Section 508 Compliance for Contracting Officer’s Technical Representatives and Program & Project Managers

1. Section 508 Compliance forContracting Officer’s Technical Representatives and Program & Project Managers

2. Topics Section 508 …………………...…….......................... 3 Roles and Responsibilities ..………………………… 7 • How to comply with Section 508 Section 508 Acquisition Process …………………… 21 DHS Systems Engineering Life Cycle Alignment …. 31 • Section 508 EIT Accessibility Plan Where To Go for Help …….…………………………... 64

3. Section 508 of the Rehabilitation Act

4. Section 508 is a Law • Section 508 of the Rehabilitation Act of 1973 as amended 1998 • Ensures people with disabilities have access to and use of Electronic and Information Technology (EIT), including: • Electronic data, Information, and Support services • Encoded in CFR 36:1194 and added to the Federal Acquisition Regulations at Section 39.2 • The U.S. Access Board developed accessibility standards • Applies to: • Federal agencies in support of employees and members of the public with disabilities • All DHS EIT contracts and contract actions • Enforceable as of June 21, 2001

5. The Purpose • Section 508 is intended to provide equal access and use of information for people with disabilities and eliminate barriers to employment • DHS is obligated to: • Require compliance with applicable Section 508 Technical Standards • Perform Market Research and Section 508 Analysis of Alternatives • Procure the most compliant products and services that meet the program business need! • Document compliance • DHS is not obligated to: • Procure anything that DOES NOT meet the business need

6. Key Term: Section 508 Compliant Section 508 compliance requires both a legal and atechnicalapproach to compliance Legal compliance (required by FAR 39.2) includes documenting: • Market research • WhichSection 508 technical standards apply • Any applicable Section 508 (legal) exceptions • Which standards cannot be met, if any • Including the documentation in the contract file

7. Technical Compliance Technical compliance includes: • Documenting howthe product meets the technical standards that apply • Ensuring that all custom development meets the applicable Section 508 technical standards • Planning for Section 508 compliance in project requirements, design, integration, testing, and acceptance criteria before release

8. StakeholderRoles & Responsibilities

9. Stakeholders • OAST • Component Section 508 Coordinator • Contracting Officers Technical Representative (COTR) • Requiring officials • Project or Program Managers who manage the work on behalf of the customer: • the person with the business requirement • the program owner • Section 508 Subject Matter Experts

10. Section 508 Program OfficeRoles & Responsibilities

11. Office of Accessible Systems & Technology (OAST) • OAST leads the department-wide implementation of Section 508 • Provides strategic direction, technical support, and training to ensure DHS employees and customers with disabilities have equal access to information and data • Office of the Chief Information Officer (OCIO) • Office for Civil Rights & Civil Liberties (CRCL)

12. OAST Program Management • Sets Section 508 policy for all of DHS • Provides DHS governance to ensure Section 508 compliance is part of decision-making activities • Evaluates and reports on DHS compliance with Section 508 • Offers guidance and technical assistance to DHS personnel on reasonable accommodations • Develops and delivers training

13. OAST Program Management • Reviews all acquisitions over 2.5 million • Authorizes all requests for: • National Security Exception • Undue Burden Exception • Provides the DHS Accessibility Requirements Tool (DART) • http://dhsconnect.dhs.gov/org/comp/mgmt/cio/oast/ • http://accessibility.dhs.gov

14. OAST Program Management • Mans the DHS accessibility help desk providing subject matter experts who are available to help you with all aspects of Section 508 compliance, including procurement review, application and document testing, standards and exception analysis, and general information and training. • Evaluates and reportson DHS compliance with Section 508 • Is available for technical assistance to DHS Components when acquiring EIT

15. Component Section 508 Coordinator • Authorize component requests for: • Back Office Exception • Fundamental Alteration Exception • Incidental to Contract Exceptions • Are required to review component IT acquisitions with dollar value less than $2.5 million • Provide Section 508 technical assistance • Participate in IT governance activities regarding Section 508 compliance. • Report component Section 508 implementation status

16. Contracting Officer’s Technical Representative Roles & Responsibilities

17. Contracting Officer’s Technical Representative Has to ensure proper contractual and project activities occur for three areas: • Acquisition Support Responsibilities • Project Management Responsibilities • Ensuring proper documentation • From Requiring Official

18. Acquisition Support Role Acquisition Support Section 508 Activities: • Ensure Section 508 standards and exceptions are identified and included in Contractual language • Purchase Requests • SOO, SOW, IGCE, ARD, RFP, RFI • PRISM • FirstSource Appendix G • EAGLE Task Orders Appendix H • Ensure Section 508 exceptions , if any, are requested and authorized

19. COTR Project Management Role • Ensure DHS SELC Alignment & Project Life-cycle Support • Confirm Acceptance Testing • Confirm Remediation Plan, if needed • Confirm required artifacts (documentation) per the Section 508 EIT Accessibility Plan (CPPM Training) • Ensure that Requiring Officials provide documentation • Description of Market Research performed • If compliant product is not available show which Section 508 standards are not met •  Basis for exception decision

20. Requiring Official and Project Manager Roles & Responsibilities

21. Requiring Official Role Requiring Official Section 508 Role: • Define functional requirements for their business needs. • Identify applicable Section 508 technical standards and exceptions • Obtain authorization for exceptions or seek advice when needed (DHS Forms #4103, 4105, 4107, 4108, 4109) • Perform market research for items that best meet business needs (DHS Form #4106) • Identify the most compliant that meet business needs • Draft contract Section 508 language using DART

22. Program or Project Manager • Knowledge of DHS SELC Alignment and Project Life Cycle Support activities ensures: • Identification of Section 508 technical standards or exceptions • Authorization for exceptionsis obtained • Market research is performed • The most compliant product that meet business needs is chosen (DHS Form #4106) • Section 508 issues are resolved or a remediation plan is approved. • Communication, Communication, Communication • Talk to the right people • Get the right people talking to each other

23. Section 508 Subject Matter Expert • Advise on lifecycle requirements • Test EIT products for Section 508 compliance • Recommend technical development solutions • Review market research/alternative analyses • Train key personnel • Explain Section 508 governance activities Request SME assistance at http://accessibility.dhs.gov

24. Section 508 Acquisition Process

25. Acquisition Process: Need, Analyze, Obtain, Deploy • Clearly define your Business Need • Product or service must meet the Business Need • If the product or service does not do what you need it to do then what good is it? • If a product is Section 508 compliant but doesn’t meet the Business Need, you do not have to buy it. • Collect and analyze relevant market information • Identify possible sources for the acquisition • Perform effective market analysis and industry knowledge • Select and document the most 508 compliant product that meets business needs! • DHS FORM # 4106

26. Market Research Form Image fills this entire area (OR originates at the upperleft corner of the area outlined and is sized to the full width or height of this bounding box.) • Compliance requires market research • Custom, commercial, or free • Section 508 compliance requires documenting analysis of alternatives • Summarizes additional documentation required

27. Most Compliant • If no fully-compliant product is available, the agency must procure the most compliant product that meets the business needs • Commercial products that do NOT fully meet Section 508 Technical Standards require market research documentation • DHS 4106 - Most Compliant Product - Market Research Form • Most compliant product • No COTS product exists that meetsALLthe applicable 508 technical requirements OR • Fully compliant products cannot be furnished in time to satisfy the agency’s delivery requirements • With most compliant product the vendor must be given a list of defects and asked for a remediation plan

28. Voluntary Product Accessibility Template (VPAT) • Provided by EIT Product Vendor to Show 508 Compliance • Assists Federal contracting officials and other buyers in making preliminary assessments regarding the availability of commercial Electronic and Information Technology products and services with features that support accessibility. • It is assumed and recommended that offerers will provide additional contact information to facilitate more detailed inquiries.

29. Voluntary Product Accessibility Template (VPAT) Bluebeam PDF Revu version 6.5.4

30. Other Sources • http://accessibility.dhs.gov/PublicAppRepository.aspx. • OAST Section 508 Test results • Test the product • Ask the vendor for a test version • Request Section 508 testing OR • Have your “Trusted Testers” do the testing

31. Section 508 Acquisition Language

32. DHS Accessibility Requirements Tool (DART) • Tool generates Section 508 language for acquisition SOW, PWS, RFP, RFQ and SOO • Provides summary of Section 508 requirements • Select applicable Section 508 exceptions and technical standards • Copy Section 508 language from tool • Paste into acquisition documentation DART is available under the DHSConnect, MGMT >> CIO >> OAST >> OAST Component Resources

33. Commercial Vendors • Perform based on standard procurement language: • For any COTS or GOTS procured EIT • Does this acquisition include a requirement for QA or IV&V testing? • Sample DART Tool Contract language • 36 CFR 1194.2(b) – (COTS/GOTS products), When procuring a product, each agency shall procure products which comply with the provisions in this part when such products are available in the commercial marketplace or when such products are developed in response to a Government solicitation. • Custom (developed in response) requires additional contract & lifecycle language

34. Standard Procurement Language Section 508 requirements are applicable to all Federal procurements including… • EAGLE – Task Orders • First Source – Appendix G • Information Technology Acquisition Review (ITAR) – Management Directive 0007.1

35. DHS SELC Alignment

36. DHS SELC • DHS Acquisition Instruction/Guidebook #102-01-001: Appendix B Version 2.0, Sep 2010 • Ensuring that appropriate activities are planned and implemented in each stage of the life cycle to increase the project’s success • DHS Connect > Organization > Components > Management (MGMT) > Chief Information Officer (CIO) > Offices > Enterprise Business Management Office (EBMO) > Systems Engineering Life Cycle • Search for “SELC” • Section 508 compliance relies on common life cycle documents and activities! • MNS, CONOPS, AoA, RTM, SRD, FRD, TRD

37. Section 508 EIT Accessibility Plan

38. Building Accessibility in is Cost Effective • Planning saves money! • It is expensive to retrofit software to meet accessibility standards • The cost of revision is estimated to be - 1.5 to 6 times greater during development than during the design phase - 60 to100 times greater after release [Pressman, 2005]

39. Several steps to the project, it all begins with an idea and more planning Stage 1: Solution Engineering & Planning Stage 2: Requirements Definition Stage 3: Design & Development Stage 4: Integration & Test Stage 5: Implementation & Operations Project managers and developers might relate to this as a classic waterfall development approach, but it is iterative and can be adapted to rapid application development or other methods Section 508 EIT Accessibility Plan

40. Exiting Solutions Engineering and Planning There are 2 ways to fulfill the requirements for this section: • Have a documented and authorized exception • Complete the preliminary work for requirements definition

41. Before Planning Begins • National Security Exception Request and Authorization Form (DHS Form 4105) • Usually known during planning if the project will involve National Security • Recognized Section 508 exception • Section 508 compliance includes clearly documenting any exceptions

42. What are you engineering? What are you planning to buy? What are you planning to build? How will you select the best products? What is the business need? Solution Engineering & Planning

43. Planning • Considerations • Identify Section 508 Exceptions that might apply • Section 508 Exceptions Worksheet • Identify the applicable Section 508 Technical Standards • Section 508 Applicable Standards Worksheet • Select the most compliant product available • DHS Form 4106: Most Compliant Product Market Research Formand supporting documents

44. Exceptions Worksheet Image fills this entire area (OR originates at the upperleft corner of the area outlined and is sized to the full width or height of this bounding box.) • Assists in • Identifying possible exceptions • Asking the right questions • Legal Section 508 compliance requires clearly documenting any exceptions

45. Exceptions • Requires Section 508 Coordinator approval • EIT acquired by a contractor incidental to a contract • Back Office (Maintenance only) Equipment • Fundamental Alteration • Requires OAST Director approval • National Security Systems • Undue Burden

46. Exceptions Worksheet Screenshot

47. Applicable Standards Worksheet Image fills this entire area (OR originates at the upperleft corner of the area outlined and is sized to the full width or height of this bounding box.) • Used as a documentation template • Reminder to include Section 508 in other generic project documentation • Possibly unused until later in the life cycle • Copy and paste into your requirements documents • Do not edit or modify standards

48. Functional Performance Criteria • Requires at least one mode of operation and information retrievalforEIT that can be used by persons with the following impairments: • § 1194.31(a & b)Vision (blind and low vision), • § 1194.31(c & d) Hearing (Deaf and hard of hearing), • § 1194.31(e) Speech & Communication OR • § 1194.31(f) Fine Motor Control • Remember § 1194.31 Functional Performance Criteria • Always apply • Are met by complying with the Section 508 technical standards

49. Subpart B – Technical Standards • Your role includes identifying EIT as categorized by the technical standards: • § 1194.21 Software applications and operating systems (Windows, Microsoft Word / Excel) • § 1194.22 Web-based information and applications (Web pages, linked documents, forms, Internet and intranet applications) • § 1194.23 Telecommunications (telephones, voicemail systems) • § 1194.24 Video and multimedia (broadcasts, videotapes, webcasts) • § 1194.25 Self contained, closed products (copiers, plotters, fax machines, kiosks) • § 1194.26 Desktop and portable computers (laptops, desktops, PDAs)

50. Applicable Standards Screenshot