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Play 8: Integrate Accessibility Needs into Market Research and Acquisition Processes

Integrating accessibility into market research and acquisition is essential to meet Section 508 requirements and to provide equivalent access to electronic information and digital services. This play provides practical guidance to help agencies identify and address accessibility needs during planning, requirements development, evaluation, and acceptance. It includes key questions, checklists, and metrics to reduce compliance risk and ensure technology solutions are usable by everyone—including users with disabilities.

Key Questions

  • How does your agency ensure that Section 508 compliance requirements are clearly and accurately included in solicitation documentation and processes?
  • What steps does your agency take to verify the accuracy of vendors' Section 508 conformance claims? Are these steps strong enough to reduce the risk of non-conformance?
  • How does your agency fulfill its legal obligation to procure digital services and technology that fully meet—or best meet—Section 508 requirements?
  • What testing or procedures ensure that the final product being procured or developed is accessible to users with disabilities?

Checklists

Table 1: Play 8 Basic Checklist—General Preparation
Item Actions
Review the Federal Acquisition Regulation (FAR), focusing on sections that address Section 508—particularly ​Parts 39.2, ​10, and ​11, among others.
Note: Stay informed about changes to the FAR, referred to as the Revolutionary FAR Overhaul, that may affect how accessibility requirements are addressed in the acquisition process.
Identify and understand your agency’s acquisition policies and procedures related to procuring information and communication technology.
Determine if the Section 508 Standards are adequately addressed in current acquisition policies and procedures. If gaps exist, collaborate with the appropriate stakeholders to make necessary updates.
Define criteria for when and how to include the following in solicitations:
  • Acceptance criteria
  • Applicable exceptions
  • Curing processes and procedures
  • Evaluation methods
  • Proposal response requirements
  • Section 508 ICT accessibility requirements
  • Terms and conditions
Ensure Contracting Officers are aware of their responsibilities and know what to expect from Requiring Officials regarding Section 508.
Ensure Requiring Officials:
  • Include appropriate accessibility language in solicitations
  • Know when and whom to contact for accessibility guidance
Establish a formal Section 508 compliance determination process, and document all decisions using relevant artifacts—such as Market Research, Accessibility Conformance Reports (ACR), Supplemental ACRs, Exceptions or “Best Meets” justifications, and test results.
Establish a formal Section 508 Exceptions Request and Approval Process to include appropriate tracking and reporting.
Require independent expert reviews of vendor conformance claims and Section 508 exceptions before contract award.
Apply a risk-based model to determine when independent accessibility testing is needed to validate vendor claims. Use the forthcoming federal accessibility risk model as a guide.
Establish processes to ensure Section 508 conformance is considered in evaluation and award decisions.
Authorize the Section 508 Program team to halt contracts or procurements that pose significant compliance risks.
Create a process to track and monitor Section 508 compliance activities across all technology procurements.
Plan for “alternative means” when a fully accessible solution cannot be procured, and document your process for implementation.

Table 2: Play 8 Basic Checklist—ICT Procurement Preparation
Task Resources
Work with program managers or requiring officials to define, review, and approve applicable Section 508 standards and/or exceptions.
Consider accessibility needs during market research.
Include Section 508 contract language and accessibility terms and conditions, as required:
Ensure accessibility is part of the contract evaluation plan, and clearly define the role of the Section 508 subject matter expert on the Technical Evaluation Panel.
Require vendors to provide detailed responses to accessibility requirements in the Statement of Work.
Confirm vendor conformance claims using expert analysis and appropriate documentation, such as Accessibility Conformance Reports (ACRs).
Require Accessibility Conformance Reports for all solicitation responses.
Include accessibility requirements in the Quality Assurance Surveillance Plan (QASP) in each project plan.
When another agency claims a product is conformant, verify that:
  • Section 508 test processes endorsed by the ICT Testing Baselines were used
  • DHS Trusted Tester—certified professionals conducted the testing (if applicable) If confirmed, consider accepting the prior determination to streamline your review
Conduct accessibility testing:
  • Before award for commercially available solutions
  • Before acceptance for custom-developed, customized, or integrated technology solutions—See Play 10 for more on testing.
Provide all relevant documentation—including conformance claims, expert analysis, and test results—to the Decision Making Team (pre-award) or Contracting Officer (pre-acceptance).
Ensure Section 508 compliance is factored into award decisions. If no product fully meets the standards, document which one "best meets" the standards—see E202.7.
Conduct an alternative means assessment when products fall short of full compliance, and document how impacted users with disabilities will be provided equivalent access to the information or functionality.
Follow through on post-award contract acceptance activities as specified in the solicitation.
Develop and track remediation or alternative means plans when a fully accessible solution is not procured.

Table 3: Play 8 Advanced Checklist—ICT Procurement Preparation
Task Resources
Include contract language that allows for penalties or requires remediation at the contractor's expense when accessibility requirements are not met.
Develop standard language and procedures for Blanket Purchase Agreements (BPAs) and other task order–based contracting vehicles to ensure accessibility requirements are included.
Consider establishing a process to assess the maturity of a vendor’s accessibility program during market research and proposal evaluation.
Conduct post-award reviews and audits to confirm conformance with accessibility requirements, and use the findings to strengthen future procurement practices.
Collaborate with other agencies in the Section 508 community to share insights and experiences with vendors and products.

Key Performance Indicators (KPI)

This section outlines Key Performance Indicators (KPIs) to track and measure accessibility testing, remediation, and overall Section 508 conformance across web, intranet, and enterprise ICT solutions.

Generic KPI: In FY2X, include sufficient ICT accessibility requirements in XX% of ICT related solicitations.

Generic KPI: In FY2X, consider Section 508 conformance as a part of market research phase of ICT Acquisitions for XX% of upcoming solicitations.
Note: This is before the acquisition or development phase.

Generic KPI: In FY2X, verify XX% of milestone/major deliverables for Section 508 conformance.

Generic KPI: By FY2X explicitly include Section 508 as a technical factor in the evaluation of proposals of ICT services and products.

Generic KPI: By FY2X, ensure that XX% of solicitations released in the XX include all applicable Section 508 requirements.

Generic KPI: By QX FY2X, define a plan to purchase, replace, or remediate all non-conformant ICT in the enterprise IT portfolio.

Generic KPI: By EOFY FY2X require remediation or purchase a new Enterprise Email Application that can be accessed and used by all users.

Generic KPI: By EOFY FY2X remediate existing platform or purchase a new meeting platform that can be accessed and used by all users.

Generic KPI: By EOFY FY2X replace, remediate, or purchase a new Time and Attendance System that can be accessed and used by all users.

Generic KPI: By EOFY FY2X require remediation or purchase a new Virtual Meeting Platform that can be accessed and used by all users.

Reviewed/Updated: September 2025

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