Pre-print version of:
Accessibility of U.S. Federal Government Home Pages:
Section 508 Compliance and Site Accessibility Statements.
To be cited as: Olalere, A., and Lazar, J. (2011). Accessibility of U.S. Federal Government Home Pages: Section 508 Compliance and Site Accessibility Statements.Government Information Quarterly28(3), 303-309.
Please note that this is not the final version, and due to copyright limitations, we may not post the final version on the web. We highly suggest that you read the final published version in the journal Government Information Quarterly.
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ABSTRACT
U.S. Federal websites are required to be accessible for people with impairments. However, despite the existing regulations and guidelines, many federalwebsites continue to be inaccessible, and accessibility policy statements available on federalwebsites often do not provide any useful information. This paper provides three contributions to the research literature: (1) an accessibility evaluation of 100 federal home pages using both human and automated methods, (2) a content analysis of existing website accessibility policy statements, and (3) a discussion of the relationship between actual 508 compliance and the existing accessibility policy statements on a website. The paper concludes with recommendations for improving policy related to Section 508 compliance for websites.
Keywords
Accessibility, policy, disability, impairment, compliance, Section 508, open government, assistive technology, universal usability
1. Introduction
People with impairments are frequent users of the Internet, but many U.S.Federalwebsites continue to be inaccessible (Jaeger, 2006). In the context of U.S. laws, an “accessible” website is defined as one that follows the U.S. Section 508 regulations. Section 508 of the Rehabilitation Act of 1973, as amended in 1998, requires that when Federal agencies develop, procure, maintain, or use electronic and information technology, that the IT is fully accessible for people with impairments. This applies to, but is not limited to, websites, operating systems, hardware, and telecommunications devices. While the Americans with Disabilities Act (ADA) does not provide specific technical standards for web sites of public accommodations, there are clear technical standards for the Section 508 regulations, which clearly apply to Federal websites and other federally-funded information technology.
A website is inaccessible when people with perceptual or motor impairments cannot technically use the website. People with perceptual or motor impairments often use assistive technologies, such as screen readers (computer-synthesized speech output, AKA text-to-speech), speech recognition (speech input), and alternative input and output devices. For a website to be considered accessible, it must be flexible enough to work with various input and output devices. It’s not that the web pages must have code added for each additional impairment, but instead, when appropriate coding standards and labeling conventions are used, this will make the website accessible for people various impairments. It’s important to note that the existing federal regulations address design for perceptual and motor impairments, but not cognitive impairments. While there is a nearly 25 year track record in the research community of understanding how people with perceptual and motor impairments utilize computers, research on users with cognitive impairments is much newer, much more limited; and, while the international standards (the Web Content Accessibility Guidelines 2.0) have started to discuss cognitive impairment, the U.S. government regulations have not yet done so. For a concrete example of what happens when a Web page is inaccessible, the ready.gov home page, which is sponsored by the Federal Emergency Management Administration(FEMA), provided content in an inaccessible format in mid-2010. Information about hurricane and flood preparation was in an inaccessible flash format, and therefore, could not be heard by blind people utilizing screen reader technology. This was clearly important content, of a life-or-death nature, and it is good to therefore note that in November 2010, FEMA changed the website to make that content more accessible. Often, agencies place more content on websites than is available in other formats; if a federal website is inaccessible, it means that people with impairments have access to less information and content than the general population.
The portions of the 508 regulations that relate to the Web are based on, but not the same as, the Web Content Accessibility Guidelines (WCAG) from the Web Accessibility Initiative (WAI)(World Wide Web Consortium, 2010). While the original version of Section 508 Web regulations (implemented in 2001) was based on WCAG 1.0 (approved in 1999), the current 508 revision process is utilizing the WCAG 2.0 (approved in 2008) for the regulations related to web pages.
1.1. Previous studies
A number of previous research articles have documented that federal websites often are not in compliance with Section 508 regulations, however most of these studies utilized either automated tools or varying methodologies, so the results are not easily comparable over time. For instance, Jackson-Sanborn, Odess-Harnish and Warren (2002) evaluated 100 federal home pages (and one sub-level) using the Bobby automated software tool, but evaluated against the WCAG 1.0 rules (not Section 508), and found that only 60% of the websites were accessible (Jackson-Sanborn, Odess-Harnish, & Warren, 2002). Using the Bobby automated tool, Stower evaluated 148 Federal websites in 2002 and found that only 13.5% of 148 federal websites were accessible, although the report didn’t clearly state whether the sites had been checked for WCAG 1.0 or Section 508. In December 2003, Ellison (2004)evaluated 50 federal home pages using the Bobby tool to check for 508 compliance, and found that only 22% of 50 federal home pages were accessible. In 2005, Loiacono, McCoy and Chin evaluated 417 federal websites and federal contractor websites using the Bobby tool, and found that only 23% of websites were compliant with section 508 (Loiacono, McCoy, & Chin, 2005). Jaeger (2006) evaluated 10 federal websites using a multi-method approach involving both expert inspections and testing by people with impairments, and all 10 websites evaluated had problems related to 508 compliance(Jaeger, 2006).
Other researchers have examined state website accessibility. Fagan and Fagan (2004) examined state legislature websites for WCAG 1.0 compliance using the Bobby tool, and found that only seven of the 50 states had no accessibility violations on their main legislative, house and senate web pages (although three of those states did not have separate house and senate web pages at the time) (Fagen & Fagen, 2004). Lazar et al. (2010) examined 15 Maryland state websites in 2009 using expert inspections, and found that only one of the 15 websites was free from accessibility violations.
1.2. Compliance activities
The Section 508 regulation requires that every two years, the Attorney General must prepare and submit a report to the President and Congress, about Federal compliance with Section 508. Federal agencies and departments must provide information to the Attorney General, Department of Justice (DOJ), upon request, about their compliance with Section 508. Unfortunately, the last time that the DOJ collected data on Federal government website accessibility was in 2001. The DOJweb page on 508 compliance is out of date, and as of December 24, 2010, their website shows that accessibility data was last collected in 2001(U.S. Department of Justice, 2010).
A new memo was released by the Office of Management and Budget on July 19, 2010, which stated that the Justice Department, working with the General Services Administration (GSA),will begin collecting data again on Section 508 compliance(Office of Management and Budget, 2010). The memo states that the DOJ last collected data in 2004, although no data or results have actually been posted since 2001. While the memo states that a data collection survey related to Section 508 compliance would be issued in September 2010, as of late February2011, no survey had yet been issued.
The memo also notes that a report will be issued in Spring 2011, but again, since no survey has yet been disseminated, it is questionable whether that deadline will be met. The memo also noted that the Federal CIO Council recently created an accessibility committee, which will be working with GSA, DOJ, and the U.S. Access Board on improving compliance. The only concrete steps taken as of early January 2011 are that two public “listening sessions” were held, where the public could comment on issues related to Section 508. The July 2010 memo also noted the connection between Section 508 compliance and the Open Government Initiative, although no previous relationship has been stated publicly, and the open government website does not discuss Section 508 or accessibility (
To demonstrate the extent of the problem, it has been reported that the newly re-designed website, the government website devoted to the task of educating federal employees and building the infrastructure necessary to support Section 508 implementation, is not accessible, with many accessibility problems discovered on its home page and throughout the website (Lipowicz, 2010).
Table 1 displays a short history of the development and growth of the Section 508 regulations. While U.S. Federal government agencies have not complied with Section 508,other national governments have taken different approaches. For instance, Sweden has taken the approach of performing regular accessibility evaluations of government websites, and posting the results publicly to encourage compliance (Gulliksen, Axelson, Persson, & Goransson, 2010). In November 2010, a Canadian federal court ruled that the Canadian government is not following their own laws related to Canadian government website accessibility, and ordered the government to ensure that all government websites are made accessible within 15 months (Loriggio, 2010).
Table 1.
History of Section 508-related efforts
Date / Development Related to Section 508Aug. 1998 / Section 508 of Rehabilitation Act signed into law
Dec. 2000 / Section 508 specific regulations (technical specifications) released
June 2001 / Section 508 regulations in effect
Aug. 2001 / Last published evaluation of 508 compliance from the Justice Department
June 2004 / Draft guidelines for Federal websites released from OMB, including having an accessibility policy statement as a requirement
Dec. 2004 / OMB adopts final Federal website guidelines, with no requirement for site accessibility policy statement
April 2008 / Draft recommendations from the advisory board (TEITAC) sent to the U.S. Access Board, on the new version of Section 508 regulations
Throughout 2009 / National Federation of the Blind files administrative complaints against the Department of Education and Small Business Administration for 508 non-compliance
March 2010 / Broadband plan notes that Section 508 is not being followed
March 2010 / Draft of new Section 508 (Information and Communication Technology) released from the Access Board, public comment period begins
July 2010 / Office of Management and Budget releases a memo stating that 508 compliance actions will begin again in September 2010
2. Ensuring compliance and website accessibility policy statements
Resources and guidance on implementing accessibility are not comprehensive and often are hard to find. While interface guidelines (such as WCAG and Section 508) are provided, what is lacking is the “how” to apply and use the tools, techniques and criteria. Documents such as “Creating Section 508-Accessible PDFs Using Adobe Acrobat” provided by GSA and “Redacting with Confidence: How to Safely Publish Sanitized Reports Converted from Word to PDF” (which addresses accessibility)from National Security Agency are very helpful, but even though these documents are readily available on the Web, they are not well-known, even among government employees. Case studies of what approaches government agencies take to ensure 508 compliance, both in initial and ongoing testing, simply do not exist, either in government documents or in research publications.
Another area of concern is that a lot of websites have accessibility flaws which are not present in original design, but are added to web pages over time. Web pages are not static, they are updated often, and for many of today’s “government 2.0” websites, they are updated and modified on a daily basis. Previous studies have shown that accessibility levels fluctuate over time, and as more complexity and new content is added to a website, often the number of accessibility violations increases (Hackett, Parmento, & Zeng, 2004;Lazar & Greenidge, 2006). Therefore, it is important to document, in the form of a site accessibility policy, what accessibility features exist on a website, and how often the site is evaluated for accessibility. U.S. government websites are not required to have a site accessibility policy statement, although the idea of requiring such a statement had been discussed by the Office of Management and Budget, which adopted guidelines for federal websites in 2004 (see Table 1). Because there are multiple sources within the government for guidance and regulations, very often, if there is not a stated legal requirement, simple suggestions or good practices will not be followed. These site accessibility statements are very helpful for users when the statements are present, as they provide a roadmap to understanding the level of compliance, the features present in a site, and the process followed.
Furthermore, there is evidence from data collected at the state level that there is a correlation between strong web accessibility policies and statements, and state government websites actually being accessible (Rubaii-Barrett & Wise, 2008). In the new draft of the Information and Communication Technology (ICT) Standards and Guidelines from the U.S. Access Board, there is no requirement for a website accessibility policy statement.
2. Methodology
Three stages of data collection were planned: (1) evaluating the accessibility of 100 federal home pages, (2) evaluating the existence of and content in accessibility statements on those websites, and (3) exploring the connection between actual accessibility and stated accessibility.
We started by examining the list of government agencies from the usa.gov portal website, to compile a list of 100 federal websites. There were 15 executive departments listed (such as State and Treasury), plus the Executive Office of the President (i.e. the White House), and 65 Independent Agencies and Government Corporations. Amtrak was listed twice on USA.gov, so there were actually only 64 independent agencies. We also included 10 of the “open government sites” that have been heavily promoted by the White House (usa.gov, usajobs.gov, recovery.gov, data.gov, recreation.gov, disability.gov, regulations.gov, business.gov, usaspending.gov, and ready.gov), 2 Judicial websites (the U.S. Supreme Court, and USCourts.gov), the home pages of the U.S. Senate and House of Representatives, and six agencies that support Congress (Congressional Budget Office, Congressional Research Service, Copyright Office, Government Accountability Office, Government Printing Office, and Library of Congress). Overall, the sample of 100 websites includes 80 executive branch sites, 2 judicial branch sites, 8 legislative branch sites, and 10 open government sites.
The home page for each of the federal agencies was examined using both human evaluation and automated evaluation. Automated evaluations for accessibility are popular in the research literature and with practitioners, but they are not the most effective form of accessibility evaluation. Automated evaluations often require many manual checks, where the presence of a certain type of feature requires that a human inspect it to determine accessibility compliance. In addition, the automated tools can’t determine whether textual labels (for images, forms, and frames) are meaningful, or are meaningless, such as “picture here” or “form3.” Examples of automated inspection tools include software and websites such as Web Accessibility Checker (formerly known as A-Prompt), RAMP, Watchfire (formerly known as WebXact and Bobby), and InFocus. According to the research literature, human evaluations tend to be more effective than automated evaluations (Jaeger, 2006; Mankoff, Fait, Tran, 2005). Specifically, the most effective form of accessibility evaluation is to have usability experts (with vision) use a screen reader (e.g. JAWS) to evaluate a website (Mankoff, Fait, Tran, 2005). Validity is further improved by either having multiple experts performing the evaluation, or by following up with an inspection of the code using accessibility guidelines (Lazar et al., 2010).
For each federal website home page, the page was evaluated by an experienced web developer with previous accessibility experience, using a structured 3-step inspection methodology. The first step was to look at the web pages while listening to the web page using JAWS. The second step was to utilize typical blind user strategies (browsing headers, links lists, and keyword searching) to attempt to find content on the page, especially content that appears visually but was not read by JAWS on the first read-through. The third step was a follow-up human inspection of the code using the Section 508 guidelines.
While this method focuses on the use of screen readers for evaluation, the results do not only address blind users. This evaluation approach focuses on keyboard-only access to Web content, which also impacts people with motor impairments. People with motor impairments often cannot use pointing devices, so keyboard-only access is also the benchmark for this population. Furthermore, because the human inspection of the code checks a web page against compliance with each of the paragraphs A-P of the 508 regulations related to websites, this type of inspection actually checks for compliance for all user populations covered by the regulations. The reality is that the regulations do cover all forms of perceptual and motor impairment, but not cognitive impairment.