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10 Key Takeaways from the U.S. GAO's Digital Experience: Agency Compliance with Statutory Requirements Report

Agency collaboration is a key component of federal efforts to modernize services, especially when it comes to improving customer experience.


by Brian Chidester, Head of Industry Strategy at Adobe & Host of The Government Huddle Podcast


A recent report by the U.S. Government Accountability Office (GAO), titled Digital Experience: Agency Compliance with Statutory Requirements (GAO-24-106764), presents a detailed evaluation of federal agencies' efforts to modernize their digital services as mandated by the 21st Century Integrated Digital Experience Act (IDEA).


Enacted in December 2018, the act was intended to improve public-facing federal digital services by establishing requirements for website accessibility, security, and user experience.


One of the report’s more concerning findings is that only 70% of the required annual reports were submitted over the five-year period from 2019 to 2023. In 2023 alone, six agencies did not submit their reports, which leaves the public and oversight bodies in the dark about their progress—or lack thereof—in meeting modernization goals.


The level of detail in the reports varied significantly across agencies. Some agencies provided thorough information on their compliance efforts, while others offered only minimal detail. This lack of standardization made it difficult to assess the overall progress of federal digital services modernization. Agencies often cited the absence of clear guidance from the Office of Management and Budget (OMB) as a reason for these discrepancies.


In response to these challenges, OMB issued new guidance in September 2023 to clarify the modernization requirements. The guidance outlined specific actions agencies should take to comply with the IDEA mandates. However, given that this guidance came just three months before the reporting requirements sunsetted in December 2023, its impact on improving agency compliance remains to be seen.



Based on what was reported, here are ten important findings from the report:


  1. Incomplete Compliance with Modernization Requirements: Federal agencies did not fully comply with the eight key modernization requirements under the 21st Century IDEA. In 2023, only seven of the 18 agencies that submitted reports addressed all eight requirements.


  2. Missed Reporting Deadlines: Of the 120 total reports required over five years (2019-2023), only 70% were submitted. Six agencies failed to submit the 2023 reports, leaving their progress unknown.


  3. Inconsistent Reporting Across Agencies: There was significant variation in how agencies reported compliance with the eight requirements. While some provided detailed information, others offered minimal detail or failed to address all areas.


  4. Lack of Guidance Led to Reporting Variability: Agencies cited a lack of clear reporting guidance from the Office of Management and Budget (OMB) as a reason for the inconsistent reporting and missing reports.


  5. 2023 Guidance Issued by OMB: In September 2023, OMB provided updated guidance to clarify the modernization requirements, offering agencies a clearer roadmap for compliance moving forward.


  6. Challenges with Specific Requirements: Agencies struggled most with the "Customizable" requirement. In 2023, only nine out of 18 agencies addressed this, while the "Accessible" requirement was the most frequently addressed.


  7. Technical Resources Were Underutilized: Some agencies used advanced tools like the Digital Analytics Program (DAP), FedRAMP, and US Web Design System (USWDS) to meet compliance, but these resources were not consistently adopted across all agencies.


  8. High-Impact Service Providers (HISPs) Leveraged Collaboration: Select HISPs, including FEMA and TSA, used inter-agency collaboration to meet digital modernization goals, adopting GSA's tools like Login.gov and Touchpoints to enhance customer experience.


  9. Agency-Specific Efforts Showed Mixed Results: Agencies such as the EPA and Department of the Interior demonstrated strong efforts toward meeting the requirements, but others like the Department of Defense (DoD) lagged behind, addressing only three out of eight requirements in 2023.


  10. Future Oversight and Actions: M-23-22 requires agencies to appoint a primary digital experience lead and utilize scanning tools for ongoing compliance. The goal is to improve the government's overall digital experience through continued collaboration between OMB, GSA, and the agencies.


While the GAO’s report recognizes the significant strides some agencies have made, it also highlights the need for more consistent and complete reporting, clearer guidance, and better utilization of available resources.


The introduction of new OMB guidelines provides a framework for agencies to meet the statutory requirements more effectively. However, it will require sustained effort and collaboration across government entities to fully realize the vision of a digitally transformed federal service delivery system.


As federal agencies continue to enhance their digital experiences, the lessons learned from the GAO’s findings will be essential in driving more comprehensive and cohesive progress in the future.



Brian Chidester is the Head of Industry Strategy at Adobe and the host of "The Government Huddle with Brian Chidester" podcast from GovExec. Mr. Chidester holds a B.S. in Communications Studies from Liberty University, is an Advisory Board Member for Digital Government Central, an advisor to the G20 Global Smart Cities Alliance at the World Economic Forum, and a member of the Forbes Technology Council.



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