Thread Subject: Re: Buying a non-conformant test product

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From: Robinson, Norman B - Washington, DC
Date: Thu, Jan 25 2007 12:50 PM

Tom,

I think from the Section 508 point of view, acknowledging we
don't follow the FAR, the refresh should require the contracting officer
to certify the solution purchased is the most accessible product that
best meets the business need. I think that is clear, is a functional
specification that can be considered in a legal (procurement) framework,
yet required by Section 508.

In the event deployment starts with the pilot equipment (as does
happen or as one can imaging possible) the contracting officer has a
responsibility to certify they were Section 508 compliant. Having this
specific clause or requirement would make it clear _the contracting
officer_ thus the _contracting division_ has a responsibility, not
simply "it isn't 508 compliant, now who's fault is it?".

We've always known the purchasing event is where the rubber hits
the road for making decisions relevant to Section 508 compliance. Let us
solidify this and be clear in the refresh. I look forward to people with
the real world acquisition procurement point of view on this subject.

Regards,


Norman B. Robinson
Section 508 Coordinator
IT Governance, US Postal Service
phone: 202.268.8246


-----Original Message-----
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Tom Brett
Sent: Thursday, January 25, 2007 9:23 AM
To: 'TEITAC Subpart A Subcommittee'
Subject: Re: [teitac-subparta] Buying a non-conformant test product


One problem with that is that the government has already sunk money and
resources into the deployment of the first product. They will now have
to
expend resources and money to take the product out of the infrastructure
and
then do the same thing over again.

It would seem to me that a better alternative would be to require the
government have evaluators available during the demonstration and
contract
evaluation period be for any commitments are made.

Tom Brett

-----Original Message-----
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Hoffman,
Allen
Sent: Thursday, January 25, 2007 8:54 AM
To: TEITAC Subpart A Subcommittee
Subject: Re: [teitac-subparta] Buying a non-conformant test product

Tom:

I don't think we are talking about reuse of loaner items. What I was
intending with the reuse language is that the government doesn't acquire
an item to "evaluate it", and then deploy it because the money is spent.
If it isn't accessible, or after evaluation more accessible items are
found, we shouldn't be deploying all the evaluation items just because
we purchased them.


Let me provide a scenario.

Government intends to purchase an item that will perform a set of
actions. It is a software item. market research shows on the surface
that no Section 508 compliance data is available from vendors, and no
"trial" items are offered by vendors. The government, if it wants to
get better information about this aspect of the items, is left to
assessing the available items on their own. Yes, often this can be
accomplished by "loaner" items, but that is not always the option. We
should not tell folks they can't perform such evaluations in this kind
of situation, but lets not leave the door open to buying items like this
and then just deploying them all either.

Tom Brett wrote:

"I do believe that there are other FAR regulations that would prohibit
the use/reuse of products without the Government making some sort of
payment. I really think that before the Government commits to buy there
needs to be an
evaluation completed."

allen Hoffman
DHS Office on Accessible Systems & Technology

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