Ensuring IT Accessibility in Federal Agencies

Section 508 IT Accessibility Through The Acquisition Lifecycle June 14, 2022 Betsy Sirk Section 508 Program Manager, National Aeronautics and Space Administration Chairperson, Federal CIO Council Accessibility Community of Practice Industry Outreach Program Email: betsy.sirk@nasa.gov

Agenda Agenda Section 508 Introduction Why Section 508 Matters Acquisition Overview New Contracts Existing Contracts/Commercial Off The Shelf (COTS) Solutions Best Practices Resources 2

Section 508 Introduction Section 508 Introduction Section 508 of the Rehabilitation Act requires that Federal agencies make Information and Communication Technology (ICT) accessible to all its employees and members of the public regardless of disability IT/ICT defined as any equipment, interconnected system, or subsystem of equipment used in the automatic acquisition, storage, analysis, evaluation, manipulation, management, movement, control, display, switching, interchange, transmission, or reception of data or information Applies to technology that is "procured, developed, maintained, or used" by the Federal Government Examples of ICT include but not limited to: Computers, Hardware, Software/Applications, Peripheral equipment, Scientific/specialized equipment, Office equipment, Multi-function devices, Telecommunications equipment, Websites, Videos, Electronic documents, Official agency communications Original Section 508 technical standards implemented 2001; Revised Section 508 standards published 2017 3

Why Section 508 Matters Why Section 508 Matters Gartner s Top Strategic Predictions for 2020 and beyond include: By 2023, the number of people with disabilities employed will triple due to Artificial Intelligence and emerging technologies reducing barriers to access In US, only 30% of labor force with disabilities is employed huge untapped talent pool Organizations that actively employ people with disabilities: 89% higher retention rates 72% increased employee productivity 29% increased profitability Added diversity = added perspectives Inaccessible technology hurts employees and organizations Accessibility is a win-win situation for Industry and Government Opens the door for the Federal government to purchase ICT Allows Industry to reach a broader customer base Improved customer experience 4

Acquisition Overview Acquisition Overview Federal acquisition processes for procuring ICT solutions provide key opportunities to ensure accessible technology is acquired Building accessibility into acquisitions Enables workforce productivity Improves customer experience Prevents the risk of litigation Prevents expensive retrofitting of ICT solutions Allows those with disabilities an equal footing Including accessibility requirements in acquisitions Depends on what is being procured (Commercial Off The Shelf (COTS) products, custom development, IT support services, etc.) Depends on how it s being procured (Full and open competition, requests for proposals, requests for quotes, established Government-wide Acquisition Vehicles, purchase card, etc.) One size does not fit all 5

New New Contracts Contracts Step 1: Determine accessibility requirements Understand which Section 508 Technical Standards apply to the specific procurement Step 2: Conduct market research Identify accessible products or services available within the market Step 3: Develop solicitation language Include specific relevant accessibility requirements, contract terms and conditions for testing and validation, and expectations throughout the contract period of performance Step 4: Evaluate each proposal to validate Industry claims against the stated accessibility requirements Trust but verify Step 5: Validate compliance over time ICT must remain accessible throughout the contract period of performance As ICT solutions are updated, ensure updates meet Section 508 requirements originally established in the contract 6

Existing Contracts/COTS Solutions Existing Contracts/COTS Solutions (1 of 2) (1 of 2) Step 1: Requiring Official identifies specific product or service to be purchased and acquisition method (i.e. existing contract vehicles or purchase cards) Determine if one of the following Section 508 Exceptions applies. If YES, skip to Step 5; if NO, proceed to Step 2 E202.3 National Security Systems E202.4 Federal Contracts E202.5 ICT Functions Located in Maintenance or Monitoring Spaces (status indicators and operable parts) Step 2: Obtain an Accessibility Conformance Report (ACR) Request ACR from product developer/vendor ACR developed by Industry using the IT Industry Council s Voluntary Product Accessibility Template (VPAT ) Version 2.x Government-wide Acquisition Contract (GWAC) NASA Solutions for Enterprise- Wide Procurement (SEWP) facilitates obtaining ACR from industry by requiring contract holders to provide ACR at time of quote upon request Step 3: Evaluate ACR to determine overall level of conformance Full Conformance = all applicable technical standards are met Partial Conformance = not all applicable standards are met Non-Conformance = most applicable standards are not met 7

Existing Contracts/COTS Existing Contracts/COTS Solutions (2 of (2 of 2) 2) Step 4: If not Full Conformance , determine if more conformant alternatives are available Conduct Market Research for comparable products Review ACRs of comparable products if available Solutions Step 5: Determine and document possible exceptions* E202.3 National Security Systems E202.4 Federal Contracts E202.5 ICT Functions Located in Maintenance or Monitoring Spaces (status indicators and operable parts) E202.6 Undue Burden E202.6 Fundamental Alteration E202.7 Best Meets Develop Exception documentation as required Step 6: Purchase product, and provide access to and use of information and data by an alternative means for those who need it * NOTE: Applicability of exceptions is never determined by Industry - only by government 8

Best Best Practices Practices Identifying accessibility requirements early in the acquisition lifecycle prevents costly rework Collaboration among Office of Chief Information Officer/Section 508 Program Managers, acquisition experts, customers, and Industry yields more accessible ICT Obtaining Accessibility Conformance Reports (ACR) from Industry is critical to ensure accessible ICT is being purchased Inform Industry that government requires ACRs and evaluates proposals and products for Section 508 compliance Review ACRs to promote acquisition of the most accessible IT Share NASA s Demystifying Section 508 Guide with Industry to promote the development of ACRs Use GWAC vehicles, such as NASA SEWP, that facilitate obtaining ACRs at time of quote 9

Resources Resources Download Demystifying Section 508 Guide: https://sewp.nasa.gov/documents/Section_508_Guide_111821.pdf Section 508 Technical Standards: https://www.access-board.gov/ict/ Web Content Accessibility Guidelines: https://www.w3.org/TR/WCAG20/ Accessibility Conformance Report (ACR) Template / VPAT: http://www.itic.org/resources/vpat/VPAT2.4Rev508--February2020.doc Section508.gov: https://www.section508.gov/ NASA Solutions for Enterprise-Wide Procurement: https://www.sewp.nasa.gov/ 10

Q & A 11