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Re: Inquiry Regarding Handling PDF Accessibility Challenges in School District Practices

for

From: Ryan E. Benson
Date: Dec 8, 2023 4:57AM

Good Morning

I formerly worked under HHS, and helped develop many of our accessibility
policies, including the one Bevi linked and the accessibility part of the
acquisition regulations. The one that Bevi linked is the general policy,
which doesn't quite allow the rejection of PDFs. The acquisitions policy
opens the door for that. The regs are found at Part 339—Acquisition of
Information Technology | HHS.gov
<https://www.hhs.gov/grants-contracts/contracts/contract-policies-regulations/hhsar/part-339-acquisition-information-technology/index.html>,
which lays the groundwork. Acquisitions should have the language linked to
under 339.203-70, which allows us to reject indirectly.

Instead of saying everything must be accessible or else, it says document
the accessibility of the deliverable, BUT we get to double check before
formally accepting. The secret is most vendors provide a perfect HHS
Checklist or VPAT. Most know on this list knows that perfect accessibility
is largely unattainable. Part of my job in my former agency is to get in
front of contract officers and program people to tell them to check the
stuff and/or my team before acceptance. I'd always find something, so i had
to tell the appropriate people to reject it, have the vendor fix this list
of stuff, and after another check, it can be accepted.

--
Ryan E. Benson


On Fri, Dec 8, 2023 at 6:07 AM < <EMAIL REMOVED> > wrote:

> Mark B. wrote: " Curious if other state/federal agencies have refused
> inaccessible PDFs from third parties."
>
> Yes, Mark. Many of our government clients are rejecting inaccessible ICT,
> and they are pushing back on contractors — and, of course, their
> sub-contractors — to provide fully accessible ICT. HHS is a key agency that
> started doing this about 10–12 years ago, see
> https://www.hhs.gov/web/governance/digital-strategy/it-policy-archive/hhs-policy-section-508-compliance-accessibility-information-communications-technology.html
>
> The law is very clear:
> E201.1 Scope
> ICT that is procured, developed, maintained, or used by agencies shall
> conform to the Revised 508 Standards.
>
> You can view the regulation at https://www.access-board.gov/ict/
>
> If states, schools, and school districts have adopted the federal
> standard, then what you receive from 3rd parties must be accessible.
> In our opinion, it is the responsibility of the content's owner or author
> or publisher to provide it in an accessible format. It is not the school's
> responsibility to fix bad ICT — that is cost-prohibitive, and every school
> has to fix the same crappy inaccessible ICT over and over at an insane cost
> to the public and tax payers.
>
> — — —
> Bevi Chagnon | Designer, Accessibility Technician | <EMAIL REMOVED>
> — — —
> PubCom: Technologists for Accessible Design + Publishing
> consulting • training • development • design • sec. 508 services
> Upcoming classes at www.PubCom.com/classes
> — — —
> Latest blog-newsletter – Simple Guide to Writing Alt-Text
>
>