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National Dialogue on Improving Management of the Section 508 Program - Summary

March 19, 2012 through April 16, 2012

Introduction

The National Dialogue on Improving Management of the Section 508 Program (the Dialogue) within the Executive Branch of the Federal Government was an online crowdsourcing activity sponsored by the Chief Acquisition Officers Council, the Chief Information Officers Council, and the General Services Administration. The Dialogue was open from March 19, 2012 through April 16, 2012 and provided the opportunity for any interested citizen to share ideas and comments from any web-enabled location.

The ideas generated during this Dialogue, along with input from listening sessions, will help inform the policies, standards and practices to be included in the strategic plan and/or other initiatives designed to improve management of the Section 508 program. This document summarizes the key concepts, themes, and ideas that emerged throughout the Dialogue. As these are still being analyzed for consideration for inclusion in the Section 508 strategic plan, the document does not contain comments, recommendations, or final disposition of the ideas or concepts presented in the Dialogue. It is intended to share the results of the Dialogue and the anticipated next steps.

The Dialogue successfully brought together geographically-dispersed stakeholders and interested parties from both the public and private sectors. Over 200 registered users contributed 98 ideas, posted 353 comments, and submitted 1,139 votes. The Dialogue asked participants to contribute ideas and comments in the following five areas:

1. Ensuring a focus on the relevant issues (table of contents)

2. Determining appropriate definitions and clarifications for the roles and responsibilities of key individuals (roles and responsibilities)

3. Offering suggestions on ways to improve management of Section 508 in the areas of:
    a. Increased transparency (including product accessibility information)
    b. Strengthened accountability
    c. Improved collaboration or capability

4. Sharing experiences in:
    a. Implementing Section 508 or similar accessibility policies
    b. Accessing, navigating, and using Federal websites
    c. Implementing 508 requirements as a developer

5. Action Plan

Overall, 98 ideas were submitted with the following distribution: strengthen accountability (22); improve capabilities (21); product accessibility (18); roles and responsibilities (16); action plan (11); increase transparency (7); share your experience (2); and table of contents (1).

Themes

Themes emerged within the ideas and comments and are summarized below. Some of the themes “fit” into a specific campaign or several span campaigns, while others may not align with the planned discussion. In some instances, selected ideas or comments are representative of the overall discussion and are included in the summary. The themes are presented in the order that generated the most conversation (e.g., ideas, comments, or votes), with unique themes presented last. Ideas submitted during the first week received the most votes and comments, which may be attributed to a decrease in site traffic during the second and third week after launch. Some ideas and comments pertain to multiple themes. The themes described in this report represent a summary of the content, and capture key ideas.

Theme 1. Consistent interpretation and implementation of Section 508 requirements

The discussion on this theme focused on the need to maintain consistency across Federal agencies in implementation and interpretation of Section 508. Comments indicated that individuals with disabilities should have a similar experience when accessing information, attempting to report problems, or seeking assistance from Federal agencies. Comments also indicated that this level of consistency across the Federal government would require focus across the agency, to include commitment from leadership and awareness of Section 508 throughout the entire workforce. This theme generated the most discussion, with one participant stating, “While we all have the same guidelines we've had since 2001, there are subtle differences in how agencies and even branches interpret things”. Participants contributed ideas and suggestions on how the government could achieve uniform implementation of Section 508. The discussion included ideas on what aspects of Section 508 should be required to be consistent across agencies and what aspects should remain flexible. Over 20 separate ideas and almost 80 comments expressed the consensus that some consistency in the interpretation and implementation of Section 508 is needed across agencies.

Theme 2. Hold agencies accountable for compliance to Section 508

This was one of the first themes to emerge and received the most votes. The idea that executive support is needed for 508 to succeed is representative of the theme. Participants offered many suggestions on agency accountability, including creating measurable objectives, establishing benchmarks, measuring progress at regular intervals, and making results publicly available. One participant noted “the cheapest form of enforcement is public information”.

Theme 3. Common procedure for testing electronic and information technology (EIT) for compliance and process for sharing results

This theme appeared in separate ideas and generated multiple comments. Participants suggested that there is no common method or protocol for testing Section 508 compliance. Comments indicated agencies have varying degrees of maturity and resources for testing. Participants suggested sharing best practices for testing EIT and sharing results of such testing for commonly used tools. Suggestions were also made to include individuals with disabilities as a best practice in EIT testing. The idea to encourage usability testing with people with disabilities received 29 votes. The suggestion regarding sharing test results merged into another discussion regarding shared services (Theme 9).

Theme 4. Centralized authoritative source for interpreting Section 508 standards

Participants discussed the importance of making technical and functional Section 508 requirements understandable to all, especially those without expertise in Section 508. The Dialogue generated a great deal of discussion around an authoritative source to clarify or interpret guidance. Suggestions involved developing lists of products or categories of products that would include requirements language. For example, one participant suggested doing a “Rolling Refresh” – updating standards every two years, or as necessary, based on changes in technology. The goal is to align standards more closely with changes in technologies.

Theme 5. Interactive central repository for collaborating and sharing information

Participants suggested enhancing www.section508.gov to become the central point of information for Section 508. Participants identified opportunities for sharing and collaboration.

Theme 6. Usability and accessibility should be considered throughout EIT lifecycle

Many users commented on the need to consider accessibility early in the EIT lifecycle – specifically, when gathering requirements. Comments indicated the Federal government could avoid the costs of retro-fitting EIT after procurement if accessibility was considered early on. This idea reflects conversations on the theme: Eliminate waste of Federal resources used to retrofit ICT (information and communication technology). The comments included the need to focus attention on Section 508 throughout the full lifecycle of EIT rather than just the procurement process with one participant noting: “Section 508 is often viewed as a procurement requirement for vendors, ignoring the fact that it also governs development, maintenance and use of EIT.” This idea reflects conversations surrounding legacy EIT: Establish deadline for 508 compliance for old systems.

Theme 7. Structured and enforced review of Section 508 requirements and language in contracts

Several community participants suggested more emphasis on the procurement process, with increased monitoring of agency compliance to the Section 508 related procurement requirements in the FAR. Comments also suggested sharing results of any analysis and lessons learned and best practices regarding procurement and Section 508. Two ideas that express this theme are: Start compliance at the Procurement Stage and Metrics exist for Agency procurement compliance.

Theme 8. Promote a resource tool for buyers and sellers

Participants suggested a one-stop, user-friendly location to assist agency employees in developing the appropriate technical and functional language for deliverables, evaluating compliance, connecting with other Federal employees with similar requirements, and conducting market research. While the BuyAccessible.gov wizard serves all of these purposes, one participant remarked the tool is not widely used, and another commented on user friendliness. Participants recommended a community approach to making the site more intuitive.

Theme 9. Shared services and “pools of expertise”

Comments indicated that the creation of a network of experts in Section 508 and a repository of information would be useful to develop and grow a collective knowledge base. The idea captures the discussion on this these: Need for an agency to sponsor a Community of Practice.

Theme 10. Collaborate on emerging technologies

Community participants suggested creating a web space which can be used for discussing new technologies, engaging in research and development, and assessing the impact that emerging technologies may have on assistive technologies.

Theme 11. Section 508 training for Federal employees

Comments included suggestions to develop basic and role-specific training for Federal employees on Section 508. One of the 11 ideas that expressed a part of this theme: Starts with Training.

Theme 12. Professional requirements for Section 508 coordinator

Participants provided comments on how to improve the visibility of the Section 508 program in an agency and how to ensure that Section 508 is considered in agency operations and decisions as related to EIT. This idea echoes this theme: Fed Gov should promote skilled accessibility professionals.

Other Unique Ideas

Additional ideas included an accessibility statement on agency web homepages and the creation of meaningful metrics that can be used across agencies.

Method

This Dialogue was modeled on previous efforts such as the National Dialogue on Improving Federal Websites and employed similar tools, processes, and design as those efforts. The Dialogue monitors were chosen from among volunteers from the CIO Council Accessibility Committee. All monitors were available to assist users, answer questions, provide guidance, respond to emails, and provide training as needed. Processes were in place to ensure safety for community participants and respect for every participant’s ideas and comments. The website was monitored a minimum of 20 hours per day, every day until the site was closed. Monitors were encouraged to participate in the conversation.

Topic Areas

The topic areas in the strategy were derived from input received during the listening sessions and stakeholder meetings that were held throughout FY 2011.

Incentives for Participation

One key aspect of ensuring participation in online dialogues is providing potential participants with a clear explanation of what they could expect to gain for time spent submitting or rating ideas. In this case, participants had the opportunity to consider perspectives that they might not otherwise encounter and the opportunity to share ideas that could be considered in plans, guidance, or policies. Over 200 registered participants submitted ideas, voted, and commented during this Dialogue.

Conducting Outreach for Participation

The outreach for this Dialogue included sharing information via blogs, new social media, email, working groups, Council listserves, personal interactions, and websites. The campaign was featured on two Federal government websites: www.disability.gov and www.section508.gov. Social media tools such as Twitter and Facebook were used, with 102 “likes” on Facebook and 69 tweets.

Conducting the Analysis

After the Dialogue closed on April 16, 2012, the team of monitors began analyzing the ideas. The Dialogue platform allowed the team to cross-reference ideas and comments submitted by participants in responding to the campaign topics. The platform also provided the option to sort ideas and conversations by those with the highest ratings and the most comments, as well as to search for central themes throughout the conversations.

Participants had the option of “tagging” specific ideas with key words and/or phases in order to understand the interrelation between each of the ideas. Each of these capabilities helped the project team make informed decisions about the key “themes”. The key themes were compiled by performing extensive qualitative analysis of each of the ideas and comments, packaging similar ideas and comments together to tell a common story, as represented in this report.

The team also collected and analyzed metrics on engagement and participation throughout the Dialogue, using both the built-in analytics provided by the platform and other tools.

Measuring Engagement

Over the 29 days the Dialogue was active:
• The site received 3,985 visits, not including web crawlers. Of that number, 2,637 were unique visitors;
• 34% of the visitors returned to the site on average 4 times;
• Visitors viewed 15,349 pages. The average visitor viewed 4 pages during an average stay of 5:32 minutes;
• The majority of visitors accessed the site using desktop browsers, while 9% used a mobile browser;
• During the first week, half of the visitors (53%) came via a link, while 2% found the Dialogue via a search engine.

Visits to the site peaked the day after launch (March 20th) with a sharp decline by Friday of the first week. There was another uptick on Monday and Tuesday, March 26th and 27th when the second online news story featured the URL. Following that uptick, there was a gradual decline in the number of visits during the remaining two weeks.

Best Practices

Several best practices were used during the conduct of this Dialogue:

• Subject matter experts were instrumental in generating awareness of the Dialogue, stimulating discussions through clear and thoughtful questions, and identifying pros and cons to the various issues proposed.

• Analysis of use statistics for the Dialogue were instrumental in identifying traffic patterns (e.g., useful in identifying areas needing clarification) as well as developments that could adversely impact the Dialogue.

• Announcements on blogs, through the use of social media, emails to listserv members, and articles in online news sources, generated initial interest and advertised the internet address.

• Dialogue monitors were available to provide information and assistance as needed. If users experienced any problems with the site, community participants had the ability to contact the site administrator for assistance and resolutions. In order to provide assistance pre-logon, a “need help” link to a shared email box was prominently displayed and any visitor had the ability to contact a monitor without having to first create an account or log into the application.

Lessons Learned

The most important lessons learned from the Dialogue included the following:

• Traditional methods for testing Section 508 compliance, including testing with key user groups, may not be adequate for all usability issues. A key lesson learned from the feedback of community users was the importance of having monitors available to assist with any emerging issues.

• The majority of community participants were individuals already familiar with Section 508 in the Federal government. Additional outreach to a wider audience, to include innovative technology companies, academia, etc., may have produced a richer discussion.

• Ideas related to the full range of topics, however, breaking the strategy into more focused dialogues for shorter lengths of time (i.e., roles and responsibilities for one week; action plan for one week) may have better targeted conversation to facilitate feedback in all areas.

• Best practice with social media tools is a frequent (at least twice a week) refresh of the main webpage, with statistics, directed questions, challenges to the community, guest appearances, etc. These activities tend to generate interest, attract new visitors, encourage return visits, help to form the community and can improve the level and quality of discourse. Without this level of outreach the site had trouble attracting new visitors and encouraging return visits over the four weeks’ open period.

Next Steps

Input from this Dialogue is being analyzed and considered for inclusion in the effort to continue improving management of Section 508 in the Federal government. Continuous improvement requires ongoing feedback. If you have additional ideas or thoughts on how to improve Section 508 management in agencies, please share them with the agency Section 508 contact, GSA, or the CIOC Accessibility Committee members.