Subpart A:November 02

11/2/06 Subpart A Issues

• A draft of operating procedures/protocols will be posted on the Subpart A subcommittee section for review and consideration at the November 16th subcommittee meeting. Members are asked to review and comment.

• Access Board and GSA have been asked to develop summary of Subpart A provisions that are tied to statute (§508 or other federal statutes) and can’t be changed.

• Requests for information/feedback on Subpart A issues was sent the week of 10/30/06) to several federal 508 coordinators. Coordinators were asked to summarize issues, challenges and any suggestions for improvement. Information will be shared with committee members on receipt.

• Information provided on issues identified by states implementing IT access requirements.

• Terry Weaver, GSA provided some background on federal procurement procedures.

• Mike Fratkin, SSA provided information from the SSA perspective including information about their internal testing procedures.

• Difference between SSA and GSA in terms of where accessibility fits in procurement. SSA does business need first then accessibility review/rating. GSA folds accessibility into the overall business need evaluation. GSA does paper review and SSA does hands on.

• Some agencies have specific AT compatibility issues, they extend/expand access requirements to require compatibility with specific AT used by that agency. This may shift emphasis from building to standards to requiring compatibility with specific AT.

• Suggestion: Eliminate “best meets” language and allow FAR to address role and function of accessibility review in best value assessment.

• Concern about eliminating “best meets” reducing overall level of access.

• Suggestion: Revise the standards so they clarify role of accessibility in procurement decision-making.

• Terry’s clarification: “Best meets” term is used because not all the standards can be met at a 100% level for every solicitation.

• Katie Haritos-Shea summary: We do business need evaluation first (identify maybe top three) then must purchase the one that best meets accessibility standards.

• Summary: Evident from discussion that there are many different interpretations of how to implement application provisions of Subpart A – whether its tied to the FAR or not. Much more discussion needs to occur, but it appears that desired end goal of the members is to ensure enough flexibility to allow agencies (or states that adopt §508) to apply requirements in way that works for their agency and their procurement requirements AND Enough clarity to support uniform understanding about how the standards will be used/applied to minimize false expectations, e.g. everything purchased is “508 compliant” which equals “fully accessible.”

Next Steps:

• Information from Access Board and 508 coordinators will be summarized and posted when received.
• Subcommittee members were asked to review the summary of issues developed by Diane Golden and contribute their own issues relative to applications, exemptions and definitions.

Next Meeting: Thursday, November 16, 2006 1:00 – 2:00 ET

• Number: Toll-Free (US and Canada): 866-500-6738 Toll: 203-480-8000
• Participant Code: 520044 followed by the # sign.