Our Guide to the Federal CX Mandates
First, a little background info
Since the 1970s, there’s been an awareness of the concept of “customer service” and of the need for our government to attend to how it serves the American public. Yet it wasn’t until the rise of digital technologies, and the self-service and automated capabilities of servicing within the private sector, that the U.S. federal government acknowledged the critical need to recognize and support the role of service design.
Within the past seven years, a set of baseline requirements, starting with the 21st Century IDEA (Act). And while it gave compliance criteria for federal agencies’ service improvements, it didn’t say where should they start. How would or should agencies go about meeting the requirements and achieving improvements?
Three years later, in Executive Order (EO) 14058, this need for the “how” guidance was partially answered. The EO prescribed a ‘first set’ of agency sites, named the High Impact Service Providers (HISPs) – as those sites most in need of and required to comply with, the CX improvements.
Two years later, in 2023, Office of Management and Budget (OMB) M-23-22 honed in on specific digital requirements. Seven starting points were provided for enhancing digital service components. M23-22 also outlined a rubric for agencies to use to reach approachable and achievable goals for accessibility, plain language, search, digitizing forms, and electronic signatures.
Most recently, in January 2025, the Government Service Delivery Improvement Act was passed to orchestrate service improvement efforts across agencies. The Act mandated that executive agencies name a Federal Service Delivery Lead who is accountable for delivering federal service transformations for the agency. The Federal Service Delivery Leads are intended to form a uniform network of officials responsible for oversight of the delivery of service improvements.
What follows is our WebFirst CX team’s guide to the federal CX mandates.
21st Century IDEA
The first – and likely the most familiar – the 21st Century Integrated Digital Experience Act or “IDEA Act” sets fundamental requirements for digital experiences. It establishes the baseline standards that have to be met for any new digital websites, web or mobile applications, or digital service touchpoints.
What are the intended outcomes of the Law?
Standardize the baseline set of requirements for creating, delivering and maintaining digital user experiences.
“Agencies should ensure their websites, including all web applications, digital services, and mobile applications, conform to these requirements and principles.”
2018 Idea Act
Digital services requirements:
- Is accessible (according to Section 508 Rehabilitation Act of 1973)
- Uses consistent branding and visual identification patterns
- Doesn’t duplicate or overlap existing agency websites or web content
- Contains a search function for public use
- Is available via private and secure connections
- Requires iterative user testing and performance testing to ensure user needs are addressed
- Is fully functional on mobile devices
Process requirements – Head of each executive agency is required to:
- Regularly review public-facing applications and services to ensure they are made available – to the greatest extent possible – to the public in digital form
- Coordinate alignment of internal and customer experience programs and strategies
- Coordinate with management leaders of the executive agency to ensure proper funding to support the implementation of this act
- Continuously examine the digital service delivery strategy and submit recommendations for guidance and best practices
- Use qualitative and quantitative data related to customer experience and satisfaction to identify areas of concern/needs for improvement
For the American public, it means we are granted the ability to get to the information we need, on the platform we choose, securely. It means everyone can access the content and the content is organized to be findable. It means the site looks, acts, and performs as expected; and we can easily verify that it’s an authentic U.S. federal website or digital service. It means we shouldn’t find conflicting information on other government sites and should feel confident we are getting the most accurate, up-to-date, and trusted information from the truest source.
21st Century IDEA Deadlines:
Within 180 days:
Director of OMB is required to provide guidance to the head of each executive agency that establishes processes for:
- Identifying public non-digital, paper-based, or in-person government services
- Including in the agency’s budget, request a list of non-digital services with greatest impact that could be made digital along with estimates and schedules for implementation
- Submitting plan to use accelerate the use of electronic signatures standards
- Report annually to the Director (of the OMB) on progress for the prior year
Within 2 years:
- The Head of each executive agency shall make sure any paper-based form that is related to serving the public be made available in digital format
- If it cannot be made digital, the agency head must document the form title, description, responsible parties, blockers, and potential solutions
- Each agency must ensure a paper-based or in-person method of form completion remains available so as not to deprive individuals who lack access to digital services
Federal government requirements:
- U.S. General Services Administration (GSA) shall make available under a Federal Supply Schedule, the systems and services necessary to fulfill act requirements
Executive Order 14058
December 2021
In this EO, the idea of our government being “of the people and by the people” was extended to digital experiences and services. The President asserted that it’s the government’s duty to improve, and be accountable for the quality of, the delivery of its services to its citizens. In possibly the most democratic expression of this idea, the order instructs the federal government to establish direct lines of feedback with American people that enable ongoing support for co-designing federal programs, processes, and services.
What are the intended outcomes of the order?
Establishes a requirement across all agencies, to ensure iterative feedback methods are available on each federal agency website to support agency services are co-designed with end users.
“It is the policy of the United States that, in a Government of the people, by the people, and for the people, improving service delivery and customer experience should be fundamental priorities.”
2021 EO 14058
New U.S. policy requirements for executive agencies to demonstrate measurable improvements to their customer service:
- The government’s performance must be measured empirically by on-the-ground results for the American people
- Agencies should continuously improve their understanding of their customers to identify root causes of CX challenges
- Agencies should have action plans for resolving CX challenges
- Customer experience is defined as the “public’s perceptions of and overall satisfaction with interactions with an agency, product, or service.”
- Definitions are given for “customer,” “equity,” “High Impact Service Provider (HISP),” “human centered design,” and “service delivery.”
- Specific Agency Actions are mandated for HISP’s
For the American public, it means we should be part of the design of modernizing federal services. It means agencies are required to know and validate how Americans user their services and to provide the ability for customers to provide feedback on service quality and satisfaction. The order requires federal agencies to work together to tackle integrated services, specifically gearing services to be more efficient and less burdensome to use.
EO 14058 Deadlines:
Within 90 days:
A limited number of customer life experiences are to be prioritized for government-wide customer experience improvements.
- Appropriate leadership structures will be organized to assess the designated customer life experiences
- Specific improvement outcomes, action plans, and measurement tools will be defined as a system to measure progress against goals
- A report is presented to the Assistant to the President and Chief of Staff on the status of the action plans
- The Administrator of the Office of Information and Regulatory Affairs is require to provide guidance on specific steps to reduce information collection burdens on customers, including increased flexibility under the Paperwork Reduction Act (PRA)
Within 180 days:
- All participant agencies supporting a life experience shall coordinate their respective efforts to improve data sharing and support processes both inter-agency and with state and local governments
- The GSA is required to submit a roadmap for the development of prioritized common services to the Director of OMB including assessment of improvements needed in CX management and service design capabilities (within each agency’s available budgeted resources)
- Director of OMB establishes and maintains a list of designated HISPs
- Deputy Director for Management of OMB is required to issue guidance for all HISPs that outlines annual process for assessing their capacity to manage CX, and their performance of service delivery according to public perspectives
- The Director of OMB is required to establish a team within OMB to lead and support agency CX initiatives as well as inter-agency initiatives and facilitate decision-making processes
- A report is presented to the Assistant to the President and Chief of Staff on the status of the action plans
OMB M-23-22 Delivering a Digital-First Public Experience
The first federal CX guidance specifically for Digital CX – for improving digital servicing touchpoints including federal websites, web applications, digital services, and mobile applications.
What are the intended outcomes of the Order?
Provide practical design, development, and delivery requirements for the production and delivery of all federal digital servicing touchpoints.
“This memorandum applies to all executive agencies. …Agencies should ensure their websites, including web applications, digital services, and mobile applications, conform to the(se) requirements and principals.”
2023 OMB M23-22
Digital experience (DX) requirements:
- Must be accessible
- Uses consistent visual design and agency brand identify
- Content must meet plain language requirements ensuring it’s easy to understand
- Content must be authoritative (single source of truth)
- Information must be discoverable and optimized for search
- Must be secure by design
- Must respond to user-driven requirements as shown by user data and research; and demonstrate user-centered design principles
- Must offer customized and dynamic user experiences
- Must be designed and optimized for mobile first
Specific requirements for digitizing forms and services:
- All forms must be made available to the public in a digital format
- Services should be provided to the public digitally and to accommodate self-servicing
- Forms can no longer require a handwritten “wet” signature or in-person proof of identification without also providing an equivalent digital method
For the American public, it means every government-provided service should be accessible via a digital servicing option that enables customer self-servicing. All government websites will use a common method to identify their authenticity, and each executive agency’s website design should consistently use established visual design patterns to build recognition, credibility, and trust in the information it provides. Every American should be able to securely access and understand content presented on federal websites or digital applications (mobile, internal, or public facing).
OMB M-23-22 Deadlines:
By March 20, 2024:
- Any new or redesigned website, service, or form is expected to meet included DX requirements
By September, 2024:
- Executive agencies were to complete a series of immediate actions, including defining a list of DX compliance violations, prioritization of remediation, or digitization efforts based on the memo’s guidance
Government Service Delivery Improvement Act
This act establishes a chain of accountability for implementing federal CX policies for improving services to Americans.
What are the intended outcomes of the Order?
To name responsible parties for delivery of improved services to the American people.
“The head of each agency shall be responsible for the Government service delivery of the agency.”
“Stakeholders (will) ensure that the websites of agencies, including those associated with high impact service providers, are consistent with the objectives of this subchapter, the 21st Century Integrated Digital Experience Act, and any other applicable law.”
2024 Government Service Delivery Improvement Act
Federal Government Service Delivery Leads must:
- Orchestrate government-wide efforts to improve agencies’ service delivery
- Develop and oversee delivery standards
For the American public, it means there are designated individuals given the responsibility and accountability for improving services across each executive agency and sub-agency. It means there’s a network of accountable leaders that should have significant authority to collaborate and govern CX improvement strategies and implementation.
Government Service Delivery Act Deadlines:
Within 1 year:
- The head of each agency must designate or appoint a senior official to implement CX improvement delivery plans
- Agency reports on service improvement plans and metrics on success or impediments are to be delivered to the Committee on Oversight and Accountability of the House of Representatives and the Committee on Homeland Security and Governmental Affairs of the Senate
Putting federal CX mandates into practice
The WebFirst CX team is well-versed in the above set of guidance and our team of research, content, and design professionals is accomplished in the areas of CX capability-building, CX operations, CX metrics, and digital service design and implementation. Find out more about the services we offer for enabling the service design processes and ultimate outcomes the American people deserve.