U S General Services Administration Accessibility Requirements for

U. S. General Services Administration Accessibility Requirements for Micro-purchases John Sullivan GSA Smart. Pay Training Forum August 4 -5, 2020

Purpose and Objectives Purpose: • Explain how Section 508 requirements apply to ICT micro-purchases Objectives: • Define Section 508 and how it applies to your procurement • Identify a micro-purchase • Determine the impact of Section 508 standards on micro-purchases 2

Section 508 of the Rehabilitation Act • As of 1998, amendments to the Rehabilitation Act of 1973 require Federal agencies to make electronic and information technology accessible to people with disabilities. • Section 508 eliminates barriers in information technology, opens new opportunities for people with disabilities, and Section 508 is a encourages development of technologies that will help achieve required standard and you have a these goals. • Section 508 applies to all federal agencies and the U. S. Postal comply. Service when they “develop, procure, maintain, or use” ICT. vested interest to 3

Accessibility for All What disabilities does Section 508 cover? : • Visual, hearing, mobility, cognitive, other What does Section 508 apply to? : All ICT products and services that you purchase, including small dollar purchases known as micro-purchases. Review the standards and regulations below for more information on Section 508 and how to support implementation of accessibility standards. • Section 508. gov • Section 508 Standards • Section 508 Federal Acquisition Regulation (FAR) • Micro-purchase and the FAR 4

What Is a Micro-purchase? FAR Subpart 13. 2 defines a micro-purchase as: • “an acquisition of supplies or services using simplified acquisition procedures, the aggregate amount of which does not exceed the micro-purchase threshold” • The micro-purchase threshold is $10, 000 • Always check FAR Subpart 13. 2 for the current micropurchase threshold information and any exceptions that may apply to your procurement 5

Micro-purchases and Section 508 (1 of 2) Who is responsible for following the micro-purchase standards? : All Government employees that purchase ICT, such as Requiring Officials, Contracting Officers, Approving Officials, and other “Government Buyers” must be aware of their responsibilities regarding Section 508. Preferred Purchasing Method: The government-wide commercial purchase card is the preferred method to buy goods and services that do not exceed the micro-purchase limit, this includes cardholders using a government purchase card. Requiring Official: When you decide you want to procure something, you become the “Requiring Official. ” Requiring Officials “own” the need and requirements that will be met by the contract. If you are a Requiring Official, you may have several different responsibilities that require that you understand the Section 508 accessibility standards. 6

Micro-purchases and Section 508 (2 of 2) Government Buyer: A “Government Buyer” is an individual given written delegation to procure on behalf of the government and are the only individuals authorized to obligate the government for the purchase of goods/services (FAR 1. 602 -2 and FAR 1. 603 -3). Approving Official (AO): In purchase card programs, the AO ensures that the purchase card is used properly. The AO authorizes cardholder purchases and makes sure that the statements are reconciled and submitted to the designated billing office in a timely manner. The AO also reviews proposed purchases to ensure that purchase cardholders comply with Section 508 requirements. 7

Micro-Purchase Process Overview The following six steps are tasks you must perform when making a micro-purchase to follow the FAR and Section 508: 1. Determine if your requirement is considered ICT 2. Determine which Section 508 standards apply to your requirement 3. Perform market research 4. Complete documentation 5. Perform any additional agency-specific procedures or requirements (such as receiving AO approval) 6. Purchase your product or service 8

What is Considered ICT? • The Architectural and Transportation Barriers Compliance Board (Access Board) defines Information and Communication Technology (ICT) as: Information technology and other equipment, systems, technologies, or processes, for which the principal function is the creation, manipulation, storage, display, receipt, or transmission of electronic data and information, as well as any associated content. • ICT Includes but is not limited to: q Computers and peripheral equipment q Information kiosks and transaction machines q Telecommunications equipment q Applications q Websites q Customer premises equipment q Multifunction office machines q Videos q Electronic documents Example: A multifunction machine is definitely ICT 9

What Section 508 Standards Apply to ICT When purchasing ICT, you must determine which Section 508 technical standards apply to the product or service you are procuring. There are Section 508 technical standards for: • Electronic content, including websites and agency communications • Hardware • Software • Support documentation and services (i. e. help desk services) These standards are all defined in CFR Part 1194, Appendices A-C 10

Generating Section 508 Procurement Requirements The General Services Administration has numerous free resources on www. section 508. gov that can help you develop Section 508 requirements for your procurement of ICT. Accessibility Requirements Tool (ART): ART is a tool for generating accessibility requirements for inclusion in procurement language. For micro-purchases, while you won’t be defining contractual language or custom-defined accessibility requirements, the “sample procurement language” listed within ART contains accessibility requirements for 40+ typical ICT procurements. Additional research may be needed (seek assistance from your agency’s Section 508 PM). 11

Section 508 Exceptions There are some general exceptions that pertain to Section 508: Ask your 508 PM if any of these apply to your procurement, and document which exception applies. Worth noting is that exceptions rarely apply to micropurchases. However, here are some common exceptions: • • • Legacy ICT National Security Federal Contracts (ICT that is incidental to a contract, but won’t be part of the delivered procurement) ICT Functions Located in Maintenance or Monitoring Spaces Undue Burden or Fundamental Alteration Best Meets (due to commercial non-availability) 12

Procurement: Market Research (1 of 2) Once you know which Section 508 technical standards apply to your micro-purchase, you must perform market research. Regarding accessibility, the goal of market research is to find a Section 508 conformant product or service for your procurement or to decide which of the available products or services best meets the accessibility requirements. Steps for conducting market research for accessible products are defined on GSA’s Section 508. gov website under the Buy Accessible Products and Services, Market Research section. 13

Procurement: Market Research (2 of 2) Steps for conducting market research include: 1. Determine your business need: What functionality do you require? 2. Search for possible solutions that could meet your business needs. Review the information you obtain. 3. For micro-purchases, this activity will primarily consist of gathering and comparing the Accessibility Conformance Reports or product VPATs for the options you are considering. 4. Your responsibility here is to identify which options best meets the accessibility requirements you defined in Step 2 of the micro-purchase process. **Note: Please see the notes section for more detailed information on the how to conduct market research for accessible ICT products or services. 14

Micro-purchase Documentation • • Document your justification for the solution you select, and explain why other possible solutions were not chosen If claiming exception to 508 conformance, you must document in writing that your 508 PM verified that a 508 exception applies for this micro-purchase If you purchase an ICT product or service that is not fully Section 508 conformant, you must document that you conducted adequate market research and provide a justification of your reasons for the purchase (i. e. , budget, mission) In addition, you must complete any documentation required by your agency for the procurement Multi-function Machine Section 508 Compliance Documentation 15

Agency Specific Policies & Procedures • • • All agencies are required to adhere to Section 508; however, procedures may differ from one agency to another. As a cardholder, it is your responsibility to be aware of any agency-specific policies and procedures related to ICT micro-purchases and Section 508. If you are unsure of any agency-specific policies and procedures, check with your agency's Office of the Chief Information Officer (OCIO), Procurement Officer, and/or your Section 508 Program Manager or Section 508 Coordinator. 16

Complete Your ICT Purchase The final step in the process is to purchase your product or service. Follow your agency’s procurement practices to complete your purchase, remembering to maintain records of your efforts to ensure the accessibility of your procurement. 17

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