CPACC Procurement and Accessibility 2 — Questions and Answers
Question 1: Why should accessibility be included in procurement requirements from the beginning?
- It is optional and can be added after contract signing
- Including requirements upfront ensures accessible products, avoids costly retrofitting, and establishes vendor accountability (Correct answer)
- It is only relevant for government procurement
- It only matters for software purchases
Correct answer: Including requirements upfront ensures accessible products, avoids costly retrofitting, and establishes vendor accountability
Including accessibility at procurement ensures vendors build it in from the start, reduces cost (retrofitting is 10-100x more expensive), and establishes accountability.
Key reasons include cost efficiency, legal compliance (Section 508, EN 301 549 mandate accessible procurement), market influence, risk reduction, and consistency. Best practices include WCAG requirements in RFPs, requiring VPATs, independent testing, and remediation SLAs.
Question 2: What is an Accessibility Conformance Report (ACR) and how does it differ from a VPAT?
- They are identical documents
- A VPAT is the template vendors complete, while the ACR is the completed document showing specific product conformance (Correct answer)
- An ACR is a government audit while a VPAT is self-assessment
- An ACR only covers physical products
Correct answer: A VPAT is the template vendors complete, while the ACR is the completed document showing specific product conformance
The VPAT is the blank template published by ITI; when completed for a specific product, the resulting document is an ACR.
The current VPAT 2.5 includes sections for WCAG 2.x, Section 508, and EN 301 549. Each criterion is rated as Supports, Partially Supports, Does Not Support, or Not Applicable. Procurement teams should check dates, product versions, and conduct independent testing.
Question 3: What accessibility requirements does Section 508 impose on federal procurement?
- Only software purchases must be accessible
- Federal agencies must ensure all ICT they develop, procure, maintain, or use is accessible (Correct answer)
- Section 508 only applies to purchases over $1 million
- Section 508 requirements are voluntary
Correct answer: Federal agencies must ensure all ICT they develop, procure, maintain, or use is accessible
Section 508 requires federal agencies to ensure accessibility of all ICT, making it a mandatory evaluation criterion in acquisitions.
The 2017 refresh incorporates WCAG 2.0 Level AA. Vendors must provide VPATs/ACRs. Exceptions are limited to undue burden, fundamental alteration, national security, and back-office systems. FAR Subpart 39.2 implements Section 508 in procurement.
Question 4: How should organizations evaluate vendor accessibility claims during procurement?
- Trust all vendor claims without verification
- Use a multi-layered approach including reviewing VPATs critically, conducting independent testing, and requesting assistive technology demos (Correct answer)
- Only check if the vendor has an accessibility statement
- Only evaluate after deployment
Correct answer: Use a multi-layered approach including reviewing VPATs critically, conducting independent testing, and requesting assistive technology demos
Effective evaluation requires critical VPAT review, independent testing, AT demonstrations, reference checks, and roadmap assessment.
Self-reported VPATs can be inaccurate or outdated. Best practices include live AT demonstrations, automated and manual testing, reference checks, reviewing vendor accessibility teams, pilot period acceptance criteria, and contractual remediation obligations.
Question 5: What role does EN 301 549 play in European public procurement?
- It is optional with no legal standing
- It is the mandatory reference standard for ICT accessibility in European public procurement (Correct answer)
- It only applies to hardware procurement
- It is used only by private sector voluntarily
Correct answer: It is the mandatory reference standard for ICT accessibility in European public procurement
EN 301 549 is the harmonized standard providing presumption of conformity with EU accessibility directives in public procurement.
EU Directive 2014/24 requires technical specifications reference European standards. For ICT, EN 301 549 is this standard, covering websites (Section 9 with WCAG 2.1 AA), software (Section 11), hardware (Section 8), and documentation (Section 12).
Question 6: What is a 'market analysis' in accessible procurement?
- Analyzing stock market trends for AT companies
- Research to identify available accessible products, understand the market landscape, and determine achievable accessibility levels (Correct answer)
- A vendor-provided document comparing products
- Analysis of how many disabled users are in the target market
Correct answer: Research to identify available accessible products, understand the market landscape, and determine achievable accessibility levels
Market analysis surveys available products to understand what accessibility levels are achievable, informing realistic requirements.
Involves identifying available products, evaluating their accessibility (reviewing ACRs, preliminary testing), understanding achievable WCAG levels, and identifying accessible alternatives. Under Section 508, federal agencies are required to conduct market research.
CPACC Procurement and Accessibility 2
Why should accessibility be included in procurement requirements from the beginning?