This article was contributed by Jeff Kline, the author of Strategic IT Accessibility: Enabling the Organization. Kline is the current Statewide Electronic and Information Resources (EIR) Accessibility Coordinator at the Texas Department of Information Resources and previous EIR Accessibility Coordinator at the Texas Department of Family and Protective Services. Before entering public service, he spent 26 years at IBM, during which he managed its Worldwide Accessibility Consulting and Business Transformation initiatives and several other efforts related to product development, industrial design, software development and system usability.
Think about the technology you use to do your job each day. If your business or organization is like most, it probably comes from outside information and communications technology (ICT) providers—computer distributors, software companies, Internet service providers, web development firms, and others.
While this makes you dependent on how well these vendors build accessibility into their products, it also gives you significant market power—if you communicate clearly about your accessibility goals for the products and services you are purchasing, providers should be happy to help you meet them. After all, you’re the customer.
The key to success is to address accessibility from the start, by incorporating it into the procurement process, and then making sure to evaluate what technology providers promise and deliver. Because procurements processes differ from company to company, there is no one right way to do this. In his book, Strategic IT Accessibility: Enabling the Organization, IT accessibility expert Jeff Kline outlines 10 steps for determining where and when accessibility can be infused:
Step 1: Confirm the Type of Procurement
Although it may be obvious, the first step is to confirm that the product under consideration does in fact qualify as ICT. If so, accessibility should be a factor in the procurement process, right from the start.
Step 2: Develop Specifications, Scope, and Terms
This step involves developing criteria. To do this, you must first understand which, if any, technical standards and/or laws and regulations apply to you and what specifications the ICT you are procuring should include. Also, an assessment of the ICT in your workplace and gathering of information from employees may be helpful in understanding what has and has not worked well in the past. Once you conduct this research, you should develop a list of clear specifications that detail the accessibility requirements, the scope of work to be completed by the vendor, and the terms of conditions to which you expect the vendor to adhere.
Step 3: Perform Market Research
Next, you should perform market research on the accessibility status of identified products. This includes but is not limited to reviewing Voluntary Product Accessibility Templates (VPATs) created by the suppliers you are considering and determining whether their documented compliance meets the criteria you developed during Step 2. VPATs are used to help federal contracting officers assess, at least preliminarily, a product’s compliance with the accessibility standards set forth in Section 508 of the Rehabilitation Act. Although VPATs were created for federal government purchasers, they can be very useful tools for all companies seeking to purchase accessible technology products and services.
Remember, though, just because a company has created a VPAT doesn’t necessarily mean its product or service is fully accessible. So be sure to read the VPAT closely. You may find that some features of the product are in fact not accessible right out of the box, but rather through customization or workarounds. You should also crosscheck the features the vendor claims are accessible against your own requirements. And finally, be sure to confirm that the version number of the product on the VPAT is in fact the one you are interested in procuring. Upgrades and other product enhancements may have increased (or decreased) accessibility.
Step 4: Incorporate Accessibility Requirements
It’s now time to incorporate your accessibility requirements in your solicitation document. As you draft it, clearly lay out your business requirements, including the importance of accessibility compliance. As part of this, be sure to include a VPAT documentation request.
Step 5: Review Internally
The next step is to route the solicitation document for internal review as appropriate in your organization. Other internal stakeholders, whether connected to accessibility or not, may want to comment on the solicitation. This is the time to resolve any internal differences—including about accessibility specifications or their priority.
Step 6: Submit Solicitation
Now you can submit your purchase request and initiate the solicitation. If possible, be sure to circulate it to vendors with a reputation for understanding—and delivering on—accessibility requirements.
Step 7: Evaluate Responses
Once responses are received, they must be evaluated against various criteria, including the potential vendor’s ability to meet your accessibility requirements. When doing this, it’s important to remember that documentation such as a VPAT is only a small part of the equation. Your accessibility coordinator or other qualified staff must review and validate the entire response. This may include accessibility and assistive technology compatibility testing. It may also include a risk assessment for non-compliant bids and subsequent requests for plans for accessibility remediation. After considering all bids and related research, you should identify the solution that best meets your requirements.
Step 8: Review the Solution
Of course, it’s very important to review the solution to ensure it does in fact comply with your accessibility requirements. Hopefully this process goes well! But, if the chosen vendor does not produce a product that meets your accessibility requirements, you may need to:
- Request a formal accessibility remediation plan from the supplier, including the compliance date.
- Obtain or develop a plan for temporary alternative methods of access (commonly referred to as “workarounds”), facilitated either internally or by the vendor.
- In certain circumstances only, initiate an accessibility exception process that explains the decision. In developing such a process, be sure to draft a step-by-step protocol to follow for qualifying exceptions that explains why you are accepting the product in spite of its accessibility shortcomings.
Step 9: Award Contract
After you receive and install the product, you should conduct a final accessibility validation by testing the product—in your organization’s environment—to make sure that it works on your servers. You should also prepare and implement a solution maintenance plan that includes accessibility.
Step 10: Maintain
The final step is to implement the maintenance plan and monitor accessibility concerns over the contract life cycle. This may mean additional testing for upgrades and periodic quality assurance and necessary corrective actions. You should also monitor any contract changes to ensure that accessibility compliance conveys and review or dispute invoices for non-compliant billings. Finally, be sure to reassess compliance prior to contract renewal. As part of this process, you may want to network with other customers to learn about their experiences.
Models in Procurement
To learn more about the processes several universities have used to incorporate accessibility into their procurement processes, including samples of procurement language, read Let the Buyer be Aware: The Importance of Procurement in Accessibility Policy. Additional, institution-specific resources include the following. While these were developed for educational institutions, it is important to note that the processes they describe may be applicable to employers of all sizes and in all industries.
Join the Conversation
Have you had success incorporating accessibility into the procurement process? If so, PEAT wants to hear from you! Please contact us to share your company’s strategies and best practices for ensuring the technology you procure can help enhance the productivity of all employees who use it.
