Ensuring ICT Accessibility in Federal Acquisitions
This content highlights the importance of ensuring Information and Communication Technology (ICT) accessibility throughout the acquisition lifecycle in federal agencies. Section 508 of the Rehabilitation Act of 1973 mandates that federal agencies make technology accessible to employees and the public with disabilities. The technical standards under Section 508 have evolved to include the World Wide Web Consortium's Web Content Accessibility Guidelines (WCAG 2.0), ensuring that ICT is usable by all individuals. The overview covers the scope of ICT, examples of covered technologies, and the shift to feature-based standards to bridge the gap between ICT and assistive technologies.
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Ensuring Information and Communication Technology (ICT) Accessibility Throughout the Acquisition Lifecycle Interagency Accessibility Forum October 12, 2021 Betsy Sirk ICT Accessibility/Section 508 Program Manager National Aeronautics and Space Administration Chairperson, Federal CIO Council Accessibility Community of Practice Industry Outreach Program Email: betsy.sirk@nasa.gov
Agenda Agenda Section 508 Overview Acquisition Overview New Contracting Commercial Off The Shelf (COTS) Solutions Best Practices Resources 2
Section 508 Overview (1 of 3) Section 508 Overview (1 of 3) Section 508 of the Rehabilitation Act of 1973 amended in 1998 to address ICT; Technical standards issued in 2001 and revised in 2017 Requires that Federal agencies make technology accessible to employees and members of the public who have disabilities in a comparable manner to those without disabilities ICT defined as information technology and other equipment, systems, technologies, or processes, for which the principal function is the creation, manipulation, storage, display, receipt, or transmission of electronic data and information as well as any associated content 3
Section 508 Overview (2 of 3) Section 508 Overview (2 of 3) Section 508 applies to ICT that is "procured, developed, maintained, or used" by agencies of the Federal government Examples of ICT include and are not limited to: Computers Hardware Software/Applications Peripheral equipment Scientific/specialized equipment Office equipment Multi-function devices Telecommunications equipment Websites Videos Electronic documents Official agency communications 4
Section 508 Overview (3 of 3) Section 508 Overview (3 of 3) Revised Section 508 Technical Standards Include World Wide Web Consortium Web Content Accessibility Guidelines (WCAG 2.0) by reference Moved from technology-based to feature-based standards Increased in number mostly because of added detail; overall requirements did not substantially change Form a bridge between the ICT we use and the Assistive or Adaptive Technologies that a person might use 5
Acquisition Overview (1 of 2) Acquisition Overview (1 of 2) Federal acquisition processes for procuring ICT solutions provide key opportunities to ensure the goals of Section 508 are met Building accessibility into acquisitions: Enables workforce productivity Improves customer experience Prevents the risk of litigation costs Prevents expensive retrofitting ICT solutions Allows those with disabilities an equal footing Including accessibility requirements in acquisitions depends on: What is being procured: COTS products, custom development, IT support services, etc. How it s being procured: full and open competition, requests for proposals, requests for quotes, established Government-wide Acquisition Contracts (GWAC) or schedules, purchase card, etc. One size does not fit all 6
Acquisition Overview (2 of 2) Acquisition Overview (2 of 2) For new contracts/solicitations which include ICT for products or services for which there is a Statement of Work or Performance Work Statement: Ensure appropriate ICT accessibility requirements are included Inform Industry that Government will evaluate proposals for Section 508 conformance For acquisition of COTS or other known ICT commodities: Ask Industry to provide an Accessibility Conformance Report (ACR) showing conformance Industry usually uses template (VPAT 2.4) developed by IT Industry Council to create its ACRs; Any report which addresses relevant Section 508 technical standards is acceptable 7
New Contracting New Contracting Step 1: Determine accessibility requirements Understand which standards apply to the specific procurement Step 2: Conduct market research Identify accessible products or services available within the market Step 3: Develop solicitation language Include specific relevant accessibility requirements, contract terms and conditions for testing and validation, and expectations throughout the contract period of performance if applicable Step 4: Evaluate Each Proposal To Validate Vendor Claims Against Your Stated Accessibility Requirements Trust but verify Test for accessibility Step 5: Validate Compliance Over Time (If an Ongoing Contract) ICT must remain accessible throughout the contract period of performance As ICT solutions are updated, re-test each new version against the Section 508 requirements originally established in the contract 8
COTS Solutions (1 of 2) COTS Solutions (1 of 2) Step 1: Requiring official identifies specific product or service to be purchased and acquisition method (existing contract vehicles or purchase cards) Determine if a Section 508 exception applies; if not proceed to step 2 E202.3 National Security Systems E202.4 Federal Contracts E202.5 ICT Functions Located in Maintenance or Monitoring Spaces (status indicators and operable parts) Step 2: Obtain an Accessibility Conformance Report (ACR) Request ACR from vendor ACR developed by vendor using the IT Industry Council s Voluntary Product Accessibility Template (VPAT ) Version 2.x NASA SEWP (GWAC) facilitates obtaining Accessibility Conformance Reports from Industry by requiring contract holders to provide reports at time of quote upon customer request Step 3: Evaluate ACR to determine overall level of conformance Full Conformance = all applicable technical standards are fully supported Partial Conformance = not all applicable standards are fully supported Non-Conformance = most applicable standards are not fully supported 9
COTS Solutions (2 of 2) COTS Solutions (2 of 2) Step 4: If not Full Conformance , determine if more conformant alternatives are available Perform Market Research Review ACRs of comparable products Step 5: Determine possible exceptions* Develop Exception documentation as required E202.6 Undue Burden E202.6 Fundamental Alteration E202.7 Best Meets Purchase Product Step 6: Provide individuals with disabilities access to and use of information and data by an alternative means as needed * NOTE: Applicability of exceptions is never determined by industry - only by government 10
Best Practices Best Practices Collaboration among Office of Chief Information Officer/Section 508 Program Managers, acquisition experts, customers, and Industry yields accessible solutions that are available and responsive to needs Identifying accessibility requirements early in the acquisition lifecycle prevents costly rework Determine if accessible solutions are available by reviewing ACRs, visiting Industry websites, and by collaborating with colleagues Inform Industry that Government requires ACRs and evaluates proposals for Section 508 compliance Use GWAC vehicles or other existing government contract solutions which facilitate obtaining ACRs, such as NASA SEWP which allows customers to request conformance reports to be provided at time of quote When developing solicitations, use automated requirements tools and Section 508 checklists where possible to help identify ICT accessibility requirements 11
Resources Resources Section508.gov: https://www.section508.gov/ Section 508 Standards refresh: https://www.access-board.gov/guidelines-and- standards/communications-and-it/about-the-ict-refresh Complete New Section 508 Standards and Appendices: https://www.govinfo.gov/content/pkg/CFR-2017-title36-vol3/xml/CFR-2017- title36-vol3-part1194.xml Web Content Accessibility Guidelines: https://www.w3.org/TR/WCAG20/ Accessibility Conformance Report (ACR) Template / VPAT: http://www.itic.org/resources/vpat/VPAT2.4Rev508--February2020.doc NASA Solutions for Enterprise-Wide Procurement: https://www.sewp.nasa.gov/ Federal CIO Council Accessibility Community of Practice Industry Outreach Betsy Sirk Email: betsy.sirk@nasa.gov Antonio Haileselassie Email: antonio.o.haileselassie@nasa.gov 12
