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From: terry.weaver@gsa.gov
Date: Mon, Feb 05 2007 7:01 AM

Per our meeting this afternoon, I am following up on providing clarifying
language for 1194.41. I am basing my suggestion on language that we have
been including in our solicitations for some time now. Our approach
(which is also built into the Buy Accessible Wizard) is to require all
electronically transmitted deliverables to be in a format that conforms
minimally to the web provisions so that we do not have to remediate those
deliverables at a later date in order to post them on our intranet or
internet sites. Here is a sample:

Deliverables

3.1 All products of this contract must be accessible to people with
disabilities. Therefore, all reports and deliverables provided in
electronic media, including web-based intranet and internet format, shall
conform to the relevant accessibility standards referenced in Section 508
of the Rehabilitation Act (29 U.S.C. 794d), as amended by the Workforce
Investment Act of 1998 (P.L. 105-220), August 7, 1998. At a minimum,
these provisions include:
1194.22 Web-based Intranet and Internet Information and Applications
1194.31 Functional Performance Criteria
1194.41 Information, Documentation, and Support

The FAQs that we have posted on www.section508.gov also address this
issue. I am pasting the citation from C.3 Vendor Responsibilities 11
immediately below this paragraph. It clarifies that it is the agencies'
responsibility, not the vendor, to comply with 1194.41. It only becomes
the vendor's requirement when it is included in a contract.


ii. Do vendors have to provide product documentation in alternate formats?

Yes, if it is a deliverable under a contract. Section 1194.41 of the
Access Board's standards provides that product support documentation that
is provided to end-users must be made available in alternate format upon
request. However, it is the agency's responsibility, not the vendor's, to
comply with this provision. Typically, agencies will require such
documentation from the vendor to be in an alternate format as part of the
deliverables required under the contract. The format of the documentation
requested from the vendor may vary. For example, an agency may request the
documentation in an electronic format that will allow the agency to
reprint information in Braille or alternate formats. Other agencies may
request the information to be provided by the vendor in Braille, large
print, audio cassette or other format as part of the procurement.



So, to make it more clear in the Access Board's Standards, my initial
suggestion follows. It is rougher than I like but I hope to refine it
thru the listserv dialogue.



Subpart D -- Information, Documentation, and Support
§ 1194.41 Information, documentation, and support.
(a) To enable Federal agencies to provide product support documentation to
end-users in an accessible format, Federal agencies need to require that
all electronically transmitted deliverables, reports or documentation
shall conform the relevant accessibility provisions in 1194 Subparts B and
C.
(b) If the deliverables, reports or documentation are to be provided via a
contract, then the contract must include this requirement.
(c) Federal agencies need to provide end-users access to a description of
the accessibility and compatibility features of products in alternate
formats or alternate methods upon request.
(d) If the descriptions for the end-users regarding the accessibility and
compatibility features of products in alternate formats are to be provided
via a contract, then the contract must include this requirement.
(e) Support services for products shall accommodate the communication
needs of end-users with disabilities

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