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How to request accessibility information from vendors

How to request accessibility information from vendors. ROBERT BAKER DIRECTOR –SECTION 508 GOVERNANCE DHS OFFICE OF ACCESSIBLE SYSTEMS & TECHNOLOGY. Goals. Overview – Major changes that impact procurement Guidance you can use now to Identify Section 508 requirements in a solicitation

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How to request accessibility information from vendors

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  1. How to request accessibility information from vendors ROBERT BAKER DIRECTOR –SECTION 508 GOVERNANCE DHS OFFICE OF ACCESSIBLE SYSTEMS & TECHNOLOGY

  2. Goals • Overview – Major changes that impact procurement • Guidance you can use now to • Identify Section 508 requirements in a solicitation • Obtain better accessibility information from vendors • Additional provisions and clauses to help agency manage accessibility post award

  3. Changes to the 508 Standards • Effective January 18, 2018 • New and revised scoping criteria • New safe harbor and revised exceptions • New technical provisions • New & revised functional performance provisions

  4. Scoping Changes ICT vs EIT Feature vs product based Implication: Identify all required items that contain ICT features and components

  5. Scoping – New Considerations • Electronic Content • Public facing • Non public facing official communications • Authoring Tools

  6. Safe Harbor • Does not apply to technology procured after January 17, 2018 • Need to modify existing contracts

  7. Exceptions • Assessed for ICT features and components • Undue Burden assessed on agency resources available to program or component • Commercial non-availability now “Best Meets” Exception • Documentation for Best Meets

  8. New Technical Standards • Web content - WCAG 2.0 Level A & AA Success Criteria • Software must comply with • WCAG 2.0 guidelines • 5 Additional provisions in Chapter 5 • Non Web Software excludes 4 WCAG provisions • Hardware - 15 Provisions in Chapter 4 • Support Documentation & Services – 5 provisions in Chapter 6

  9. Revised functional performance criteria • Covers: • No vision, limited vision, color blindness • No hearing and limited hearing • No speech • Limited manipulation, limited reach & strength, • Limited language, cognitive and learning abilities

  10. How to request accessibility information from vendors 1 2 3 Identify all items that contain ICT features or components, and for each identify applicable exceptions and standards Request detailed accessibility conformance information from potential offerors Consider including provisions and clauses to manage agency risk after award

  11. Step 1 1 Identify all items that contain ICT features or components, and for each identify applicable exceptions and standards

  12. Step 1 Resources • Use the Revised 508 Standards Applicability Checklist & Instructions to define requirements • Use the 508 Standards Checklist or the 508 Solicitation Conformance Chart template to communicate 508 requirements in solicitations • Use GSA Accessibility Requirements Tool to get automated output

  13. Outcomes & Benefits Outcomes • Tailored list of applicable exceptions and standards for each item that contains ICT features and components Benefits • Reduces ambiguity when communicating with vendors • Supports more relevant responses from vendors • Provides foundation for comparison between offers

  14. Step 2 2 1 Request detailed accessibility conformance information from potential offerors

  15. New Conformance Reporting Tool Accessibility Conformance Report Based on VPAT 2.0 • Supports new standards and WCAG 2.0 • Documents conformance level of functions and features • Detailed instructions advise vendors to explain • How conformance was tested • Application dependencies to support accessibility (e.g. operating system,, app frameworks, browsers recommended) • How customers can find more information on accessibility issues (ex. Bug reports) • Known workarounds for accessibility issues

  16. Guidance for requesting ACRs • Explicitly require an ACR for each item that includes ICT, subject to the following standards • All VPAT 2.0 instructions are followed • Must address all the applicable standards defined by the agency • Must state exactly how the item meets the applicable standards in remarks and explanations • Must indicate whether conformance is achieved through all or specific parts of the item • Must describe the evaluation methods used to develop the ACR • Add a statement that agency reserves the right to validate ACRs through manual testing

  17. Additional suggestions • Require vendor to provide • 508 test results (preferably based on trusted tester / AED ACOP guidance) • A demonstration of the item’s support for 508 conformance • Documentation of core functions which can’t be used by PWDs • Information on how authoring tools support the creation of accessibile electronic content • Information on how to configure and install the item to support access • Information on training available to use the item’s accessibility features and associated costs • An Accessibility “Test Plan” illustrating typical user scenarios • Information on the vendor’s IT accessibility program

  18. Include 508 requirements in your evaluation factors

  19. Step 2 Outcomes • Provides clear expectations for how you want offerors to communicate 508 conformance information • Provides for more accurate and complete accessibility information from vendors • Ensures you have what you need to make an effective 508 conformance and “best meets” determination

  20. Step 2 Resources • Sample instructions to contractors published on 508 Toolkit Website • GSA accessibility requirements tool • Voluntary Product Accessibility Template version 2.0

  21. Step 3 Consider including provisions and clauses to manage agency risk after award 3

  22. Key challenge – Part 1 Inaccurate 508 conformance claims

  23. Risk Mitigation • Reserve the right to perform 508 testing to validate conformance claims prior to acceptance • Require contractor to remediate the item to match original conformance claims if the delivered items provide less support for 508 than originally documented by the contractor, or consider other contract remedies.

  24. Key Challenge – Part 2 • Risk too high to accept 508 conformance claims at face value based on ACRs alone • Limited bandwidth to conduct independent Section 508 testing to validate claims prior to acceptance

  25. Proactive Measures Insert provisions or clauses to require the contractor to • Conduct 508 testing and provide the agency test results prior to acceptance • Test using the Trusted Tester and AED ACOP test methodologies • Ensure key personnel who will perform 508 testing are DHS certified trusted testers.

  26. Key challenges – Part 3 • Accessibility support may change post award • Custom development and updates • Configuration • Integration • Maintenance • Upgrades and substitutions • Deployment in cloud or other hosted environments

  27. More Proactive Measures Use provisions or clauses to ensure post award activities support 508 compliance requirements

  28. Step 3 Resources • Sample provisions & clauses published on 508 toolkit website • GSA accessibility requirements tool • Trusted tester methodology for web and software & AED ACOP testing guidance for electronic documents

  29. Where to get resources https://section508.gov/refresh-toolkit

  30. Questions?

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