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CHIPS Articles: Tips for Creating 508 Compliant IT Solicitations

Tips for Creating 508 Compliant IT Solicitations
By Sherrian Finneran - April-June 2012
Accessible information technology is technology that can be used by people with disabilities. Electronic documents, websites, software, computers, kiosks and other IT equipment that are inaccessible to people with disabilities essentially exclude them from the technological advantages enjoyed by people without disabilities who can easily access IT products.

Section 508 of the Rehabilitation Act supports employment of people with disabilities, improves public access to government IT, reduces the need for individual accommodations, encourages improvements in accessible design, increases the availability of accessible products and raises general awareness of disability issues. To comply with Section 508, it is essential to understand the law, the Section 508 standards (available on the U.S. Access Board website at: www.access-board.gov/508.htm) and the Federal Acquisition Regulation (FAR) both Subpart 7.103 and Subpart 39.2. Solicitations created by the federal government to procure, develop or maintain IT equipment must comply with these requirements. To ensure DON solicitations are compliant with Section 508, heed these Dos and Don'ts.

DO

Provide a clear statement that the provisions of Section 508 do or do not apply to the solicitation. It is important that the solicitation documentation indicates if the deliverables to be acquired are electronic information technology (EIT) and subject to Section 508. In accordance with FAR 39.203, this determination is the responsibility of the agency.

Indicate if an exception is being claimed. When claiming an exception as provided by the FAR 39.204, clearly specify this in the solicitation and show which general exception is being claimed.

Request accessibility information from the responder. Potential vendors should be asked to provide information about the accessibility of their EIT product through a Volunteer Product Accessibility Template (VPAT) or a Government Product Accessibility Template (GPAT) (available on the Information Technology Industry Council website at: www.itic.org).

Indicate which technical standards in Subpart B of the Section 508 Standards Guide (www.section508.gov/docs/Section%20508%20Standards%20Guide.pdf) apply to the EIT contract deliverables being procured, developed or maintained. The technical standards are: • Software applications and operating systems (§1194.21);
• Web-based intranet and Internet information and applications (§1194.22);
• Telecommunications products (§1194.23);
• Video and multimedia products (§1194.24);
• Self-contained or closed products (§1194.25); and
• Desktop and portable computers (§1194.26).
Indicate which information, documentation and support requirements are applicable to the EIT contract deliverables. Solicitations for EIT equipment should identify whether information, documentation and support requirements apply to support the documentation and services provided by agencies to end users of the acquired EIT products.

Specify applicable accessibility factors as evaluation criteria. Solicitation evaluation should be based in part on the proposal responses to the identified Section 508 requirements and accessibility considerations. Solicitations for EIT equipment should specify accessibility factors as part of their evaluation criteria.

Specify accessibility factors as part of the acceptance criteria. Solicitations should include a statement indicating that supplies or services delivered as a result of the solicitation will be reviewed to verify they meet accessibility requirements. Potential vendors need to be informed of these reviews and inspections.

Create solicitation documents that are accessible. All documents and attachments associated with an EIT solicitation should be in accessible format. A service-disabled veteran owned business or other disabled vendor may be able to fulfill the solicitation requirements.

DON'T

Create solicitations that fail to reference Section 508. As noted above, it is a FAR requirement to state whether Section 508 applies to the solicitation. Further, once a solicitation is posted on FedBizOpps.Gov, it may be evaluated for Section 508 compliance by automated software. Not mentioning Section 508 or referring to it in a vague, nonspecific manner may be detected.

Request a vendor to determine Section 508 exceptions. This is the responsibility of the agency and cannot be delegated to a vendor.

Request a vendor to determine Section 508 relevance.This is the responsibility of the agency and cannot be delegated to a vendor.

Request a vendor to determine Section 508 applicability.This is the responsibility of the agency. However, assistance can and should be requested from the vendor in the form of a VPAT or a GPAT.

Request an accessibility certificate of compliance. Potential vendors should be asked for proof of conformance with the stated accessibility factor requirements through a VPAT or a GPAT. A certifying body for Section 508 accessibility does not exist.

Create inaccessible solicitation documents. A service-disabled veteran owned business or other disabled vendor may be able to fulfill the solicitation requirements.

Additional information about Section 508 is available at www.section508.gov and the BuyAccessible.Gov website at www.buyaccessible.gov. The BuyAccessible website assists federal agencies in determining when Section 508 applies to a particular purchase and helps in conducting market research for compliant vendors.

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