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                              Navigating Section 752
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Navigating Section 752:  Insights from Program Managers on Success, Challenges, and Tools for Change








  
  
    

  
      **October 12, 2023**
                |
        By:  Kate    Sweeney, Section 508 Program Director, Office of the Chief Information Officer

  
**Summary:**
  





Section 752 of the Consolidated Appropriations Act of 2023 signals a new chapter in pursuing digital accessibility for federal agencies.


      The level of detail in the Section 508 Assessment questionnaire criteria certainly came as a surprise to many of us.  However, we quickly learned how it would help us understand our program’s maturity and make recommendations to program managers on areas they can improve.  To make it more easily digestible, we grouped the criteria into four areas:

**Culture Change:**  Questions that drive changes in the way work gets done.
	**Leadership:**  Questions that measure the success of our leadership’s accessibility efforts.
	**Empowered Program Managers:**  Questions about the role of agency Section 508 Program Manager and the role’s ability to influence IT accessibility policy and operations.
	**Limited Scope:**  Questions that need input from other groups to answer.We determined an empowered program manager can influence about 45% of the questionnaire.  That means more than 55% of our success and maturity depends on leadership and cross-functional workforce collaboration.  Since we will report on the assessment annually, we will focus on improving the 45% we can control.

As Elvis Presley once said, “When things go wrong, don’t go with them.”  In my experience, things often don’t go as planned.  This means we need a resilient and flexible solution, which can be challenging in the government.  To keep making progress, we first updated our policy.  This gave us the power to make decisions that help ensure access to information, and this would naturally reflect improvements in our performance metrics.  This strong foundation helps us continue to succeed while we work with our leadership to change the workplace culture.

Former Secretary of State and U.S. Army General Colin Powell said, “There are no secrets to success.  It is the result of preparation, hard work, and learning from failure.”  When we ask for things from leadership, we start with our ideal goal and then break it down.  We plan for different levels so if we get a “no,” we have backup plans.  For example, one goal is to require enterprise digital accessibility training. To reach this goal, we have a developed a 3-tier training plan:

**Tier 1 Solution:**  An enterprise policy that makes digital accessibility training mandatory for all employees.

	**Funding Goal:**  Include the training cost in our annual budget.
	**Tier 2 Solution:**  Each component has its own policy requiring digital accessibility training for all employees.
	**Funding Goal:**  Increase the funding for each component.
		**Scalability:**  Award a contract that can scale to support the enterprise.
	**Tier 3 Solution:**  Component-level policy that requires digital accessibility training for a category of staff such as content developers.
	**Funding Goals:**  Reprioritize our current budget to pay for some licenses.
		**Scalability:**  Award a contract that can scale up to the component and enterprise level.To prepare for a “no” from leadership, we collect data for all three tiers during our research.  We figure out what we can afford with our current budget yet aim for the best solution.  We also look for other sources of funding, like interagency agreements (IAAs).  Having different ways to get money lets us be flexible and help other groups that want to make progress.

R. Buckminster Fuller said, “You can’t change the way people think, all you can do is give them a tool, the use of which will change their thinking.”  In this case, the assessment is the tool.  By measuring the quality of our digital products and what goes into making them, we can make data-driven decisions regarding the effectiveness of policy and procedures, workforce training and performance, and product acquisition, development, and operations.

Through metrics, like those in the annual assessments, we can work continuously to improve the quality of the products we buy, build and use, ensuring employees and members of the public with disabilities have access to information comparable to the access available to others.
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