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When the topic of Section 508 comes up, most people immediately think of people with visual disabilities using web sites. But there's so much more to it! Section 508 addresses accessibility issues for people with visual, auditory, speech and mobility disabilities, and the requisite assistive hardware, software, and other Electronic and Information Technology (EIT) they need. (Learn more about EIT in the sidebar below.)Section 508 generally requires that when Federal agencies develop, procure, maintain, or use EIT, they ensure they take into account the needs of all end users, including people with disabilities, unless an undue burden would be imposed on the agency. The intent is to ensure that Federal employees with disabilities have access to and use of information and data that is comparable to the access and use by Federal employees who are not individuals with disabilities. And that disabled members of the general public seeking information or services from a Federal agency have access to and use of information and data that is comparable to that provided to the public who are not individuals with disabilities.
If you are tasked with initiating an action to develop, maintain, procure or use EIT products or services, you're probably wondering how the requirements for accessibility affect you. Whether you are a Requiring Official, IT Manager, Procurement Manager, Contracting Officer, Project Manager, or Acquisition personnel, you'll need to know how the Section 508 standards and the changes in the Federal Acquisition Regulation (FAR) impact how you develop requirements for EIT procurements.The most significant impact is on your development of Section 508 compliant procurement requirements for your agency or department.Here are the steps which the FAR requires of Federal EIT purchases:
Determine whether the buy falls under EIT (see sidebar).
Identify which standards apply to the procurement, using the Access Board's EIT Accessibility Standards at 36 CFR 1194.4 and in the FAR at 2.101.
Determine whether an exception (other than undue burden) applies. Agencies are allowed to procure EIT that is not fully-conformant to the Access Board's standard if they can claim that the procurement:
Conduct market research at the earliest stages in the acquisition process. As it relates to Section 508, market research is the mechanism for determining the availability of compliant EIT products and comparing products that meet the government's requirements for accessibility.
The definition of market research is: A process used to collect, organize, maintain, analyze, and present data for the purpose of maximizing the capabilities, technology and competitive force of the marketplace to meet an organization's needs for supplies or services.
Market research information will differ depending on whether the research is being conducted to develop a requirements document, support preparation of a solicitation, or both. Market research early in the acquisition cycle is intended to ensure that, if commercial items are available to satisfy the government requirement, then those commercial items will be acquired — rather than a government-unique item.
The extent to which you should conduct your market research will vary depending on such factors as urgency, estimated dollar value, complexity, and past experience.
Part 10 of the FAR provides a detailed description of information to obtain on products and techniques for doing so.
Determine if commercial items or nondevelopmental items (NDI, which are previously developed products, so no cost is incurred to develop new technology) are available to meet the Government's needs.
Market research will also aid you in developing your requirements documents because it enables you to identify those terms and conditions that are appropriate for acquisition and consistent with customary commercial practices.
A good place to start researching product information is at vendor websites and at www.Section508.gov.
The GSA's Buy Accessible database is another resource for completing market research. You can search for a specific product or service type and obtain a list of links to vendors that provide products or services that address Section 508 standards. You should note, however, that all information provided and obtained via Buy Accessible is based upon vendor self-representations. Buy Accessible does not warrant or verify the accuracy of the information.
Document nonavailability and undue burden determination. Agencies do not have to acquire EIT that meets the applicable technical provisions if doing so would impose an undue burden on the agency. In the context of Section 508, undue burden means that an acquisition imposes a significant difficulty or expense, taking into account all agency resources available to the program or component for which the EIT is being procured (36 CFR 1194.4 and FAR 39.202, 39.204(e)). An undue burden determination must be applied on a case-by-case basis. If an agency invokes the undue burden exception, it must document in writing the basis for the decision and provide documentation for inclusion in the contract file.
EIT vendors play a critical role in the implementation of Section 508. Using the purchasing power of the Federal government as an incentive, it is the EIT vendors that incorporate accessibility features in their product and service offerings that will achieve the competitive advantage in this emerging market place. GSA's Center for IT Accommodation (CITA) assists the vendor community through several programs, including one known as the Buy Accessible database. This database offers a common format for vendors to describe the accessibility features of their products. The Information Technology Industry Council (ITI) is hosting a Voluntary Product Accessibility Template (VPAT) on their site which allows vendors, who choose to participate, the ability to copy the template and complete it to describe how a particular EIT product or service they offer addresses each of the relevant accessibility standards of the Section 508 Access Board standards. The completed VPAT should be placed on the vendor's accessible web site, and the link to the template provided to the Buy Accessible database. Federal procurement and requiring officials use the Buy Accessible database to search by specific product or service type and see all vendors who have provided links. They can then use the links to reach the template information and product or service descriptions necessary to conduct market research and support their requirements development and procurement selection processes.ITI's Best Practices for Electronic & Information Technology Vendors provides businesses with basic guidelines for filling out the VPAT and promotes consistency in the methods used to complete it.
The term electronic and information technology (EIT) includes, but is not limited to, computer hardware, software, peripherals, networks, video productions, telephones, information kiosks and transaction machines, World Wide Web sites, multimedia, and office equipment, such as copiers and fax machines (and many other electronic and communications devices), and any other equipment or interconnected system or subsystem of equipment, that is used in the creation, conversion, or duplication of data or information. The term does not include any equipment that contains embedded information technology that is used as an integral part of the product, but the principal function of which is not the acquisition, storage, manipulation, management, movement, control, display, switching, interchange, transmission, or reception of data or information. For example, HVAC (heating, ventilation, and air conditioning) equipment such as thermostats or temperature control devices, and medical equipment where information technology is integral to its operation, are not information technology.
Most of the specifications for software pertain to usability for people with vision impairments. For example, one provision requires alternative keyboard navigation, which is essential for people with vision impairments who cannot rely on pointing devices, such as a mouse. Other provisions address animated displays, color and contrast settings, flash rate, and electronic forms, among others.
The criteria for web-based technology and information are based on access guidelines developed by the Web Accessibility Initiative of the World Wide Web Consortium. Many of these provisions ensure access for people with vision impairments who rely on various assistive products to access computer-based information, such as screen readers, which translate what's on a computer screen into automated audible output, and refreshable Braille displays. Certain conventions, such as verbal tags or identification of graphics and format devices, like frames, are necessary so that these devices can "read" them for the user in a sensible way. The standards do not prohibit the use of web site graphics or animation. Instead, the standards aim to ensure that such information is also available in an accessible format. Generally, this means use of text labels or descriptors for graphics and certain format elements. (HTML code already provides an "Alt Text" tag for graphics which can serve as a verbal descriptor for graphics). This section also addresses the usability of multimedia presentations, image maps, style sheets, scripting languages, applets and plug-ins, and electronic forms. The standards apply to Federal web sites but not to private sector web sites (unless a site is provided under contract to a Federal agency, in which case only that web site or portion covered by the contract would have to comply). Accessible sites offer significant advantages that go beyond access. For example, those with "text-only" options provide a faster downloading alternative and can facilitate transmission of web-based data to cell phones and personal digital assistants.
The criteria of this section are designed primarily to ensure access to people who are deaf or hard of hearing. This includes compatibility with hearing aids, cochlear implants, assistive listening devices, and TTYs. TTYs are devices that enable people with hearing or speech impairments to communicate over the telephone; they typically include an acoustic coupler for the telephone handset, a simplified keyboard, and a visible message display. One requirement calls for a standard non-acoustic TTY connection point for telecommunication products that allow voice communication but that do provide TTY functionality. Other specifications address adjustable volume controls for output, product interface with hearing technologies, and the usability of keys and controls by people who may have impaired vision or limited dexterity or motor control.
Multimedia products involve more than one media and include, but are not limited to, video programs, narrated slide production, and computer generated presentations. Provisions address caption decoder circuitry (for any system with a screen larger than 13 inches) and secondary audio channels for television tuners, including tuner cards for use in computers. The standards also require captioning and audio description for certain training and informational multimedia productions developed or procured by Federal agencies. The standards also provide that viewers be able to turn captioning or video description features on or off.
This section covers products that generally have imbedded software but are often designed in such a way that a user cannot easily attach or install assistive technology. Examples include information kiosks, information transaction machines, copiers, printers, calculators, fax machines, and similar types of products. The standards require that access features be built into the system so users do not have to attach an assistive device to it. Other specifications address mechanisms for private listening (handset or a standard headphone jack), touchscreens, auditory output and adjustable volume controls, and location of controls in accessible reach ranges.
This section focuses on keyboards and other mechanically operated controls, touch screens, use of biometric form of identification, and ports and connectors.