GSA's Section 508 team has conducted a solicitation assessment program since 2007 to gain insight into how well Section 508 accessibility requirements are correctly considered in government procurements that contain deliverables related to Information and Communication Technology (ICT). Results from this program are provided to Federal Agencies to help them improve their performance. This process is broken down into 4 sequential phases; Sampling, Assessment, Feedback, and Metrics as illustrated below.
Information flow between each process phase is annotated in the flow diagram by red text call-outs associated with the connections between processes phases and stakeholders:
- Solicitation Listings: this information flows from the stakeholder FedBizOpps (FBO) as input to the initial phase "Sampling".
- Selected EIT Solicitation: this information flows as output from the first phase "Sampling" to become input into the second phase "Assessment".
- Assessed EIT Solicitation: this information flows as output from the second phase "Assessment" to become input into the third phase "Feedback".
- Feedback Notice: this information flows as output from the third phase "Feedback" to the stakeholder "Agency Contact".
- EIT Solicitation Metrics: this information flows as output from the third phase "Feedback" to become input to the fourth phase "Metrics".
- Monthly Report: this information flows as output from the fourth phase "Metrics" to the stakeholder "GSA".
The documents "FAR Parts 7, 10, 11, and 39" and "Access Board Standard CFR 1194" are shown as supporting resources connected to the phase "Assessment".
Each process phase is described in more detail below.
Each day the Computer Aided Bid Assessment (CABA) tool is used to select a sample of the daily Federal Business Opportunities (FBO or FedBizOpps) postings to be assessed. FBO postings are randomly selected for CABA each day from the set of new or revised solicitations. Each posting is ranked by CABA based on the likelihood that posted solicitations contain ICT deliverables using heuristics, keywords, and history of previous assessments including:
- Classification Code indicating the service or supply (FAR Section 5.207(g))
- NAICS code
- Words used in the solicitation title
The postings are separated into a DoD and a Civilian list of the ten highest rankings.
The assessment process is conducted by analysts in order to:
Check for ICT Deliverables
Verify that solicitation contains ICT deliverables and thus subject to Section 508.
Apply assessment criteria
Requirements Agencies should include in their solicitation
- 1194 Subpart B – Technical Sections and Provisions: Identified applicable technical sections or provisions within Subpart B (e.g. 1194.2x or 1194.2x(y)).
- 1194 Subpart C – Functional Performance Criteria: Identified applicability of Subpart C or specific provisions within (1194.31 or 1194.31(x)).
- 1194 Subpart D – Information, Documentation and Support: Identified applicability of Subpart D or specific provisions within ((1194.41 or 1194.41(x)).
Things to avoid in solicitations
- No Section 508 Reference: Had no mention or only a vague, non-specific Section 508 reference
- Inaccessible Documentation: All or portions of the solicitation, associated documents, or attachments were in an inaccessible format
- Section 508 Relevance: Made a statement or implied that Section 508 Relevance should be determined by the vendor
- Section 508 Exception: Made a statement or implied that Section 508 Exception should be determined by the vendor
- Section 508 Determination: Made a statement or implied that Determination of Section 508 Applicability should be determined by the vendor
- Certificate of Compliance: Requested or implied the receipt of a certificate of compliance
Score each posted solicitation.
Score each assessed solicitation based on these criteria as Fully, Minimally, or Non-Compliant and identify the specific evaluation scenario. Each combination of criteria values constitutes a unique evaluation scenario. The criteria and evaluation scenarios are documented in BuyAccessible Evaluation Scenarios for Solicitations. [docx]
Criteria from CIO.gov
CIO.gov also has an example of metrics that can be used in checking Section 508 Requirements in Procurements. CIO suggests tracking:
- # Solicitations Sampled
- % that state IT must be accessible
- % indicating which Section 508 standard apply to the purchase
- % that request accessibility information from vendors (e.g. VPATs and other clarifying materials)
- % that state how vendor proposals are evaluated for Section 508 compliance, including acceptance criteria
- % containing language giving the agency the option to perform hands-on testing to validate vendor 508 compliance claims
- % requiring product replacements to be equally 508 compliant (or better) than original product purchased
Feedback from the FBO assessments is sent each applicable agency.
An email notification is generated for each fully accessed posting identifying the level of compliance score and specific evaluation scenario. Each notice also contains information to help the agency improve their Section 508 compliance. The GSA Section 508 Program Manager reviews the notices and sends the actual reports to the solicitation point of contacts and Section 508 coordinators within the applicable agency. Agencies are encouraged to engage if they have any questions comments, concerns, or need for further assistance.
Measures of the overall assessment process, including sampling statistics, assessment statistics, and measures of feedback provided are consolidated into a monthly report for review and trend analysis. Overall agency reports are provided upon request.