Accessibility and the Procurement Process

What are the components of a robust procurement process for technology that ensures accessibility needs are identified and addressed in the planning, requirements gathering, research and evaluation phases as well as the determination of acceptance criteria?

 Here are four pieces of the puzzle to get you started. 

  1. Procurement requirements related to accessibility should be written into your organization’s accessibility policy. For example: "Vendors who provide information and communication technology (ICT) or tools shall be required to demonstrate and commit that the products and services they provide are and will continue to be accessible to individuals with disabilities, or if accessibility is not possible to provide a plan for reasonable alternative access. All contracts shall require a Voluntary Product Accessibility Template (VPAT)."

  2. Accessibility requirements related to federal law and standards should be written into ALL solicitations. For example: "... all ICT procured through this Request for Proposal (or Invitation for Bid) must meet the applicable accessibility standards of Section 508 of the Rehabilitation Act of 1973 (https://www.section508.gov), as amended to include the Web Content Accessibility Guidelines 2.0 (WCAG 2.0), Level AA. For each ICT included in this RFP, the Bidder is required to submit a Voluntary Product Accessibility Template (VPAT), version 2.4. If there are issues that prevent the Bidder’s ICT from conforming to the standards outlined in the WCAG 2.0, Level AA, and Section 508, the Bidder is to provide an Equally Effective Alternative Access Plan for addressing those issues as well as a timeline for bringing the ICT to full compliance."
                                   
  3. Test and validate all claims included in the Accessibility Conformance Report. While an expert review of Section 508 and WCAG 2.0 conformance claims documented through a VPAT may indicate accessibility, it is highly recommended that you validate those claims through automated and manual testing. Section 508 and WCAG 2.0 conformance is complex. Vendors may not fully understand what conformance requires. If not fully compliant, provide an Equally Effective Alternative Access Plan template for the vendor to complete.

  4. Build in support for accessibility within your IT department. Many organizations have IT vetting committees with the sole responsibility of ensuring all IT purchases meet IT standards and work within the current network and infrastructure. Those standards must also include accessibility standards and be required for all IT-related purchases.

But what if a product is critical to the operation of an organization but isn’t compliant? This will happen on occasion, so you need to be prepared. There are steps you can take to document the organization’s due diligence and "reasons why" for purchasing a non-compliant product. Take a look at this – Procurement Process of Non-Compliant ICT. Included in this example is the use of a Request for Exemption from Regulations. This form documents the business case for the purchase and the risk associated with the non-compliant ICT.

Ensuring that accessibility needs are identified and addressed within your organization’s procurement process is just one more way to show your company's pledge to accessibility and social responsibility.

Resources

Maggie Vaughan, CPACC
~ friend of DubBot, A11Y practitioner in higher ed