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General Services Administration

General Services Administration. Policy, the Procurement Process, the Buy Accessible Wizard, and Purchasing Section 508 Conformant Products & Services. Helen Chamberlain Governmentwide Section 508 Program Director Office of Governmentwide Policy. Agenda.

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General Services Administration

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  1. General Services Administration Policy, the Procurement Process, the Buy Accessible Wizard, and Purchasing Section 508 Conformant Products & Services Helen Chamberlain Governmentwide Section 508 Program Director Office of Governmentwide Policy

  2. Agenda • Difference Between Accessibility, Accommodation, and Assistive Technology • Why Accessibility is Important • Section 508 - The Law • Resources to Help with Procurements

  3. Definitions • Three important terms • All three start with “A” • They are NOT interchangeable 3 Important Terms Accessibility Accommodation Assistive Technology

  4. Accessibility • Focuses on ensuring the E&IT can be accessed by persons with disabilities • An example would be ensuring that the agency time and attendance system works, so that persons accommodated with screen readers can successfully use the system to get paid 3 Important Terms Accessible design allows the use of assistive technology

  5. Accommodation • Focuses on the person, on providing needed technology to allow people to do their jobs • An example would be providing a screen reader to a visually impaired person 3 Important Terms Assistive Technology can be provided as an accommodation, but requires accessible E&IT to be useful – required by Section 508

  6. Assistive Technology • “any item, piece of equipment, or product system, whether acquired commercially, modified, or customized, that is used to increase, maintain, or improve functional capabilities of individuals with disabilities” Source of AT definition – Assistive Technology Act of 1998 (29U.S.C) 3 Important Terms

  7. AT Assistive Technology Model User Computer Assistive Technology fits between the user and the computer, addresses functional limitations AT can be focused on: • Input • Output • Both

  8. Section 508 Overview

  9. Section 508 of the Rehabilitation Act • 2000 amendment to Section 508 required Federal agencies to make EIT accessible • Enacted to: • Eliminate barriers in information technology • Make available new opportunities for people with disabilities • Encourage development of technologies that will help achieve these goals • Section 508 mandated GSA and the Access Board to provide technical assistance on the requirements of the law to Federal departments and agencies 9

  10. Why is Section 508 Important? • It eliminates barriers for people with disabilities • Supports Federal initiatives • Benefits everyone • Achieves legal compliance • Promotes positive public image • Facilitates public access to Federal information It’s the law!

  11. Why is Section 508 Important? • U.S. government spends $37 B+ per year on IT • Supports employment of people with disabilities • Improves public access to government IT services • Reduces the need for individual accommodations • Encourages improvements in accessible design • Increases availability of accessible products • Raises general awareness of disability issues and promotes societal change

  12. Why Enforce the Law? • It’s the right thing to do • An agency can be sued • Supports Federal and State initiatives • President’s Management Agenda • New Freedom Initiative • YOU have a vested interest

  13. Do you have problems with:

  14. Simulated Glaucoma

  15. Simulated Macular Degeneration

  16. It happens more often than you'd imagine • Just over 1 in 4 of today's 20 year-olds will become disabled before they retire. (SSA) • Over 36 million Americans are classified as disabled; about 12% of the total population. More than 50% of those disabled Americans are in their working years, from 18-64.(Census) • 8.3 million disabled wage earners, over 5% of U.S. workers, were receiving Social Security Disability (SSDI) benefits at the conclusion of March, 2011. (SSA) • In December of 2010, there were over 2.5 million disabled workers in their 20s, 30s, and 40s receiving SSDI benefits. (SSA)

  17. Disability Statistics • In 2011, the overall percentage (prevalence rate) of working age people (ages 21 to 64) with a disability in the US was 10.5 percent. • In other words, in 2011, 18,858,600 of the 180,037,400 individuals ages 21 to 64 in the US reported one or more disabilities. • In the US in 2011, among the six types of disabilities identified in the ACS, the highest prevalence rate was for "Ambulatory Disability," 5.5 percent. The lowest prevalence rate was "Visual Disability," 1.8 percent. www.disabilitystatistics.org

  18. How Many Persons Benefit From Accessibility? • 8 million who have difficulty seeing • 7 million who work for the government • 6.2 million who are in school systems • 10,198 who are deaf and blind, • Over 56.7 million Americans are persons with disabilities!

  19. Disability Statistics • Disability in America • More than 30 million Americans between the ages of 21 and 64 are disabled, according to the most recent U.S. Census. • 2.3 million people filed disability claims with Social Security in 2008. • 25+ million American lives are restricted by the effects of disability, according to the Centers for Disease Control and Prevention.

  20. Section 508 Standard • Subpart A – General • Subpart B – Technical provisions • Subpart C – Functional performance criteria • Disabilities addressed: hearing, speech, vision, dexterity. mobility • Subpart D – Documentation and support

  21. Dissecting the Law • Subpart B consists of standards for: • Software applications/operating systems • Web-based information and applications • Telecommunication products • Video and multimedia products • Self-contained, closed products • Desktop and portable computers

  22. Dissecting the Law • Subpart C • Technologies or components for which there is no specific requirement under the technical standards in Subpart B • Covers operation, including input and control functions, operation of mechanisms, and access to visual and audible information • Subpart D • Consists of information, documentation and support • Requires manufacturer upon request, to provide compliant electronic text for all documentation associated with the product

  23. Software applications and operating systems Web-based Intranet and Internet information and applications Telecommunications products Video and multimedia products Self contained, closed products Desktop and portable computers Types of Products Covered

  24. First Cell Phone - 1973

  25. First Portable Computer - 1981

  26. First Website - 1991

  27. What does Section 508 Apply To? • Section 508 applies to ALL EIT contract vehicles and procurement actions, including micro-purchases. • All EIT that is “procured, maintained, developed, or used” • Note: Section 508 accessible documentation and support should be included in every solicitation since all deliverables are in electronic format even if it is not an EIT contract.

  28. Who does Section 508 Apply To? Section 508 applies to the Federal Government and the US Postal Service

  29. Requiring Authority Responsibilities Determine Section 508 applicability Identify Section 508 requirements and include in SOW Conducting market research Coordinate with: IT Specialist to: Identify 508 applicability and accessibility requirements IT Testers 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 Participate in proposal evaluation

  30. Contracting Officer Responsibilities • Ensuring that the Requiring Authority : • Properly identifies Section 508 technical requirements • Conducts market research • Documents Section 508 due diligence (BAW) • Ensure that requirements, inspection and acceptance criteria and evaluation factors are appropriately represented in the solicitation • Participates in proposal evaluation • Makes sure the solicitation is in an accessible format

  31. IT/CIO Responsibilities • IT/CIO is responsible for: • Identifying current needs for IT purchases • IT/CIO may coordinate with Requiring Authority to: • Identify applicability and Section 508 technical requirements • Determine inspection and acceptance criteria for deliverables • Determine program evaluation factors • Conducting accessibility testing

  32. Agency EIT Developers Responsibilities • Agency EIT Developers (internal to agency) are responsible for ensuring compliance with Section 508, including: • Determining Section 508 applicability • Identifying accessibility requirements • Identifying inspection and acceptance criteria for deliverables

  33. Developing Software • Most Section 508 standards are simply good old coding practices • Always code to the standards and not the accessibility tools (e.g., JAWS, Dragon Naturally Speaking) • Currently, there are no tools designed to evaluate software automatically

  34. Developing Software • If JAWS can read a program, that is no guarantee that it is compliant • If JAWS cannot read a program, that is no guarantee that it has deficiencies • Few sighted people have sufficient expertise with JAWS to use it as an evaluation tool

  35. Developing Software • Allow sufficient time to correct 508 deficiencies and still meet the schedule for production • Remember the Contracting Officer is the only person who can authorize changes to a contract • Contractor is responsible for ensuring compliance until the Government accepts the system

  36. Web Development • Most visible 508 area…both internally and with customers • The more complex and fancy a site, the more difficult it may be to make compliant • This does not imply that you have to “dummy down” the site

  37. Web Development • Web products must comply not only with Section 508, but also any other standards and formats prescribed by the agency’s webmaster • No matter what the requirements are to post a web document, Section 508 has priority since it is a law

  38. Web Development • Several tools exist for web evaluations, although differing tools sometimes yield differing results • Do not rely on the tools as the final determining factor for compliance • Always use at least two different evaluation tools, one of which should be the tool that the Webmaster uses

  39. Testing Principles • DO 508 standards-based testing • DO NOT do testing based on Assistive Technology • Have reliable test results • Document your procedures • Have easy to use testing tools • Document your results • Be able to be repeatable by other testers

  40. What Makes a Successful Program • Where program is located within organization • Dedicated 508 Coordinator (not 5%) • Need for strong policies & procedures • Resources required (FTE or contract support) • Building relationships with stakeholders • IT governance bodies/processes • IT procurement/acquisition (508 requirements, etc) • Testing/remediation capabilities (or access to) • Training/outreach

  41. Section 508 Policy • Section 508 Strategic Plan • Exceptions • Section 508 Refresh • FAR • Section 508 Assessments • Evaluation Criteria • VPATS/GPATS • Micro Purchases • Buy Accessible Wizard Tool

  42. Strategic Plan • January 2013, the White House released: “Strategic Plan for Improving Management of Section 508 of the Rehabilitation Act.” • Federal agencies must appoint a 508 coordinator • Federal agencies must post an accessibility statement on their website • Federal agencies must submit assess their 508 program and submit a report • Federal government will refresh their 508 learning modules

  43. Section 508 Exceptions • National Security • Any EIT operated by agencies, the function, operation, or use of which involves intelligence activities, cryptologic activities related to national security, command and control of military forces, equipment that is an integral part of a weapon or weapons system, or systems which are critical to the direct fulfillment of military or intelligence missions. Systems which are critical to the direct fulfillment of military or intelligence missions do not include a system that is to be used for routine administrative and business applications (including payroll, finance, logistics, and personnel management applications).

  44. Section 508 Exceptions • Incidental to a Contract: • This part does not apply to electronic and information technology that is acquired by a contractor incidental to a contract. • Back Office: • Products located in spaces frequented only by service personnel for maintenance, repair, or occasional monitoring of equipment are not required to comply with this part

  45. Information, Documentation & Support • The standards also address access to all information, documentation, and support provided to end users (e.g., Federal employees) of covered technologies. This includes user guides, installation guides for end-user installable devices, and customer support and technical support communications. Such information must be available in alternate formats upon request at no additional charge. • NOTE: This should be included in every solicitation whether or not it is EIT

  46. Section 508 Refresh • §255 guidelines effective (1998) • §508 standards effective (2001) • 2 ANPRMs for comments • Develop regulatory assessment (2012-13) • OMB July 2013 • Publish NPRM for comments Fall/Winter 2013 • Final rule

  47. FAR Part 39.2 Acquisition of EIT states: • When acquiring EIT, agencies must ensure that— • (1) 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 • (2) Members of the public with disabilities seeking information or services from an agency have access to and use of information and data that is comparable to the access to and use of information and data by members of the public who are not individuals with disabilities.

  48. VPATS and GPATS • What is a VPAT? • Voluntary Product Accessibility Template • Industry created form • Who uses it? • What is a GPAT? • Government Product Accessibility Template • Output from BAW • How is it used?

  49. Micro Purchases • Section 508 still applies! • Still have to do market research • Purchases under $3000 • Usually with a Credit Card • Can use the Buy Accessible Wizard • Can use the Quick Links

  50. Agency POC GSA / OMB FBO Solicitation Assessment Process Feedback Letter Quarterly Report Solicitation listings CABA Sample Apply Assessment Criteria Generate Feedback Consolidate Metrics Start End Selected EIT Solicitation Assessed EIT Solicitation EIT Solicitation Metrics Access Board Standard CFR 1194 FAR Parts 7, 10, 11, and 39

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