Subpart A:November 30

Subpart A Issues 11/30/06 Meeting Notes

Discussion on Accessibility and "Best Meets"

The discussion focused on the consideration of accessibility as part of the procurement process. Intent was to get a better understanding of how federal agencies are guided to consider accessibility and whether implementation at the agency level reflects the guidance and technical assistance provided.

1. Subcommittee members indicated the GSA suggests that agencies consider accessibility and business needs on the same level.
2. Concept of “Best Meets” seems problematic as the concept may not be clear as it could/should be. Federal agencies appear to be interpreting Best Meets differently and implementing strategies that are not consistent across the board.
3. When to consider accessibility and methodologies to address accessibility is increasingly identified as a challenge for states as they attempt to implement their state 508 statutes.
4. It appears from the discussion that several federal agencies do not consider accessibility and business & technical needs as equal considerations.
5. Several agencies on the call indicated that they look at business and technical needs first then consider accessibility.

SSA noted that they have tried different methodologies such as weighting the standards, but they felt that this was not a legitimate approach as many of the products came out with similar scores and there was nothing to differential and support the selection of one product over another. SSA indicates that they have moved to an empirical method to evaluate “Best Meets” and the method is documented and they are willing to share with other interested groups.

Questions

1. Can we determine Congressional intent regarding 508? Was the intent to have accessibility considered as the first screen before considering business and technical needs of the acquisition?
2. Are agencies implementing in a manner inconsistent with the guidance from GSA?
3. Do we need to define “Best Meets”?

Next Steps

1. D. Buck will follow up with Terry Weaver, GSA to get a better understanding of GSA recommended approach to fulfill “Best Meets” and how is the operationalized in the procurement process.
2. D. Buck will follow up with Access Board staff to see if they are aware of or have access to any info from Congressional Record, etc regarding reauthorization of Section 508 and any documentation that speaks to Congressional intent.
3. Use information to determine recommendations: Does Subpart A currently address how accessibility should be considered as part of the acquisition process to assure consistent application? If not, do we need to:
   1. Recommend adding a definition for “Best Meets” to subpart A?
   2. Add other clarifying guidance to Subpart A?, or
   3. Is it an issue that is better addressed through the training and technical assistance documentation and support services?
      

Discussion- Prioritization

Part of the meeting focused on considering the need and other ways to evaluate accessibility and the technical standards to promote consistency and ensure that standards that are critical are not minimized or evaluated on an equal basis with other technical standards that may not be viewed as important. The subcommittee discussed the value and likelihood of being able to structure the technical standards in a way that would make acquisition decisions clearer and more consistent. The group discussed the concept of prioritizing the standards and categorizing them by levels for example: level 1 would be considered mandatory; level 2 would be important; and, level 3 would be nice to have.

SSA indicated that they have moved to a strategy that mirrors this approach identifying standards within each category as critical; major and minor. This methodology negates the prior approach of assigning different points to the different standards and instead frames how the product is reviewed based on addressing the levels. The subcommittee discussed the value in this approach and suggested as a next step that we run the idea by one of the technical subcommittees to gather their feedback and clarify the pros and cons of such an approach.

Next Steps:

R. Lint offered to follow up with the Software Standards Subcommittee to address this concept and get their input on the feasibility of such an approach.

Next Meeting Logistics:

Date & Time: Wednesday, December 14, 2006 11:00 – 12:30 ET
10:00 AM - 11:30 AM Central Time
9:00 AM - 10:30 AM Mountain Time
8:00 AM - 9:30 AM Pacific Time
Number: Toll-Free (US & Canada): 866-500-6738 Toll: 203-480-8000
Participant Code: 520044 followed by the # sign
Captions via FedRCC, Event ID 629551
Hand raising tool: http://teitac.org/tohru/