Accessibility Forum 2.0

Jul 19 2012

We are starting a new blog series called, “Department/Agency Section 508 Roles and Responsibilities.” Each post will be discussing different roles and responsibilities with regard to the implementation of Section 508. This is the first blog in the series: Requiring Authority (Program/Project Management and Office/Statement of Work developer)

Who is the Requiring Authority?

• Program/Project Management Office (PMO)
• Statement of Work (SOW) developer

What are the requiring authority’s responsibilities regarding Section 508 implementation?

• Determine the Section 508 applicability by answering the question, “Does Section 508 apply to my solicitation?”
• Identify the accessibility requirements by answering the question, “What Section 508 technical and functional provisions apply to the type of product or service that I want to purchase?”
• Conduct market research to determine the availability of an accessible product or service. This market research should be documented to show Section 508 due diligence.

The BuyAccessible tools may be used to perform all of these functions. Going through the Buy Accessible Wizard process can help determine Section 508 applicability, select relevant Section 508 technical provisions, and document market research. The Accessibility Resource Center (ARC) with links to accessibility information for many IT vendors can also assist with the accessibility portion of market research.

The Requiring Authority (PMO/SOW developer) should coordinate with:

• IT Specialists to identify 508 applicability and accessibility requirements
• IT/Testing Specialists to identify inspection and acceptance criteria for deliverables
• Program Management to determine proposal evaluation factors
• Contracting Officers to ensure that accessibility requirements, inspection and acceptance criteria, and evaluation factors are appropriately represented in the solicitation
• Testing Specialists to develop test plans and conduct delivery inspection, testing and acceptance

Our continuing blog series will discuss roles and responsibilities for:

• Contracting Officer/COTR
• Department/Agency Chief Information Officer (CIO) Office
• Department/Agency IT Developers

Tags: Section 508 Roles and Responsibilities

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Jul 10 2012

GSA’s Section 508 program recently updated their guidance document, Guidance on Conducting Accessibility Market Research

Buyers in federal agencies are required by law and regulation to conduct market research. Market research is a means of ensuring that what we want to purchase is in fact actually available. For ensuring accessibility and compliance with Section 508 when the planned purchase is for an Electronic and Information Technology (EIT) product or service, market research is absolutely essential and needs to be documented in writing.

Conducting market research is easy, if information is available. There are several existing paths to achieve quality market research. One option is to use BuyAccessible.gov, which contains a set of free web-based tools that helps in the acquisition of EIT products and services. This document also provides guidance on using the internet to conduct searches for accessibility information.

Check out our newest guidance document and, as always, please send us your comments here on the Accessibility Forum 2.0 blog.

Tags: guidance document, Market Research

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Jun 19 2012

The last of six public forums to collect suggestions for the Section 508 strategy ended April 2012. This forum (or dialogue) was conducted using the IdeaScale crowdsourcing tool and was sponsored by the White House, the Office of Management and Budget (OMB), Chief Acquisition Officers Council (CAOC), the Chief Information Officers Council (CIOC), and the General Services Administration (GSA). The dialogue bought together a diverse community of stakeholders who contributed thoughtful ideas, comments, and identified challenges. Section 508 of the Rehabilitation Act is designed to ensure the technology used by the government is fully accessible so that people with disabilities, both inside and outside the government, can access and use government information and data. A summary of the dialogs can be found here: section508.ideascale.com/a/pages/dialogue-summary/

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Jun 12 2012

Earlier this year an agency stated, “Responses to this solicitation will only be considered for award after it has been determined that the proposal adequately addresses the requirements for Section 508. Only proposals which contain adequate information to document their responsiveness to the Section 508 requirements (i.e. a completed VPAT-attached on page 30 or equivalent) will be eligible for any additional merit consideration.”

Last month, we found an example of another agency that used language directly from those tools and copied the Acceptance Guide for their deliverable from the BuyAccessible Wizard. They said, “This guide is for use of government buyers and helps them to evaluate acquisition deliverables against applicable provisions as determined by the Wizard, based on generally accepted inspection and/or test methods.”

Tags: evaluation, GSA FedBizOpps Sampling Letters

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Jun 05 2012

Did you know that the BuyAccessible site has tools to help you test products to see how well they meet Section 508 provisions? One approach is to evaluate products for conformance to the applicable section 508 provisions. GSA helped develop a document that can make this process easier.

Years ago GSA facilitated the Accessibility Forum. Over 960 individuals from more than 600 companies, associations for people with disabilities, research and standards institutes, and government agencies from throughout the US and Canada registered interest and contributed in the work of the Forum. One of the documents that came out of the Forum was the Quick Reference Guide, which lists every Section 508 provision, defines terms, explains the provision, and answers, “How can I tell if this provision is met?”

In addition, if you are buying a macro purchase, i.e. IT valued above $3,000, then your BuyAccessible Wizard Guest User session will produce an Acceptance Guide tailored for that product. The Acceptance Guide includes a list of provisions that are relevant as well as the answer to the question, “How can I tell if this requirement is met?” (The Wizard also give you a GPAT to include in your solicitation, as well as an Evaluation Guide that helps you assess responses to the GPAT.)

Example from an Acceptance Guide: Provision 1194.21 (h)

Provision text

When animation is displayed, the information shall be displayable in at least one non-animated presentation mode at the option of the user.

How can I tell if this requirement is met?

Identify the set of occurrences where animation is displayed by the product. Methods for determining the full set of controls that display animation include review of the product interface and the product documentation (e.g. user manuals plus online help).

Inspect the application.

1. Check for option turning on redundant information for animated presentations.
2. Check for a method of turning off animation in the display. If available, inactivate animation. For each animated element verify animation is not displayed and alternate information is provided.

Note: Satisfying this requirement may involve interoperability with assistive technology, such as screen readers. The non-animated presentation mode must be accessible to assistive technology. Moving text and animation is a particular problem for screen magnification AT and other technologies.

Tags: Quick Reference Guide

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May 18 2012

As a celebration of Accessibility Forum 2.0’s two year anniversary, here are our top posts over time.

The winner is: New Guidance Document on Acquisition for Accessible EIT with 3696 total views!

The other top posts in the top ten are:

• Need Section 508 Testing Tools?
• Guidance on Creating Section 508 Compliant IT Solicitations
• Section 508 Resources for Developers and Vendors from SSA
• Common Misconceptions about Section 508
• Common Misconception: Section 508 Certification
• One Size Does Not Fit All
• Is a GPAT the same as a VPAT?
• Accessible CAPTCHA
• Need Help Making Your PDF Accessible?

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May 11 2012

We were recently told by a contracting officer that access to an on-line database was not Electronic and Information Technology (EIT) and therefore not subject to Section 508. This is clearly wrong. The web interface that the government agency would be using as a result of the purchase is applicable to Section 508 1194.22 Web-based internet information and applications (as well as functional performance criteria. When the government makes a purchase and as a result their employees or the general public will be interacting with EIT, then Section 508 applies. Even if the software doesn’t sit on computers at a government site, the website interface applies. Don’t forget that you may need to look at the interface for regular users and also user administration.

A related example is Cloud Computing. Have you come across similar examples that you can share?

We also have more posts in our “Is it EIT?” category. Please let us know your thoughts on this question.

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May 08 2012

As a vendor, what do you do when a Government Product Accessibility Template (GPAT) is included in a solicitation? The GPAT identifies government accessibility requirements applicable Section 508 provisions to that acquisition. Here is what you need to do to respond.

The first section of the GPAT is a summary table of the government’s accessibility requirements. It identifies the total number of applicable provisions, with notes that further explain these requirements. You need to wait to fill out this summary until after you fill out the rest of the GPAT.

Next the GPAT has a table for each section of the standard with 5 columns, as a vendor you fill out columns four and five.

1. Column one is the full text of the provision from the Standard.
2. Column two documents the agency’s accessibility requirement based on common characteristics or special requirements for the EIT deliverable. There will be a Yes or No in this column based on program need and actual characteristics of the expected deliverable (i.e., Is this provision seen as applicable to the expected deliverable?)
3. Column three provides explanatory information about the provision to help both the agency in determining applicability and the vendor in providing accessibility information.
4. Column four is for the vendor to check off whether the deliverable meets, partially meets or does not meet the specific provision.
5. Column five is for the vendor to provide an explanation of how the deliverable meets or does not meet the specific provision. It is also an opportunity to explain why a deliverable does not have an applicable feature or why it has a feature that was not identified as applicable.

In many cases your deliverable will have extra functionality that the government did not anticipate when they prepared their solicitation. For example say you have a video included in a training module, Section 508 requires you to let the government know how well that functionality meets Section 508, even if they marked video/captioning requirements as not applicable.

Returning to the summary aection, you can now indicate how the accessibility features of your product or service meet these requirements (fully, partially or not al all) for each section of the standard. There is room for notes to summarize accessibility features.

You can see some example GPATs in the GSA Quick Links page. If you want to have the competitive advantage of letting the government know about your commitment to accessibility during their market research, then you can create a Voluntary Product Accessibility Template (VPAT). A VPAT lists the Section 508 provisions you think apply and how well you meet them. You can use the Quick Links or Buy Accessible Wizard to generate a good list of requirements.

If any of the Section 508 technical or functional provisions are confusing, you can check out the Quick Reference Guide which goes over each individual sub-part. There is also list of tools on the Section508.gov website.

What if the government only included a general statement about Section 508 in their solicitation, with no specifics like a GPAT? Then it is to your advantage to include the VPAT you prepared before.

Tags: GPAT

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Apr 26 2012

Recently, a new set of Quick Links about ebooks were added to BuyAccessible.gov. Quick Links contain solicitation language and a Government Product Accessibility Template (GPAT) for a specific deliverable, in this case an ebook. There are also Quick Links for ebook readers and ebook software.

The GPAT for ebooks will let you know what Section 508 technical provisions most likely apply to ebooks. For example most of the provisions in Section 1194.22 Web-based intranet and Internet information and applications apply. You can use this information to include in your solicitation requirements when making a purchase, or in your design requirements when creating an ebook.

Tags: ebooks, Quick Links

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Apr 17 2012

Yes. Section 508 applies when Federal agencies “develop, procure, maintain, or use electronic and information technology.” Even if the agency is simply procuring a new version of an existing product, Section 508 applies. Section 508 requirements must be considered in the Brand Name justification and in the “or Equal” decision. It is a best practice to include Section 508 requirements in solicitation documentation for Brand Name or Equal, otherwise how are vendors able to propose products or services that equals the brand name? Since agencies are required to document the justification for other than full and open procurement, it should not add any significant effort to include that Section 508 documentation in your solicitation.

It would also be useful to request a Voluntary Product Accessibility Template (VPAT) from all bidders. Brand Name updates can change accessibility features, so it is always good to get the most current data. Further, accessibility information is needed from Brand Name alternatives to determine if they are in fact equal in terms of their accessibility and usability.

Tags: acquisition, brand name

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