By Digital Accessibility Specialist Angelina Smith and Digital Accessibility Manager Amy Cole.

It's been over a year since the Office of Management and Budget (OMB) released memorandum M-23-22, a landmark policy urging federal agencies to create top-tier, digital-first experiences for the public. The memo’s demographic data highlights an increasing need for online accessibility, underscoring the importance of our work at Bixal. Our accessibility team is dedicated to lowering barriers to federal resources, and the OMB guidelines have been instrumental in shaping our client recommendations.

However, while the memo provides valuable guidance, it comes with a challenge—it's an unfunded mandate.

So, how can understaffed or underfunded agencies meet the accessibility requirements outlined in the memo? Not every team has dedicated accessibility or 508 support. At Bixal, we've used the OMB memo to help us prioritize and tailor our consultations to fit each client's needs.

We've created a checklist based on the guidance in OMB M-23-22 to help teams focus their efforts on their accessibility journey.

We know time and resources are limited, so we've structured the list to start with the lowest effort and biggest gains. The list is also structured to reflect the least amount of technical expertise to the highest. 

Remember, not all accessibility improvements require technology. At its core, accessibility is about people helping people. Let’s begin there!

Step 1: Provide a public feedback mechanism

Ensure the public has a way to contact someone with an accessibility concern about your website. (See Vote.gov for an example.) Section508.gov offers clear guidance on what to include.

☐ Designate a contact person(s) who will address accessibility concerns in a timely manner.
☐ Ensure there is a custom 508 or accessibility email link or form.
☐ Date the statement so the public knows how often the page updates.

Who might this involve? Legal and/or human resources; some tech input.
 

Step 2: Design accessible experiences

Discover more about your visitors. As your audience members age, they may acquire disabilities they didn’t have before. Your understanding of their needs will help you meet them where they are.

☐ Include people with disabilities in your user personas.
☐ Gather data on how people access your site and know that a minimum of 15–25% are disabled.

Who might this involve? Usability research team, content team, and/or search engine optimization (SEO) analysts.
 

Step 3: Expand your usability research to include people with disabilities

We realize not every team has a usability researcher, just like many don’t have a 508 specialist. However, you can still take stock of your current site and find out what is causing the most friction. Do you get the same questions frequently? Barriers that obstruct a non-disabled person from accessing resources are going to be even more problematic for people with disabilities.

☐ Identify your agency’s “top tasks.” What do people come to your site for?
☐ Use your feedback mechanism (see Step 1) to gain insight into what people are telling you needs to be fixed.
☐ Review the Digital.gov User Experience resource page.

Who might this involve? User experience research (UXR) team and/or legal.

Great user experience research resources:

• 18F User Experience Guide
• Research at VA guides and templates

Step 4: Evaluate your CMS platform for compliance

Many teams use a content management system (CMS) to quickly update their website. But did you know the CMS must also be accessible? And even with an accessible CMS and accessible site code, your site editors can inadvertently create 508 violations by adding content incorrectly. Before more inaccessible content is added, it’s best to provide training then move on to the next step.

☐ Check to ensure that your CMS procurement follows federal procurement laws.
☐ Do your content editors know how to create accessible content? If you’re unsure, survey their knowledge or add this topic to an upcoming meeting.
☐  Share resources such as Accessibility for Content Designers from Digital.gov.

Who might this involve? Procurement, content, and those with authoring permissions.
 

Step 5: Get a baseline to establish where your site is starting with accessibility

Begin by having a clear picture of where your site does or doesn’t comply with Section 508. This step does include some technical know-how.

☐ Identify your top ten visited pages or your top ten downloads (if you have any) and conduct a quick audit. Run that content through automated tools to get a composite score.
☐ Identify issues and categorize them. Some issues can be fixed by content editors, but others may need to be fixed by a developer or a designer.

Who might this involve? Content, design, developers, quality assurance (QA), and/or SEO analysts.

Free tool options include page-by-page checkers. We recommend ANDI, WAVE, or Lighthouse.
 

Step 6: Conduct a manual accessibility audit

If your project is using the US Web Design System (USWDS), that’s a great start, since it’s mentioned in the OMB memo, but ensure you are performing manual accessibility audits of your site. This step needs some level of Web Content Accessibility Guidelines (WCAG) understanding, but not all accessibility testing requires a developer.

☐ See USWDS component checklists for proper usage guidance and tips on how to conduct manual audits with little to no technical experience needed.

Who might this involve? Designer, developer, content owner, QA team.
 

Concluding Thoughts

Accessibility doesn’t have to be costly or time consuming. Non-technical improvements, such as adding a feedback mechanism (Step 1) for disability requests, can provide insight into your audiences’ needs and will signal to them that you are aware of areas that need improvement.

If you have a clear picture of who your audience is (Step 2) and include them in your research (Step 3), you are on the right path!

More technical steps, such as ensuring your team can add accessible content (Step 4), getting a handle on where you are now (Step 5), and testing what you’ve got live (Step 6), will help inform your broader plan.

Achieving a 100% fully accessible site is rare (or doesn’t exist in most cases!). Strive for improvement, not perfection. Use OMB M-23-22 as a guide and reach out to our accessibility team at Bixal if you want a consultation to learn more.

Click on this link to access a printable version of this Essential 6-Step Checklist.