Thread Subject: Re: FW: FAQ on FPC

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From: Randy Marsden
Date: Tue, Nov 13 2007 8:25 PM

Yes - many of us have already seen this FAQ and examined it
carefully, and unfortunately it is not completely clear. It is what
we were asking clarification for from the Access Board on the list a
few weeks ago (but didn't receive).

-Randy

On Nov 13, 2007, at 7:30 PM, Gregg Vanderheiden wrote:

> Thanks Mike,
>
>
>
> This is in keeping with what was proposed today. The FAQ
> says âIf there are applicable provisions in Subpart B that fully
> address the product or service being procured, then the agency need
> not look to Subpart C.â
>
> However â it does not say how one would go about
> determining if âprovisions in Subpart B that fully address the
> product or service being procuredâ The only way that we were able
> to determine if the subpart B provisions fully addressed the
> product were to check the product using Subpart C to see if the
> technical provisions did indeed cover the product functionality.
> And the 508 standard specifically says that subpart C is to be used
> for overall product evaluation. So I think we have a circular
> reference here. One more thing to make clear.
>
>
> Gregg
> -- ------------------------------
> Gregg C Vanderheiden Ph.D.
>
>
>
>
>
> From: = EMAIL ADDRESS REMOVED = [mailto:teitac-
> = EMAIL ADDRESS REMOVED = ] On Behalf Of Mike Paciello
> Sent: Tuesday, November 13, 2007 6:28 PM
> To: 'TEITAC Committee'
> Subject: [teitac-committee] FW: FAQ on FPC
>
> Folks -
>
>
>
> David Baquis was kind enough to forward this FAQ on FPC created by
> federal agencies. The use of the word "must" in this context is
> interesting.
>
>
>
> Regards,
>
>
>
> Mike
>
>
>
> Mike Paciello
>
> Cell: +1.603.566.7713
>
>
>
>
>
> From: Baquis David [mailto: = EMAIL ADDRESS REMOVED = ]
> Sent: Tuesday, November 13, 2007 7:00 PM
> To: Mike Paciello; = EMAIL ADDRESS REMOVED =
> Cc: Bailey Bruce
> Subject: FAQ on FPC
>
> Mike and Jim,
>
>
>
> For what it is worth, the TEITAC may find it helpful to know that
> the issue of applying the FPC was addressed, to some extent, in the
> FAQs. See: http://www.section508.gov/index.cfm?
> FuseAction=Content&ID=75. In case they do not recall, the FAQs were
> developed through a consensus of many federal agencies (over 20 of
> them) participating in the 508 Working Group about 4 years ago.
> They do not serve as 508 rules, but the fact that they were created
> through a lengthy process (which was open and inclusive on a
> federal level) carries some weight and the Access Board refers to
> the 508 FAQs occasionally when we provide technical assistance.
>
> âB.2.ii. How should an agency proceed in identifying "applicable"
> technical provisions in Subparts B, C, and D of the Access Boardâs
> standards to ensure acquired products provide comparable access?
>
> Agencies should first look to the provisions in Subpart B to
> determine if there are specific technical provisions that apply to
> the EIT need they are seeking to satisfy.
>
> If there are applicable provisions in Subpart B that fully address
> the product or service being procured, then the agency need not
> look to Subpart C. Acquired products that meet the specific
> technical provisions set forth in Subpart B will also meet the
> broader functional performance criteria in Subpart C.
>
> If an agencyâs procurement needs are not fully addressed by Subpart
> B, then the agency must look to Subpart C for applicable functional
> performance requirements.
>
> Agencies must also remember the additional considerations of
> Subpart D. Subpart D requires that: (a) product support
> documentation provided to end users shall be made available in
> alternate formats upon request at no additional charge; (b) end
> users shall have access to a description of the accessibility and
> compatibility features of products in alternate formats or methods
> upon request, also at no additional charge; and (c) support
> services (e.g., help desk) for products shall accommodate the
> communication needs of end users with disabilities.
>
> For example, if an agency were to enter into a seat management
> contract for desktop computing resources, the hardware and software
> to be provided by the contractor would be required to meet the
> provisions in section 1194.26 (Desktop and Portable Computers), and
> 1194.21 (Software Applications and Operating Systems) of Subpart B
> of the Access Boardâs standards. If these provisions fully
> addressed the agencyâs procurement software and hardware needs, the
> agency would also be in compliance with Subpart C. If some or all
> of the features were not covered by Subpart B, the agency would
> also have to look to Subpart C. With respect to the support
> services provided under the seat management contract, the agency
> would also need to take into account any appropriate information,
> documentation, or support requirements in Subpart D.
>
> In all cases, agencies, when evaluating offers, must consider
> products that provide equivalent facilitation (see section B.3,
> below). â
>
>
>
> David Baquis
>
> Accessibility Specialist
>
> U.S. Access Board
>
> 1331 F Street, NW, #1000
>
> Washington, DC 20004
>
> 800-USA-ABLE; (202) 272-0013 (voice)
>
> www.access-board.gov; = EMAIL ADDRESS REMOVED = âLeading the
> way to excellence in accessibilityâ
>
>
>
> "Thank you for your questions concerning section 508 of the
> Rehabilitation Act Amendments of 1998. Section 508 authorizes the
> Access Board to provide technical assistance to individuals and
> Federal departments and agencies concerning the requirements of
> this section. This technical assistance is intended solely as
> informal guidance; it is not a determination of the legal rights or
> responsibilities of entities subject to section 508."
>
>
>
>

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