This guide focuses on Accessibility in procurement. Contracting Officers (COs)/Contract Specialists (CSs) play an integral role in the Information and Communication Technology (ICT) lifecycle. Including them early on in the process will ensure optimal results in ensuring products are fully accessible. The procurement process is very dynamic and can be very overwhelming.
The purpose of this guide is to align acquisition professionals within Technology Transformation Services (TTS) with its process and mission; provide a user-friendly approach to incorporating accessibility into the lifecycle of ICT projects; and provide a tool to support the inclusion of procurement personnel throughout the process. This guide follows agile principles and should be iterated on, as needed. It can be applied to any part of the General Services Administration (GSA) and other federal agencies.
ICT must be accessible to people with physical, sensory, and cognitive disabilities. Access to ICT is addressed by US Acess Board standards and guidelines under section 508 of the Rehabilitation Act and Section 255 of the Communications Act. These ICT Accessibility standards include requirements that ensure compatibility with assistive technology (AT) used by people with disabilities. Federal Acquisition Regulation (FAR) Subpart 39. Information and Communication Technology also governs the procurement of Accessible technology.
Defining the Requirement
The most important step in acquiring accessible products is defining the requirements. What is the project team, client, partner, etc. interested in procuring? What are the minimum specifications? Is there a timeline? Is it a standalone item or is it something that involves multiple items in order to make the requirement successful?
Documenting what products are currently available in the market is important to understand if the Government can meet its needs with a commercial-off-the-shelf (COTS) item. This can be done through Requests for Information (*RFIs), sources sought notices, industry days, general internet searches, etc.
In some instances, a particular dollar threshold will require higher-level approvals and more stakeholders. At the basic level, personnel from the technical, acquisition, and financial offices should be included from the beginning. Although not always a requirement, involving legal can be necessary to avoid any issues later on, so keep that in mind as questions arise during the process.
The Information Technology (IT) office should be involved as early as possible to ensure all agency and federal-level approvals are met. Keep in mind, this process can be lengthy and impact the acquisition of a particular product, especially with regards to security requirements.
Before doing market research, understanding accessibility regulations will help you identify compliant products. An RFI can request a vendor to provide an updated Voluntary Product Accessibility Template (VPAT®) or comparable Accessible Conformance Report (ACR). It may also be publicly available if a vendor opts to post it to its website.
It is critical that one or more of the stakeholders be familiar with the VPAT® or ACR. An agency may have a point of contact who may serve as the Subject Matter Expert (SME) to review and comment on accessibility claims made by a vendor. This will be necessary during the process, especially evaluating accessibility during pre- and post-award. For the Section 508 Program Managers currently supporting TTS and GSA, please visit Find Your 508 Program Manager.
- [VPAT Revised Section 508 Edition (March 2022)(DOC)
- Web Content Accessibility Guidelines (WCAG) 2.1
- VPAT WCAG Edition (March 2022) (DOC)
What if a product or service does not meet all of the Accessibility requirements? [Section E202.7 Best Meets of the Revised 508 Standards states that if one cannot find an accessible commercial solution, an agency should procure the ICT solution that best meets the standards consistent with business needs. If no technically acceptable alternative fully conforms to the Revised 508 Standards, select the alternative that best meets the standards when making an award, and request a “best meets” exception. Where product features or components are not fully accessible, the agency is required to make available alternate means of accessing the information or functions supported by the ICT.
GSA also has the Accessibility Requirements Tool (ART) which is a user-friendly form that will develop language for including Accessibility requirements in a solicitation.
Sample Language for RFI:
Please provide a copy of the most updated version of the appropriate Voluntary Procurement Accessibility Template (VPAT® (or similar Accessibility Conformance Report(s) (ACR))). In addition, please provide the contact information for an individual most qualified to speak to the accessibility of this product/service.
Reviewed/Updated: September 2023