U S General Services Administration Policy the Procurement

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

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

3 Important Terms 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 Accessible design allows the use of assistive technology 4

3 Important Terms 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 Assistive Technology can be provided as an accommodation, but requires accessible E&IT to be useful – required by Section 508 5

3 Important Terms 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 (29 U. S. C) 6

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

Section 508 Overview 8

Section 508 of the Rehabilitation Act Ø 2000 amendment to Section 508 required Federal agencies to make EIT accessible Ø 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 Ø Section 508 mandated GSA and the Access Board to provide technical assistance on the requirements of the law to Federal departments and agencies 9 9

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

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

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

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

Simulated Glaucoma

Simulated Macular Degeneration

It happens more often than you'd imagine Ø Just over 1 in 4 of today's 20 year-olds will become disabled before they retire. (SSA) Ø 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) Ø 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) Ø In December of 2010, there were over 2. 5 million disabled workers in their 20 s, 30 s, and 40 s receiving SSDI benefits. (SSA)

Disability Statistics Ø 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. Ø 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. Ø 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

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!

Disability Statistics Ø Disability in America Ø More than 30 million Americans between the ages of 21 and 64 are disabled, according to the most recent U. S. Census. Ø 2. 3 million people filed disability claims with Social Security in 2008. Ø 25+ million American lives are restricted by the effects of disability, according to the Centers for Disease Control and Prevention.

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

Dissecting the Law Ø 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

Dissecting the Law Ø 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 Ø Subpart D Consists of information, documentation and support Requires manufacturer upon request, to provide compliant electronic text for all documentation associated with the product

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

First Cell Phone - 1973

First Portable Computer - 1981

First Website - 1991

What does Section 508 Apply To? Ø Section 508 applies to ALL EIT contract vehicles and procurement actions, including micro-purchases. Ø All EIT that is “procured, maintained, developed, or used” Ø 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. 27

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

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

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

IT/CIO Responsibilities Ø IT/CIO is responsible for: Identifying current needs for IT purchases Ø 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

Agency EIT Developers Responsibilities Ø 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

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

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

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

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

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

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

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

What Makes a Successful Program Ø Ø Ø Ø Ø 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 40

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

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

Section 508 Exceptions Ø National Security Ø Any EIT operated by agencies, the function, operation, or use of which involves intelligence activities, cryptologic activities related to national security, command 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). 43

Section 508 Exceptions Ø Incidental to a Contract: Ø This part does not apply to electronic and information technology that is acquired by a contractor incidental to a contract. Ø Back Office: Ø 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 44

Information, Documentation & Support Ø 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 enduser installable devices, and customer support and technical support communications. Such information must be available in alternate formats upon request at no additional charge. Ø NOTE: This should be included in every solicitation whether or not it is EIT 45

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

FAR Part 39. 2 Acquisition of EIT states: Ø When acquiring EIT, agencies must ensure that— Ø (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 Ø (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. 47

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

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

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

Solicitation Assessment Progress From Inception to Date 51 51

How long can you wait for Section 508 Compliance? 52

Lets take a break! 53

Buy Accessible Ø What is it? Ø Who should use it? Ø How can it help? Ø Market Research Ø How do I get started? Ø Features Ø Where do I get training? 54

What is the Buy Accessible Wizard? Ø 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 Ø The Accessibility Resource Center (ARC) has access to vendor provided accessibility information 55

Who Should Use the BA Wizard? Ø Requirements Officials – responsible for writing SOW and providing requirements for the procurement Ø Technical specialists (IT) - determine IT requirements Ø Micro purchasers (IT) with government purchase cards Ø Anyone else involved in the procurement process Ø Who are the Gate Keepers Ø Procurement officials – responsible for monitoring procurements and regulations (gate keeper) Ø Contract officers – responsible for the contract award process (gate keeper) Ø Contract Specialists – responsible for preparing RFQ/RFP 56

How Can the Wizard Help Your Agency? Ø Standardize the acquisition process by documenting your procedures to demonstrate due diligence Ø Market Research recording within the tool Ø Tailor your solicitations by ensuring there is specific Section 508 language and technical requirements in solicitations that include EIT 57

Market Research Why do it? Ø It’s FAR Requirement Ø It’s used to gauge the state of the EIT industry in meeting your requirements with products and services Ø Method for identifying products that claim to meet section 508 requirements 58

Getting Started with the Wizard…… Ø Anyone can log in as a “Guest” user No ID or password required Can save or print output Can restart process 59

BAW Features Ø 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. Design Guide: Provides qualified development resources 60

Section 508 BAW Quick Links 61

Why Quick Links? Ø Some buyers are in a hurry. Ø Some buyers know exactly what they want. Ø Some buyers don’t want to take the time to learn about Section 508. “Just get me to the bottom line and fast!” 62

What are Quick Links Ø Inputs are common and standard deliverables (products and services) Ø Current outputs are solicitation documents associated with these deliverables. 63

Quick Links Currently Provide: Ø Standard definition of the deliverable Ø GPAT: Technical standards (Subpart B) Functional performance criteria (Subpart C) Information, documentation and support (Subpart D) Ø 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) 64

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Be Our Guest for a Test Drive Ø We invite you to test drive the Buy Accessible Wizard Ø To access the Buy Accessible Wizard go to: http: //www. buyaccessible. gov 66

It’s the BLOB!!!!!! No, it’s the new Section 508 http: //buyaccessible. net/blog. Bl og Stop by and take a look! 67

Big Picture Ø Section 508 should ultimately become transparent and simply part of doing business Ø Interagency support/collaboration needs to improve Ø Need for a more cohesive 508 Community Ø Need to improve ability to share 508 results/resources (test results, training, procedures, etc) 68

Resources Ø Ø Ø Ø www. section 508. gov www. buyaccessible. gov www. access-board. gov Web Accessibility Evaluation and Repair Tools: http: //www. w 3. 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%20 B%20%20 accessibility%20 checklist. pdf Web. AIM: http: //webaim. org 69

Questions?

Buy Accessible Wizard Demo 71

Thank you Ø Contact Information: Helen Chamberlain helen. chamberlain@gsa. gov 72

Additional Slides 73

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