Buying Accessible Products
Training for End Users & New Hires
California State University, Long Beach
Rev 8-26-13 1

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)
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Outline
• Market Research
• General Exceptions
• Product Evaluation
• Roles and Responsibilities
• Other Resources
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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.
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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.
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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
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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
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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
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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
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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
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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
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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)
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The EEAAP shall be reviewed at least once a year for any updates. Review will coincide with the maintenance renewal of the product.
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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.ht
ml#0
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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.
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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)
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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.
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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.
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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.
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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
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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
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FLOWCHART FOR ATI END USER PROCESS
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?
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
High impact
End user/
Dept. to contact vendor for
VPAT for product (s)
No
Submit requisition to Purchasing for standard processing
Low Impact approved checklist sent back to requestor
VPAT received
Yes
Submit
VPAT(s) with quote and requisition to
Purchasing for
Processing
No
Contact
Purchasing
Product under
$5,000
Yes
Note:
VPAT: Voluntary Product
Accessibility Template
EEAAP: Equally
Effective Alternate
Access Plan
Upgrades to Software require a new VPAT
No
Submit requisition with approved checklist and quote to
Purchasing for processing
Purchase product
(s) with the pcard. Submit copy of approved checklist with monthly p-card reconciliation report
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