Meeting the Federal Government Reporting Requirements of Section 752

Federal government agencies are facing a fast-approaching digital accessibility compliance deadline. That’s because of Section 752 of the Consolidated Appropriations Act of 2023 (HR 2617): a recent law aimed at driving increased accountability for, and transparency around, compliance with Section 508 of the Rehabilitation Act of 1973. To accomplish this, Section 752 establishes a timeline for agencies to begin reporting on the accessibility of their information and communications technology (ICT) for people of all abilities.

On April 7, the General Services Administration (GSA) released its requirements for reporting on ICT accessibility in the form of a 105-item questionnaire. The GSA also established August 11, 2023, as the official deadline for agencies to submit their responses.

Have a hundred questions of your own? You’re in the right place. In this post, we’ll explain Section 752, dissect the Section 752 requirements for reporting, and provide guidance for meeting these requirements quickly.

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What is Section 752?

Section 752 is part of the Consolidated Appropriations Act of 2023, which was passed by the U.S. Congress and signed by President Joe Biden in December 2022. Section 752 of that bill mandates that all U.S. federal government agencies begin reporting on the accessibility of their ICT within 250 days of the law’s enactment. To establish a reporting framework, Section 752 calls on the U.S. Access Board, GSA, and Office of Management and Budget (OMB) to release specific criteria within 100 days. The latter obligation was met on April 7.

Importantly, Section 752 does not introduce new ICT accessibility standards for federal government agencies. Instead, it establishes a process to hold agencies accountable for compliance with Section 508 requirements that were signed into law on August 7, 1998. These requirements state that federal agencies must create, buy, and use ICT that is accessible to people with disabilities.

Need a primer on Section 508? Check out our Complete Guide to Section 508 Compliance.

Why is Section 752 significant?

Historically, Section 508 has not been consistently enforced, but this is quickly changing. In February 2023, the Department of Justice released its first report on Section 508 compliance in more than a decade, disclosing that only 38 percent of agencies abided by the law. In the context of this news, Section 752 is part of a concerted effort by lawmakers to close the gap between legal accessibility requirements and the current reality of many agencies’ practices.

For federal organizations, complying with Section 752 requirements is not optional. Individual agencies’ responses to the GSA’s questionnaire will be available to the public—so agencies that fail to meet Section 508 requirements and are not actively working towards this goal are likely to face reputational damage as well as legal consequences. Over time, the U.S. Access Board aims to closely monitor this public data, aiding agencies that are struggling and questioning those that state they’re furthest along.

What are the Section 752 requirements for reporting?

The 105 questions recently released by the GSA broadly fall into two categories: organizational processes and conformance metrics. Here’s a quick run-down of some of the topics covered in each category.

Organizational processes

In the first 61 questions of the Section 752 questionnaire, agencies must provide qualitative information about their infrastructure and practices surrounding ICT accessibility. They should be prepared to comment on:

• How they leverage different types of accessibility testing: automated testing, manual testing, and testing by people with disabilities
• How they track, remediate, and prioritize accessibility issues
• The impact of ICT accessibility issues on hiring and retaining employees with disabilities (such as whether full-time employees or interns have been unable to begin or continue work due to accessibility barriers)
• Processes surrounding governance, accountability, procurement, and feedback
• The guidance, templates, and tools for improving accessibility that are available to employees
• The accessibility knowledge and skills of individuals involved in the technical development life cycle, and the integration of accessibility into employees’ professional development plans

Conformance metrics

Questions 62 to 105 of the Section 752 questionnaire are quantitative. They require that agencies report concrete metrics indicating their degree of conformance with Section 508 standards.

To complete this portion of the questionnaire, organizations must use both automated and manual accessibility testing to evaluate their 10 most-visited digital properties in each of the following categories:

• Public web pages
• Intranet pages
• Electronic documents
• Videos

Additionally, agencies must indicate whether a range of other digital systems and assets—including email applications, video conferencing platforms, tax documents, kiosks, custom desktop software, native mobile apps, and even the most widely distributed multifunction printers—meet Section 508’s accessibility requirements.

Get your roadmap to Section 508 compliance.

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How to get started on the Section 752 questionnaire

You may not have enough information to properly answer all 105 questions in the GSA’s questionnaire right away. But you can put together a plan for collecting the data and insight you need. Here are a few steps that your agency can take today to build a framework for approaching Section 752 reporting requirements.

1. 1. Identify individuals with direct knowledge of your agency’s ICT, and any related accessibility practices.
   2. Interview these individuals to gather relevant information about how your agency uses different types of ICT and manages their accessibility. Brief them on Section 752 and Section 508 so they have sufficient context to answer your questions. When possible, ask for anecdotes: stories from just one or two employees may be enough to complete some questionnaire items if you don’t have robust statistics.
   3. Based on these interviews, determine the scope and applicability of each item in the questionnaire to your organization.
   4. Identify and source any additional tooling (such as automated testing solutions) and support (such as help with manual testing and prioritization) your team will need to collect information that’s not available through your existing internal resources.

We’re here to help

As the market-leading digital accessibility solution provider, Level Access has decades of experience helping organizations achieve compliance with Section 508 and other digital accessibility laws. And we’ve developed a process for our federal government customers to complete the Section 752 questionnaire efficiently.

Our suite of solutions encompasses automated and manual accessibility testing—including testing performed by people with disabilities—along with monitoring and governance tools, and strategic consulting to support with procurement and accountability. We also provide role-specific accessibility training to help teams build internal expertise.

What’s more? We hold a contract with the GSA and offer a product that has been cleared for security by the federal government’s FedRAMP authorization program, streamlining the procurement process for federal agencies.

Ready to get on track to meet the Section 752 reporting deadline? Engage with our team today.

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