%) 1 (16.7%) 1 (20.0%) 0 (0.0%)
(f) Other 12 (11.8%) 9 (12.3%) 1 (7.1%) 1 (16.7%) 1 (20.0%) 0 (0.0%)

Question 4 is similar to Question 3, except agency components were asked to identify the minimal level of administrative approval for all exceptions other than undue burden.  Agency components reported a less stringent approval process for exceptions other than undue burden.  Overall, almost one and a half times as many agency components (29.4% versus 19.6%) permitted the requiring or procurement officer to make the exceptions determination alone.  Only 27 agency components (26.5%) reported requiring approval at the top agency or top component level.

The agency components’ responses are summarized in the table below:

Minimal Level of Approval for Exceptions Other than Undue Burden

by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) An approving official or board at the agency level 11 (10.8%) 7 (9.6%) 2 (14.3%) 1 (16.7%) 1 (20.0%) 0 (0.0%)
(b) An approving official or board at each component of the agency 16 (15.7%) 12 (16.4%) 3 (21.4%) 0 (0.0%) 0 (0.0%) 1 (25.0%)
(c) An approving official or board below the component level 6 (5.9%) 3 (4.1%) 2 (14.3%) 0 (0.0%) 0 (0.0%) 1 (25.0%)
(d) Requiring or procurement official without additional approval 30 (29.4%) 22 (30.1%) 2 (14.3%) 3 (50.0%) 2 (40.0%) 1 (25.0%)
(e) Section 508 coordinator 30 (29.4%) 22 (30.1%) 4 (28.6%) 1 (16.7%) 2 (40.0%) 1 (25.0%)
(f) Other 9 (8.8%) 7 (9.6%) 1 (7.1%) 1 (16.7%) 0 (0.0%) 0 (0.0%)

E. Pre or Post Award Protests

Agencies and their components were asked questions relating to protests on EIT procurements.  A total of 102 agency components that established a decision documentation policy responded to the survey questions.  The agency components’ responses are summarized below:

  • Questions 1 and 2 asked whether agency components received any procurement protests, and if so, to estimate the number of procurement protests filed claiming that the component did not properly follow the requirements of Section 508.  One very large agency component reported receiving one procurement protest based on Section 508.
  • Questions 3 and 4 asked whether agency components sustained any procurement protests, and if so, to estimate the number of procurement protests sustained based on Section 508 related issues.  One very large agency component reported sustaining one procurement protest based on Section 508.

IV. Administrative Complaints and Civil Actions

Persons with disabilities can file administrative complaints or civil lawsuits on or after June 21, 2001.  29 U.S.C. § 794d(f)(1)(B).  Section 794d(f)(1(B) provides:

This subsection shall apply only to electronic and information technology that is procured by a Federal department or agency not less than 6 months after the date of publication by the Access Board of final standards described in subsection (a)(2). [21]

By statute, persons with disabilities who file administrative complaints alleging that an agency’s procurement has violated Section 508 must file it with the agency alleged to be in noncompliance.  29 U.S.C. § 794d(f)(2).  Specifically, section 794d(f)(2) provides:

Complaints filed under paragraph (1) shall be filed with the Federal department or agency alleged to be in noncompliance.  The Federal department or agency receiving the complaint shall apply the complaint procedures established to implement section 794 of this title for resolving allegations of discrimination in a federally conducted program or activity.

Thus, Section 508 adopts the section 504 complaint processes of the federal agencies. [22]

This section of the survey focused on administrative complaints and civil actions related to Section 508 within the agency components.  Two specific areas were analyzed:

  • Policies and procedures for processing Section 508 complaints
  • Number of complaints and civil actions

The following provides a brief summary of findings for Section IV – Administrative Complaints and Civil Actions.

  • Policies and Procedures for Processing Section 508 Complaints.  Slightly more than thirty percent of agency components had already established an appropriate set of policies and procedures specifically to process Section 508 complaints.  Fifty-seven percent of the agency components were either using existing Section 504 complaint processes or some other process.  Also, a majority of agency components reported success at incorporating ADR into their complaint processes, and about half of the agency components widely disseminated complaint filing information on their website.
  • Number of complaints and civil actions.  Agency components reported that 140 administrative complaints and seven civil actions were filed against agency components alleging a violation of Section 508. [23]  Most of the administrative complaints and civil action were filed against very large and large agency components.

A. Policies and Procedures for Processing Section 508 Complaints

Agencies and their components were asked questions regarding their policies and procedures for processing complaints under Section 508.  A total of 318 agency components participated in this section.  However, 128 agency components did not complete this section because they were not responsible for receiving or processing their own administrative complaints under the Rehabilitation Act.

In general, slightly more than thirty percent of agency components had already established an appropriate set of policies and procedures specifically to process Section 508 complaints.  Fifty-seven percent of the agency components were either using existing Section 504 complaint processes or some other process.  Also, a majority of agency components reported success at incorporating ADR into their complaint processes, and about half of the agency components widely disseminated complaint filing information on their website.

Question 1 asked whether agency components examined their existing complaint processes applicable to complaints filed under Section 504 for federally conducted activities, and established formal, written policies and procedures to process complaints filed under Section 508.  Overall, 75 agency components (39.5%) reported using their existing Section 504 complaint processes, and 60 agency components (31.6%) reported establishing specific Section 508 complaint processes.  Small and very small agency components reported placing a higher reliance on existing Section 504 processes.

The following table provides the agency components’ responses:

Section 508 Complaint Process by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes, a specific policy and procedure was established to process Section 508 complaints 60 (31.6%) 41 (37.3%) 6 (25.0%) 5 (35.7%) 5 (20.0%) 3 (17.6%)
(b) No, but a timetable was established to do so 22 (11.6%) 9 (8.2%) 3 (12.5%) 3 (21.4%) 4 (16.0%) 3 (17.6%)
(c) No, existing Section 504 complaint process was used for Section 508 complaints 75 (39.5%) 42 (38.2%) 10 (41.7%) 6 (42.9%) 10 (40.0%) 7 (41.2%)
(d) Other 33 (17.4%) 18 (16.4%) 5 (20.8%) 0 (0.0%) 6 (24.0%) 4 (23.5%)

Question 2 asked whether agency components incorporated Alternative Dispute Resolution (ADR), such as mediation or arbitration, into their existing administrative complaint resolution process.  In general, a majority of agency components (68.9%) reported success at incorporating ADR into their complaint processes.

The agency components reported the following:

ADR Incorporation by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes, existing complaint process includes ADR 131 (68.9%) 82 (74.5%) 14 (58.3%) 11 (78.6%) 16 (64.0%) 8 (47.1%)
(b) Yes and no, parts of our components have done this, while others have not 13 (6.8%) 7 (6.4%) 4 (16.7%) 0 (0.0%) 2 (8.0%) 0 (0.0%)
(c) No, but a timetable was established to do so 9 (4.7%) 4 (3.6%) 0 (0.0%) 1 (7.1%) 3 (12.0%) 1 (5.9%)
(d) No, and there were no plans to do so 37 (19.5%) 17 (15.5%) 6 (25.0%) 2 (14.3%) 4 (16.0%) 8 (47.1%)

Question 3 asked whether agency components widely disseminated, on their website, instructions to the public and to employees regarding how to file administrative complaints under Section 508.  Generally, about half of the agency components widely disseminated complaint filing information to the public and to employees.  A total of 84 agency components (44.2%) reported widely disseminating complaint filing information on their website.  By contrast, 86 agency components (45.2%) reported not disseminating complaint filing information on their website.

The following table summarizes the responses provided by the agency components:

Complaint Filing Information Availability by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes, information was available on our website for the public and employees 84 (44.2%) 51 (46.4%) 13 (54.2%) 8 (57.1%) 7 (28.0%) 5 (29.4%)
(b) Yes and no, information was available for the public but not employees 6 (3.2%) 5 (4.5%) 0 (0.0%) 0 (0.0%) 1 (4.0%) 0 (0.0%)
(c) Yes and no, this information was available for employees but not for the public 14 (7.4%) 11 (10.0%) 0 (0.0%) 1 (7.1%) 2 (8.0%) 0 (0.0%)
(d) No, but a timetable was established to do so 36 (18.9%) 19 (17.3%) 2 (8.3%) 2 (14.3%) 8 (32.0%) 5 (29.4%)
(e) No, and there were no plans to do so 50 (26.3%) 24 (21.8%) 9 (37.5%) 3 (21.4%) 7 (28.0%) 7 (41.2%)

B. Number of Complaints and Civil Actions

Agencies and their components were asked questions regarding administrative complaints or civil actions filed against the components alleging a violation of Section 508.  A total of 318 agency components participated in this section.  However, 187 agency components did not complete this section because they did not offer Section 508 training to their employees.

Question 1 - 5 asked agency components to estimate the number of administrative complaints and civil actions filed, assessed, and resolved.  Agency components were asked to answer the following questions using information since June 21, 2001, the effective date of the Section 508 EIT Accessibility Standards.  Overall, agency components reported that 140 administrative complaints and seven civil actions were filed against agency components alleging a violation of Section 508.  Most of the administrative complaints and civil action were filed against very large and large agency components.

The following table summarizes the responses provided by the agency components:

Administrative Complaints and Civil Actions by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
Question 1: Administrative complaints filed 140 101 31 8 0 0
Question 2: Complaints determined to not be under Section 508 10 6 4 0 0 0
Question 3: Resolved Section 508 complaints 81 69 7 5 0 0
Question 4: Civil actions filed 7 7 0 0 0 0
Question 5: Resolved civil actions 1 1 0 0 0 0

V. Website Compliance

This section of the survey focused on policies and practices established by agency components to ensure accessibility of their websites.  This section also was designed to evaluate whether an agency component’s web pages, web-based forms, and web-based applications were accessible to people with disabilities.  Specifically, this section was divided into two areas concerning website compliance:

  • Web Policies and Practices
  • Four Representative Web Pages

The following provides a general summary of findings for Section V – Website Compliance.

  • Web Policies and Practices.  Nearly ninety percent of agency components reported having control over their website development and maintenance, and seventy percent of these agency components reported establishing formal, written web accessibility policies.  Agency components also reported that Adobe Acrobat (.pdf) files and video and audio multimedia content were the most frequently used content on their websites, and a majority of agency components reported that their web accessibility policies addressed the use of Adobe Acrobat (.pdf) files and video and audio multimedia content.  In addition, almost fifty-eight percent of agency components reported performing routine automated and/or manual evaluation and remediation on their websites.
  • Four Representative Web Pages.  Agency components reported that their web pages, web-based forms, and web-based applications were generally accessible to persons with disabilities.  A majority of agency components reported success in using alternative text attribute or other descriptive elements to represent non-text elements (images).  Also, a majority of agency components reported success in identifying row and column headers for data tables and associating data and header cells.  A majority of agency components reported that their forms permitted users of assistive technology to access the information, field elements, and functionality required for completion and submission of the form.  In addition, a majority of agency components reported that their applications provided sufficient information about user interface elements (such as check boxes, radio buttons, menus, toolbars, dialog and popup windows and controls) to assistive technology.  Agency components did, however, report some difficulty in providing captioning, audio description, and keyboard accessibility.

A. Web Policies and Practices

Agencies and their components were asked questions regarding their policies and practices for ensuring that their websites are accessible to people with disabilities.  A total of 318 agency components participated in this section.  However, ten agency components did not complete this section because they did not have a website.

The following provides a brief summary of the agency components’ responses:

  • Nearly ninety percent of agency components reported creating and/or maintaining their own websites, and seventy percent of these agency components reported establishing formal, written web accessibility policies.
  • Agency components reported that Adobe Acrobat (.pdf) files and video and audio multimedia content were the most frequently used content on their websites, and a majority of agency components reported that their web accessibility policies addressed the use of Adobe Acrobat (.pdf) files and video and audio multimedia content.
  • Almost fifty-eight percent of agency components reported performing routine automated and/or manual evaluation and remediation on their websites.  Specifically, twenty-eight percent of agency components performed both automated and manual evaluation, while twenty-four percent of agency components performed only manual evaluation, and six percent of agency components performed only automated evaluation.
  • Nearly seventy-three percent of agency components reported designating and widely advertising e-mail addresses on their websites to allow people with disabilities to inform the agency components of accessibility problems encountered on their websites.

Question 1 asked whether agency components have a website.  While 96.9% of all agency components did have a website, 3.1% did not.

The agency components reported the following:

Website by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes, we have a website 308 (96.9%) 176 (98.9%) 66 (97.1%) 18 (100.0%) 26 (92.9%) 22 (84.6%)
(b) No 10 (3.1%) 2 (1.1%) 2 (2.9%) 0 (0.0%) 2 (7.1%) 4 (15.4%)

Question 2 asked whether agency components created and/or maintained their own websites.  While most agency components (89.6%) created and/or maintained their own web pages, many other practices were also followed.

The following table summarizes the responses provided by the agency components:

Website Creation and Maintenance by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes, the component created its own web pages and maintained them. 204 (66.2%) 121 (68.8%) 43 (65.2%) 12 (66.7%) 21 (80.8%) 7 (31.8%)
(b) Yes and no. The component created the web pages, but another entity maintained them. 19 (6.2%) 8 (4.5%) 5 (7.6%) 2 (11.1%) 0 (0.0%) 4 (18.2%)
(c) Yes and no. Another entity created the web pages but the component maintained them. 10 (3.2%) 6 (3.4%) 2 (3.0%) 0 (0.0%) 0 (0.0%) 2 (9.1%)
(d) Yes and no. Some parts of the component created and maintained their own web pages, while others adopted a different practice. 43 (14.0%) 24 (13.6%) 12 (18.2%) 3 (16.7%) 4 (15.4%) 0 (0.0%)
(e) No. An independent contractor created and maintained the web pages. 18 (5.8%) 9 (5.1%) 3 (4.5%) 1 (5.6%) 1 (3.8%) 4 (18.2%)
(f) No. Another federal agency created and maintained the web pages. 9 (2.9%) 4 (2.3%) 0 (0.0%) 0 (0.0%) 0 (0.0%) 5 (22.7%)
(g) No. Another entity created and maintained the web pages. 5 (1.6%) 4 (2.3%) 1 (1.5%) 0 (0.0%) 0 (0.0%) 0 (0.0%)

Question 3 asked agency components to identify the most common types of content, applications, or features used on their websites.  This question permitted agency components to select any number of available options.  Thus, the total of percentages within each column of the tables may exceed 100%.  The agency components reported that Adobe Acrobat (.pdf) files (95.8%) and video and audio multimedia content (76.9%) were the most frequently used elements on their websites.  The agency components reported that MySpace (7.8%) and Flickr (20.1%) were the most infrequently used elements on their websites.

The following table provides the specific responses by the agency components:

Website Elements by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Portable document files (.pdfs) 295 (95.8%) 165 (93.8%) 65 (98.5%) 18 (100.0%) 26 (100.0%) 21 (95.5%)
(b) Multimedia content (video and audio) 237 (76.9%) 140 (79.5%) 51 (77.3%) 18 (100.0%) 18 (69.2%) 10 (45.5%)
(c) Flash content 179 (58.1%) 113 (64.2%) 34 (51.5%) 15 (83.3%) 12 (46.2%) 5 (22.7%)
(d) Word processing files 227 (73.7%) 135 (76.7%) 46 (69.7%) 15 (83.3%) 16 (61.5%) 15 (68.2%)
(e) Microsoft PowerPoint files 206 (66.9%) 126 (71.6%) 44 (66.7%) 14 (77.8%) 13 (50.0%) 9 (40.9%)
(f) Data tables 207 (67.2%) 120 (68.2%) 41 (62.1%) 16 (88.9%) 19 (73.1%) 11 (50.0%)
(g) Spreadsheet files 200 (64.9%) 117 (66.5%) 41 (62.1%) 17 (94.4%) 15 (57.7%) 10 (45.5%)
(h) JavaScript or other Scripts 232 (75.3%) 140 (79.5%) 49 (74.2%) 18 (100.0%) 19 (73.1%) 6 (27.3%)
(i) Java applets 82 (26.6%) 57 (32.4%) 13 (19.7%) 6 (33.3%) 15 (57.7%) 1 (4.5%)
(j) Blogs (web logs) 117 (38.0%) 69 (39.2%) 27 (19.7%) 11 (61.1%) 15 (57.7%) 2 (9.1%)
(k) Facebook 120 (39.0%) 79 (44.9%) 17 (25.8%) 11 (61.1%) 8 (30.8%) 1 (4.5%)
(l) MySpace 24 (7.8%) 19 (10.8%) 3 (4.5%) 2 (11.1%) 0 (0.0%) 0 (0.0%)
(m) Twitter 122 (39.6%) 72 (40.9%) 27 (40.9%) 10 (55.6%) 9 (34.6%) 4 (18.2%)
(n) YouTube 118 (38.3%) 73 (41.5%) 22 (33.3%) 11 (61.1%) 9 (34.6%) 3 (13.6%)
(o) Flickr 62 (20.1%) 43 (24.4%) 12 (18.2%) 4 (22.2%) 3 (11.5%) 0 (0.0%)

Question 4 asked whether agency components established a formal, written web accessibility policy to ensure their websites comply with Section 508.  Those agency components that did not establish a formal, written policy were asked to skip the remaining questions in this section regarding web accessibility policies.  Overall, a majority of agency components (70.4%) that created and maintained websites reported establishing web accessibility policies.  Small (50%) and very small agency components (54.5%), however, reported a lower incidence of establishing web accessibility policies.  Also, 32 agency components (10.4%) reported that they did not plan to establish a web accessibility policy.

Specifically, the agency components provided the following responses:

Section 508 Web Policy by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes, a formal, written web policy was established 119 (38.6%) 73 (41.5%) 20 (30.3%) 9 (50.0%) 8 (30.8%) 9 (40.9%)
(b) No, but a timetable was established to do so 36 (11.7%) 12 (6.8%) 3 (4.5%) 4 (22.2%) 10 (38.5%) 7 (31.8%)
(c) No, and there were no plans to do so 32 (10.4%) 17 (9.7%) 8 (12.1%) 1 (5.6%) 3 (11.5%) 3 (13.6%)
(d) Yes and no, parts of our components have done this, while others have not 23 (7.5%) 11 (6.3%) 6 (9.1%) 4 (22.2%) 1 (3.8%) 1 (4.5%)
(e) Yes and no. While the components had not established a specific web policy, they followed agency's web policy. 98 (31.8%) 63 (35.8%) 29 (43.9%) 0 (0.0%) 4 (15.4%) 2 (9.1%)

Question 5 asked whether each agency component’s web accessibility policy included a process to ensure that employees that have responsibility for the content of their website comply with the web accessibility policy. A total of 240 agency components that established a web accessibility policy responded to this survey question.  Overall, a majority of agency components (67.1%) that established a web accessibility policy reported that those who have responsibility for web content actually followed the web accessibility policy.

The agency components’ responses are summarized in the table below:

Section 508 Web Policy by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes, a process was established to ensure that those who are responsible for web content followed the web policy 161 (67.1%) 104 (70.7%) 34 (61.8%) 6 (46.2%) 7 (53.8%) 10 (83.3%)
(b) No, while parts of our components follow the web policy, a process was not established 64 (26.7%) 34 (23.1%) 18 (32.7%) 7 (53.8%) 4 (30.8%) 1 (8.3%)
(c) No, but a timetable was established to do so 7 (2.9%) 4 (2.7%) 0 (0.0%) 0 (0.0%) 2 (15.4%) 1 (8.3%)
(d) No, and there were no plans to do so 8 (3.3%) 5 (3.4%) 3 (5.5%) 0 (0.0%) 0 (0.0%) 0 (0.0%)

Question 6 asked whether each agency component’s web accessibility policy addressed the most common types of content, applications, or features used on their websites.  This question permitted agency components to select any number of available options.  Thus, the total of percentages within each column of the tables may exceed 100%.  A majority of agency components reported that their web accessibility policies addressed frequently used elements on their websites, such as Adobe Acrobat (.pdf) files (86.7%) and video and audio multimedia content (70.8%).

The following table provides the agency components’ responses:

Section 508 Web Policy on Website Elements by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Portable document files (.pdfs) 208 (86.7%) 124 (84.4%) 51 (92.7%) 11 (84.6%) 11 (84.6%) 11 (91.7%)
(b) Multimedia content (video and audio) 170 (70.8%) 103 (70.1%) 43 (78.2%) 12 (92.3%) 8 (61.5%) 4 (33.3%)
(c) Flash content 123 (51.2%) 79 (53.7%) 30 (54.5%) 9 (69.2%) 2 (15.4%) 3 (25.0%)
(d) Word processing files 152 (63.3%) 96 (65.3%) 34 (61.8%) 9 (69.2%) 6 (46.2%) 7 (58.3%)
(e) Microsoft PowerPoint files 131 (54.6%) 86 (58.5%) 28 (50.9%) 8 (61.5%) 4 (30.8%) 5 (41.7%)
(f) Data tables 148 (61.7%) 98 (66.7%) 31 (56.4%) 10 (76.9%) 4 (30.8%) 5 (41.7%)
(g) Spreadsheet files 126 (52.5%) 78 (53.1%) 28 (50.9%) 9 (69.2%) 5 (38.5%) 6 (50.0%)
(h) JavaScript or other Scripts 144 (60.0%) 91 (61.9%) 36 (65.5%) 9 (69.2%) 5 (38.5%) 3 (25.0%)
(i) Java applets 67 (27.9%) 47 (32.0%) 15 (27.3%) 3 (23.1%) 5 (38.5%) 1 (8.3%)
(j) Blogs (web logs) 70 (29.2%) 48 (32.7%) 15 (27.3%) 4 (30.8%) 5 (38.5%) 1 (8.3%)
(k) Facebook 59 (24.6%) 40 (27.2%) 13 (23.6%) 3 (23.1%) 1 (7.7%) 1 (8.3%)
(l) MySpace 21 (8.8%) 16 (10.9%) 5 (9.1%) 0 (0.0%) 0 (0.0%) 0 (0.0%)
(m) Twitter 122 (50.8%) 37 (25.2%) 12 (21.8%) 2 (15.4%) 1 (7.7%) 0 (0.0%)
(n) YouTube 68 (28.3%) 46 (31.3%) 15 (27.3%) 4 (30.8%) 2 (15.4%) 1 (8.3%)
(o) Flickr 34 (14.2%) 24 (16.3%) 7 (12.7%) 1 (7.7%) 2 (15.4%) 0 (0.0%)

Question 7 asked whether each agency component’s web accessibility policy included a process to routinely evaluate and remediate their websites for Section 508 compliance.  Overall, a slight majority of agency components (57.5%) reported performing routine automated and/or manual evaluation and remediation on their websites.  Specifically, 27.9% of agency components performed both automated and manual evaluation, while 23.8% of agency components performed only manual evaluation, and 5.8% of agency components performed only automated evaluation.  Another 22.1% of agency components reported performing evaluation and remediation only when notified of accessibility problems.  Surprisingly, 28 agency components (11.7%) reported that they had no plans to evaluate and remediate their websites.

The agency components reported the following:

Section 508 Web Policy on Testing by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes, we conduct routine automated and manual web evaluations and remediate problems 67 (27.9%) 47 (32.0%) 14 (25.5%) 2 (15.4%) 1 (7.7%) 3 (25.0%)
(b) Yes, we conduct routine automated web evaluations and remediate problems 14 (5.8%) 12 (8.2%) 1 (1.8%) 0 (0.0%) 1 (7.7%) 0 (0.0%)
(c) Yes, we conduct routine manual web evaluations and remediate problems 57 (23.8%) 34 (23.1%) 13 (23.6%) 4 (30.8%) 5 (38.5%) 1 (8.3%)
(d) Yes, but we evaluate and remediate only when notified of accessibility problems 53 (22.1%) 25 (17.0%) 17 (30.9%) 4 (30.8%) 2 (15.4%) 5 (41.7%)
(e) No, but a timetable was established to do so 21 (8.8%) 13 (8.8%) 4 (7.3%) 1 (7.7%) 2 (15.4%) 1 (8.3%)
(f) No, and there were no plans to do so 28 (11.7%) 16 (10.9%) 6 (10.9%) 2 (15.4%) 2 (15.4%) 2 (16.7%)

Question 8 asked whether agency components designated and advertised e-mail addresses on their website to allow people with disabilities to inform the agency components of accessibility problems encountered on their website.  A total of 308 agency components responded to this survey question.  Overall, nearly 73.0% of agency components reported providing this e-mail address on their websites.

The following table summarizes the responses provided by the agency components:

Designated E-Mail Address by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes, an email address and instructions were available on the website 195 (63.3%) 112 (63.6%) 38 (57.6%) 13 (72.2%) 14 (53.8%) 18 (81.8%)
(b) No, but a telephone number and a TTY number were available on the website 20 (6.5%) 7 (4.0%) 5 (7.6%) 1 (5.6%) 5 (19.2%) 2 (9.1%)
(c) No, but a timetable was established to do so 26 (8.4%) 17 (9.7%) 2 (3.0%) 1 (5.6%) 5 (19.2%) 1 (4.5%)
(d) No, and there were no plans to do so 37 (12.0%) 22 (12.5%) 11 (16.7%) 1 (5.6%) 2 (7.7%) 1 (4.5%)
(e) Yes and no, parts of our components have done this, while others have not 30 (9.7%) 18 (10.2%) 10 (15.2%) 2 (11.1%) 0 (0.0%) 0 (0.0%)

B. Four Representative Web Pages

Agencies and their components were asked to evaluate the accessibility of their Internet home pages, Intranet home pages, web-based forms, and web-based applications.  A total of 318 agency components participated in this section.  However, some agency components did not complete parts of this section because they did not have an Internet home page, Intranet home page, web-based form, or web-based application.

The following provides a brief summary of the agency components’ responses:

  • Agency components reported very similar findings for their external Internet and internal Intranet home pages.  More than eighty percent of agency components reported either complying with the web requirements in the Section 508 EIT Accessibility Standards or that the requirements were not applicable.  For example, slightly more than eighty percent of agency components reported the use of alternative text attribute or other descriptive elements to represent non-text elements (images) on their external Internet home pages, while five percent of agency components reported that this requirement was not applicable.  Also, slightly more than fifty percent of agency components reported identifying row and column headers for data tables on their external Internet home pages, while forty percent of agency components reported that this requirement was not applicable.  Agency components did, however, report some difficulty in providing captioning and audio description for multimedia content.
  • More than eighty-five percent of agency components reported either complying with the requirements in the Section 508 EIT Accessibility Standards for web-based forms or that the requirements were not applicable.  For example, seventy-five percent agency components reported the use of alternative text attribute or other descriptive elements to represent non-text elements on their web-based forms, while almost ten percent of agency components reported that this requirement was not applicable.  Also, eighty percent of agency components reported that their forms permitted users of assistive technology to access the information, field elements, and functionality required for completion and submission of the form, while seven percent of agency components reported that this requirement was not applicable.  Agency components did, however, report some difficulty in providing keyboard accessibility.
  • More than eighty percent of agency components reported either complying with the requirements in the Section 508 EIT Accessibility Standards for web-based applications or that the requirements were not applicable.  For example, seventy-five percent of agency components reported the use of alternative text attribute or other descriptive elements to represent non-text elements on their web-based applications, while almost seven percent of agency components reported that this requirement was not applicable.  Also, slightly more than sixty percent of agency components reported that their applications provided sufficient information about user interface elements (such as check boxes, radio buttons, menus, toolbars, dialog and popup windows and controls) to assistive technology, while slightly more than twenty percent of agency components reported that this requirement was not applicable.  Agency components did, however, report some difficulty in providing keyboard accessibility.

1. External Internet Home Page

A total of 289 agency components that use external Internet home pages responded to the following survey questions.

Question 1 asked agency components to provide the URLs for their external Internet home pages.

Question 2 asked agency components to provide the best description of the purpose of their external Internet web pages.  Overall, most agency components (74.4%) reported that their web pages described the missions and activities of the component.

The following table provides the specific responses by the agency components:

Purpose of Web Page by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Description of component's missions and activities 215 (74.4%) 126 (76.8%) 38 (62.3%) 13 (72.2%) 22 (84.6%) 16 (80.0%)
(b) Information about programs and benefits 26 (9.0%) 12 (7.3%) 7 (11.5%) 2 (11.1%) 1 (3.8%) 4 (20.0%)
(c) Information about products and services 25 (8.7%) 15 (9.1%) 6 (9.8%) 2 (11.1%) 2 (7.7%) 0 (0.0%)
(d) Publication of resources 8 (2.8%) 3 (1.8%) 4 (6.6%) 0 (0.0%) 1 (3.8%) 0 (0.0%)
(e) Employment postings 1 (0.3%) 1 (0.6%) 0 (0.0%) 0 (0.0%) 0 (0.0%) 0 (0.0%)
(f) Other 14 (4.8%) 7 (4.3%) 6 (9.8%) 1 (5.6%) 0 (0.0%) 0 (0.0%)

Question 3 asked agency components about the use of “alt” (alternative text attribute) or other descriptive elements to represent non-text elements in the page.  They are chiefly used to make visual information accessible for people with visual impairments.  Most agency components from all size categories reported the use of the alternative text attribute or other descriptive elements to represent non-text elements in the page.  Overall, a majority of agency components reported a high degree of success in meeting this requirement for their surveyed web pages.  Larger agency components were more successful in meeting this requirement than smaller agency components.

Specifically, the agency components provided the following responses:

Text Equivalence by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes 238 (82.4%) 134 (81.7%) 55 (90.2%) 17 (94.4%) 17 (65.4%) 15 (75.0%)
(b) No 37 (12.8%) 19 (11.6%) 4 (6.6%) 1 (5.6%) 9 (34.6%) 4 (20.0%)
(c) Not Applicable 14 (4.8%) 11 (6.7%) 2 (3.3%) 0 (0.0%) 0 (0.0%) 1 (5.0%)

Question 4 asked agency components whether audio description and text captions provided were synchronized with their associated dynamic content.  Synchronization allows the multimedia content to be more accessible and readily understood by users with hearing and/or visual impairments.  Many agency components (38.8%) reported that their web pages did not include multimedia content.  For those web pages with multimedia content, a majority of agency components reported success with synchronized captioning and descriptive text.  Larger agency components were more successful in meeting this requirement than smaller agency components.

The agency components’ responses are summarized in the table below:

Multimedia Content Accessibility Synchronization by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes 134 (46.4%) 79 (48.2%) 31 (50.8%) 12 (66.7%) 7 (26.9%) 5 (25.0%)
(b) No 43 (14.9%) 25 (15.2%) 5 (8.2%) 0 (0.0%) 9 (34.6%) 4 (20.0%)
(c) Not Applicable 112 (38.8%) 60 (36.6%) 25 (41.0%) 6 (33.3%) 10 (38.5%) 11 (55.0%)

Question 5 asked agency components about the accessibility of their web pages for users with varying degrees of color-blindness.  Overall, a majority of agency components reported that all information conveyed with color was also available without color.  Mid-size agency components were the most successful in meeting this requirement.

The following table provides the agency components’ responses:

Appropriate Use of Color by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes 194 (67.1%) 109 (66.5%) 42 (68.9%) 15 (83.3%) 15 (57.7%) 13 (65.0%)
(b) No 43 (14.9%) 26 (15.9%) 4 (6.6%) 0 (0.0%) 8 (30.8%) 5 (25.0%)
(c) Not Applicable 52 (18.0%) 29 (17.7%) 15 (24.6%) 3 (16.7%) 3 (11.5%) 2 (10.0%)

Question 6 focused on the use of Cascading Style Sheets (CSS) in web pages.  Agency components were asked whether their web pages were readable if the corresponding style sheets were deactivated, and whether the style sheets, if used, were designed so that they did not interfere with custom style sheets set by the browser.  Most agency components reported success in meeting this requirement.  Small agency components were the least successful in meeting this requirement.

The agency components reported the following:

Style Sheet Accessibility by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes 242 (83.7%) 142 (86.6%) 49 (80.3%) 18 (100.0%) 16 (61.5%) 17 (85.0%)
(b) No 22 (7.6%) 14 (8.5%) 1 (1.6%) 0 (0.0%) 5 (19.2%) 2 (10.0%)
(c) Not Applicable 25 (8.7%) 8 (4.9%) 11 (18.0%) 0 (0.0%) 5 (19.2%) 1 (5.0%)

Question 7 asked agency components to provide information on the use of server-side image maps and whether duplicate text links were provided for all links within the image maps.  A majority of agency components (58.8%) from all agency size categories reported not using image maps and thereby avoiding problems with this requirement.  For those web pages with server-side image maps, a majority of agency components reported having success with this requirement.

The following table summarizes the responses provided by the agency components:

Server-Side Image Map Accessibility by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes 95 (32.9%) 55 (33.5%) 25 (41.0%) 6 (33.3%) 5 (19.2%) 4 (20.0%)
(b) No 24 (8.3%) 14 (8.5%) 1 (1.6%) 0 (0.0%) 7 (26.9%) 2 (10.0%)
(c) Not Applicable 170 (58.8%) 95 (57.9%) 35 (57.4%) 12 (66.7%) 14 (53.8%) 14 (70.0%)

Question 8 continues the image maps question by asking agency components whether they provided client-side image maps instead of server-side image maps, except where the regions cannot be defined with an available geometric shape.  A majority of agency components (56.7%) from all agency size categories reported not using image maps.  For those web pages with image maps, a majority of agency components reported success in providing client-side image maps instead of server-side image maps.

The following table provides the specific responses by the agency components:

Use of Client-Side Image Map by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes 107 (37.0%) 61 (37.2%) 26 (42.6%) 6 (33.3%) 9 (34.6%) 5 (25.0%)
(b) No 18 (6.2%) 11 (6.7%) 1 (1.6%) 0 (0.0%) 4 (15.4%) 2 (10.0%)
(c) Not Applicable 164 (56.7%) 92 (56.1%) 34 (55.7%) 12 (66.7%) 13 (50.0%) 13 (65.0%)

Question 9 inquired about data tables in web pages.  Agency components were asked if they identified row and column headers (when such table headers existed) for data tables in web pages.  Many agency components (40.5%) reported that their web pages did not include data tables.  For those web pages with data tables, a majority of agency components reported success identifying row and column headers for data tables.  Small agency components had more difficulty meeting this requirement.

Specifically, the agency components provided the following responses:

Row and Column Header Identification by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes 151 (52.2%) 84 (51.2%) 33 (54.1%) 10 (55.6%) 14 (53.8%) 10 (50.0%)
(b) No 21 (7.3%) 11 (6.7%) 5 (8.2%) 0 (0.0%) 5 (19.2%) 0 (0.0%)
(c) Not Applicable 117 (40.5%) 69 (42.1%) 23 (37.7%) 8 (44.4%) 7 (26.9%) 10 (50.0%)

Question 10 continues the data tables question by asking agency components whether each cell in a data table was provided identification of row and column headers (when such table headers existed).  A majority of agency components (52.9%) reported that their web pages did not include data tables.  For those web pages with data tables, a majority of agency components reported success associating data cells and header cells.  Small agency components were the least successful in meeting this requirement.

The agency components’ responses are summarized in the table below:

Data and Header Cell Association by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes 113 (39.1%) 66 (40.2%) 26 (42.6%) 5 (27.8%) 8 (30.8%) 8 (40.0%)
(b) No 23 (8.0%) 12 (7.3%) 3 (4.9%) 0 (0.0%) 8 (30.8%) 0 (0.0%)
(c) Not Applicable 153 (52.9%) 86 (52.4%) 32 (52.5%) 13 (72.2%) 10 (38.5%) 12 (60.0%)

Question 11 asked agency components whether descriptive titles were used for web pages with frames.  A majority of agency components (64.4%) reported that their web pages did not use frames.  For those web pages with frames, a majority of agency components reported success in meeting this requirement.  Small agency components were the least successful in meeting this requirement.

The following table provides the agency components’ responses:

Frame Accessibility by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes 89 (30.8%) 55 (28.8%) 14 (21.1%) 6 (38.9%) 6 (20.0%) 8 (42.9%)
(b) No 14 (4.8%) 7 (8.5%) 3 (1.8%) 0 (5.6%) 4 (24.0%) 0 (0.0%)
(c) Not Applicable 186 (64.4%) 102 (62.2%) 44 (72.1%) 12 (66.7%) 16 (61.5%) 12 (60.0%)

Question 12 asked agency components whether content (such as applets or plug-ins) on their web pages were designed to avoid causing the screen to flicker with a frequency greater than 2 Hz and lower than 55 Hz.  Overall, most agency components reported that their web pages did not flicker.

The agency components reported the following:

Designed to Avoid Screen Flicker by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes 205 (70.9%) 111 (67.7%) 48 (78.7%) 15 (83.3%) 17 (65.4%) 14 (70.0%)
(b) No 11 (3.8%) 6 (3.7%) 1 (1.6%) 0 (0.0%) 3 (11.5%) 1 (5.0%)
(c) Not Applicable 73 (25.3%) 47 (28.7%) 12 (19.7%) 3 (16.7%) 6 (23.1%) 5 (25.0%)

Question 13 asked whether agency components provided an alternative text-only web page because their surveyed web pages contained barriers to people with disabilities, and whether the alternative text-only web page contained the same information and was updated as often as the inaccessible surveyed web page.  Many agency components (47.8%) in all agency size categories reported that text-only alternative pages were not needed because their web pages did not contain barriers for people with disabilities.  When alternative text-only web pages were provided, a majority of agency components reported success in providing up to date, equivalent information and functionality.

The following table summarizes the responses provided by the agency components:

Alternative Text-Only Page Availability and Accessibility by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes 105 (36.3%) 57 (34.8%) 24 (39.3%) 8 (44.4%) 6 (23.1%) 10 (50.0%)
(b) No 46 (15.9%) 26 (15.9%) 7 (11.5%) 1 (5.6%) 7 (26.9%) 5 (25.0%)
(c) Not Applicable 138 (47.8%) 81 (49.4%) 30 (49.2%) 9 (50.0%) 13 (50.0%) 5 (25.0%)

Question 14 asked agency components whether equivalent text was made available for web pages using JavaScript or Macromedia Flash scripts that affected content displayed to the user.  Overall, a majority of agency components reported that their web pages with scripting were accessible.  Small agency components were the least successful in meeting this requirement when scripting was used.

The following table provides the specific responses by the agency components:

Java/Flash Accessibility by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes 187 (64.7%) 109 (66.5%) 39 (63.9%) 14 (77.8%) 13 (50.0%) 12 (60.0%)
(b) No 38 (13.1%) 21 (12.8%) 5 (8.2%) 1 (5.6%) 8 (30.8%) 3 (15.0%)
(c) Not Applicable 64 (22.1%) 34 (20.7%) 17 (27.9%) 3 (16.7%) 5 (19.2%) 5 (25.0%)

Question 15 asked agency components whether their web pages included a link to the plug-in or other programmatic item required for accessing the content of their web pages, and if that plug-in or other programmatic item itself was accessible to people with disabilities.  Many agency components (37.7%) reported that their web pages did not use programmatic elements.  Overall, a majority of agency components reported success in meeting this requirement.

Specifically, the agency components provided the following responses:

Plug-In or Other Programmatic Object Accessibility by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes 153 (52.9%) 91 (55.5%) 30 (49.2%) 13 (72.2%) 8 (30.8%) 11 (55.0%)
(b) No 27 (9.3%) 15 (9.1%) 3 (4.9%) 0 (0.0%) 8 (30.8%) 1 (5.0%)
(c) Not Applicable 109 (37.7%) 58 (35.4%) 28 (45.9%) 5 (27.8%) 10 (38.5%) 8 (40.0%)

Question 16 asked agency components about their use of online electronic forms.  Specifically, agency components were asked whether each form permitted users of assistive technology to access the information, field elements, and functionality required for completion and submission of the form, including all directions and cues.  Many agency components (34.9%) reported that their web pages did not use online electronic forms.  Overall, a majority of agency components reported that their forms were accessible. 

The agency components’ responses are summarized in the table below:

Electronic Form Accessibility by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes 163 (56.4%) 90 (54.9%) 39 (63.9%) 13 (72.2%) 9 (34.6%) 12 (60.0%)
(b) No 25 (8.7%) 13 (7.9%) 3 (4.9%) 1 (5.6%) 6 (23.1%) 2 (10.0%)
(c) Not Applicable 101 (34.9%) 61 (37.2%) 19 (31.1%) 4 (22.2%) 11 (42.3%) 6 (30.0%)

Question 17 asked agency components whether navigational links to other web pages within the same website had special links that allowed screen readers to skip over those navigational links.  Overall, a majority of agency components reported including skip navigational links.  Small agency components had more difficulty meeting this requirement.

The following table provides the agency components’ responses:

Navigational Link Skipping by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes 179 (61.9%) 104 (63.4%) 46 (75.4%) 14 (77.8%) 5 (19.2%) 10 (50.0%)
(b) No 46 (15.9%) 22 (13.4%) 4 (6.6%) 2 (11.1%) 14 (53.8%) 4 (20.0%)
(c) Not Applicable 64 (22.1%) 38 (23.2%) 11 (18.0%) 2 (11.1%) 7 (26.9%) 6 (30.0%)

Question 18 focused on web pages that imposed time limits on users.  Specifically, agency components were asked if users were alerted that they would be timed out and then given sufficient time to indicate that more time was needed before actually being timed out.  A majority of agency components (79.9%) reported that time limits were not used.  For those web pages that imposed time limits, a majority of agency components reported success in meeting this requirement.  Mid-size agency components were the most successful in meeting this requirement.

The agency components reported the following:

Time Limits by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes 44 (15.2%) 29 (17.7%) 5 (8.2%) 7 (38.9%) 1 (3.8%) 2 (10.0%)
(b) No 14 (4.8%) 8 (4.9%) 2 (3.3%) 0 (0.0%) 3 (11.5%) 1 (5.0%)
(c) Not Applicable 231 (79.9%) 127 (77.4%) 54 (88.5%) 11 (61.1%) 22 (84.6%) 17 (85.0%)

Question 19 asked agency components whether programmatic elements on their web pages provided keyboard accessibility.  Keyboard accessibility allows people with disabilities to access a program’s controls and features from a keyboard instead of a mouse or other pointing device.  Many agency components (39.4%) reported that their web pages did not use programmatic elements.  Overall, a majority of agency components reported success in meeting this requirement. 

The following table summarizes the responses provided by the agency components:

Keyboard Accessibility by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes 153 (52.9%) 90 (54.9%) 31 (50.8%) 11 (61.1%) 12 (46.2%) 9 (45.0%)
(b) No 22 (7.6%) 13 (7.9%) 4 (6.6%) 0 (0.0%) 5 (19.2%) 0 (0.0%)
(c) Not Applicable 114 (39.4%) 61 (37.2%) 26 (42.6%) 7 (38.9%) 9 (34.6%) 11 (55.0%)

Question 20 asked agency components whether programmatic elements on their web pages provided a well-defined on-screen indication of the current focus that moves with keyboard navigation.  The position on a screen where an action will take place is referred to as the focus.  Many agency components (34.6%) reported that their web pages did not use programmatic elements.  Overall, a majority of agency components reported success in ensuring that focus was programmatically exposed so that assistive technology can track focus. 

The following table provides the specific responses by the agency components:

Screen Focus by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes 146 (50.5%) 91 (55.5%) 30 (49.2%) 10 (55.6%) 6 (23.1%) 9 (45.0%)
(b) No 43 (14.9%) 25 (15.2%) 4 (6.6%) 1 (5.6%) 10 (38.5%) 3 (15.0%)
(c) Not Applicable 100 (34.6%) 48 (29.3%) 27 (44.3%) 7 (38.9%) 10 (38.5%) 8 (40.0%)

Question 21 asked agency components whether programmatic elements on their web pages provided sufficient information about user interface elements (such as check boxes, radio buttons, menus, toolbars, dialog and popup windows and controls) to assistive technology.  Overall, a majority of agency components reported success in meeting this requirement.  Small agency components had more difficulty meeting this requirement.                                                           

Specifically, the agency components provided the following responses:

Availability of User Interface Information by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes 190 (65.7%) 113 (68.9%) 42 (68.9%) 13 (72.2%) 10 (38.5%) 12 (60.0%)
(b) No 36 (12.5%) 17 (10.4%) 6 (9.8%) 1 (5.6%) 9 (34.6%) 3 (15.0%)
(c) Not Applicable 63 (21.8%) 34 (20.7%) 13 (21.3%) 4 (22.2%) 7 (26.9%) 5 (25.0%)

Question 22 asked whether agency components used text captioning for multimedia content.  Such accessibility features are used to make multimedia features accessible to users with hearing and/or visual impairments.  Many agency components (42.2%) reported that their surveyed web pages did not include multimedia content.  For those web pages that used multimedia content, a majority of agency components reported success in captioning multimedia content.  Small and very small agency components had more difficulty meeting this requirement.

The agency components’ responses are summarized in the table below:

Captioning by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes 115 (39.8%) 70 (42.7%) 27 (44.3%) 9 (50.0%) 6 (23.1%) 3 (15.0%)
(b) No 52 (18.0%) 26 (15.9%) 9 (14.8%) 3 (16.7%) 9 (34.6%) 5 (25.0%)
(c) Not Applicable 122 (42.2%) 68 (41.5%) 25 (41.0%) 6 (33.3%) 11 (42.3%) 12 (60.0%)

Question 23 asked whether agency components used descriptive narration for multimedia content.  Many agency components (47.4%) reported that their surveyed web pages did not include multimedia content.  For those web pages that used multimedia content, a majority of agency components reported success in providing audio description for multimedia content.  Small and very small agency components had more difficulty meeting this requirement.

The following table provides the agency components’ responses:

Audio Description by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes 92 (31.8%) 57 (34.8%) 21 (34.4%) 8 (44.4%) 4 (15.4%) 2 (10.0%)
(b) No 60 (20.8%) 31 (18.9%) 9 (14.8%) 3 (16.7%) 11 (42.3%) 6 (30.0%)
(c) Not Applicable 137 (47.4%) 76 (46.3%) 31 (50.8%) 7 (38.9%) 11 (42.3%) 12 (60.0%)

2. Internal Intranet Home Page

A total of 260 agency components that use internal Intranet home pages responded to the following survey questions.

Question 1 asked agency components to provide the URLs for their internal Intranet home pages.

Question 2 asked agency components to provide the best description of the purpose of their internal Intranet web pages.  Overall, a majority of agency components reported that their web pages either described the missions and activities of the component (35.0%) or provided information about their programs and benefits (20.4%).

The following table provides the specific responses by the agency components:

Purpose of Web Page by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Description of component's missions and activities 91 (35.0%) 62 (40.5%) 15 (26.3%) 8 (44.4%) 6 (24.0%) 0 (0.0%)
(b) Information about programs and benefits 53 (20.4%) 21 (13.7%) 14 (24.6%) 4 (22.2%) 9 (36.0%) 5 (71.4%)
(c) Information about products and services 30 (11.5%) 15 (9.8%) 9 (15.8%) 3 (16.7%) 3 (12.0%) 0 (0.0%)
(d) Publication of resources 40 (15.4%) 24 (15.7%) 10 (17.5%) 1 (5.6%) 3 (12.0%) 2 (28.6%)
(e) Employment postings 1 (0.4%) 1 (0.7%) 0 (0.0%) 0 (0.0%) 0 (0.0%) 0 (0.0%)
(f) Other 45 (17.3%) 30 (19.6%) 9 (15.8%) 2 (11.1%) 4 (16.0%) 0 (0.0%)

Question 3 asked agency components about the use of “alt” (alternative text attribute) or other descriptive elements to represent non-text elements in the page.  They are chiefly used make visual information accessible for people with visual impairments.  Most agency components from all size categories reported the use of the alternative text attribute or other descriptive elements to represent non-text elements in the page.  Overall, a majority of agency components reported a high degree of success in meeting this requirement for their surveyed web pages.  Small agency components had more difficulty meeting this requirement.

Specifically, the agency components provided the following responses:

Text Equivalence by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes 196 (75.4%) 118 (77.1%) 47 (82.5%) 14 (77.8%) 12 (48.0%) 5 (71.4%)
(b) No 52 (20.0%) 29 (19.0%) 6 (10.5%) 3 (16.7%) 12 (48.0%) 2 (28.6%)
(c) Not Applicable 12 (4.6%) 6 (3.9%) 4 (7.0%) 1 (5.6%) 1 (4.0%) 0 (0.0%)

Question 4 asked agency components whether audio description and text captions provided were synchronized with their associated dynamic content.  Synchronization allows the multimedia content to be more accessible and readily understood by users with hearing and/or visual impairments.  Many agency components (47.7%) reported that their web pages did not include multimedia content.  For those web pages with multimedia content, a majority of agency components reported having synchronized captioning and descriptive text.  Small and very small agency components had more difficulty meeting this requirement.

The agency components’ responses are summarized in the table below:

Multimedia Content Accessibility Synchronization by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes 91 (35.0%) 58 (37.9%) 21 (36.8%) 9 (50.0%) 3 (12.0%) 0 (0.0%)
(b) No 45 (17.3%) 28 (18.3%) 5 (8.8%) 1 (5.6%) 9 (36.0%) 2 (28.6%)
(c) Not Applicable 124 (47.7%) 67 (43.8%) 31 (54.4%) 8 (44.4%) 13 (52.0%) 5 (71.4%)

Question 5 asked agency components about the accessibility of their web pages for users with varying degrees of color-blindness.  Overall, a majority of agency components reported that all information conveyed with color was also available without color.  Mid-size agency components were the most successful in meeting this requirement, and small agency components were the least successful in meeting this requirement.

The following table provides the agency components’ responses:

Appropriate Use of Color by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes 173 (66.5%) 100 (65.4%) 39 (68.4%) 15 (83.3%) 14 (56.0%) 5 (71.4%)
(b) No 32 (12.3%) 23 (15.0%) 1 (1.8%) 0 (0.0%) 7 (28.0%) 1 (14.3%)
(c) Not Applicable 55 (21.2%) 30 (19.6%) 17 (29.8%) 3 (16.7%) 4 (16.0%) 1 (14.3%)

Question 6 focused on the use of Cascading Style Sheets (CSS) in web pages.  Agency components were asked whether their web pages were readable if the corresponding style sheets were deactivated, and whether the style sheets, if used, were designed so that they did not interfere with custom style sheets set by the browser.  Most agency components reported success in meeting this requirement.  Small agency components had more difficulty meeting this requirement.

The agency components reported the following:

Style Sheet Accessibility by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes 221 (85.0%) 129 (84.3%) 50 (87.7%) 18 (100.0%) 19 (76.0%) 5 (71.4%)
(b) No 26 (10.0%) 16 (10.5%) 4 (7.0%) 0 (0.0%) 5 (20.0%) 1 (14.3%)
(c) Not Applicable 13 (5.0%) 8 (5.2%) 3 (5.3%) 0 (0.0%) 1 (4.0%) 1 (14.3%)

Question 7 asked agency components to provide information on the use of server-side image maps and whether duplicate text links were provided for all links within the image maps.  Overall, a majority of agency components (60.8%) from all agency size categories reported not using image maps and thereby avoiding problems with this requirement.  For those web pages with server-side image maps, a majority of agency components reported having success with this requirement.

The following table summarizes the responses provided by the agency components:

Server-Side Image Map Accessibility by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes 86 (33.1%) 50 (32.7%) 21 (36.8%) 9 (50.0%) 4 (16.0%) 2 (28.6%)
(b) No 16 (6.2%) 10 (6.5%) 0 (0.0%) 0 (0.0%) 6 (24.0%) 0 (0.0%)
(c) Not Applicable 158 (60.8%) 93 (60.8%) 36 (63.2%) 9 (50.0%) 15 (60.0%) 5 (71.4%)

Question 8 continues the image maps question by asking agency components whether they provided client-side image maps instead of server-side image maps, except where the regions cannot be defined with an available geometric shape.  A majority of agency components (63.5%) from all agency size categories reported not using image maps.  For those web pages with image maps, a majority of agency components reported success in providing client-side image maps instead of server-side image maps.

The following table provides the specific responses by the agency components:

Use of Client-Side Image Map by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes 82 (31.5%) 46 (30.1%) 21 (36.8%) 8 (44.4%) 5 (20.0%) 2 (28.6%)
(b) No 13 (5.0%) 9 (5.9%) 0 (0.0%) 0 (0.0%) 4 (16.0%) 0 (0.0%)
(c) Not Applicable 165 (63.5%) 98 (64.1%) 36 (63.2%) 10 (55.6%) 16 (64.0%) 5 (71.4%)

Question 9 inquired about data tables in web pages.  Agency components were asked if they identified row and column headers (when such table headers existed) for data tables in web pages.  Many agency components (40.0%) reported that their web pages did not include data tables.  Overall, a majority of agency components reported success identifying row and column headers for data tables.  Small agency components had more difficulty meeting this requirement.

Specifically, the agency components provided the following responses:

Row and Column Header Identification by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes 134 (51.5%) 83 (54.2%) 28 (49.1%) 11 (61.1%) 6 (24.0%) 6 (85.7%)
(b) No 22 (8.5%) 12 (7.8%) 3 (5.3%) 0 (0.0%) 7 (28.0%) 0 (0.0%)
(c) Not Applicable 104 (40.0%) 58 (37.9%) 26 (45.6%) 7 (38.9%) 12 (48.0%) 1 (14.3%)

Question 10 continues the data tables question by asking agency components whether each cell in a data table was provided identification of row and column headers (when such table headers existed).  A majority of agency components (50.4%) reported that their web pages did not include data tables.  For those web pages with data tables, a majority of agency components reported success associating data cells and header cells.  Small agency components were the least successful in meeting this requirement.

The agency components’ responses are summarized in the table below:

Data and Header Cell Association by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes 105 (40.4%) 64 (41.8%) 22 (38.6%) 8 (44.4%) 7 (28.0%) 4 (57.1%)
(b) No 24 (9.2%) 13 (8.5%) 4 (7.0%) 0 (0.0%) 7 (28.0%) 0 (0.0%)
(c) Not Applicable 131 (50.4%) 76 (49.7%) 31 (54.4%) 10 (55.6%) 11 (44.0%) 3 (42.9%)

Question 11 asked agency components whether descriptive titles were used for web pages with frames.  A majority of agency components (64.6%) reported that their web pages did not use frames.  For those web pages with frames, a majority of agency components reported success in meeting this requirement.  Small agency components were the least successful in meeting this requirement.

The following table provides the agency components’ responses:

Frame Accessibility by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes 71 (27.3%) 44 (28.8%) 12 (21.1%) 7 (38.9%) 5 (20.0%) 3 (42.9%)
(b) No 21 (8.1%) 13 (8.5%) 1 (1.8%) 1 (5.6%) 6 (24.0%) 0 (0.0%)
(c) Not Applicable 168 (64.6%) 96 (62.7%) 44 (77.2%) 10 (55.6%) 14 (56.0%) 4 (57.1%)

Question 12 asked agency components whether content (such as applets or plug-ins) on their web pages were designed to avoid causing the screen to flicker with a frequency greater than 2 Hz and lower than 55 Hz.  Overall, most agency components reported that their web pages did not flicker.

The agency components reported the following:

Designed to Avoid Screen Flicker by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes 165 (63.5%) 100 (65.4%) 34 (59.6%) 13 (72.2%) 13 (52.0%) 5 (71.4%)
(b) No 15 (5.8%) 8 (5.2%) 2 (3.5%) 0 (0.0%) 5 (20.0%) 0 (0.0%)
(c) Not Applicable 80 (30.8%) 45 (29.4%) 21 (36.8%) 5 (27.8%) 7 (28.0%) 2 (28.6%)

Question 13 asked whether agency components provided an alternative text-only web page because their surveyed web pages contained barriers to people with disabilities, and whether the alternative text-only web page contained the same information and was updated as often as the inaccessible surveyed web page.  Many agency components (44.6%) in all agency size categories reported that text-only alternative pages were not needed because their web pages did not contain barriers for people with disabilities.  When alternative text-only web pages were provided, a majority of agency components reported success in providing up to date, equivalent information and functionality.

The following table summarizes the responses provided by the agency components:

Alternative Text-Only Page Availability and Accessibility by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes 98 (37.7%) 55 (35.9%) 25 (43.9%) 8 (44.4%) 7 (28.0%) 3 (42.9%)
(b) No 46 (17.7%) 28 (18.3%) 5 (8.8%) 2 (11.1%) 10 (40.0%) 1 (14.3%)
(c) Not Applicable 116 (44.6%) 70 (45.8%) 27 (47.4%) 8 (44.4%) 8 (32.0%) 3 (42.9%)

Question 14 asked agency components whether equivalent text was made available for web pages using JavaScript or Macromedia Flash scripts that affected content displayed to the user.  Overall, a majority of agency components reported that their web pages with scripting were accessible.  Small agency components were the least successful in meeting this requirement when scripting was used.

The following table provides the specific responses by the agency components:

Java/Flash Accessibility by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes 147 (56.5%) 90 (58.8%) 31 (54.4%) 14 (77.8%) 9 (36.0%) 3 (42.9%)
(b) No 42 (16.2%) 24 (15.7%) 7 (12.3%) 1 (5.6%) 9 (36.0%) 1 (14.3%)
(c) Not Applicable 71 (27.3%) 39 (25.5%) 19 (33.3%) 3 (16.7%) 7 (28.0%) 3 (42.9%)

Question 15 asked agency components whether their web pages included a link to the plug-in or other programmatic item required for accessing the content of their web pages, and if that plug-in or other programmatic item itself was accessible to people with disabilities.  Many agency components (47.7%) reported that their web pages did not use programmatic elements.  For those web pages with programmatic elements, a majority of agency components reported success in meeting this requirement.

Specifically, the agency components provided the following responses:

Plug-In or Other Programmatic Object Accessibility by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes 107 (41.2%) 63 (41.2%) 21 (36.8%) 10 (55.6%) 8 (32.0%) 5 (71.4%)
(b) No 29 (11.2%) 17 (11.1%) 4 (7.0%) 1 (5.6%) 7 (28.0%) 0 (0.0%)
(c) Not Applicable 124 (47.7%) 73 (47.7%) 32 (56.1%) 7 (38.9%) 10 (40.0%) 2 (28.6%)

Question 16 asked agency components about their use of online electronic forms.  Specifically, agency components were asked whether each form permitted users of assistive technology to access the information, field elements, and functionality required for completion and submission of the form, including all directions and cues.  Many agency components (30.0%) reported that their web pages did not use online electronic forms.  Overall, a majority of agency components reported that their forms were accessible. 

The agency components’ responses are summarized in the table below:

Electronic Form Accessibility by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes 148 (56.9%) 91 (59.5%) 29 (50.9%) 14 (77.8%) 10 (40.0%) 4 (57.1%)
(b) No 34 (13.1%) 22 (14.4%) 3 (5.3%) 0 (0.0%) 8 (32.0%) 1 (14.3%)
(c) Not Applicable 78 (30.0%) 40 (26.1%) 25 (43.9%) 4 (22.2%) 7 (28.0%) 2 (28.6%)

Question 17 asked agency components whether navigational links to other web pages within the same website had special links that allowed screen readers to skip over those navigational links.  Overall, a majority of agency components reported including skip navigational links.  Small agency components had more difficulty meeting this requirement.

The following table provides the agency components’ responses:

Navigational Link Skipping by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes 145 (55.8%) 86 (56.2%) 34 (59.6%) 12 (66.7%) 10 (40.0%) 3 (42.9%)
(b) No 51 (19.6%) 30 (19.6%) 8 (14.0%) 3 (16.7%) 9 (36.0%) 1 (14.3%)
(c) Not Applicable 64 (24.6%) 37 (24.2%) 15 (26.3%) 3 (16.7%) 6 (24.0%) 3 (42.9%)

Question 18 focused on web pages that imposed time limits on users.  Specifically, agency components were asked if users were alerted that they would be timed out and then given sufficient time to indicate that more time was needed before actually being timed out.  Most agency components (78.8%) reported that time limits were not used.  For those web pages that imposed time limits, a majority of agency components reported success in meeting this requirement.  Mid-size agency components were the most successful in meeting this requirement.

The agency components reported the following:

Time Limits by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes 43 (16.5%) 29 (19.0%) 7 (12.3%) 6 (33.3%) 0 (0.0%) 1 (14.3%)
(b) No 12 (4.6%) 8 (5.2%) 2 (3.5%) 0 (0.0%) 2 (8.0%) 0 (0.0%)
(c) Not Applicable 205 (78.8%) 116 (75.8%) 48 (84.2%) 12 (66.7%) 23 (92.0%) 6 (85.7%)

Question 19 asked agency components whether programmatic elements on their web pages provided keyboard accessibility.  Keyboard accessibility allows people with disabilities to access a program’s controls and features from a keyboard instead of a mouse or other pointing device.  Many agency components (38.1%) reported that their web pages did not use programmatic elements.  Overall, a majority of agency components reported success in meeting this requirement.

The following table summarizes the responses provided by the agency components:

Keyboard Accessibility by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes 131 (50.4%) 79 (51.6%) 25 (43.9%) 13 (72.2%) 10 (40.0%) 4 (57.1%)
(b) No 30 (11.5%) 18 (11.8%) 4 (7.0%) 1 (5.6%) 6 (24.0%) 1 (14.3%)
(c) Not Applicable 99 (38.1%) 56 (36.6%) 28 (49.1%) 4 (22.2%) 9 (36.0%) 2 (28.6%)

Question 20 asked agency components whether programmatic elements on their web pages provided a well-defined on-screen indication of the current focus that moves with keyboard navigation.  The position on a screen where an action will take place is referred to as the focus.  Many agency components (34.6%) reported that their web pages did not use programmatic elements.  For those web pages with programmatic elements, a majority of agency components reported success in ensuring that focus was programmatically exposed so that assistive technology can track focus.

The following table provides the specific responses by the agency components:

Screen Focus by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes 129 (49.6%) 83 (54.2%) 25 (43.9%) 9 (50.0%) 9 (36.0%) 3 (42.9%)
(b) No 41 (15.8%) 24 (15.7%) 6 (10.5%) 2 (11.1%) 8 (32.0%) 1 (14.3%)
(c) Not Applicable 90 (34.6%) 46 (30.1%) 26 (45.6%) 7 (38.9%) 8 (32.0%) 3 (42.9%)

Question 21 asked agency components whether programmatic elements on their web pages provided sufficient information about user interface elements (such as check boxes, radio buttons, menus, toolbars, dialog and popup windows and controls) to assistive technology.  Overall, a majority of agency components reported success in meeting this requirement.  Small agency components had more difficulty meeting this requirement.

Specifically, the agency components provided the following responses:

Availability of User Interface Information by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes 157 (60.4%) 96 (62.7%) 38 (66.7%) 10 (55.6%) 9 (36.0%) 4 (57.1%)
(b) No 37 (14.2%) 22 (14.4%) 4 (7.0%) 2 (11.1%) 8 (32.0%) 1 (14.3%)
(c) Not Applicable 66 (25.4%) 35 (22.9%) 15 (26.3%) 6 (33.3%) 8 (32.0%) 2 (28.6%)

Question 22 asked whether agency components used text captioning for multimedia content.  Such accessibility features are used to make multimedia features accessible to users with hearing and/or visual impairments.  Many agency components (45.0%) reported that their surveyed web pages did not include multimedia content.  For those web pages that used multimedia content, a majority of agency components reported success in captioning multimedia content.  Small agency components had more difficulty meeting this requirement.

The agency components’ responses are summarized in the table below:

Captioning by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes 91 (35.0%) 56 (36.6%) 21 (36.8%) 10 (55.6%) 3 (12.0%) 1 (14.3%)
(b) No 52 (20.0%) 33 (21.6%) 7 (12.3%) 2 (11.1%) 9 (36.0%) 1 (14.3%)
(c) Not Applicable 117 (45.0%) 64 (41.8%) 29 (50.9%) 6 (33.3%) 13 (52.0%) 5 (71.4%)

Question 23 asked whether agency components used descriptive narration for multimedia content.  A majority of agency components (52.7%) reported that their surveyed web pages did not include multimedia content.  For those web pages that used multimedia content, a majority of agency components reported success in providing audio description for multimedia content.  Small agency components had more difficulty meeting this requirement.

The following table provides the agency components’ responses:

Audio Description by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes 71 (27.3%) 43 (28.1%) 16 (28.1%) 8 (44.4%) 3 (12.0%) 1 (14.3%)
(b) No 52 (20.0%) 31 (20.3%) 9 (15.8%) 2 (11.1%) 9 (36.0%) 1 (14.3%)
(c) Not Applicable 137 (52.7%) 79 (51.6%) 32 (56.1%) 8 (44.4%) 13 (52.0%) 5 (71.4%)

3. Web-Based Form

A total of 235 agency components that used web-based forms responded to the following survey questions.

Question 1 asked agency components to provide the URLs for their web-based forms.

Question 2 asked agency components to provide the best description of the purpose of their web-based form.  Overall, agency components (30.6%) reported that the most common purpose for a web-based form was for providing feedback to the component.

The following table provides the specific responses by the agency components:

Purpose of Web-Based Form by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Applying for programs and benefits 27 (11.5%) 15 (11.0%) 1 (2.1%) 2 (11.8%) 4 (18.2%) 5 (38.5%)
(b) Ordering products and services 32 (13.6%) 23 (16.9%) 3 (6.4%) 2 (11.8%) 4 (18.2%) 0 (0.0%)
(c) Feedback 72 (30.6%) 42 (30.9%) 22 (46.8%) 1 (5.9%) 4 (18.2%) 3 (23.1%)
(d) Contact information search 15 (6.4%) 7 (5.1%) 4 (8.5%) 4 (23.5%) 0 (0.0%) 0 (0.0%)
(e) Publication resource search 13 (5.5%) 9 (6.6%) 1 (2.1%) 1 (5.9%) 1 (4.5%) 1 (7.7%)
(f) Filing a complaint 13 (5.5%) 3 (2.2%) 4 (8.5%) 3 (17.6%) 2 (9.1%) 1 (7.7%)
(g) Employment search 1 (0.4%) 1 (0.7%) 0 (0.0%) 0 (0.0%) 0 (0.0%) 0 (0.0%)
(h) Other 62 (26.4%) 36 (26.5%) 12 (25.5%) 4 (23.5%) 7 (31.8%) 3 (23.1%)

Question 3 asked agency components about the use of “alt” (alternative text attribute) or other descriptive elements to represent non-text elements in the web-based form.  They are chiefly used to make visual information accessible for people with visual impairments.  Most agency components from all size categories reported the use of the alternative text attribute or other descriptive elements to represent non-text elements.  Overall, a majority of agency components reported a high degree of success in meeting this requirement for their surveyed forms.

Specifically, the agency components provided the following responses:

Text Equivalence by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes 177 (75.3%) 107 (78.7%) 35 (74.5%) 13 (76.5%) 13 (59.1%) 9 (69.2%)
(b) No 36 (15.3%) 19 (14.0%) 7 (14.9%) 2 (11.8%) 6 (27.3%) 2 (15.4%)
(c) Not Applicable 22 (9.4%) 10 (7.4%) 5 (10.6%) 2 (11.8%) 3 (13.6%) 2 (15.4%)

Question 4 asked agency components whether audio description and text captions provided were synchronized with their associated dynamic content.  Synchronization allows the multimedia content to be more accessible and readily understood by users with hearing and/or visual impairments.  Most agency components (77.9%) reported that their web-based forms did not include multimedia content.

The agency components’ responses are summarized in the table below:

Multimedia Content Accessibility Synchronization by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes 34 (14.5%) 21 (15.4%) 4 (8.5%) 5 (29.4%) 2 (9.1%) 2 (15.4%)
(b) No 18 (7.7%) 15 (11.0%) 1 (2.1%) 0 (0.0%) 1 (4.5%) 1 (7.7%)
(c) Not Applicable 183 (77.9%) 100 (73.5%) 42 (89.4%) 12 (70.6%) 19 (86.4%) 10 (76.9%)

Question 5 asked agency components about the accessibility of their web-based forms for users with varying degrees of color-blindness.  Overall, a majority of agency components reported that all information conveyed with color was also available without color.

The following table provides the agency components’ responses:

Appropriate Use of Color by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes 146 (62.1%) 84 (61.8%) 30 (63.8%) 12 (70.6%) 13 (59.1%) 7 (53.8%)
(b) No 19 (8.1%) 15 (11.0%) 1 (2.1%) 0 (0.0%) 2 (9.1%) 1 (7.7%)
(c) Not Applicable 70 (29.8%) 37 (27.2%) 16 (34.0%) 5 (29.4%) 7 (31.8%) 5 (38.5%)

Question 6 focused on the use of Cascading Style Sheets (CSS).  Agency components were asked whether their forms were readable if the corresponding style sheets were deactivated, and whether the style sheets, if used, were designed so that they did not interfere with custom style sheets set by the browser.  Overall, most agency components reported success meeting this requirement.

The agency components reported the following:

Style Sheet Accessibility by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes 188 (80.0%) 109 (80.1%) 39 (83.0%) 16 (94.1%) 17 (77.3%) 7 (53.8%)
(b) No 16 (6.8%) 13 (9.6%) 0 (0.0%) 0 (0.0%) 1 (4.5%) 2 (15.4%)
(c) Not Applicable 31 (13.2%) 14 (10.3%) 8 (17.0%) 1 (5.9%) 4 (18.2%) 4 (30.8%)

Question 7 asked agency components to provide information on the use of server-side image maps and whether duplicate text links were provided for all links within the image maps.  A majority of agency components (71.5%) from all agency size categories reported not using image maps and thereby avoiding problems with this requirement.  For those web-based forms with server-side image maps, a majority of agency components reported having success with this requirement.

The following table summarizes the responses provided by the agency components:

Server-Side Image Map Accessibility by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes 55 (23.4%) 30 (22.1%) 12 (25.5%) 5 (29.4%) 3 (13.6%) 5 (38.5%)
(b) No 12 (5.1%) 8 (5.9%) 0 (0.0%) 0 (0.0%) 2 (9.1%) 2 (15.4%)
(c) Not Applicable 168 (71.5%) 98 (72.1%) 35 (74.5%) 12 (70.6%) 17 (77.3%) 6 (46.2%)

Question 8 continues the image maps question by asking agency components whether they provided client-side image maps instead of server-side image maps, except where the regions cannot be defined with an available geometric shape.  A majority of agency components (75.3%) from all agency size categories reported not using image maps.  For those web-based forms with image maps, a majority of agency components reported success in providing client-side image maps instead of server-side image maps.

The following table provides the specific responses by the agency components:

Use of Client-Side Image Map by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes 48 (20.4%) 27 (19.9%) 8 (17.0%) 5 (29.4%) 5 (22.7%) 3 (23.1%)
(b) No 10 (4.3%) 7 (5.1%) 0 (0.0%) 0 (0.0%) 1 (4.5%) 2 (15.4%)
(c) Not Applicable 177 (75.3%) 102 (75.0%) 39 (83.0%) 12 (70.6%) 16 (72.7%) 8 (61.5%)

Question 9 asked whether agency components identified row and column headers (when such table headers existed) for data tables in web-based forms.  A majority of agency components (56.2%) reported that their web-based forms did not include data tables.  For those web-based forms with data tables, a majority of agency components reported success identifying row and column headers.

Specifically, the agency components provided the following responses:

Row and Column Header Identification by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes 86 (36.6%) 54 (39.7%) 12 (25.5%) 8 (47.1%) 6 (27.3%) 6 (46.2%)
(b) No 17 (7.2%) 5 (3.7%) 5 (10.6%) 0 (0.0%) 6 (27.3%) 1 (7.7%)
(c) Not Applicable 132 (56.2%) 77 (56.6%) 30 (63.8%) 9 (52.9%) 10 (45.5%) 6 (46.2%)

Question 10 continues the data tables question by asking agency components whether each cell in a data table was provided identification of row and column headers (when such table headers existed).  A majority of agency components (60.4%) reported that their web-based forms did not include data tables.  For those web-based forms with data tables, a majority of agency components reported success associating data cells and header cells.  Small agency components were the least successful in meeting this requirement.

The agency components’ responses are summarized in the table below:

Data and Header Cell Association by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes 80 (34.0%) 49 (36.0%) 15 (31.9%) 6 (35.3%) 5 (22.7%) 5 (38.5%)
(b) No 13 (5.5%) 5 (3.7%) 2 (4.3%) 0 (0.0%) 5 (22.7%) 1 (7.7%)
(c) Not Applicable 142 (60.4%) 82 (60.3%) 30 (63.8%) 11 (64.7%) 12 (54.5%) 7 (53.8%)

Question 11 asked agency components whether descriptive titles were used for web-based forms with frames.  A majority of agency components (74.5%) reported that their web-based forms did not use frames.  For those web-based forms with frames, a majority of agency components reported success in meeting this requirement.

The following table provides the agency components’ responses:

Frame Accessibility by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes 54 (23.0%) 29 (21.3%) 11 (23.4%) 5 (29.4%) 3 (13.6%) 6 (46.2%)
(b) No 6 (2.6%) 3 (2.2%) 1 (2.1%) 0 (0.0%) 1 (4.5%) 1 (7.7%)
(c) Not Applicable 175 (74.5%) 104 (76.5%) 35 (74.5%) 12 (70.6%) 18 (81.8%) 6 (46.2%)

Question 12 asked agency components whether content on their web-based forms were designed to avoid causing the screen to flicker with a frequency greater than 2 Hz and lower than 55 Hz.  Overall, a majority of agency components reported that their web-based forms did not flicker.

The agency components reported the following:

Designed to Avoid Screen Flicker by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes 147 (62.6%) 83 (61.0%) 31 (66.0%) 12 (70.6%) 11 (50.0%) 10 (76.9%)
(b) No 6 (2.6%) 3 (2.2%) 0 (0.0%) 0 (0.0%) 2 (9.1%) 1 (7.7%)
(c) Not Applicable 82 (34.9%) 50 (36.8%) 16 (34.0%) 5 (29.4%) 9 (40.9%) 2 (15.4%)

Question 13 asked whether agency components provided a text-only alternative because their surveyed web-based forms contained barriers to people with disabilities, and whether the text-only alternative contained the same information and was updated as often as the inaccessible surveyed web-based form.  A majority of agency components (55.7%) in all agency size categories reported that text-only alternatives were not needed because their web-based forms did not contain barriers for people with disabilities.  When alternative text-only forms were provided, a majority of agency components reported success in providing up to date, equivalent information and functionality.

The following table summarizes the responses provided by the agency components:

Alternative Text-Only Page Availability and Accessibility by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes 74 (31.5%) 37 (27.2%) 17 (36.2%) 8 (47.1%) 6 (27.3%) 6 (46.2%)
(b) No 30 (12.8%) 18 (13.2%) 4 (8.5%) 1 (5.9%) 5 (22.7%) 2 (15.4%)
(c) Not Applicable 131 (55.7%) 81 (59.6%) 26 (55.3%) 8 (47.1%) 11 (50.0%) 5 (38.5%)

Question 14 asked agency components whether equivalent text was made available for web-based forms using JavaScript or Macromedia Flash scripts that affected content displayed to the user.  Many agency components (36.2%) reported that their web-based forms did not use scripts.  Overall, a majority of agency components reported that their web-based forms were accessible.

The following table provides the specific responses by the agency components:

Java/Flash Accessibility by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes 125 (53.2%) 72 (52.9%) 24 (51.1%) 11 (64.7%) 9 (40.9%) 9 (69.2%)
(b) No 25 (10.6%) 14 (10.3%) 4 (8.5%) 2 (11.8%) 4 (18.2%) 1 (7.7%)
(c) Not Applicable 85 (36.2%) 50 (36.8%) 19 (40.4%) 4 (23.5%) 9 (40.9%) 3 (23.1%)

Question 15 asked agency components whether they included a link to the plug-in or other programmatic item required for accessing the content of their web-based form, and if that plug-in or other programmatic item itself was accessible to people with disabilities.  A majority of agency components (60.9%) reported that their web-based forms did not require a plug-in or other programmatic item.  For those web-based forms with programmatic elements, a majority of agency components reported success in meeting this requirement.

Specifically, the agency components provided the following responses:

Plug-In or Other Programmatic Object Accessibility by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes 74 (31.5%) 48 (35.3%) 9 (19.1%) 8 (47.1%) 4 (18.2%) 5 (38.5%)
(b) No 18 (7.7%) 12 (8.8%) 3 (6.4%) 0 (0.0%) 1 (4.5%) 2 (15.4%)
(c) Not Applicable 143 (60.9%) 76 (55.9%) 35 (74.5%) 9 (52.9%) 17 (77.3%) 6 (46.2%)

Question 16 asked agency components about their use of online electronic forms.  Specifically, agency components were asked whether each form permitted users of assistive technology to access the information, field elements, and functionality required for completion and submission of the form, including all directions and cues.  Overall, most agency components reported that their forms were accessible.  Small agency components had more difficulty meeting this requirement.

The agency components’ responses are summarized in the table below:

Electronic Form Accessibility by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes 188 (80.0%) 109 (80.1%) 40 (85.1%) 15 (88.2%) 15 (68.2%) 9 (69.2%)
(b) No 30 (12.8%) 17 (12.5%) 5 (10.6%) 1 (5.9%) 6 (27.3%) 1 (7.7%)
(c) Not Applicable 17 (7.2%) 10 (7.4%) 2 (4.3%) 1 (5.9%) 1 (4.5%) 3 (23.1%)

Question 17 asked agency components whether web-based forms included special links that allowed screen readers to skip over navigational links.  Overall, a majority of agency components reported including skip navigational links.  Small agency components had more difficulty meeting this requirement.

The following table provides the agency components’ responses:

Navigational Link Skipping by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes 134 (57.0%) 73 (53.7%) 34 (72.3%) 13 (76.5%) 8 (36.4%) 6 (46.2%)
(b) No 32 (13.6%) 20 (14.7%) 1 (2.1%) 2 (11.8%) 7 (31.8%) 2 (15.4%)
(c) Not Applicable 69 (29.4%) 43 (31.6%) 12 (25.5%) 2 (11.8%) 7 (31.8%) 5 (38.5%)

Question 18 focused on web-based forms that imposed time limits on users.  Specifically, agency components were asked if users were alerted that they would be timed out and then given sufficient time to indicate that more time was needed before actually being timed out.  Most agency components (77.4%) reported that time limits were not used.  For those web-based forms that imposed time limits, a majority of agency components reported success in meeting this requirement.

The agency components reported the following:

Time Limits by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes 41 (17.4%) 25 (18.4%) 4 (8.5%) 7 (41.2%) 3 (13.6%) 2 (15.4%)
(b) No 12 (5.1%) 8 (5.9%) 1 (2.1%) 0 (0.0%) 2 (9.1%) 1 (7.7%)
(c) Not Applicable 182 (77.4%) 103 (75.7%) 42 (89.4%) 10 (58.8%) 17 (77.3%) 10 (76.9%)

Question 19 asked agency components whether their web-based forms provided keyboard accessibility.  Keyboard accessibility allows people with disabilities to access a program’s controls and features from a keyboard instead of a mouse or other pointing device.  Overall, a majority of agency components reported success in meeting this requirement.

The following table summarizes the responses provided by the agency components:

Keyboard Accessibility by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes 152 (64.7%) 92 (67.6%) 26 (55.3%) 12 (70.6%) 14 (63.6%) 8 (61.5%)
(b) No 18 (7.7%) 9 (6.6%) 2 (4.3%) 1 (5.9%) 4 (18.2%) 2 (15.4%)
(c) Not Applicable 65 (27.7%) 35 (25.7%) 19 (40.4%) 4 (23.5%) 4 (18.2%) 3 (23.1%)

Question 20 asked agency components whether their web-based forms provided a well-defined on-screen indication of the current focus that moves with keyboard navigation.  The position on a screen where an action will take place is referred to as the focus.  Overall, a majority of agency components reported success in ensuring that focus was programmatically exposed so that assistive technology can track focus.

The following table provides the specific responses by the agency components:

Screen Focus by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes 155 (66.0%) 96 (70.6%) 29 (61.7%) 11 (64.7%) 13 (59.1%) 6 (46.2%)
(b) No 24 (10.2%) 14 (10.3%) 3 (6.4%) 1 (5.9%) 4 (18.2%) 2 (15.4%)
(c) Not Applicable 56 (23.8%) 26 (19.1%) 15 (31.9%) 5 (29.4%) 5 (22.7%) 5 (38.5%)

Question 21 asked agency components whether their web-based forms provided sufficient information about user interface elements (such as check boxes, radio buttons, menus, toolbars, dialog and popup windows and controls) to assistive technology.  Overall, a majority of agency components reported success in meeting this requirement.

Specifically, the agency components provided the following responses:

Availability of User Interface Information by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes 134 (57.0%) 79 (58.1%) 29 (61.7%) 11 (64.7%) 8 (36.4%) 7 (53.8%)
(b) No 27 (11.5%) 19 (14.0%) 2 (4.3%) 1 (5.9%) 3 (13.6%) 2 (15.4%)
(c) Not Applicable 74 (31.5%) 38 (27.9%) 16 (34.0%) 5 (29.4%) 11 (50.0%) 4 (30.8%)

Question 22 asked whether agency components used text captioning for multimedia content.  Such accessibility features are used to make multimedia features accessible to users with hearing and/or visual impairments.  A majority of agency components (77.0%) reported that their web-based forms did not include multimedia content.  The agency components’ responses are summarized in the table below:

Captioning by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes 37 (15.7%) 22 (16.2%) 5 (10.6%) 5 (29.4%) 4 (18.2%) 1 (7.7%)
(b) No 17 (7.2%) 13 (9.6%) 0 (0.0%) 1 (5.9%) 2 (9.1%) 1 (7.7%)
(c) Not Applicable 181 (77.0%) 101 (74.3%) 42 (89.4%) 11 (64.7%) 16 (72.7%) 11 (84.6%)

Question 23 asked whether agency components used descriptive narration for multimedia content.  A majority of agency components (78.3%) reported that their web-based forms did not include multimedia content.

The following table provides the agency components’ responses:

Audio Description by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes 29 (12.3%) 17 (12.5%) 4 (8.5%) 4 (23.5%) 3 (13.6%) 1 (7.7%)
(b) No 22 (9.4%) 15 (11.0%) 2 (4.3%) 1 (5.9%) 3 (13.6%) 1 (7.7%)
(c) Not Applicable 184 (78.3%) 104 (76.5%) 41 (87.2%) 12 (70.6%) 16 (72.7%) 11 (84.6%)

4. Web-Based Application

A total of 223 agency components that used web-based applications responded to the following survey questions.

Question 1 asked agency components to provide the URLs for their web-based applications.

Question 2 asked agency components to provide the best description of the purpose of their web-based applications.  Many agency components selected record keeping and tracking (17.9%), employment (13.0%), and ordering products and services (10.8%) as the purpose of their web-based applications.

The following table provides the specific responses by the agency components:

Purpose of Web-Based Applications by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Applying for programs and benefits 21 (9.4%) 9 (6.9%) 5 (10.9%) 2 (11.8%) 3 (14.3%) 2 (25.0%)
(b) Ordering products and services 24 (10.8%) 17 (13.0%) 4 (8.7%) 2 (11.8%) 1 (4.8%) 0 (0.0%)
(c) Training and learning 23 (10.3%) 16 (12.2%) 4 (8.7%) 0 (0.0%) 1 (4.8%) 2 (25.0%)
(d) Travel reservation 1 (0.4%) 0 (0.0%) 1 (2.2%) 0 (0.0%) 0 (0.0%) 0 (0.0%)
(e) Time and attendance 17 (7.6%) 12 (9.2%) 2 (4.3%) 1 (5.9%) 2 (9.5%) 0 (0.0%)
(f) Record keeping and tracking 40 (17.9%) 21 (16.0%) 10 (21.7%) 3 (17.6%) 3 (14.3%) 3 (37.5%)
(g) Survey 3 (1.3%) 1 (0.8%) 2 (4.3%) 0 (0.0%) 0 (0.0%) 0 (0.0%)
(h) Employment 29 (13.0%) 23 (17.6%) 5 (10.9%) 1 (5.9%) 0 (0.0%) 0 (0.0%)
(i) Other 65 (29.1%) 32 (24.4%) 13 (28.3%) 8 (47.1%) 11 (52.4%) 1 (12.5%)

Question 3 asked agency components about the use of “alt” (alternative text attribute) or other descriptive elements to represent non-text elements in the web-based application.  They are chiefly used to make visual information accessible for people with visual impairments.  Most agency components from all size categories reported the use of the alternative text attribute or other descriptive elements to represent non-text elements.  Overall, a majority of agency components reported a high degree of success in meeting this requirement for their web-based applications.  Small agency components had more difficulty meeting this requirement.

Specifically, the agency components provided the following responses:

Text Equivalence by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes 167 (74.9%) 102 (77.9%) 36 (78.3%) 13 (76.5%) 10 (47.6%) 6 (75.0%)
(b) No 41 (18.4%) 24 (18.3%) 6 (13.0%) 1 (5.9%) 9 (42.9%) 1 (12.5%)
(c) Not Applicable 15 (6.7%) 5 (3.8%) 4 (8.7%) 3 (17.6%) 2 (9.5%) 1 (12.5%)

Question 4 asked agency components whether audio description and text captions provided were synchronized with their associated dynamic content.  Synchronization allows the multimedia content to be even more accessible and readily understood by users with hearing and/or visual impairments.  Most agency components (69.1%) reported that their web-based applications did not include multimedia content.

The agency components’ responses are summarized in the table below:

Multimedia Content Accessibility Synchronization by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes 45 (20.2%) 21 (16.0%) 14 (30.4%) 5 (29.4%) 2 (9.5%) 3 (37.5%)
(b) No 24 (10.8%) 22 (16.8%) 0 (0.0%) 1 (5.9%) 1 (4.8%) 0 (0.0%)
(c) Not Applicable 154 (69.1%) 88 (67.2%) 32 (69.6%) 11 (64.7%) 18 (85.7%) 5 (62.5%)

Question 5 asked agency components about the accessibility of their web-based applications for users with varying degrees of color-blindness.  Overall, a majority of agency components reported that all information conveyed with color was also available without color.  Mid-size agency components were the most successful in meeting this requirement.

The following table provides the agency components’ responses:

Appropriate Use of Color by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes 150 (67.3%) 84 (64.1%) 32 (69.6%) 14 (82.4%) 14 (66.7%) 6 (75.0%)
(b) No 21 (9.4%) 14 (10.7%) 5 (10.9%) 1 (5.9%) 1 (4.8%) 0 (0.0%)
(c) Not Applicable 52 (23.3%) 33 (25.2%) 9 (19.6%) 2 (11.8%) 6 (28.6%) 2 (25.0%)

Question 6 focused on the use of Cascading Style Sheets (CSS).  Agency components were asked whether their web-based applications were viewable if the corresponding style sheets were deactivated, and whether the style sheets, if used, were designed so that they did not interfere with custom style sheets set by the browser.  Overall, a majority of agency components reported success in meeting this requirement.  The agency components reported the following:

Style Sheet Accessibility by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes 165 (74.0%) 99 (75.6%) 34 (73.9%) 14 (82.4%) 13 (61.9%) 5 (62.5%)
(b) No 24 (10.8%) 19 (14.5%) 2 (4.3%) 1 (5.9%) 2 (9.5%) 0 (0.0%)
(c) Not Applicable 34 (15.2%) 13 (9.9%) 10 (21.7%) 2 (11.8%) 6 (28.6%) 3 (37.5%)

Question 7 asked agency components to provide information on the use of server-side image maps and whether duplicate text links were provided for all links within the image maps.  A majority of agency components (69.5%) from all agency size categories reported not using image maps and thereby avoiding problems with this requirement.  For those web-based applications with server-side image maps, a majority of agency components reported having success with this requirement.

The following table summarizes the responses provided by the agency components:

Server-Side Image Map Accessibility by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes 56 (25.1%) 29 (22.1%) 17 (37.0%) 4 (23.5%) 4 (19.0%) 2 (25.0%)
(b) No 12 (5.4%) 8 (6.1%) 2 (4.3%) 0 (0.0%) 2 (9.5%) 0 (0.0%)
(c) Not Applicable 155 (69.5%) 94 (71.8%) 27 (58.7%) 13 (76.5%) 15 (71.4%) 6 (75.0%)

Question 8 continues the image maps question by asking agency components whether they provided client-side image maps instead of server-side image maps, except where the regions cannot be defined with an available geometric shape.  A majority of agency components (70.4%) from all agency size categories reported not using image maps.  For those web-based applications with image maps, a majority of agency components reported success in providing client-side image maps instead of server-side image maps.

The following table provides the specific responses by the agency components:

Use of Client-Side Image Map by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes 57 (25.6%) 32 (24.4%) 14 (30.4%) 6 (35.3%) 4 (19.0%) 1 (12.5%)
(b) No 9 (4.0%) 7 (5.3%) 1 (2.2%) 0 (0.0%) 1 (4.8%) 0 (0.0%)
(c) Not Applicable 157 (70.4%) 92 (70.2%) 31 (67.4%) 11 (64.7%) 16 (76.2%) 7 (87.5%)

Question 9 inquired about data tables.  Agency components were asked if they identified row and column headers (when such table headers existed) for data tables in web-based applications.  Overall, a majority of agency components reported success identifying row and column headers for data tables.

Specifically, the agency components provided the following responses:

Row and Column Header Identification by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes 137 (61.4%) 83 (63.4%) 27 (58.7%) 13 (76.5%) 10 (47.6%) 4 (50.0%)
(b) No 30 (13.5%) 13 (9.9%) 9 (19.6%) 1 (5.9%) 6 (28.6%) 1 (12.5%)
(c) Not Applicable 56 (25.1%) 35 (26.7%) 10 (21.7%) 3 (17.6%) 5 (23.8%) 3 (37.5%)

Question 10 continues the data tables question by asking agency components whether each cell in a data table was provided identification of row and column headers (when such table headers existed).  Many agency components (38.6%) reported that their web-based applications did not include data tables.  For those web-based applications with data tables, a majority of agency components reported success associating data cells and header cells.  Small and very small agency components had more difficulty meeting this requirement.

The agency components’ responses are summarized in the table below:

Data and Header Cell Association by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes 104 (46.6%) 63 (48.1%) 21 (45.7%) 8 (47.1%) 10 (47.6%) 2 (25.0%)
(b) No 33 (14.8%) 14 (10.7%) 11 (23.9%) 1 (5.9%) 5 (23.8%) 2 (25.0%)
(c) Not Applicable 86 (38.6%) 54 (41.2%) 14 (30.4%) 8 (47.1%) 6 (28.6%) 4 (50.0%)

Question 11 asked agency components whether descriptive titles were used for web-based applications with frames.  A majority of agency components (61.9%) reported that their web-based applications did not use frames.  For those web-based applications with frames, a majority of agency components reported success in meeting this requirement.

The following table provides the agency components’ responses:

Frame Accessibility by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes 70 (31.4%) 45 (34.4%) 13 (28.3%) 7 (41.2%) 4 (19.0%) 1 (12.5%)
(b) No 15 (6.7%) 6 (4.6%) 4 (8.7%) 1 (5.9%) 3 (14.3%) 1 (12.5%)
(c) Not Applicable 138 (61.9%) 80 (61.1%) 29 (63.0%) 9 (52.9%) 14 (66.7%) 6 (75.0%)

Question 12 asked agency components whether their web-based applications were designed to avoid causing the screen to flicker with a frequency greater than 2 Hz and lower than 55 Hz.  Overall, most agency components reported that their web-based applications did not flicker.

The agency components reported the following:

Designed to Avoid Screen Flicker by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes 140 (62.8%) 82 (62.6%) 31 (67.4%) 10 (58.8%) 11 (52.4%) 6 (75.0%)
(b) No 9 (4.0%) 4 (3.1%) 0 (0.0%) 2 (11.8%) 3 (14.3%) 0 (0.0%)
(c) Not Applicable 74 (33.2%) 45 (34.4%) 15 (32.6%) 5 (29.4%) 7 (33.3%) 2 (25.0%)

Question 13 asked whether agency components provided a text-only alternative because their surveyed web-based applications contained barriers to people with disabilities, and whether the text-only alternative contained the same information and was updated as often as the inaccessible surveyed web-based application.  A majority of agency components (59.2%) reported that text-only alternatives were not needed because their web-based applications did not contain barriers for people with disabilities.  When text-only alternatives were provided, a majority of agency components reported success in providing up to date, equivalent information and functionality.

The following table summarizes the responses provided by the agency components:

Alternative Text-Only Page Availability and Accessibility by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes 60 (26.9%) 35 (26.7%) 15 (32.6%) 3 (17.6%) 5 (23.8%) 2 (25.0%)
(b) No 31 (13.9%) 17 (13.0%) 6 (13.0%) 3 (17.6%) 5 (23.8%) 0 (0.0%)
(c) Not Applicable 132 (59.2%) 79 (60.3%) 25 (54.3%) 11 (64.7%) 11 (52.4%) 6 (75.0%)

Question 14 asked agency components whether equivalent text was made available for web-based applications using JavaScript or Macromedia Flash scripts that affected content displayed to the user. Overall, a majority of agency components reported that their web-based applications were accessible.  Small and very small agency components had more difficulty meeting this requirement when scripting was used.

The following table provides the specific responses by the agency components:

Java/Flash Accessibility by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes 129 (57.8%) 78 (59.5%) 25 (54.3%) 13 (76.5%) 8 (38.1%) 5 (62.5%)
(b) No 38 (17.0%) 18 (13.7%) 10 (21.7%) 1 (5.9%) 7 (33.3%) 2 (25.0%)
(c) Not Applicable 56 (25.1%) 35 (26.7%) 11 (23.9%) 3 (17.6%) 6 (28.6%) 1 (12.5%)

Question 15 asked agency components whether they included a link to the plug-in or other programmatic item required for accessing the content of their web-based applications, and if that plug-in or other programmatic item itself was accessible to people with disabilities.  A majority of agency components (59.2%) reported that their web-based applications did not require a plug-in or other programmatic item.  For those web-based applications that require a plug-in or other programmatic item, a majority of agency components reported success in meeting this requirement.

Specifically, the agency components provided the following responses:

Plug-In or Other Programmatic Object Accessibility by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes 66 (29.6%) 37 (28.2%) 17 (37.0%) 5 (29.4%) 3 (14.3%) 4 (50.0%)
(b) No 25 (11.2%) 19 (14.5%) 2 (4.3%) 1 (5.9%) 3 (14.3%) 0 (0.0%)
(c) Not Applicable 132 (59.2%) 75 (57.3%) 27 (58.7%) 11 (64.7%) 15 (71.4%) 4 (50.0%)

Question 16 asked agency components about their use of online electronic forms.  Specifically, agency components were asked whether each form permitted users of assistive technology to access the information, field elements, and functionality required for completion and submission of the form, including all directions and cues.  Overall, a majority of agency components reported success in meeting this requirement.

The agency components’ responses are summarized in the table below:

Electronic Form Accessibility by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes 154 (69.1%) 98 (74.8%) 26 (56.5%) 14 (82.4%) 11 (52.4%) 5 (62.5%)
(b) No 38 (17.0%) 16 (12.2%) 11 (23.9%) 1 (5.9%) 8 (38.1%) 2 (25.0%)
(c) Not Applicable 31 (13.9%) 17 (13.0%) 9 (19.6%) 2 (11.8%) 2 (9.5%) 1 (12.5%)

Question 17 asked agency components whether web-based applications included special links that allowed screen readers to skip over navigational links.  Overall, a majority of agency components reported including skip navigational links.  Small agency components had more difficulty meeting this requirement.

The following table provides the agency components’ responses:

Navigational Link Skipping by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes 127 (57.0%) 76 (58.0%) 28 (60.9%) 12 (70.6%) 9 (42.9%) 2 (25.0%)
(b) No 40 (17.9%) 21 (16.0%) 6 (13.0%) 1 (5.9%) 10 (47.6%) 2 (25.0%)
(c) Not Applicable 56 (25.1%) 34 (26.0%) 12 (26.1%) 4 (23.5%) 2 (9.5%) 4 (50.0%)

Question 18 focused on web-based applications that imposed time limits on users.  Specifically, agency components were asked if users were alerted that they would be timed out and then given sufficient time to indicate that more time was needed before actually being timed out.  Most agency components (62.8%) reported that time limits were not used.  For those web-based applications that imposed time limits, a majority of agency components reported success in meeting this requirement.  Mid-size agency components were the most successful in meeting this requirement.

The agency components reported the following:

Time Limits by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes 62 (27.8%) 36 (27.5%) 12 (26.1%) 8 (47.1%) 5 (23.8%) 1 (12.5%)
(b) No 21 (9.4%) 16 (12.2%) 2 (4.3%) 1 (5.9%) 2 (9.5%) 0 (0.0%)
(c) Not Applicable 140 (62.8%) 79 (60.3%) 32 (69.6%) 8 (47.1%) 14 (66.7%) 7 (87.5%)

Question 19 asked agency components whether their web-based applications provided keyboard accessibility.  Keyboard accessibility allows people with disabilities to access a program’s controls and features from a keyboard instead of a mouse or other pointing device.  Overall, a majority of agency components reported success in meeting this requirement.

The following table summarizes the responses provided by the agency components:

Keyboard Accessibility by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes 153 (68.6%) 92 (70.2%) 31 (67.4%) 14 (82.4%) 11 (52.4%) 5 (62.5%)
(b) No 22 (9.9%) 13 (9.9%) 3 (6.5%) 0 (0.0%) 5 (23.8%) 1 (12.5%)
(c) Not Applicable 48 (21.5%) 26 (19.8%) 12 (26.1%) 3 (17.6%) 5 (23.8%) 2 (25.0%)

Question 20 asked agency components whether their web-based applications provided a well-defined on-screen indication of the current focus that moves with keyboard navigation.  The position on a screen where an action will take place is referred to as the focus.  Overall, a majority of agency components reported success in ensuring that focus was programmatically exposed so that assistive technology can track focus.

The following table provides the specific responses by the agency components:

Screen Focus by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes 147 (65.9%) 93 (71.0%) 25 (54.3%) 12 (70.6%) 12 (57.1%) 5 (62.5%)
(b) No 34 (15.2%) 19 (14.5%) 7 (15.2%) 2 (11.8%) 5 (23.8%) 1 (12.5%)
(c) Not Applicable 42 (18.8%) 19 (14.5%) 14 (30.4%) 3 (17.6%) 4 (19.0%) 2 (25.0%)

Question 21 asked agency components whether their web-based applications provided sufficient information about user interface elements (such as check boxes, radio buttons, menus, toolbars, dialog and popup windows and controls) to assistive technology.  Overall, a majority of agency components reported success in meeting this requirement.  Small agency components had more difficulty meeting this requirement.

Specifically, the agency components provided the following responses:

Availability of User Interface Information by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes 141 (63.2%) 82 (62.6%) 32 (69.6%) 13 (76.5%) 8 (38.1%) 6 (75.0%)
(b) No 32 (14.3%) 21 (16.0%) 4 (8.7%) 1 (5.9%) 5 (23.8%) 1 (12.5%)
(c) Not applicable 50 (22.4%) 28 (21.4%) 10 (21.7%) 3 (17.6%) 8 (38.1%) 1 (12.5%)

Question 22 asked whether agency components used text captioning for multimedia content.  Such accessibility features are used to make multimedia features accessible to users with hearing and/or visual impairments.  Overall, most agency components (74.0%) reported that their web-based applications did not include multimedia content.  The agency components’ responses are summarized in the table below:

Captioning by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes 37 (16.6%) 21 (16.0%) 8 (17.4%) 3 (17.6%) 4 (19.0%) 1 (12.5%)
(b) No 21 (9.4%) 18 (13.7%) 1 (2.2%) 1 (5.9%) 1 (4.8%) 0 (0.0%)
(c) Not applicable 165 (74.0%) 92 (70.2%) 37 (80.4%) 13 (76.5%) 16 (76.2%) 7 (87.5%)

Question 23 asked whether agency components used descriptive narration for multimedia content.  Overall, most agency components (74.9%) reported that their web-based applications did not include multimedia content.

The following table provides the agency components’ responses:

Audio Description by Number (Percent) of Components in Differently-Sized Agencies

Answer All Very Large Large Mid-Size Small Very Small
(a) Yes 36 (16.1%) 21 (16.0%) 8 (17.4%) 2 (11.8%) 4 (19.0%) 1 (12.5%)
(b) No 20 (9.0%) 17 (13.0%) 1 (2.2%) 1 (5.9%) 1 (4.8%) 0 (0.0%)
(c) Not applicable 167 (74.9%) 93 (71.0%) 37 (80.4%) 14 (82.4%) 16 (76.2%) 7 (87.5%)

VI. Appendices

A. Section 508 Statutory Language

SECTION 508 OF THE REHABILITATION ACT OF 1973, AS AMENDED, 29 U.S.C. § 794(d)

(a) REQUIREMENTS FOR FEDERAL DEPARTMENTS AND AGENCIES. --

(1) ACCESSIBILITY. --

(A) DEVELOPMENT, PROCUREMENT, MAINTENANCE, OR USE OF ELECTRONIC AND INFORMATION TECHNOLOGY. --When developing, procuring, maintaining, or using electronic and information technology, each Federal department or agency, including the United States Postal Service, shall ensure, unless an undue burden would be imposed on the department or agency, that the electronic and information technology allows, regardless of the type of medium of the technology--

(i) individuals with disabilities who are Federal employees to have access to and use of information and data that is comparable to the access to and use of the information and data by Federal employees who are not individuals with disabilities; and

(ii) individuals with disabilities who are members of the public seeking information or services from a Federal department or agency to have access to and use of information and data that is comparable to the access to and use of the information and data by such members of the public who are not individuals with disabilities.

(B) ALTERNATIVE MEANS EFFORTS. --When development, procurement, maintenance, or use of electronic and information technology that meets the standards published by the Access Board under paragraph (2) would impose an undue burden, the Federal department or agency shall provide individuals with disabilities covered by paragraph (1) with the information and data involved by an alternative means of access that allows the individual to use the information and data.

(2) ELECTRONIC AND INFORMATION TECHNOLOGY STANDARDS. --

(A) IN GENERAL.–Not later than 18 months after August 7, 1998, the Architectural and Transportation Barriers Compliance Board (referred to in this section as the 'Access Board'), after consultation with the Secretary of Education, the Administrator of General Services, the Secretary of Commerce, the Chairman of the Federal Communications Commission, the Secretary of Defense, and the head of any other Federal department or agency that the Access Board determines to be appropriate, including consultation on relevant research findings, and after consultation with the electronic and information technology industry and appropriate public or nonprofit agencies or organizations, including organizations representing individuals with disabilities, shall issue and publish standards setting forth--

(i) for purposes of this section, a definition of electronic and information technology that is consistent with the definition of information technology specified in section 5002(3) of the Clinger-Cohen Act of 1996 (40 U.S.C. 1401(3)); and

(ii) the technical and functional performance criteria necessary to implement the requirements set forth in paragraph (1).

(B) REVIEW AND AMENDMENT. --The Access Board shall periodically review and, as appropriate, amend the standards required under subparagraph (A) to reflect technological advances or changes in electronic and information technology.

(3) INCORPORATION OF STANDARDS. --Not later than 6 months after the Access Board publishes the standards required under paragraph (2), the Federal Acquisition Regulatory Council shall revise the Federal Acquisition Regulation and each Federal department or agency shall revise the Federal procurement policies and directives under the control of the department or agency to incorporate those standards. Not later than 6 months after the Access Board revises any standards required under paragraph (2), the Council shall revise the Federal Acquisition Regulation and each appropriate Federal department or agency shall revise the procurement policies and directives, as necessary, to incorporate the revisions.

(4) ACQUISITION PLANNING. --In the event that a Federal department or agency determines that compliance with the standards issued by the Access Board under paragraph (2) relating to procurement imposes an undue burden, the documentation by the department or agency supporting the procurement shall explain why compliance creates an undue burden.

(5) EXEMPTION FOR NATIONAL SECURITY SYSTEMS. --This section shall not apply to national security systems, as that term is defined in section 5142 of the Clinger-Cohen Act of 1996 (40 U.S.C. 1452).

(6) CONSTRUCTION. --

(A) EQUIPMENT. --In a case in which the Federal Government provides access to the public to information or data through electronic and information technology, nothing in this section shall be construed to require a Federal department or agency--

(i) to make equipment owned by the Federal Government available for access and use by individuals with disabilities covered by paragraph (1) at a location other than that where the electronic and information technology is provided to the public; or

(ii) to purchase equipment for access and use by individuals with disabilities covered by paragraph (1) at a location other than that where the electronic and information technology is provided to the public.

(B) SOFTWARE AND PERIPHERAL DEVICES. --Except as required to comply with standards issued by the Access Board under paragraph (2), nothing in paragraph (1) requires the installation of specific accessibility-related software or the attachment of a specific accessibility-related peripheral device at a workstation of a Federal employee who is not an individual with a disability.

(b) TECHNICAL ASSISTANCE. --The Administrator of General Services and the Access Board shall provide technical assistance to individuals and Federal departments and agencies concerning the requirements of this section.

(c) AGENCY EVALUATIONS. --Not later than 6 months after August 7, 1998, the head of each Federal department or agency shall evaluate the extent to which the electronic and information technology of the department or agency is accessible to and usable by individuals with disabilities described in subsection (a)(1), compared to the access to and use of the technology by individuals described in such subsection who are not individuals with disabilities, and submit a report containing the evaluation to the Attorney General.

(d) REPORTS. --

(1) INTERIM REPORT. --Not later than 18 months after August 7, 1998, the Attorney General shall prepare and submit to the President a report containing information on and recommendations regarding the extent to which the electronic and information technology of the Federal Government is accessible to and usable by individuals with disabilities described in subsection (a)(1).

(2) BIENNIAL REPORTS. --Not later than 3 years after August 7, 1998, and every 2 years thereafter, the Attorney General shall prepare and submit to the President and Congress a report containing information on and recommendations regarding the state of Federal department and agency compliance with the requirements of this section, including actions regarding individual complaints under subsection (f).

(e) COOPERATION. --Each head of a Federal department or agency (including the Access Board, the Equal Employment Opportunity Commission, and the General Services Administration) shall provide to the Attorney General such information as the Attorney General determines is necessary to conduct the evaluations under subsection (c) and prepare the reports under subsection (d).

(f) ENFORCEMENT. --

(1) GENERAL. --

(A) COMPLAINTS.–Effective 6 months after the date of publication by the Access Board of final standards described in subsection (a)(2), any individual with a disability may file a complaint alleging that a Federal department or agency fails to comply with subsection (a)(1) in providing electronic and information technology.

(B) APPLICATION. -This subsection shall apply only to electronic and information technology that is procured by a Federal department or agency not less than 6 months after the date of publication by the Access Board of final standards described in subsection (a)(2).

(2) ADMINISTRATIVE COMPLAINTS. -Complaints filed under paragraph (1) shall be filed with the Federal department or agency alleged to be in noncompliance. The Federal department or agency receiving the complaint shall apply the complaint procedures established to implement section 794 of this title for resolving allegations of discrimination in a federally conducted program or activity.

(3) CIVIL ACTIONS. --The remedies, procedures, and rights set forth in sections 794a(a)(2) and 794a(b) of this title shall be the remedies, procedures, and rights available to any individual with a disability filing a complaint under paragraph (1).

(g) APPLICATION TO OTHER FEDERAL LAWS. -This section shall not be construed to limit any right, remedy, or procedure otherwise available under any provision of Federal law (including sections 791 through 794(a) of this title) that provides greater or equal protection for the rights of individuals with disabilities than this section.

B. Section 508 EIT Accessibility Standards

ARCHITECTURAL AND TRANSPORTATION BARRIERS COMPLIANCE BOARD

[Published in the Federal Register December 21, 2000]

36 CFR Part 1194

PART 1194 -- ELECTRONIC AND INFORMATION TECHNOLOGY ACCESSIBILITY STANDARDS

Subpart A -- General

1194.1 Purpose. 1194.2 Application. 1194.3 General exceptions. 1194.4 Definitions. 1194.5 Equivalent facilitation.

Subpart B -- Technical Standards

1194.21 Software applications and operating systems. 1194.22 Web-based intranet and internet information and applications. 1194.23 Telecommunications products. 1194.24 Video and multimedia products. 1194.25 Self contained, closed products. 1194.26 Desktop and portable computers.

Subpart C -- Functional Performance Criteria

1194.31 Functional performance criteria.

Subpart D -- Information, Documentation, and Support

1194.41 Information, documentation, and support.

Figures to Part 1194

Authority: 29 U.S.C. 794d.

Subpart A -- General

§ 1194.1 Purpose.

The purpose of this part is to implement section 508 of the Rehabilitation Act of 1973, as amended (29 U.S.C. 794d). Section 508 requires that when Federal agencies develop, procure, maintain, or use electronic and information technology, Federal employees with disabilities have access to and use of information and data that is comparable to the access and use by Federal employees who are not individuals with disabilities, unless an undue burden would be imposed on the agency. Section 508 also requires that individuals with disabilities, who are members of the public seeking information or services from a Federal agency, have access to and use of information and data that is comparable to that provided to the public who are not individuals with disabilities, unless an undue burden would be imposed on the agency.

§ 1194.2 Application.

(a) Products covered by this part shall comply with all applicable provisions of this part. When developing, procuring, maintaining, or using electronic and information technology, each agency shall ensure that the products comply with the applicable provisions of this part, unless an undue burden would be imposed on the agency.

(1) When compliance with the provisions of this part imposes an undue burden, agencies shall provide individuals with disabilities with the information and data involved by an alternative means of access that allows the individual to use the information and data.

(2) When procuring a product, if an agency determines that compliance with any provision of this part imposes an undue burden, the documentation by the agency supporting the procurement shall explain why, and to what extent, compliance with each such provision creates an undue burden.

(b) When procuring a product, each agency shall procure products which comply with the provisions in this part when such products are available in the commercial marketplace or when such products are developed in response to a Government solicitation. Agencies cannot claim a product as a whole is not commercially available because no product in the marketplace meets all the standards. If products are commercially available that meet some but not all of the standards, the agency must procure the product that best meets the standards.

(c) Except as provided by § 1194.3(b), this part applies to electronic and information technology developed, procured, maintained, or used by agencies directly or used by a contractor under a contract with an agency which requires the use of such product, or requires the use, to a significant extent, of such product in the performance of a service or the furnishing of a product.

§ 1194.3 General exceptions.

(a) This part does not apply to any electronic and information technology operated by agencies, the function, operation, or use of which involves intelligence activities, cryptologic activities related to national security, command and control of military forces, equipment that is an integral part of a weapon or weapons system, or systems which are critical to the direct fulfillment of military or intelligence missions. Systems which are critical to the direct fulfillment of military or intelligence missions do not include a system that is to be used for routine administrative and business applications (including payroll, finance, logistics, and personnel management applications).

(b) This part does not apply to electronic and information technology that is acquired by a contractor incidental to a contract.

(c) Except as required to comply with the provisions in this part, this part does not require the installation of specific accessibility-related software or the attachment of an assistive technology device at a workstation of a Federal employee who is not an individual with a disability.

(d) When agencies provide access to the public to information or data through electronic and information technology, agencies are not required to make products owned by the agency available for access and use by individuals with disabilities at a location other than that where the electronic and information technology is provided to the public, or to purchase products for access and use by individuals with disabilities at a location other than that where the electronic and information technology is provided to the public.

(e) This part shall not be construed to require a fundamental alteration in the nature of a product or its components.

(f) Products located in spaces frequented only by service personnel for maintenance, repair, or occasional monitoring of equipment are not required to comply with this part.

§ 1194.4 Definitions.

The following definitions apply to this part:

Agency. Any Federal department or agency, including the United States Postal Service.

Alternate formats. Alternate formats usable by people with disabilities may include, but are not limited to, Braille, ASCII text, large print, recorded audio, and electronic formats that comply with this part.

Alternate methods. Different means of providing information, including product documentation, to people with disabilities. Alternate methods may include, but are not limited to, voice, fax, relay service, TTY, Internet posting, captioning, text-to-speech synthesis, and audio description.

Assistive technology. Any item, piece of equipment, or system, whether acquired commercially, modified, or customized, that is commonly used to increase, maintain, or improve functional capabilities of individuals with disabilities.

Electronic and information technology. Includes information technology and any equipment or interconnected system or subsystem of equipment, that is used in the creation, conversion, or duplication of data or information. The term electronic and information technology includes, but is not limited to, telecommunications products (such as telephones), information kiosks and transaction machines, World Wide Web sites, multimedia, and office equipment such as copiers and fax machines. The term does not include any equipment that contains embedded information technology that is used as an integral part of the product, but the principal function of which is not the acquisition, storage, manipulation, management, movement, control, display, switching, interchange, transmission, or reception of data or information. For example, HVAC (heating, ventilation, and air conditioning) equipment such as thermostats or temperature control devices, and medical equipment where information technology is integral to its operation, are not information technology.

Information technology. Any equipment or interconnected system or subsystem of equipment, that is used in the automatic acquisition, storage, manipulation, management, movement, control, display, switching, interchange, transmission, or reception of data or information. The term information technology includes computers, ancillary equipment, software, firmware and similar procedures, services (including support services), and related resources.

Operable controls. A component of a product that requires physical contact for normal operation. Operable controls include, but are not limited to, mechanically operated controls, input and output trays, card slots, keyboards, or keypads.

Product. Electronic and information technology.

Self Contained, Closed Products. Products that generally have embedded software and are commonly designed in such a fashion that a user cannot easily attach or install assistive technology. These products include, but are not limited to, information kiosks and information transaction machines, copiers, printers, calculators, fax machines, and other similar types of products.

Telecommunications. The transmission, between or among points specified by the user, of information of the user's choosing, without change in the form or content of the information as sent and received.

TTY. An abbreviation for teletypewriter. Machinery or equipment that employs interactive text based communications through the transmission of coded signals across the telephone network. TTYs may include, for example, devices known as TDDs (telecommunication display devices or telecommunication devices for deaf persons) or computers with special modems. TTYs are also called text telephones.

Undue burden. Undue burden means significant difficulty or expense. In determining whether an action would result in an undue burden, an agency shall consider all agency resources available to the program or component for which the product is being developed, procured, maintained, or used.

§ 1194.5 Equivalent facilitation.

Nothing in this part is intended to prevent the use of designs or technologies as alternatives to those prescribed in this part provided they result in substantially equivalent or greater access to and use of a product for people with disabilities.

Subpart B -- Technical Standards

§ 1194.21 Software applications and operating systems.

(a) When software is designed to run on a system that has a keyboard, product functions shall be executable from a keyboard where the function itself or the result of performing a function can be discerned textually.

(b) Applications shall not disrupt or disable activated features of other products that are identified as accessibility features, where those features are developed and documented according to industry standards. Applications also shall not disrupt or disable activated features of any operating system that are identified as accessibility features where the application programming interface for those accessibility features has been documented by the manufacturer of the operating system and is available to the product developer.

(c) A well-defined on-screen indication of the current focus shall be provided that moves among interactive interface elements as the input focus changes. The focus shall be programmatically exposed so that assistive technology can track focus and focus changes.

(d) Sufficient information about a user interface element including the identity, operation and state of the element shall be available to assistive technology. When an image represents a program element, the information conveyed by the image must also be available in text.

(e) When bitmap images are used to identify controls, status indicators, or other programmatic elements, the meaning assigned to those images shall be consistent throughout an application's performance.

(f) Textual information shall be provided through operating system functions for displaying text. The minimum information that shall be made available is text content, text input caret location, and text attributes.

(g) Applications shall not override user selected contrast and color selections and other individual display attributes.

(h) When animation is displayed, the information shall be displayable in at least one non-animated presentation mode at the option of the user.

(i) Color coding shall not be used as the only means of conveying information, indicating an action, prompting a response, or distinguishing a visual element.

(j) When a product permits a user to adjust color and contrast settings, a variety of color selections capable of producing a range of contrast levels shall be provided.

(k) Software shall not use flashing or blinking text, objects, or other elements having a flash or blink frequency greater than 2 Hz and lower than 55 Hz.

(l) When electronic forms are used, the form shall allow people using assistive technology to access the information, field elements, and functionality required for completion and submission of the form, including all directions and cues.

§ 1194.22 Web-based intranet and internet information and applications.

(a) A text equivalent for every non-text element shall be provided (e.g. , via "alt", "longdesc", or in element content).

(b) Equivalent alternatives for any multimedia presentation shall be synchronized with the presentation.

(c) Web pages shall be designed so that all information conveyed with color is also available without color, for example from context or markup.

(d) Documents shall be organized so they are readable without requiring an associated style sheet.

(e) Redundant text links shall be provided for each active region of a server-side image map.

(f) Client-side image maps shall be provided instead of server-side image maps except where the regions cannot be defined with an available geometric shape.

(g) Row and column headers shall be identified for data tables.

(h) Markup shall be used to associate data cells and header cells for data tables that have two or more logical levels of row or column headers.

(i) Frames shall be titled with text that facilitates frame identification and navigation.

(j) Pages shall be designed to avoid causing the screen to flicker with a frequency greater than 2 Hz and lower than 55 Hz.

(k) A text-only page, with equivalent information or functionality, shall be provided to make a web site comply with the provisions of this part, when compliance cannot be accomplished in any other way. The content of the text-only page shall be updated whenever the primary page changes.

(l) When pages utilize scripting languages to display content, or to create interface elements, the information provided by the script shall be identified with functional text that can be read by assistive technology.

(m) When a web page requires that an applet, plug-in or other application be present on the client system to interpret page content, the page must provide a link to a plug-in or applet that complies with § 1194.21(a) through (l).

(n) When electronic forms are designed to be completed on-line, the form shall allow people using assistive technology to access the information, field elements, and functionality required for completion and submission of the form, including all directions and cues.

(o) A method shall be provided that permits users to skip repetitive navigation links.

(p) When a timed response is required, the user shall be alerted and given sufficient time to indicate more time is required.

Note to § 1194.22: 1. The Board interprets paragraphs (a) through (k) of this section as consistent with the following priority 1 Checkpoints of the Web Content Accessibility Guidelines 1.0 (WCAG 1.0) (May 5, 1999) published by the Web Accessibility Initiative of the World Wide Web Consortium:

Section 1194.22 Paragraph WCAG 1.0 Checkpoint
(a) 1.1
(b) 1.4
(c) 2.1
(d) 6.1
(e) 1.2
(f) 9.1
(g) 5.1
(h) 5.2
(i) 12.1
(j) 7.1
(k) 11.4

2. Paragraphs (l), (m), (n), (o), and (p) of this section are different from WCAG 1.0. Web pages that conform to WCAG 1.0, level A (i.e. , all priority 1 checkpoints) must also meet paragraphs (l), (m), (n), (o), and (p) of this section to comply with this section. WCAG 1.0 is available at http://www.w3.org/TR/1999/WAI-WEBCONTENT-19990505.

§ 1194.23 Telecommunications products.

(a) Telecommunications products or systems which provide a function allowing voice communication and which do not themselves provide a TTY functionality shall provide a standard non-acoustic connection point for TTYs. Microphones shall be capable of being turned on and off to allow the user to intermix speech with TTY use.

(b) Telecommunications products which include voice communication functionality shall support all commonly used cross-manufacturer non-proprietary standard TTY signal protocols.

(c) Voice mail, auto-attendant, and interactive voice response telecommunications systems shall be usable by TTY users with their TTYs.

(d) Voice mail, messaging, auto-attendant, and interactive voice response telecommunications systems that require a response from a user within a time interval, shall give an alert when the time interval is about to run out, and shall provide sufficient time for the user to indicate more time is required.

(e) Where provided, caller identification and similar telecommunications functions shall also be available for users of TTYs, and for users who cannot see displays.

(f) For transmitted voice signals, telecommunications products shall provide a gain adjustable up to a minimum of 20 dB. For incremental volume control, at least one intermediate step of 12 dB of gain shall be provided.

(g) If the telecommunications product allows a user to adjust the receive volume, a function shall be provided to automatically reset the volume to the default level after every use.

(h) Where a telecommunications product delivers output by an audio transducer which is normally held up to the ear, a means for effective magnetic wireless coupling to hearing technologies shall be provided.

(i) Interference to hearing technologies (including hearing aids, cochlear implants, and assistive listening devices) shall be reduced to the lowest possible level that allows a user of hearing technologies to utilize the telecommunications product.

(j) Products that transmit or conduct information or communication, shall pass through cross-manufacturer, non-proprietary, industry-standard codes, translation protocols, formats or other information necessary to provide the information or communication in a usable format. Technologies which use encoding, signal compression, format transformation, or similar techniques shall not remove information needed for access or shall restore it upon delivery.

(k) Products which have mechanically operated controls or keys, shall comply with the following:

(1) Controls and keys shall be tactilely discernible without activating the controls or keys.

(2) Controls and keys shall be operable with one hand and shall not require tight grasping, pinching, or twisting of the wrist. The force required to activate controls and keys shall be 5 lbs. (22.2 N) maximum.

(3) If key repeat is supported, the delay before repeat shall be adjustable to at least 2 seconds. Key repeat rate shall be adjustable to 2 seconds per character.

(4) The status of all locking or toggle controls or keys shall be visually discernible, and discernible either through touch or sound.

§ 1194.24 Video and multimedia products.

(a) All analog television displays 13 inches and larger, and computer equipment that includes analog television receiver or display circuitry, shall be equipped with caption decoder circuitry which appropriately receives, decodes, and displays closed captions from broadcast, cable, videotape, and DVD signals. As soon as practicable, but not later than July 1, 2002, widescreen digital television (DTV) displays measuring at least 7.8 inches vertically, DTV sets with conventional displays measuring at least 13 inches vertically, and stand-alone DTV tuners, whether or not they are marketed with display screens, and computer equipment that includes DTV receiver or display circuitry, shall be equipped with caption decoder circuitry which appropriately receives, decodes, and displays closed captions from broadcast, cable, videotape, and DVD signals.

(b) Television tuners, including tuner cards for use in computers, shall be equipped with secondary audio program playback circuitry.

(c) All training and informational video and multimedia productions which support the agency's mission, regardless of format, that contain speech or other audio information necessary for the comprehension of the content, shall be open or closed captioned.

(d) All training and informational video and multimedia productions which support the agency's mission, regardless of format, that contain visual information necessary for the comprehension of the content, shall be audio described.

(e) Display or presentation of alternate text presentation or audio descriptions shall be user-selectable unless permanent.

§ 1194.25 Self contained, closed products.

(a) Self contained products shall be usable by people with disabilities without requiring an end-user to attach assistive technology to the product. Personal headsets for private listening are not assistive technology.

(b) When a timed response is required, the user shall be alerted and given sufficient time to indicate more time is required.

(c) Where a product utilizes touchscreens or contact-sensitive controls, an input method shall be provided that complies with § 1194.23 (k) (1) through (4).

(d) When biometric forms of user identification or control are used, an alternative form of identification or activation, which does not require the user to possess particular biological characteristics, shall also be provided.

(e) When products provide auditory output, the audio signal shall be provided at a standard signal level through an industry standard connector that will allow for private listening. The product must provide the ability to interrupt, pause, and restart the audio at anytime.

(f) When products deliver voice output in a public area, incremental volume control shall be provided with output amplification up to a level of at least 65 dB. Where the ambient noise level of the environment is above 45 dB, a volume gain of at least 20 dB above the ambient level shall be user selectable. A function shall be provided to automatically reset the volume to the default level after every use.

(g) Color coding shall not be used as the only means of conveying information, indicating an action, prompting a response, or distinguishing a visual element.

(h) When a product permits a user to adjust color and contrast settings, a range of color selections capable of producing a variety of contrast levels shall be provided.

(i) Products shall be designed to avoid causing the screen to flicker with a frequency greater than 2 Hz and lower than 55 Hz.

(j) Products which are freestanding, non-portable, and intended to be used in one location and which have operable controls shall comply with the following:

(1) The position of any operable control shall be determined with respect to a vertical plane, which is 48 inches in length, centered on the operable control, and at the maximum protrusion of the product within the 48 inch length (see Figure 1 of this part).

(2) Where any operable control is 10 inches or less behind the reference plane, the height shall be 54 inches maximum and 15 inches minimum above the floor.

(3) Where any operable control is more than 10 inches and not more than 24 inches behind the reference plane, the height shall be 46 inches maximum and 15 inches minimum above the floor.

(4) Operable controls shall not be more than 24 inches behind the reference plane (see Figure 2 of this part).

§ 1194.26 Desktop and portable computers.

(a) All mechanically operated controls and keys shall comply with § 1194.23 (k) (1) through (4).

(b) If a product utilizes touchscreens or touch-operated controls, an input method shall be provided that complies with § 1194.23 (k) (1) through (4).

(c) When biometric forms of user identification or control are used, an alternative form of identification or activation, which does not require the user to possess particular biological characteristics, shall also be provided.

(d) Where provided, at least one of each type of expansion slots, ports and connectors shall comply with publicly available industry standards.

Subpart C -- Functional Performance Criteria

§ 1194.31 Functional performance criteria.

(a) At least one mode of operation and information retrieval that does not require user vision shall be provided, or support for assistive technology used by people who are blind or visually impaired shall be provided.

(b) At least one mode of operation and information retrieval that does not require visual acuity greater than 20/70 shall be provided in audio and enlarged print output working together or independently, or support for assistive technology used by people who are visually impaired shall be provided.

(c) At least one mode of operation and information retrieval that does not require user hearing shall be provided, or support for assistive technology used by people who are deaf or hard of hearing shall be provided.

(d) Where audio information is important for the use of a product, at least one mode of operation and information retrieval shall be provided in an enhanced auditory fashion, or support for assistive hearing devices shall be provided.

(e) At least one mode of operation and information retrieval that does not require user speech shall be provided, or support for assistive technology used by people with disabilities shall be provided.

(f) At least one mode of operation and information retrieval that does not require fine motor control or simultaneous actions and that is operable with limited reach and strength shall be provided.

Subpart D -- Information, Documentation, and Support

§ 1194.41 Information, documentation, and support.

(a) Product support documentation provided to end-users shall be made available in alternate formats upon request, at no additional charge.

(b) End-users shall have access to a description of the accessibility and compatibility features of products in alternate formats or alternate methods upon request, at no additional charge.

(c) Support services for products shall accommodate the communication needs of end-users with disabilities.

Figures to Part 1194

C. The Attorney General’s Memorandum to Heads of All Federal Agencies

The Attorney General’s Memorandum to Heads of All Federal Agencies (HTML) | (PDF)

 

D. Section 508 Survey Questions

Section 508 Survey Questions

 

E. Agencies Listed by Size Categories

Very Large Agencies (25,001 or more employees)
1. Department of Commerce
2. Department of Defense
3. Department of Health and Human Services
4. Department of Homeland Security
5. Department of Interior
6. Department of Justice
7. Department of State
8. Department of the Treasury
9. Department of Transportation
10. Department of Veterans Affairs
11. National Aeronautics and Space Administration
12. Postal Service
13. Social Security Administration
Large Agencies (10,001 to 25,000 employees)
1. Department of Agriculture
2. Department of Energy
3. Department of Labor
4. Environmental Protection Agency
5. General Services Administration
6. Tennessee Valley Authority
Mid-Size Agencies (1,001 to 10,000 employees)
1.  Agency for International Development
2. Broadcasting Board of Governors
3. Department of Education
4. Department of Housing and Urban Development
5. Federal Communications Commission
6.  Equal Employment Opportunity Commission
7. Federal Deposit Insurance Corporation
8. Federal Energy Regulatory Commission
9. Federal Reserve Board
10. Federal Trade Commission
11. National Archives and Records Administration
12. National Credit Union Administration
13. National Labor Relations Board
14. National Science Foundation
15.  Nuclear Regulatory Commission
16. Office of Personnel Management
17. Securities and Exchange Commission
18. Small Business Administration
Small Agencies (101 to 1,000 employees)
1. American Battle Monuments Commission
2. Commodity Futures Trading Commission
3.  Consumer Product Safety Commission
4. Corporation for National and Community Service
5. Court Services and Offender Supervision Agency (CSP)
6. Defense Nuclear Facilities Safety Board
7. Export Import Bank of the United States
8. Farm Credit Administration
9. Federal Election Commission
10. Federal Housing Finance Agency
11. Federal Labor Relations Authority
12. Federal Maritime Commission
13. Federal Mediation and Conciliation Service
14.  Holocaust Memorial Museum
15.  International Trade Commission
16.  Merit Systems Protection Board
17. National Endowment for the Arts
18. National Endowment for the Humanities
19. National Indian Gaming Commission
20. National Transportation Safety Board
21. Office of Special Council
22. Overseas Private Investment Corporation
23. Peace Corps
24. Pension Benefit Guaranty Corporation
25.  Railroad Retirement Board
26. Selective Service System
Very Small Agencies (100 or less employees)
1. Access Board
2. Advisory Council on Historic Preservation
3.  African Development Foundation
4. Chemical Safety and Hazard Investigation Board
5. Committee for Purchase From People Who Are Blind or Severely Disabled
6.  Commission of Fine Arts
7.  Commission on Civil Rights
8.  Election Assistance Commission
9. Federal Mine Safety and Health Review Commission
10. Federal Retirement Thrift Investment Board
11. Harry S. Truman Scholarship Foundation
12. Institute of Museum and Library Services
13. Inter-American Foundation
14. James Madison Memorial Fellowship Foundation
15. Japan-US Friendship Commission
16. Marine Mammal Commission
17. National Capital Planning Commission
18. National Council on Disability
19. National Mediation Board
20. Occupational Safety and Health Review Commission
21.  Office of Government Ethics
22. Office of Navajo and Hopi Indian Relocation
23. Postal Regulatory Commission
24. Social Security Advisory Board
25.  Trade and Development Agency
26. Udall Foundation


[1] The Department did not publish a report based on the results of the 2004 Survey.

[2] 29 U.S.C. § 794d.

[3] The survey and the report would not have been possible without substantial assistance from the General Services Administration and other agencies.

[4] The federal executive Cabinet level agencies, independent agencies, and boards, commissions and committees were identified from the United States government’s official web portal, USA.gov.

[5]The calculation of average number of FTEs and dollars were based on responses from 110 agency components that reported establishing a Section 508 office or program.  A total of 318 agency components participated in the survey.  Thus, the average number of FTEs and dollars represent only 35% of the total number of agency components that participated in the survey.

[6]The Department of Health and Human Services has taken such an approach in its Guidance for Exchange and Medicaid Information Technology (IT) Systems, Version 2.0 (May 2011):  “Systems should include usability features or functions that accommodate the needs of persons with disabilities, including those who use assistive technology.  State enrollment and eligibility systems are subject to the program accessibility provisions of Section 504 of the Rehabilitation Act, which include an obligation to provide individuals with disabilities an equal and effective opportunity to benefit from or participate in a program, including those offered through electronic and information technology.  At this time, HHS will consider a recipient’s websites, interactive kiosks, and other information systems addressed by Section 508 standards as being in compliance with Section 504 if such technologies meet those standards.  We encourage states to follow either the Section 508 guidelines or guidelines that provider greater accessibility to individuals with disabilities.  States may wish to consult the latest Section 508 guidelines issued by the US Access Board ….”

[7] For example, in 2008, the U.S. Equal Employment Opportunity Commission updated their Section 504 regulations to establish procedures for processing complaints alleging a violation of Section 508.  29 C.F.R. pt. 1615.

[8] The calculation of average number of FTEs and dollars were based on responses from 110 agency components that reported establishing a Section 508 office or program.  A total of 318 agency components participated in the survey.  Thus, the average number of FTEs and dollars represent only 35% of the total number of agency components that participated in the survey.

[9] The calculation of average number of dollars was based on responses from 42 agency components that tracked their spending to implement and comply with Section 508.  A total of 318 agency components participated in the survey.  Thus, the average number of dollars represents only 13% of the total number of agency components that participated in the survey.

[10] The calculation of average number of FTEs and dollars were based on responses from 110 agency components that reported establishing a Section 508 office or program.  A total of 318 agency components participated in the survey.  Thus, the average number of FTEs and dollars represent only 35% of the total number of agency components that participated in the survey.

[11] The calculation of average number of FTEs was based on responses from 110 agency components that reported establishing a Section 508 office or program.  A total of 318 agency components participated in the survey.  Thus, the average number of FTEs represents only 35% of the total number of agency components that participated in the survey.

[12] The calculation of average number of dollars was based on responses from 110 agency components that reported establishing a Section 508 office or program.  A total of 318 agency components participated in the survey.  Thus, the average number of dollars represents only 35% of the total number of agency components that participated in the survey.

[13] The calculation of average number of dollars was based on responses from 42 agency components that tracked their spending to implement and comply with Section 508.  A total of 318 agency components participated in the survey.  Thus, the average number of dollars represents only 13% of the total number of agency components that participated in the survey.

[14] The calculation of average number of dollars was based on responses from 42 agency components that tracked their spending to implement and comply with Section 508.  A total of 318 agency components participated in the survey.  Thus, the average number of dollars represents only 13% of the total number of agency components that participated in the survey.

[15] Alternate formats usable by people with disabilities include, but are not limited to, Braille, ASCII text, large print, recorded audio, and electronic formats.  Alternate methods are different means of providing information, including product documentation, to people with disabilities.  Alternate methods include, but are not limited to, voice, fax, relay service, TTY, Internet posting, captioning, text-to-speech synthesis, and audio description.

[16] Section 508(a) requires federal departments and agencies, including the United States Postal Service, to ensure the accessibility of their EIT when they develop, procure, maintain, or use that EIT.  Section 508(f) authorizes civil actions and administrative complaints by persons with disabilities for violations of Section 508(a).  This section, however, is limited to electronic and information technology procured after June 21, 2001.

[17] Voluntary Product Accessibility Template or VPAT is a non-governmental tool voluntarily used by vendors to document a product’s conformance with the accessibility standards under Section 508.

[18] Section 508 EIT Accessibility Standards are not applicable for “[p]roducts located in spaces frequented only by service personnel for maintenance, repair, or occasional monitoring of equipment.”  36 C.F.R. § 1194.3(f).

[19] Section 508 EIT Accessibility Standards are not applicable for “[p]roducts located in spaces frequented only by service personnel for maintenance, repair, or occasional monitoring of equipment.”  36 C.F.R. § 1194.3(f).

[20] Answer choices (a) and (b) have been combined to present the overall number (and percentage) of agency components that require approval at the top agency or top component level.

[21] Federal agencies have additional longstanding obligations that are enforceable under sections 501 and 504 of the Rehabilitation Act.  Thus, if individuals file complaints pertaining to EIT, agencies should review the allegations to determine if they more properly allege violations of sections 501 or 504 of the Rehabilitation Act.

[22] In addition to administrative complaints, individuals with disabilities may file civil lawsuits in federal district court for violations of Section 508.  The remedies available in court proceedings are defined by sections 505(a)(2) and 505(b) of the Rehabilitation Act, 29 U.S.C. §§ 794a(a)(2) and 794a(b), and include injunctive relief and attorneys’ fees, but do not include monetary damages.  See Lane v. Pena, 518 U.S. 187 (1996).

[23] The number of administrative complaints and civil actions are based on information since June 21, 2001, the effective date of the Section 508 EIT Accessibility Standards.