Rev 8-26-13 1

Buying Accessible Products

Training for End Users & New Hires

California State University, Long Beach

Rev 8-26-13 2

Outline

• Introduction: Section 508 and the CSU

• ATI Subparts: A, B, C, and D

• Procurement Checklist

• Impact to the University

• Voluntary Product Accessibility Template (VPAT)

Rev 8-26-13 3

Outline

• Market Research

• General Exceptions

• Product Evaluation

• Roles and Responsibilities

• Other Resources

Rev 8-26-13 4

ATI Section 508 and the CSU

ATI Section 508 is: An update to the “Americans with Disabilities Act of 1990 ADA

and Section 504 of the Rehabilitation Act of1973” Enacted to eliminate barriers in information technology to

provide equal opportunities for people with disabilities in the workplace.

Executive Order 926: December 2004 memo from the Chancellors Office requiring

CSU Campuses to address the Federal Section 508 Standard Compliance when purchasing Information Technology.

Rev 8-26-13 5

ATI Section 508 and the CSU

Coded Memorandum AA-2007-04 Ensures electronic and information technology is accessible for

all disabled individuals on the campus Requirement is applicable to CSULB auxiliaries All Electronic and information technology products and services

procurements must go through the process of evaluation for the 508 compliance.

Coded Memorandum AA-2010-13 Sets forth the Vision/Mission/Goals/Scope for the University to

give students, faculty and the general public with disabilities access to technology that is timely and seamless as possible.

Provides clarification for setting priorities on the ATI Implementation for the CSU.

ATI Milestones and requirements are defined.

Rev 8-26-13 6

Section 508 Applies To…

Only “Electronic and Information Technologies”

Included: “equipment [or systems, services] that is used in the creation, conversion, or duplication of data or information” and that has a user interface (display, keys).

Excluded: anything whose principal function is not information, such as microwave ovens, thermostats, and medical equipment, even if they are electronic.

Link to CSULB Purchasing Website for a list of E & IT products that must address the ATI Section 508 Compliance:

http://daf.csulb.edu/offices/financial/purchasing/ati/index.html

Rev 8-26-13 7

Section 508 Subparts A-D

Subpart A: General

Explains exceptions; defines terms; recognizes alternatives when products do not comply.

Subpart B: Technical Standards

1194.21 - Software and operating systems

1194.22 – Web-based Internet and Intranet information and applications

1194.23 – Telecommunication products

Rev 8-26-13 8

Section 508 Subparts A-D

Subpart B: Technical Standards (continued)

1194.24 – Video and multimedia products

1194.25 – Self-contained, closed products

1194.26 – Desktop and portable computers

Rev 8-26-13 9

Subpart C: Functional Performance Criteria

1194.31 – Required to be filled out on the VPAT when 1194.22 (Web based Internet/Intranet products or services)are applicable.

Products must provide at least one mode of operation and information retrieval for users with:

Visual disabilities Hearing disabilities Mobility disabilities Speech disabilities

Rev 8-26-13 10

Subpart D: Information, Documentation and Support Documentation

1194.41 – Always required to be filled out on the VPAT

Product documentation must be accessible

Manuals, online help files, in alternate formats such as braille if needed at no charge

Documentation must include information about accessibility features

Support services must be accessible Call centers, chat on line

Rev 8-26-13 11

Procurement Checklist

The ATI Section 508 Electronic and Information Technology Product Checklist form is:

A simple tool to manage Section 508 Compliance in the procurement process

Provides information to the Purchasing Department regarding impact/risk to the University

Documentation to assist in the ATI process for annual reporting

Rev 8-26-13 12

Rev 8-26-13 13

Rev 8-26-13 14

Rev 8-26-13 15

Rev 8-26-13 16

Rev 8-26-13 17

Rev 8-26-13 18

Impact to the University

Impact/Risk to the University will be evaluated by the following factors:

How many users will be affected? One user only Staff or Faculty only Students, Staff, Faculty and the Public at large

Product is deficient and/or not compliant Product fits into an exception category Product requires EEAAP (Purchasing will contact

end user when this applies)

Rev 8-26-13 19

Rev 8-26-13 20

Rev 8-26-13 21

Rev 8-26-13 22

The EEAAP shall be reviewed at least once a year for any updates. Review will coincide with the maintenance renewal of the product.

Rev 8-26-13 23

Voluntary Product Accessibility Template

The VPAT form was developed for manufacturers to show how well their products comply with the 508 Standard requirements.

End users are responsible to request this form from vendors when getting a quote for electronic and information technology products. The end user will attach this form to the quote when submitting a requisition to the Purchasing Department.

Link to the VPAT Guide:

http://www.calstate.edu/Accessibility/EIT_Procurement/VPAT_Guide.html#0

Rev 8-26-13 24

Rev 8-26-13 25

Rev 8-26-13 26

Where to get the VPAT

• CSU sources (other campuses that have already acquired the same type of product)

• Manufacturers (many manufacturers have an accessibility module on their website where you can print off a VPAT for one of their products)

• Vendors (vendor may contact the manufacturer and acquire the VPAT for you as part of their customer service)

• Web search using the product name in conjunction with a “buzz” word such as “disabled”, “Section 508”, “accessibility”, etc.

Rev 8-26-13 27

Market Research

(Analysis to be completed by the Purchasing Department)

• Products that meet the functional requirements and are 508 compliant

• If one product meets more of the 508 Standard than others

• Products previously purchased by the University and still are compliant/conformant

• When only one product meets functional specifications (sole source justification)

Rev 8-26-13 28

General Exceptions

• Back office – users do not interact with the product (technical personnel only, in data closets)

Example: Computer Servers• Commercial Non-Availability of Conformant Product

Example: Adobe Creative Suite• Fundamental Alteration (making it accessible would

change its purpose/function)

Example: Police radios • Undue Burden (significant difficulty or expense to a

business) Purchasing reviews this exception which is rare and must be fully documented.

Rev 8-26-13 29

Product Evaluation

Testing products – for special circumstances products may be tested for compatibility with accessible technology.

Assistive technology may be incorporated when the product is not accessible to the end user.

Equally Effective Alternate Access Plan (for non-conformant products) is incorporated when a product fails to comply but is still essential to the mission of the University. End users provide a plan to aide individuals who may require it.

Rev 8-26-13 30

Roles and Responsibilities

For Requestors: Find products/services that are compliant whenever

possible Determine which technical standards in Section II of

the ATI Checklist apply to the requested product or service

Complete the ATI Checklist form and send to Purchasing to evaluate impact/risk

If impact applies obtain VPAT from vendor Submit Requisition, VPAT, and Checklist to the

Purchasing Department for further processing once impact has been evaluated.

Rev 8-26-13 31

Roles and Responsibilities

For Purchasing:

• Inform and assist end users with ATI process when requested or required

• Process all electronic and information technology requisitions in accordance with CSU policies

• Contact vendors when required• Communicate with end user if product is non-compliant

and assist in finding compliant product when required

Rev 8-26-13 32

Other Resources

Contact the Purchasing Department when:• A product is new/first time acquisition•Information Technology donations/gifts to the University (ATI still applies even when free)•No VPAT exists

Reference Material:

Executive Order 926:

Coded Memo AA-2007-04:

Coded Memo AA-2010-13: http://www.calstate.edu/AcadAff/codedmemos/AA-2010-13.shtml

Direct questions to the Purchasing Department ATI Section 508 contacts:

Alex Rosales: extension 55797

Paula Serrano: extension 58288

Rev 8-26-13 33

End user/Dept. requests to purchase

product (s) that fall into the ATI

category.

Go to CSULB Purchasing

Website: http://daf.csulb.edu/

offices/financial/purchasing/ati/

index.html

Does the product (s) appear on

the ATI list?

No

Submit requisition to Purchasing for

standard processing

Yes

End user/Dept. needs to fill out

the CSULB ATI Section

508 Electronic &

Information Technology

Checklist and submit to

Purchasing ATI Contacts

Product (s) are evaluated

by Purchasing

ATI Contacts for Impact to the University

Determine product (s)

impact to the University

Low Impact approved

checklist sent back to requestor

High impact

End user/Dept. to contact

vendor for VPAT for

product (s)

Product under $5,000

Yes

No

Submit requisition with approved checklist and

quote to Purchasing for

processing

Purchase product (s) with the p-card. Submit

copy of approved checklist with

monthly p-card reconciliation

report

VPAT received

No

Contact Purchasing

Yes

Submit VPAT(s)

with quote and

requisition to Purchasing

for Processing

FLOWCHART FOR ATI END USER PROCESS

Note:VPAT: Voluntary Product

Accessibility Template

EEAAP: Equally Effective Alternate

Access Plan

Upgrades to Software require a new VPAT