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Re: Who does your VPAT?

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From: Morin, Gary (NIH/OD) [E]
Date: May 21, 2012 9:18AM

Not sure if it was on this list or not, but I recently found and read, Rangin, Bargi. How to talk and discuss about accessibility with vendors? August 24, 2010. http://blog.bargirangin.com/2010/08/how-to-talk-and-discuss-about.html. Worth a read.
I think you can take the VPAT question even one step further and better if you think about it in the following set of progressive questions:
1. If you ask any vendor "Do you comply with Section 508?" they might say yes, even if they don't know what Section 508 is at all.
2. If you ask "How do you comply with Section 508?," you'll get a better answer - including letting you know if they've already done the work in determining what applies to their EIT product.
a. This might get you a VPAT and, hopefully, one that is accurate regarding the six sets of technology standards (§ 1194.21 through § 1194.26).
3. If you ask "How do you know if someone with a disability can use your product?," you are getting to the questions asked in the FPC, and will probably get a real conversation about a vendor's accessibility and Section 508 compliance
a. This will get you, hopefully, a VPAT with a meaningful completion also of the Functional Performance Criteria.
The point being that, one needs to ask a vendor not just whether or not the product conforms to the appropriate one or more areas of technology (e.g., hardware, software, telecommunications, multimedia, etc.), but how does it perform in the real world.

Some have said that EIT can conform to the standards (see below, § 1194.21 through § 1194.26) and still not be accessible. Another way to look at it might be that without addressing the Functional Performance Criteria, the EIT product is not even conformant - i.e., FPC is one of the standards. I think it's fair to say that, from what I've seen, we sometimes (often?) overlook the Functional Performance Criteria and the Information Documentation and support.

* § 1194.21 Software applications and operating systems
* § 1194.22 Web-based information and applications
* § 1194.23 Telecommunications
* § 1194.24 Video and multimedia
* § 1194.25 Self contained, closed products
* § 1194.26 Desktop and portable computers


Gary M.