U.S. General Services Administration

Helen ChamberlainGovernmentwide Section 508 Program DirectorOffice of Governmentwide Policy

General Services AdministrationPolicy, the Procurement Process, the Buy Accessible Wizard, and Purchasing Section 508 Conformant Products & Services

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Agenda

Difference Between Accessibility, Accommodation, and Assistive TechnologyWhy Accessibility is Important Section 508 - The LawResources to Help with Procurements

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Definitions

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Three important termsAll three start with “A”They are NOT interchangeable

AccessibilityAccommodationAssistive Technology

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Accessibility

Accessible design allows the use of assistive technology3

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Focuses on ensuring the E&IT can be accessed by persons with disabilitiesAn 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

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AccommodationFocuses on the person, on providing needed technology to allow people to do their jobsAn example would be providing a screen reader to a visually impaired person

Assistive Technology can be provided as an accommodation, but requires accessible E&IT to be useful – required by Section 5083

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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)

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Assistive Technology Model

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ComputerUser AT

Assistive Technology fits between the user and the computer, addresses functional limitations Input

OutputBoth

AT can be focused on:

Why is Accessibility Important? More than a billion people are estimated to live with some form of disability, which

is about 15% of the world’s population (based on WHO 2010 global population estimates). In Australia, this represents nearly 20% of the population.

The number of people with disabilities is growing as national populations grow older and global chronic health conditions, such as diabetes, increase. Yet statistics show that Australia ranks at the very bottom of all OECD (Organisation for Economic Cooperation and Development) nations for their treatment of the disabled, with 45% of disabled people in this country living in or near poverty. (PricewaterhouseCoopers, The Australian, 3 May 2012)

Using digital technologies can be a problem not just for the visually impaired but a much wider section of the community. Hearing impairment, dementia, arthritis, attention deficit disorder and dyslexia are just some of the conditions that can make it hard for people to utilize the Web.

By making websites and digital technologies accessible, we help to create an inclusive environment for people with a disability. Accessible websites enable people to make independent decisions, and provide greater opportunity for participation, interaction, education and employment.

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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)

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Do you have problems with:

Eye sight Hearing Weight

Arthritis Diabetes Smoking

Heart Stomach Lungs

High Blood Pressure or Cholesterol

Back, knee, elbow or wrist ailments

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Flickering

Seizures can be triggered by blinking on-screen elements in the 2Hz to 55Hz range (2 to 55 times per second)

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Hearing Accommodation

Section 508 Overview

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Section 508 of the Rehabilitation Act

December 2000 amendment to Section 508 sets forth a definition of Electronic & Information Technology (EIT) and the technical and functional performance criteria for Section 508 conformance

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 to the Federal Government 1414

What does Section 508 Apply To?

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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.

Who does Section 508 Apply To?

Section 508 applies to the Federal Departments and Agencies and the US

Postal Service

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Why Enforce the Law?It’s the right thing to doAn agency can be sued

YOU have a vested interest

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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

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Dissecting the Standard

Subpart B consists of standards for: 1194.21 Software applications/operating systems 1194.22 Web-based information and applications 1194.23 Telecommunication products 1194.24 Video and multimedia products 1194.25 Self-contained, closed products 1194.26 Desktop and portable computers

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Dissecting the Standard

1194. 31 Subpart C – Functional Performance Criteria 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

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Dissecting the Standard

1194.41 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

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First Cell Phone - 1973

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First Portable Computer - 1981

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First Website - 1991

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How does Section 508 affect Procurements? Requirements Development (SOW, PWS)

Market Research

Evaluation Factors

Selection

Deliverable Acceptance

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Requiring Authority ResponsibilitiesIdentify Section 508 requirements and include in SOW

Conducting market research

Coordinate with:IT Specialist to: Identify 508 technical 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

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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

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CIO Responsibilities CIO is responsible for:

Identifying current needs for IT purchases

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

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Agency EIT Developers Responsibilities

Agency EIT Developers (internal to agency) are responsible for ensuring compliance with Section 508, including: Identifying Section 508 technical requirements Identifying inspection and acceptance criteria for

deliverables

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What Makes a Successful Program

Where program is located within organization Dedicated 508 Coordinator (not 5%) Strong policies & procedures Resources (FTE or contract support) Building relationships with stakeholders EIT procurement/acquisition support Testing/remediation capabilities Training/outreach

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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

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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 assess their 508 program and

submit a report to OMB

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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). 34

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 (phone closets, router rooms, fiber optics)

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Undue Burden Undue burden means significant difficulty or

expense. In determining whether an action would result in an undue burden, an agency shall consider all agency resources available to the program or component for which the product is being developed, procured, maintained, or used.

Agencies are required by statute to document the basis for an undue burden. Requiring officials should be aware that when there is an undue burden, the statute requires an alternative means of access to be provided to individuals with disabilities.

Approval process determined by agency policy36

Section 508 Refresh

Still a Proposed Rule NPRM Comment Period Final Rule Approval Proposed Differences

Current Rule is technical– Technical Standards

Proposed Rule is application based– WCAG2.0 AA

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FAR Part 39.2 Acquisition of EIT states: 39.201  Scope of subpart.

(a) This subpart implements Section 508 of the Rehabilitation Act of 1973 (29 U.S.C. 794d), and the Architectural and Transportation Barriers Compliance Board Electronic and Information Technology (EIT) Accessibility Standards (36 CFR Part 1194).

(b) Further information on Section 508 is available via the Internet at http://www.section508.gov.

(c) 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.

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Solicitation Assessment Progress From Inception to Date

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?

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Micro PurchasesSection 508 still applies!Still have to do market researchPurchases under $3000Usually with a Credit CardCan use the Buy Accessible WizardCan use the Quick Links

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Buy Accessible Wizard Tool What is it? Who should use it? How can it help? Market Research How do I get started? Features Where do I get training?

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What is the Buy Accessible Wizard?

The Buy Accessible Wizard is a web-based tool that: Guides users through the acquisition process,

gathering data and providing information about Electronic and Information Technology (EIT) and Section 508 compliance

Compiles a running summary documenting the process and its results

The Vendor Accessibility Resource Center (VARC) has access to vendor provided accessibility information

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Who Should Use the BA Wizard? Requirements Officials – responsible for writing SOW and

providing requirements for the procurement Technical specialists (IT) - determine IT requirements Micro purchasers (IT) with government purchase cards Anyone else involved in the procurement process Who are the Gate Keepers Procurement officials – responsible for monitoring

procurements and regulations (gate keeper) Contract officers – responsible for the contract award

process (gate keeper) Contract Specialists – responsible for preparing RFQ/RFP

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How Can the Wizard Help Your Agency?

Standardize the acquisition process by documenting your procedures to demonstrate Section 508 due diligence

Market Research recording within the tool

Tailor your solicitations by ensuring there is specific Section 508 language and technical requirements in solicitations

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Market Research Why do it?

It’s FAR Requirement It’s used to gauge the state of the EIT industry

in meeting your requirements with products and services

Method for identifying products that claim to meet section 508 requirements

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BAW Features Supplemental Guides for post-solicitation support:

GPAT: indicates how proposed solution addresses the applicable Section 508 requirements

Evaluation Guide: helps to evaluate various proposals based on commercial availability of applicable provisions as determined by the wizard. (pre filled)

Acceptance Guide: evaluate acquisition deliverables against applicable provisions as determined by the Wizard, based on generally accepted inspection and/or test methods.

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Section 508 BAW Quick Links

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What are Quick LinksCommon and standard deliverables

(products and services)

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Quick Links Currently Provide

Standard definition of the deliverable GPAT:

Technical standards (Subpart B) Functional performance criteria (Subpart C) Information, documentation and support (Subpart D)

Solicitation language: Section 508 Program Need (Section B) Section 508 Product Requirements (Section C) Section 508 Evaluation Factors (Section M) Section 508 Acceptance Criteria (Section E)

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Be Our Guest for a Test Drive

We invite you to test drive the Buy Accessible Wizard

To access the Buy Accessible Wizard go to: www.buyaccessible.gov

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It’s the BLOB!!!!!!

No, it’s the new Section 508 www.buyaccessible.gov

Stop by and take a look!

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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

Big Picture

Section 508 should ultimately become transparent and simply part of doing business

Interagency support/collaboration needs to improve

A more cohesive 508 Community Improve the ability to share 508 results/resources

(test results, training, procedures, etc)

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Resources www.section508.gov www.buyaccessible.gov www.access-board.gov Web Accessibility Evaluation and Repair Tools:

http://www.w3.org/WAI/ER/tools/ Specifications for Accessible Learning Technologies:

http://ncam.wgbh.org/salt/guidelines/ National AIM Center: http://aim.cast.org/

IBM web accessibility checklist: http://www-03.ibm.com/able/guidelines/web/accessweb.html

George Mason University Assistive Technology Initiative: http://accessibility.gmu.edu/webaccessibility/docs/Appendix%20B%20-%20accessibility%20checklist.pdf

WebAIM: http://http://webaim.orgwebaim.org

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Resources for Creating Accessible Documents

http://webaccess.msu.edu/tutorials/accessible-word-documents.html

http://www.accessibility.calpoly.edu/instmaterials/document_creation/best_practices.html

http://www.csus.edu/accessibility/guides/creating_accessible_pdfs.pdf

http://www.calstate.edu/accessibility/tutorials/pdf.shtml www.adobe.com/accessibility.html http://office.microsoft.com/en-us/word-help/creating-

accessible-word-documents-HA101999993.aspx

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Questions?

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Thank you

Contact Information:

Helen Chamberlain helen.chamberlain@gsa.gov

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