T H E C O M M ONW E A L T H OF M A S S A C H U S E T T S
EXECUTIVE OFFICE FOR ADMINISTRATION AND FINANCE
INFORMATION TECHNOLOGY DIVISION
O NE A SHBURTON P LACE
▪
R OOM 804
BOSTON, MA 02108
DEVAL L. PATRICK
GOVERNOR
TEL: (617) 626-4400
FAX: (617) 626-4459
www.mass.gov/itd
TIMOTHY P. MURRAY
LIEUTENANT GOVERNOR
JAY GONZALEZ
SECRETARY
JOHN M. LETCHFORD
COMMONWEALTH CIO
August 21, 2012
Marcie Desmond
Secretariat Chief Information Officer
Executive Office for Administration and Finance
Commonwealth of Massachusetts
One Ashburton Place, Room 804
Boston, MA 02108
Dear Ms. Desmond,
Thank you for your request for a waiver from the requirements of the ITD Enterprise Accessibility
Standards and the ITD Web Accessibility Standards ("ITD Accessibility Standards") in connection
with the Department of Revenue, Child Support Enforcement project, COMETS HD.
Introduction
The Child Support Enforcement Division of the Massachusetts Department of Revenue ("DOR")
seeks a waiver of compliance with the Information Technology Division’s (ITD) Enterprise IT
Accessibility Standards ("ITD accessibility standards") in order to proceed with a contract between
Accenture LLP ("Accenture") and DOR to design, develop, configure and implement a new, stateof-the-art integrated automated system for the Massachusetts child support program. Accenture
has proposed to subcontract with Actium Consulting, Inc., Grinnell Appreciative Consulting, LLC
and Revenue Solutions, Inc.
Background
DOR is the single state agency designated by Title IV, Part D of the Social Security Act and
Massachusetts General Laws Chapter 119A to provide child support enforcement services. DOR
seeks to position itself to more effectively manage its caseload of over 213,000 active, open child
support cases while improving performance and customer service. To do so, it requires a new,
integrated system that will support DOR’s mission to make a difference in the lives of children by
enforcing the financial responsibilities of parenthood. This new system will be known as COMETS
HD.
COMETS HD will help DOR to achieve its mission by providing a flexible, secure and stable system
that is responsive to DOR’s child support business needs. COMETS HD will be a user-friendly
system that will not simply automate the business of child support enforcement, but also enable
its work by making appropriate use of technology to meet and anticipate user needs. DOR
expects COMETS HD to be business-centric and to overcome the challenges of DOR’s current child
support system which does not support the current business needs, inhibits effective case
management and is not agile, sufficiently intuitive or efficient. In July, 2010, DOR issued Request
for Response (RFR) Number 10-637 to solicit proposals from qualified Bidders to design, develop,
configure and implement the COMETS HD system. The foundational components of COMETS HD
are to locate noncustodial parents, establish paternity, establish, modify and enforce court orders
for financial and medical support, and distribute child support payments. However, COMETS HD
is more than a core child support system. It includes supporting functions, such as a data
warehouse, advanced business intelligence and analytics, Master Data Management, Enterprise
Content Management (ECM) and Customer Relationship Management (CRM) components that
call for the use of advanced technologies.
The design, development, configuration and implementation of COMETS HD must adhere to the
guiding principles adopted by DOR. COMETS HD will be business driven, compliant with DOR and
ITD standards, leverage opportunities to collaborate across the child support program, flexible,
useable, efficient, intuitive, secure, available and accessible. In addition to the above, DOR has
required that the technologies used in the implementation of COMETS HD must be accessible to
the greatest degree possible.
The objective of the COMETS HD Program is to implement an integrated, state-of-the-art child
support system with an open and scalable architecture designed for the future. COMETS HD must
meet all child support system requirements as set forth by federal or state law and regulation,
maximize available resources, empower decision-making, expand communication channels,
support partnerships, demonstrate value to users, support training and communication and
support future needs. DOR’s ability to manage stakeholder expectations will be critical to the
success of the COMETS HD Program.
COMETS HD stakeholders are many and varied and include: families and children, COMETS HD
users, the federal Office of Child Support Enforcement, the Probate and Family Court Department,
DTA, MassHealth, DCF, criminal justice and corrections agencies, workforce development
agencies, employers, financial institutions, insurance companies, pension boards and advocacy
and community-based organizations. Given the large numbers of external and state employee
stakeholders, the success of the COMETS HD Program will be measured in part by the system’s
degree of accessibility. The RFR imposed a significant number of accessibility requirements on the
system and its development.
Accessibility Assessment
This assessment was conducted with insufficient information to produce a detailed mitigation and
remediation plan. The following conditions are based only on the information that was made
available and is not sufficient to evaluate accessibility for all components of this project.
1. DOR provided a spreadsheet listing software to be used in the project. The user group for
each is indicated. There are three user groups:

External End Users: This includes the general public and other state and local
government employees that will be using the system. With about 200,000 open cases,
this group may include up to one million people.

Internal staff: These are state employees (or contractors) who use the system to
perform their job. This group is expected to include about six hundred people.

Technology users: These are state employees (or contractors) who develop and
maintain the system. They perform various functions to develop and maintain the
system and will use software appropriate to those functions. The number of
Technology Users will be about 50 during development, but less than 30 when the
system is in production.
2. Sarah Bourne of ITD's Assistive Technology Group reviewed Accenture's "Technical Response"
bid document and the supplied Voluntary Product Accessibility Template ("VPAT") documents
for Commercial Off-The-Shelf ("COTS") products that will be used in this project. She added
VPAT file names and notes to the provided inventory of products spreadsheet. The version of
the spreadsheet included as part of this response also has clarifications from Accenture.
VPATs were provided for all but the primary software product in their proposal, "FACSES",
Accenture's "Code Quality Tool" (for use by Accenture and DOR Technology users) and
machine-to-machine software.
3. Accenture did not provide a VPAT or other accessibility test results for the primary software
product in their proposal, FACSES. They did supply the accessibility requirements from a
similar, recently completed project for the State of California, which also used FACSES.
Accenture did not supply the results of any accessibility testing performed by a credible tester
indicating that FASCES met those requirements or an analysis showing whether the same
FASCES functionality being used in the California project will be used in COMETS HD. The
accessibility requirements from the California project include only Section 1194.22 Webbased Internet information and applications of the US 508 standards, which is less the ITD
accessibility standards. Thus the requirements provided by Accenture do little to illuminate
the accessibility of FASCES based on ITD’s standards.
Waiver and Conditions
ITD has found that the procurement and Accenture's bid demonstrate commendable support for
assuring accessibility in this project. ITD therefore grants you a waiver from the requirement that
the COTS products included in COMETS HD meet the ITD Accessibility Standards as of the date the
DOR-Accenture draft Master Services Agreement is signed, subject to the following conditions.
1. Nothing in this letter should be interpreting as waiving any requirements for accessibility
included in the draft DOR/Accenture Master Services Agreement.
2. Technology users, as identified above, will use some COTS software components that will not
be used by other users. Although we agree that the software used only by the Technology
users need not be made accessible for purposes of this project, this conclusion is not to be
interpreted as precedential with respect to any future projects; it is a conclusion reached by
ITD based on the limited resources available for this project. DOR and Accenture must
conduct a review, at least annually, of these Technology users-only products, and determine
whether products equal in features, functionality and cost that are more accessible have
become available and can be substituted for the Technology users-only products proposed by
Accenture in its bid.
3. Accenture will provide accessibility testing results for their "Code Quality Tool" within three
(3) months of the commencement of this project.
4. For any COTS software that will be used only by Internal staff and Technology users,
Accenture will gather information from COTS vendors on how accessibility is handled in COTS
vendors' development and support processes, roadmaps for addressing known accessibility
issues, and how the products can be configured or customized for maximum accessibility.
Accenture will share this information with DOR. Accenture will perform all configuration and
customization of COTS software during the engagement according to those guidelines.
Upgraded versions of COTS software that address accessibility deficiencies must be
incorporated promptly.
5. The Accenture bid response includes discussion of browser support. Accenture’s bid language
shall not modify the AT/IT environment list against which Accenture and DOR’s third part
testers must test the COTS and other components of the system. Any modification of the
AT/IT Environment List must be at the direction of DOR, in consultation with ITD, Accenture
and the Accessibility Advisory Committee ("AAC").
6. DOR will modify the AT/IT Environment List to include mobile or other small form factor
devices, as required in RFR 14.2.16, including but not limited to VoiceOver support on Apple
mobile devices.
7. Accenture must ensure that documents generated automatically by the system, such as those
identified in RFR 2.3.2 (Program Overview, p. 2-65) are accessible. Documents created with
Adobe Captivate, for instance, must not use the non-compliant output features listed in
Captivate's VPAT.
8. Accenture must ensure that all training-related deliverables, including computer-based
training and training materials, are in compliance with the ITD Accessibility Standards.
9. Accenture and DOR must ensure that the accessibility testing of all COTS components for
which a VPAT is not currently available, and all other components of the system, by both
Accenture and DOR’s third party tester, is integrated with other quality and test functions.
Accessibility requirements must be included in acceptance criteria and any defects,
anomalies, or other divergences from the ITD Accessibility Standards must be recorded,
tracked, and monitored using the same methodology as other defects or anomalies.
10. Accenture and DOR must ensure that remediations and configurations made to address
accessibility deficiencies are included in the configuration management plans to minimize the
re-introduction of accessibility issues. (Program Overview, p. 5-135)
11. DOR and Accenture will include people with disabilities in the pilot groups (Program
Overview, p. 1-71, RFR 1.3.5 Pilot Activities), including but not limited to people who use
assistive technologies such as screen readers and magnifiers, people with color blindness, and
people who use a keyboard only. If volunteers are not available from potential pilot
participants, test plans will need to include usability testing by people with disabilities that
would simulate pilot activities.
12. Accenture's request that ITD "provide" assistive technology (Program Overview, p. 4-23,
[4.89]) is denied. We are not able to transfer licenses. We provide access to the Assistive
Technology Lab, which has the listed products, on a first-come-first-served basis, to all
agencies of the Commonwealth. We encourage DOR project team members to take
advantage of this facility. However, Accenture’s staff and Accenture’s accessibility testers
must use their own accessibility testing hardware and software.
13. We disagree with the approach to determining the prioritization of accessibility problems
articulated in sections [4.87] and [4.90](Program Overview, p. 4-23) of Accenture's bid. We
expect that you will substitute the following barrier analysis approach. (The following
provision is not a substitute for but an addition to the accessibility requirements included in
the draft DOR-Accenture Master Services Agreement.)
Stage 1: Accenture and DOR, with guidance as needed from the AAC, third party software
vendors, and third party accessibility testers, will assign accessibility problems a "severity
ranking" based on an assessment of impact and occurrence. "Impact" addresses a user’s
ability to use a particular feature or function, with scores based on a range of conditions from
"little or no impact" to "prevents user from performing a function". "Occurrence" addresses
how many times a user is apt to come across a defect, with scores reflecting more weight for
defects that appear more often. Severity is thereby determined by how much of a barrier a
given defect has in context. Stage 1 should not include any cost or operational
considerations.
Stage 2: DOR and Accenture will identify and analyze potential remedies for the prioritized
accessibility problems, including without limitation workarounds, reconfiguration, recoding,
shutting off unneeded inaccessible features, and construction of an alternative means of
online access for users to a particular. At this stage, Accenture and DOR can consider cost,
cost-effectiveness, operational impacts and feasibility.
Stage 3: Prioritization. DOR and Accenture can use the data from Stages 1 and 2, and
practical considerations such as those related to the timing of the overall project, in particular
the date on which it is anticipated that end users will actually have access to the system, to
choose the nature and timing of specific remediations. Resolutions for accessibility issues
must favor native accessibility in the standard interfaces. Reliance on alternatives such as
"accessibility modes," special keyboard shortcuts that have to be looked up elsewhere, or
special telephone support is not desirable.
14. Given that ITD has virtually no information about the accessibility of FASCES, all of the
accessibility testing, issue prioritization, and remediation requirements of this letter
(including, without limitation, Stage 1 through 3 referenced in section 13 above) and the
Master Services Agreement apply to FASCES as configured for use in COMETS HD.
Respectfully yours,
John R. Glennon
Deputy Commonwealth Chief Information Officer
Commonwealth of Massachusetts
Information Technology Division