1. Section 508 for Beginners

2. Note - The watermark below ("art.com") will not appear on the artwork itself. Note - The watermark below ("art.com") will not appear on the artwork itself. ‘Splain this Section 508 to me Lucy….

3. What is Section 508? Part of 1973 Rehabilitation Act, as amended in 1998 (29 U.S.C. 794d) Titled Part 1194 – Electronic & Information Technology (EIT) Provides comparable access to those with disabilities as to those without – Federal Employees and members of the public

4. 4 Why is Section 508 important? Section 508 creates binding and enforceable provisions and incorporates these provisions into the Federal Acquisition Regulations (FAR Part 39, sub part 39.2 – Electronic & Information Technology).

5. 5 Why is Section 508 Important? It eliminates barriers for people with disabilities Supports Federal initiatives Benefits everyone Achieves legal compliance Promotes positive public image Facilitates public access to Federal information It’s the law!

6. What does Section 508 Apply to? Section 508 applies to ALL contract vehicles and procurement actions, including micro- purchases EIT Products and services All EIT that is “procured, maintained, developed, or used”

7. 7 Who does Section 508 Apply To? Section 508 applies to the Federal Government and the US Postal Service

8. 8 What Are Agencies Responsibilities? Agencies are responsible for Section 508 compliance, not industry Agencies must determine if and how the Section 508 Standard applies, not industry Agencies must conduct market research to determine Section 508 requirements, not just pick a product Agencies must reflect their Section 508 requirements in acquisition solicitations

9. Why Enforce it? Because, It’s the Law It is the right thing to do An agency can be sued You have a vested interest

10. Requiring Official's Responsibilities Understanding the Section 508 requirements and requesting products that are Section 508 compliant If a product does not conform with Section 508, it still may be purchased, but the file must be documented in accordance with the exceptions listings Who can be a requiring official? Section 508 ► Hardware and COTS ► Micro-Purchase ► Software ► Web ► Training

11. Approving Official’s Responsibilities Ensure that the purchasing cardholders within their organization are complying with the Section 508 requirement Review any documentation that has been provided Who can they be? Section 508 ► Hardware and COTS ► Micro-Purchase ► Software ► Web ► Training

12. Purchase Cardholder’s Responsibilities Document, document, document Use the Buy Accessible Wizard Use the Quick Links Section 508 ► Hardware and COTS ► Micro-Purchase ► Software ► Web ► Training

13. 13 How Long can you wait for Section 508 Compliance?

14. Do you know anyone who has problems with: Eye sight, Hearing, Weight, Arthritis, Diabetes, Smoking, Heart, Stomach Lungs, High Blood Pressure or Cholesterol Back, knee, Elbow or Wrist Ailments

15. What About….. …family members? …your friends? …your co-workers? Section 508 ► Hardware and COTS ► Micro-Purchase ► Software ► Web ► Training

16. U.S. Census Data 2006 These numbers are approximate as of the American Community Survey, 2006 41.3 million people with some type of long- lasting condition or disability 11.8 million people with sensory disability 25.7 million people with some type of physical disability 15.9 million people with mental disability Section 508 ► Hardware and COTS ► Micro-Purchase ► Software ► Web ► Training http://www.census.gov/hhes/www/d isability/2006acs.html

17. Section 508 Standard There are four subparts  Subpart A – General  Subpart B – Six Technical standards  Subpart C – Functional performance criteria  Subpart D - Information and documentation requirements Section 508 ► Hardware and COTS ► Micro-Purchase ► Software ► Web ► Training

18. Subpart A Purpose Application General Exceptions Definitions Equivalent Facilitation (equivalent or greater access to and use of)

19. Subpart B Technical Standards  Software applications/operating systems  Web-based information and applications  Telecommunication products  Video and multimedia products  Self-contained, closed products  Desktop and portable computers Section 508 ► Hardware and COTS ► Micro-Purchase ► Software ► Web ► Training

20. Subpart C Functional Performance Criteria  Technologies or components for which there is no specific requirement under the technical standards in Subpart B  At least one mode of operation and information retrieval that does not require user vision, visual acuity, hearing, speech, fine motor control, and enhanced auditory shall be provided Section 508 ► Hardware and COTS ► Micro-Purchase ► Software ► Web ► Training

21. Subpart D Information, Documentation & Support  Product support documentation in alternate formats  Access to descriptions of accessibility and compatibility features of products in alternate formats  Support services for products shall accommodate communication needs of users with disabilities Section 508 ► Hardware and COTS ► Micro-Purchase ► Software ► Web ► Training

22. When determining the appropriate standards remember  More than one category of standards may apply  Not all the standards in a category are necessarily applicable Section 508 Hardware and COTS ► Micro-Purchase ► Software ► Web ► Training

23. Micro-Purchase and Section 508 Purchase Card Program It was made effective April 1, 2005 that all Micro-purchases of EIT products must comply with Section 508 requirements This includes (1) GSA schedule purchases, (2) open market purchases and (3) buys that cost $3,000 or less Section 508 ► Hardware and COTS ► Micro-Purchase ► Software ► Web ► Training

24. It’s 3AM…. Which 508 coordinator are you gonna call? ~ Hillary Clinton

25. Section 508 Policy Section 508 Refresh FAR OMB Directives Section 508 Assessments Buy Accessible Wizard Tool

26. Review of ICT Refresh History §255 guidelines effective (1998) §508 standards effective (2001) Refresh process starts (2006 – 2008): TEITAC TEITAC report: April 3, 2008 ANPRM: March 22, 2010 Public hearings  San Diego, CA; March 25, 2010  Washington, DC; May 12, 2010 Public comment period ended: June 21, 2010

27. Next Steps Analyze comments Develop proposed rule (NPRM) Develop regulatory assessment Submit to Office of Management and Budget Publish NPRM in the Federal Register  Public comment period Final rule

28. FAR Part 39 Acquisition of IT states: When acquiring EIT, agencies must ensure that— (1) Federal employees with disabilities have access to and use of information and data that is comparable to the access and use by Federal employees who are not individuals with disabilities; and (2) Members of the public with disabilities seeking information or services from an agency have access to and use of information and data that is comparable to the access to and use of information and data by members of the public who are not individuals with disabilities. 28

29. OMB CIRCULAR #A–11,Exhibit 300 Exhibit 300-CIRCULAR NO. A–11, PART 7 Planning, Budgeting, Acquisition, and Management of Capital Assets, Section 300, Part 1, Section C Acquisition/Contract Strategy, #3. Do the contracts ensure Section 508 compliance?  a. Explain why not or how this is being done? Exhibit 53 - CIRCULAR NO. A–11, Information Technology and eGovernment 29

30. OMB CIRCULAR #A–11, Exhibit 53 The information required in Exhibit 53 allows the agency and OMB to review and evaluate each agency's IT spending and to compare IT spending across the Federal Government. Specifically the information helps the agency and OMB to: Ensure spending on IT supports agency compliance with the requirements of Section 508 of the Rehabilitation Act Amendments of 1998 (Electronic and Information Technology Accessibility) and Section 504 of the Rehabilitation Act of 1973 (Reasonable Accommodation);

31. Solicitation Analysis EIT solicitations randomly selected from Federal Register Analyzed for Section 508 requirements RED, GREEN, YELLOW Technical assistance provided

32. 32 How Well Are Federal Agencies Implementing Section 508?

33. Additional Information www.access-board.gov/508.htm www.section508.gov www.justice.gov.crt/508/508home.php www.buyaccessible.gov

34. What is the Buy Accessible Wizard? The Buy Accessible Wizard is a web-based tool that:  Guides users through the acquisition process, gathering data and providing information about electronic and information technology (E&IT) and Section 508 compliance  Compiles a running summary documenting the process and its results The Buy Accessible Products and Services Directory  Access to vendor provided accessibility information The Buy Accessible System makes compliance with the requirements of Section 508 as easy and thorough as possible

35. Who Should Use the Wizard? Micro purchasers (IT) with government purchase cards Program technical specialists (IT) that determine acquisition requirements Program requirements officer – responsible for program requirements documentation development, consolidation Contract officers that specify (IT) requirements on behalf of agency programs

37. How Can the Wizard Help? Standardize the process you use for each acquisition.  Document your procedures to demonstrate due diligence Maximize market research. Use vendor-supplied accessibility information about the commercial availability of accessible EIT products and services prior to solicitation. Tailor your solicitations. Ensure there is specific Section 508 language in each solicitation that includes EIT.  Require accessibility information.  Document accessibility as a factor in source selection  Document accessibility as a factor in inspection and acceptance

38. Is a mouse covered by 508?

39. The VPAT’s where it’s at …. said the Cat in the Hat Go to: www.buyaccessible.gov

40. The VPAT and Market Research Voluntary Product Accessibility Template Completed by the Vendor Information on how a product or service conforms to the Section 508 Access Board standards Optionally, posted on their vendor site and linked to Buy Accessible Wizard Tool Vendors are not required to complete a VPAT Section 508 ► Hardware and COTS ► Micro-Purchase ► Software ► Web ► Training

41. Examples of VPATS

42. Adobe Acrobat 9 VPAT Section 508 ► Hardware and COTS ► Micro-Purchase ► Software ► Web ► Training Name of product: Adobe® Acrobat® 9 http://www.adobe.com/accessibility/product s/compliance/acrobat_9_508.html http://www.adobe.com/accessibility/product s/compliance/acrobat_9_508.html

43. Mozilla Firefox 3.0 VPAT Name of Product: Firefox 3.0 & 3.5 General Comments: Information in this VPAT is relevant to Firefox 3.0 & 3.5 running on a Windows 2000, Server 2003, XP, or Vista operating system. Additional developer tools exist in this product that are not installed by default. These optional tools have not been tested. http://www.mozilla.com/en-US/firefox/vpat-3.html Section 508 ► Hardware and COTS ► Micro-Purchase ► Software ► Web ► Training

44. Sample Source of VPAT Information Used by the USPTO http://www.evengrounds.com/resources/vpat -directory Contains a concise list of companies with VPATs Companies can be added to the list Further information on what is needed in a VPAT

45. 45 BAW QuickLinks

46. Why QuickLinks? Some buyers are in a hurry. Some buyers know exactly what they want. Some buyers don’t want to take the time to learn about Section 508. “ Just get me to the bottom line and fast!”

47. 47 What are QuickLinks? What are Quick Links? Quick Links are paths to simplified Section 508 compliance Quick and easy pre packaged Section 508 solicitation documentation for a number of standard EIT deliverables. Currently available for 17 EIT deliverables and growing. Quick Links identify applicable Section 508 provisions for VPATs for Sellers It is the “sole responsibility” of the department/agency to determine applicable provisions, not the vendor.

48. What are QuickLinks Inputs are common and standard deliverables (products and services) Current outputs are solicitation documents associated with these deliverables. Initial deliverables were selected with input from Section 508 coordinators and BuyAccessible staff Currently being validated by a Focus Group of expert federal staff

49. 49 Section 508 QuickLinks Will identify deliverables (from a list or keyword) and present one of the following: 1.Technical provisions from the Standard that typically apply to that deliverable, listed as “yes” 2.Technical provisions that may apply to that deliverable, listed as “maybe” 3.Functional Performance Criteria will apply for all deliverables 4.Information, Documentation and Support provisions will also apply for all deliverables 49

50. QuickLinks Currently Provide Standard definition of the deliverable Standard product codes (UNSPC for now) GPAT:  Technical standards (Subpart B)  Functional performance criteria (Subpart C)  Information, documentation and support (Subpart D) Solicitation language:  Section 508 Program Need (Section B)  Section 508 Product Requirements (Section C)  Section 508 Evaluation Factors (Section M)  Section 508 Acceptance Criteria (Section E)

53. 53 It’s the BLOB!!!!!! No, it’s the new Section 508 Blog http://buyaccessible.net/bloghttp://buyaccessible.net/blog. Stop by and take a look!

55. Buy Accessible DEMO

56. Be Our Guest for a Test Drive We invite you to test drive the Buy Accessible Wizard Release 3 To access the Buy Accessible Wizard Release 3 go to: http://www.buyaccessible.gov/ and use the Guest User login http://www.buyaccessible.gov/

57. Further resources More information on Section 508 can be found at: http://www.section508.gov http://www.access-board.gov/508.htm http://www.buyaccessible.gov/

58. Thank you Contact Information Helen Chamberlain, Section 508 Program Director helen.chamberlain@gsa.govhelen.chamberlain@gsa.gov Terry Weaver, Director terry.weaver@gsa.gov terry.weaver@gsa.gov

59. The Aging Population

68. Example of a Best Practice

69. US Patent and Trade Office Their Process Their Program Their Training Common Requirements Hardware and COTS

70. USPTO 508 Processes USPTO has processes for the following:  Purchase of IT Hardware and COTS Products  Credit card Purchases of IT Products  Development and Maintenance of IT Software Systems  Creating or Maintaining Web Products Section 508 ► Hardware and COTS ► Micro-Purchase ► Software ► Web ► Training

71. USPTO’s Section 508 Program Staff available to help at any time Features include:  Assistance with procurement  Consultation and testing during all phases of product development  Testing before product deployment  Training classes  Evaluation of latest technologies

72. USPTO Section 508 Training Training classes offered at USPTO include: Writing accessible documents Authoring Section 508 compliant web pages and applications Developing compliant software New and emerging technologies including AJAX and Flash

73. Appendix: USPTO Forms The following slides contain samples of forms used by the USPTO’s Section 508 program.

74. EIT Procurement Checklist Section 508 ► Hardware and COTS ► Micro-Purchase ► Software ► Web ► Training

75. Purchase Card Pre-Purchase Worksheet Section 508 ► Hardware and COTS ► Micro-Purchase ► Software ► Web ► Training

76. AIS Checklist Section 508 ► Hardware and COTS ► Micro-Purchase ► Software ► Web ► Training

77. Extra Slides USPTO

78. Developing Software

79. Writing the code for a new or revised system, makes it difficult to claim any type of exemption Retrofitting a system for compliance is extremely expensive A system should not go into production if it has Section 508 deficiencies Section 508 ► Hardware and COTS ► Micro-Purchase ► Software ► Web ► Training

80. Developing Software Most Section 508 standards are simply good old coding practices Always code to the standards and not the accessibility tools (e.g., JAWS, Dragon Naturally Speaking) Currently, there are no tools designed to evaluate software automatically Section 508 ► Hardware and COTS ► Micro-Purchase ► Software ► Web ► Training

81. Developing Software If JAWS can read a program, that is no guarantee that it is compliant If JAWS cannot read a program, that is no guarantee that it has deficiencies Few sighted people have sufficient expertise with JAWS to use it as an evaluation tool Section 508 ► Hardware and COTS ► Micro-Purchase ► Software ► Web ► Training

82. Developing Software Allow sufficient time to correct 508 deficiencies and still meet the schedule for production Remember the Contracting Officer is the only person who can authorize changes to a contract Contractor is responsible for ensuring compliance until the Government accepts the system Section 508 ► Hardware and COTS ► Micro-Purchase ► Software ► Web ► Training

83. Developing Software All software task orders should have a section that requires the product to be 508 compliant Depending on the type of contract, a contractor is responsible for correcting any deficiency at their cost Section 508 ► Hardware and COTS ► Micro-Purchase ► Software ► Web ► Training

84. USPTO Process Initial Steps Define requirements - They drive the development of the system SDM (Software Development Manager) signs the checklist certifying that the system will be 508 compliant Coordinator reviews the system and initials the checklist Section 508 ► Hardware and COTS ► Micro-Purchase ► Software ► Web ► Training

85. Initial Steps Checklist becomes part of the requirement documentation Developer determines the applicable standards Developer provides the applicable standards to testing organization There should be testing criteria for each standard and that is what the testers use for determining compliance Section 508 ► Hardware and COTS ► Micro-Purchase ► Software ► Web ► Training

86. Initial Steps Developer provides the applicable standards to testing organization There should be testing criteria for each standard and that is what the testers use for determining compliance Section 508 ► Hardware and COTS ► Micro-Purchase ► Software ► Web ► Training

87. Web Development

88. Most visible 508 area…both internally and with customers The more complex and fancy a site, the more difficult it may be to make compliant This does not imply that you have to “dummy down” the site Section 508 ► Hardware and COTS ► Micro-Purchase ► Software ► Web ► Training

89. Web Development Web products must comply not only with Section 508, but also any other standards and formats prescribed by the agency’s webmaster No matter what the requirements are to post a web document, Section 508 has priority since it is a law Section 508 ► Hardware and COTS ► Micro-Purchase ► Software ► Web ► Training

90. Web Development Several tools exist for web evaluations, although differing tools sometimes yield differing results Do not rely on the tools as the final determining factor for compliance Always use at least two different evaluation tools, one of which should be the tool that the Webmaster uses Section 508 ► Hardware and COTS ► Micro-Purchase ► Software ► Web ► Training

91. Web Development Tool Examples Wave 4.0: http://wave.webaim.org/ Web Developer toolbar for Mozilla Firefox: https://addons.mozilla.org/en- US/firefox/addon/60 HiSoftware http://www.hisoftware.com/

92. Training

93. Critical area since many requirements for promotion and skills are based on IT training media. People get testy when they miss out on promotions Secondary issue is training site that must support assistive technologies Section 508 ► Hardware and COTS ► Micro-Purchase ► Software ► Web ► Training

94. Training Frequent training problems:  PowerPoint slides Problems when Informative Animations, Images, and Diagrams are used without text equivalents Use the “Notes” section to provide information  Interactivity - Providing a text version of the training is not the same as interactivity Section 508 ► Hardware and COTS ► Micro-Purchase ► Software ► Web ► Training