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Re: VPATs for Word, PPT, Excel, etc.

for

From: Ryan E. Benson
Date: Jun 4, 2018 4:32PM

I am going to answer these questions generally from a HHS perspective. My
agency helped develop this framework. People on the list who are federal
employees, they should talk to their 508 Coordinator, or if the agency has
another resource (I run an agency 508 Help Desk). People also can reach out
to me privately for specifics at my agency.

a) Is it reasonable or plausible that an agency might demand a VPAT for
each deliverable? [RB] yes, this is required, per language in the HHS
Acquisition Regulation. Section 508 coordinators accept the checklists in
place of a VPAT. If the deliverables are identical, such as reports for
each state, and essentially just changing the name of the state, and data,
they may allow one checklist for the group. The pro for this approach is
the contractor/vendor only has to complete the checklist once. The con, if
an error is found, instead of just that one document getting
rejected/returned to be fixed the whole group would be rejected.

b) Is it reasonable to expect that "deliverable" can be construed to
include documents? [RB] Yes, of course. The new standards explicitly cover
electronic documents, see
https://www.access-board.gov/guidelines-and-standards/communications-and-it/about-the-ict-refresh/final-rule/text-of-the-standards-and-guidelines
for details. but electronic documents are named within the definition of
ICT in E103.4.

c) That while the form of the VPAT must be explicable, the actual nature of
the VPAT itself, on a per-document basis, is up to the agency (vendor,
whatever), providing the document under terms that include a VPAT….yes?
Seems obvious, but always best to ask.
[RB] If you are a vendor wanting to do or currently do business with the US
Government, it is highly recommended to create a VPAT for every [COTS]
product you create, and equally important is keeping it updated. I
recommend updating your VPAT for every major release, at minimum. Having a
VPAT that's two years old, and 3 versions ago, is effectively useless. If
your shop specializes in making accessible PDFs, a document that describes
your process, QA, and what tools you use to assist in that is more helpful
than a VPAT if you are replying to a RFQ, PWS. or another type of
solicitation. The Source Selection Evaluation Team is supposed to take the
respondents knowledge of 508 when making a selection, see
https://www.hhs.gov/grants/contracts/contract-policies-regulations/hhsar/part-339-acquisition-information-technology/index.html#339.203



--
Ryan E. Benson

On Sat, Jun 2, 2018 at 12:02 PM, Duff Johnson < <EMAIL REMOVED> > wrote:

> So, looking for clarity here…
>
> a) Is it reasonable or plausible that an agency might demand a VPAT for
> each deliverable?
>
> b) Is it reasonable to expect that "deliverable" can be construed to
> include documents?
>
> c) That while the form of the VPAT must be explicable, the actual nature
> of the VPAT itself, on a per-document basis, is up to the agency (vendor,
> whatever), providing the document under terms that include a VPAT….yes?
> Seems obvious, but always best to ask.
>
> If all of these are true I have a follow-up question.
>
> Thanks.
>
> Duff.
>
> > On Jun 1, 2018, at 22:49, Ryan E. Benson < <EMAIL REMOVED> > wrote:
> >
> >> VPAT has the word "Voluntary" in it, which to me means "whatever you
> > want."
> >
> > This is incorrect. Yes the V is for voluntary, meaning "here's the
> > documentation without asking for it." If the government asks, you either
> > provide the PAT or risk losing the contract. The company is still able to
> > deny the request, but it's not in your best interest. In terms of
> Emily's
> > question, contract language [often] says provide a VPAT for all
> > deliverables. The checklists I mentioned are an alternative to a VPAT for
> > docs. These are often written in non-legalese to make things easier.
> >
> >> The government would be better served if they required certification of
> > documents files for Sec. 508 compliant (WCAG 2.0, PDF/UA-1).
> >
> > A VPAT is literally just that. It is a document that says "We, [company],
> > certify our deliverable meets these standards." As an example, HHS' has
> >
> > d) Respondents to this solicitation must identify any exception to
> Section
> > 508 requirements. If a offeror claims its supplies or services meet
> > applicable Section 508 accessibility standards, and it is later
> determined
> > by the Government, i.e., after award of a contract or order, that
> supplies
> > or services delivered do not conform to the described accessibility
> > standards, remediation of the supplies or services to the level of
> > conformance specified in the contract will be the responsibility of the
> > Contractor at its expense.
> >
> > Source:
> > https://www.hhs.gov/grants/contracts/contract-policies-
> regulations/hhsar/part-352-solicitation-provisions-
> contract-clauses/index.html#352.239-73
> >
> > In English, vendors must document their deliverables meet HHS' standards,
> > the government reserves the right to double check, and if the government
> > finds issues prior to acceptance, the vendor must fix it. GSA has some
> > high-level guidance to develop language like I quoted above at:
> > https://section508.gov/buy/define-accessibility-criteria.
> >
> > --
> > Ryan E. Benson
> >
> > On Fri, Jun 1, 2018 at 4:47 PM, < <EMAIL REMOVED> > wrote:
> >
> >> No.
> >> VPAT has the word "Voluntary" in it, which to me means "whatever you
> want."
> >>
> >> The government would be better served if they required certification of
> >> documents files for Sec. 508 compliant (WCAG 2.0, PDF/UA-1). Use any of
> our
> >> free or not-so-free tools such as:
> >>
> >> Acrobat Pro DC:2018
> >> Word and PowerPoint built-in checker
> >> Axes 4
> >> PAC-3
> >> NetCentric's Validator
> >>
> >> Generally, we find that if the file passes any combo of two of these,
> then
> >> it's usually ok, but of course, the best testing is done my
> knowledgeable
> >> humans!
> >>
> >> --Bevi Chagnon
> >>
> >> — — —
> >> Bevi Chagnon, founder/CEO | <EMAIL REMOVED>
> >> — — —
> >> PubCom: Technologists for Accessible Design + Publishing
> >> consulting ' training ' development ' design ' sec. 508 services
> >> Upcoming classes at www.PubCom.com/classes
> >> — — —
> >>
> >>
> >>