Section 508 for Agency Purchase Card

1. Section 508 for Agency Purchase Card

2. Section 508 Program • Section 508 (found at 29 U.S.C. 794d) refers to a section in the Rehabilitation Act of 1973, which was amended by the Workforce Investment Act of 1998 (P.L. 105-220). Its primary purpose is to provide access to and use of Federal executive agencies’ EIT by individuals with disabilities. The statutory language of Section 508 can be found at www.section508.gov. Starting April 1, 2005, micro-purchases (generally those purchases made through the P-Card process) will be required to conform with Section 508 of the Rehabilitation Act. • Bottom line- It is the law and it is the right thing to do. Even if you are not aware of anyone in your office that has a disability, someone may benefit from the accessibility features. For example, if one of your colleagues suffered from repetitive stress disorder and had to refrain from using the mouse on a computer, purchasing accessible software would allow that individual use of the keyboard to maneuver through a program. • The technology covered includes those used for communication, • duplication, computing, storage, presentation, control, transport • and production. This includes computers, software networks, • peripherals and other types of electronic office equipment. • It also includes services.

3. Section 508 Continued • The standards define electronic information technology as “any equipment or • interconnected system or subsystem of equipment that is used in the creation, conversion • or duplication of data or information.” The standards provide criteria specific to various • technologies, including: • 1. Technical Standards (Subpart B): • a. Software Applications and Operating Systems – Most of the specifications for software pertain to people with vision impairments. For example, alternative keyboard navigation which is essential for people who cannot rely on pointing devices such as a mouse. • b.Web Based Intranet and Internet Information and Applications – These provisions ensure access for people with vision impairments who rely on various assistive products to access computer-based information, such as screen readers, which translates what’s on a computer screen into automated audible output, and refreshable Braille displays. • c. Telecommunications Products – The criteria of this section are designed primarily to ensure access to people who are deaf or hard of hearing. This includes compatibility with hearing aids, cochlear implants, assistive listening devices and TTY. • d. Self Contained, Closed Products – This section covers products that generally have imbedded software but are often designed in such a way that a user cannot easily attach or install assistive technology. Examples include information kiosks, information transaction machines, copiers, printers, calculators, fax machines and similar types of products. • f. Desktop and Portable Computers – This section covers keyboards and other mechanically operated controls, touch screens, use of biometric forms of identification, ports and connectors.

4. Section 508 Continued • 2. Functional Performance Criteria (Subpart C): These provisions are structured to allow people with sensory or physical disabilities to locate, identify, and operate input, control and mechanical functions and to access the information provided, including text, static or dynamic images, icons, labels, sounds or incidental operating cues. For example, one provision requires that at least one mode allow operation by people with low vision (visual acuity between 20/70 and 20/200) without relying on audio input since many people with low vision may also have a hearing loss. • 3. Information, Documentation, and Support (Subpart D): This includes user guides, installation guides for end-user installable devices, and customer support and technical support communications. Such information must be available in alternate formats upon request at no additional charge. Alternate formats or methods of communication, can include Braille, cassette recordings, large print, electronic text, Internet postings, TTY access, and captioning and audio description for video materials. • For more information go to the “Guide to Section 508 Standards • for Electronic and Information Technology” website • (www.access-board.gov/sec508/guide/index.htm) which provides • an explanation of the various criteria in easy to understand language. • Also contact your 508 Coordinator in your Center CIO’s office. • A listing of the 508 Coordinators may be found at: • http://www.section508.nasa.gov/coordinators.htm

5. Section 508 Continued • What does this mean to me the cardholder or approving official? • The cardholder must ensure that any EIT supplies and services purchased meets • applicable accessibility standards defined in the Architectural and Transportation Barriers • Compliance Board Electronic and Information Technology (EIT) Accessibility Standards (36 • CFR 1194). • When acquiring commercial items, cardholders must comply with those accessibility • standards that can be met with the supplies and/or services that are available in the • commercial market place in time to meet delivery requirements. • Approving Officials must ensure that the purchase card holders are complying • with the accessibility standards in the acquisition of any EIT. • How do I determine if a product is 508 compliant? • After determining which of the above mentioned standards apply to your order (i.e., if • you are purchasing a facsimile machine, then the self contained, closed products standard • would apply). The accessibility wizard found at http://www.buyaccessible.gov/ (left side of • the page) may be used to determine which accessibility standards must be met. At • http://www.itic.org/reports/508/vpat_guidelines.pdf you will find a table that will assist you • with determining which of the standards apply to commonly acquired E&IT. • Then conduct market research to determine if the required product or service is • available in the commercial market place. (This may be done by phone, over the • Internet, reviewing vendor literature or other means). Some useful tools are:

6. Section 508 Continued 1. GSA’s “Buy Accessible” link found at http://www.section508.gov/ to locate a specific product or service type and obtain a list of links to vendors that provide Section 508 compliant products/services. To use the site, on the left hand side of the screen type in the generic name of the product/service you are intending to purchase (i.e., facsimile); then click the radio button “buy accessible products”; and then hit the “search” bar. A list of compliant products will appear. You may click on the specific product that meets your needs, which will bring you to a list and link to vendors who supply those products. You do not need to provide a log in or user ID to use this cite. Please note that not all products contained on the site are 100% accessible. It is up to the cardholder to insure accessibility. The link to Advanced Search is currently under construction (located on the left-hand side of the page under Additional Links throughout the Section 508 website). When completed, you will be taken to a page that will provide three ways you can tailor your search for accessible products: a. Search for products by company, b. By existence of a Voluntary Product Accessibility Template (VPAT), or c. By product group. 2. The best way to determine whether a particular product is Section 508 compliant is to have the vendor provide documentation to indicate whether it satisfies all or some of the technical provisions of the Section 508 Access Board standard. Over time, more and more products and services will become compliant.

7. Section 508 Continued 3. The Information Technology Industry (ITI) Council, a partnership between government and industry, hosts a Voluntary Product Accessibility Template (VPAT) on their site. It allows vendors who choose to participate, the ability to copy the template and complete it to describe how a particular product or service they offer conforms to Section 508 Access Board Standards. This template would be placed on the vendor’s accessible web site, and the link to the template provided to the Buy Accessible data base. If there is no VPAT on your vendor’s site, then it is suggested that you send a copy of the VPAT found at http://www.itic.org/policy/508/Sec508.htmlfor the specific product you are purchasing to the vendor’s Government sales person to complete. The document should be retained with your order log. 4. Your purchases must comply with those applicable technical standards that can be met with supplies or services that are available in the commercial marketplace in time to meet the agency's delivery requirements.If you cannot find a commercial item that both meets applicable Access Board's technical standards and can be furnished in time to satisfy your delivery requirements – you should acquire the most conforming product that meets your overall needs. If no conforming or partially conforming products are found, thendocument that a conforming commercially available item is not available. Are there exceptions to 508 compliance? Yes, there a limited number of exceptions. However, items/services acquired with the purchase card should be for commercially available items, the exceptions will rarely if ever be appropriate. In addition, agencies are not required to fundamentally alter their needs in order comply with section 508.

8. Section 508 Continued • What are the Steps for Cardholders? • Do I have an E&IT requirement? • Which of the Access Board Standards apply? For assistance see: • www.access-board.gov/sec508/guide/index.htm or • http://www.itic.org/reports/508/vpat_guidelines.pdf • Conduct market research – call vendors, visit vendor Internet sites, • other government agencies, etc. • a. Is there a 508 compliant product available in the commercial market place? • b. Commercial item and none or some (but not all) of the access board standards • can be met in time to satisfy requirements? • c. Obtain technical assistance of Center 508 coordinators when necessary. • 4. Acquire 508 compliant commercially available goods/services as appropriate. • 5. Document in the comments section of your order log and/or • other files the sources contacted. Use the radio buttons on page 2 • of the order log to indicate whether E&IT acquired items are 508 • compliant or whether market research indicates that • no 508 compliant (or only partially compliant) products • or services are commercially available in time to meet • your delivery requirements. Keep copies of all • documentation with your purchase card records.

9. Section 508 Continued • Are there consequences if I don’t buy compliant products? • Yes – persons with disabilities can file administrative complaints or bring civil • actions in Federal court against the agency. Court orders compelling compliance can • also be issued. • What documentation is required on my Order Log? • As a minimum, you must indicate that the product or service is EIT and identify • the sources that you contacted to find commercially available accessible products, • i.e. commercial vendors, internet market research, contacts with other federal • agencies, etc. The radio buttons on page 2 of the order log (see sample on next • page) must be used to indicate that the goods or services: • a. Are E&IT and, either • b. meet the applicable accessibility standards, or • c. is for a commercial item (or service) and that • some or all of the applicable Access Board standards • cannot be met in time to satisfy the delivery requirements. • The market research documentation shall be included in the • comments section of the order log or maintained in a separate • file referenced back to the order log to support • the purchase of a 508 compliant product.

10. Section 508 Continued The radio buttons below will automatically default to “NO” 508 compliance indicators

11. Section 508 Continued • Help Desk • The purpose of the Help Desk is to provide NASA personnel and contractors (e.g., • Engineers, Software/Web Developers, Procurement Officers) with a facility to request • information and assistance in complying with Section 508 of the Rehabilitation Act. The Help • Desk is available via email to provide information and research regarding Section 508 • compliance requirements and to coordinate requests for 508 compliance reviews. • The Help Desk is not intended to replace the market research and similar activity • required by NASA policies nor is it intended to replace Center resources, but to assist Centers • in areas in which they are having difficulty complying with Section 508 requirements. The • E-mail address is Section508Help@hq.nasa.gov • For specific technical inquiries, the Center 508 Coordinators may be contacted. A list of • Center 508 Coordinators is located at: http://www.section508.nasa.gov/coordinators.htm