Procurement
Where the Rubber
Meets the Road

508 Has Four Parts

Part A

General information

Part B

Technical Standards

Part C

Functional Performance Criteria

Part D

Information, Documentation, and Support

For Us

In terms of conforming to the standards, we can ignore A and D.
When determining accessibility, follow B or C, not both.

We'll discuss which to use as we go along.

Where Do We Begin

Only electronic and information technology (E&IT) is covered by Section 508.
First determine if the proposed purchase is for E&IT.

Categories of E&IT

Software applications and operating systems
Web-based information and applications
Telecommunications products
Video and multimedia products
Self-contained, closed products (e.g., kiosks)
Desktop and portable computers

Definition

E&IT is defined by federal regulations as any equipment or interconnected system of equipment that is used in the creation, conversion, or duplication of data or information, or used in the automatic acquisition, storage, manipulation, management, movement, control, display, switching, interchange, transmission, or reception of data or information.
The term does not include any equipment that contains embedded information technology that is used as an integral part of the product, but the principal function of which is *not* the creation, conversion, duplication, acquisition, storage, manipulation, management, movement, control, display, switching, interchange, transmission, or reception of data or information.

?????????

Anyone else's brain just go TILT?

Rule of Thumb

Is it electronic? And/or does it fit in one of those six categories?
Does it have a display and/or keypad that humans interact with?
Does that display have information about creating, converting, sending, receiving, or duplicating any sort of data or information?
If you answer yes to all of these, you are dealing with E&IT.

Examples of E&IT under 508

Faxes
Scanners
Printers
Copiers
PDAs
Computers
Computer software
Computer operating systems

Phones
Information kiosks
ATMs
Multimedia
Videos
World Wide Web

Not E&IT under 508

Microwaves (unless it sends faxes, too)
Coffee makers
Heating and ventilation systems
Thermostats

How to Buy under 508

Technical requirements drive the procurement, not Section 508.
First determine your needs. Then consider 508 accessibility.

Overview

Figure out as specifically as possible what you need.
Decide whether to use Part B or Part C of the standards.

More on this in a bit.

Do market research.
Use VPATs and/or a checklist.
Pick the most accessible product that meets your needs.

What Do You Need?

Be clear about your functional requirements

What are the technical specifications?

How fast? how many pages? how big/small?
What features? What functions?

What are the minimum requirements?
What specific need does the product meet (i.e., what must it do)?
Are there specific academic considerations to be taken into account?

Document your needs.

Add Accessibility into the Equation

Once you have determined your needs, research the market.

You already do market research for models, prices, features, durability, etc.
Just make accessibility one more item on the list.

Getting Technical

Each of the six E&IT categories has a list of technical specifications in Part B of Section 508.
Example for video/multimedia

http://www.uspto.gov/web/offices/cio/s508/vendor_mm.doc

The First Three Categories

Software applications and operating systems

http://www.section508.gov/index.cfm?FuseAction=Content&ID=12#Software

Web-based information and applications

http://www.section508.gov/index.cfm?FuseAction=Content&ID=12#Web

Telecommunications products

http://www.section508.gov/index.cfm?FuseAction=Content&ID=12#Telecommunications

The Last Three Categories

Video and multimedia products

http://www.section508.gov/index.cfm?FuseAction=Content&ID=12#Video

Self-contained, closed products

http://www.section508.gov/index.cfm?FuseAction=Content&ID=12#Self

Desktop and portable computers

http://www.section508.gov/index.cfm?FuseAction=Content&ID=12#Desktop

Researching Accessbility

VPATs

Voluntary Product Accessibility Templates
Done by vendors
Not always done well but getting better

Examples

http://www.microsoft.com/industry/government/section508.mspx#ECAA
http://images.apple.com/accessibility/

You Can Create Your Own Checklist

Use the technical standards in Part B as a checklist.
Some federal agencies send checklists to vendors and only consider vendors who complete the checklists.
Example

http://www.uspto.gov/web/offices/cio/s508/vendor_sw.doc

Talk to Vendors

Ask vendors how their products are accessible, not just whether they are.
Ask them how they meet specific standard.
If you are suspicious of anything on the VPAT, question their representative.
Don't just accept the statement that they are fully accessible. Ask for specifics.

BEWARE!

There is no such thing as "508 Certification."
If a vendor claims that their product has been "certified" as being "508 compliant," they are not being truthful.
Currently, no independent agency certifies that a product conforms to the 508 standard, nor is there any sort of "508 seal."

Organize the Information

Using the standards from Part B, create a table listing how each vendor did with a particular standard.
Add your columns and decide who met the most standards.

Analyze the Competition

Choose

You have already determined that all of these products meet your needs, so choose the most accessible.
If there is a tie, choose whichever you prefer.
If you choose a less accessible model, there needs to be a compelling reason (other than price!).

In General

The federal government follows Part B unless the standards do not directly apply, in which case they look to Part C.
Part C is also a way to get an overview of the product.
If using Part B is too complex at this time, you may want to start just witn Part C.

However…

For major purchases

Consult the 508 committee
Study VPATs and checklists

Be wary of anyone who says they are fully 508 conformant. Few products are at this point, and that is a sign that you need to ask the vendor how they conform.

Analyze the competition
Choose the most accessible product.

For Smaller Purchases

If using Part C seems easier, you might want to do that.
Part C deals with Functional Performance Criteria.

Part C on Vision

Vision. Provide at least one mode of operation and information retrieval that does not require user vision, or support for assistive technology.
Visual acuity. Provide audio output and enlarged print output working together or independently at least one mode of operation and information retrieval that does not require visual acuity above 20/70, or support for assistive technology.

In other words…

Can someone who cannot see at all or who sees little operate this equipment?
If they cannot operate it as is, can they hook up a piece of assistive technology (AT) that will allow them to operate it?
AT might be a refreshable Braille display, a screen reader, an enlarging program, etc.

Part C on Hearing

Hearing. Provide at least one mode of operation and information retrieval that does not require hearing, or support for assistive technology.
Audio information. Provide at least one mode of operation and information retrieval in enhanced auditory fashion where audio information is important for use of a product, or support for assistive technology

AT Might Be

TTY
Blinking/vibrating signals
Hearing aid adapters

Part C on Speech & Motor Control

Speech. Provide at least one mode of operation and information retrieval that does not require speech, or support for assistive technology.
Motor skills/ coordination. Provide at least one mode of operation and information retrieval that does not require fine-motor control or simultaneous actions and that is operable with limited reach and strength.

For speech could be

Keyboard/keypad input
Mouse input

For mobility could be

Paddle handles
Switches
Large controls
Automatic openers

Brainstorm

Your campus wants to install information kiosks. The kiosks have touch screens and give voice prompts when you need to enter information.
What aspects of accessibility would you want to keep in mind.

Incorporating the Standards

Look at your current procurement processes.

Add the language from Ralph Black's letter.

Figure out where you can add an accessibility check into the current workflow.
See if you can hook the accessibility check onto procedures that are currently mandated.
Keep it as simple as possible.

Brainstorm

On your campus…

Who would come up with the technical specifications for the equipment? (person ordering? Department chair?)
Who should check VPATs or talk to vendors?
Who should make sure that the specs are documented and the research is done?
Who should analyze the research results?

Tips from the USPTO

Identify existing processes & overlay 508 on mandatory processes
Make 508 part of procurement
Beware of bottlenecks
Keep the process simple
Minimize requirements
Discourage waivers/exemptions
Have the 508 program be added value
Do not create unenforceable processes
Allow some flexibility
Train everyone

Web Links

Good Overview

www.ittatc.org/technical/508_overview.cfm

Creating Policy

www.ittatc.org/state/policy/

E-learning

www.access-board.gov/508.htm

508 Information

www.section508.gov

Excellent examples

www.uspto.gov/web/offices/cio/s508/