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The Good, The Bad and The Ugly

The Good, The Bad and The Ugly. Observations from over 9,000 EIT Solicitation Assessments. Objective. Provide salient and meaningful examples of language found in EIT solicitations to promote improved compliance and improved accessibility. Assessment Process Overview.

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The Good, The Bad and The Ugly

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  1. The Good, The Bad and The Ugly Observations from over 9,000 EIT Solicitation Assessments

  2. Objective Provide salient and meaningful examples of language found in EIT solicitations to promote improved compliance and improved accessibility.

  3. Assessment Process Overview Historical perspective (GSA statutory requirement, OMB directive)

  4. Purpose of the assessment The purpose of our solicitation monitoring program is to assessfederal solicitations that contain EIT deliverables and provide feedback to the procuring agency on Section 508 compliance.

  5. Two Components of the Assessment Process • Solicitation Assessment • Likely EIT solicitations are selected daily from FBO listings (https://www.fbo.gov) • About 400 EIT a month • Assessment Feedback • GSA provides the feedback to requiring officials (if available from the solicitation), contract officers, and Section 508 Coordinators • How many of you have received such emails? • Specific letters are created for: • Good practices in compliance • Barely complying • Non-compliant

  6. Brief explanation of random FBO sampling • In the first three years it was easy to get a passing grade; • No mention agencies fail • Any mention they pass • Mention of technical sections gets agencies a pat on the back • Grades have improved, so we raised the bar and added new checkpoints to identify good practices.

  7. Brief explanation of random FBO sampling • Assessed solicitations continue to be categorized as Failing/Barely Passing/Passing but it is more difficult to just get by. • Barely passing agencies must make some attempt to identify technical provisions or functional performance criteria. • For sole source procurements, including information, documentation and support also leads to a passing score. • Achieving a Passing score is also more difficult. • Mention of technical criteria and functional performance criteria are required • Mention of whether information, documentation and support applies is encouraged

  8. Feedback Letters What they mean, who they go to and the opportunity for interaction they present

  9. Intent of the letter • The purpose of feedback letters (email) is to open a dialogue with an agency to: • Improved agency compliance with Section 508 • Ultimately to raise the overall level of Section 508 compliance by the federal government and thereby improve accessibility • Email is sent to: • Requiring Official if we can find one • Point of Contact, typically the Procurement Official • CIO • Section 508 Coordinator

  10. Customization of Letters • The emails provide: • Specific guidance on the solicitation – what was done right, what was done wrong, what wasn’t done at all • We also identify good practices • Suggested ways the agency can improve compliance by using available tools and resources. • Information, training and tools available on section508.gov • Where to go and who to contact for further information on this solicitation or on Section 508 compliance

  11. Examples for Your Assessment!!! Tell us what you think. Please grade as Good, Bad, or Ugly!!!!

  12. Example 1 • Department of Everything submitted a Brand Name or Equal solicitation for audio visual equipment • Solicitation Language: “ Section 508 representations and ‘Department of Everything’ compliance (if applicable) certifications, etc.)) directly to John.Doe@home.gov so that they are received at that email address no later than the closing date and time for this solicitation.”

  13. Example 2 • Brand Name solicitation for web content management software • Solicitation Language: “Section 508 of the Rehabilitation Act of 1973, as amended, does not apply to this acquisition because the user does not interact with the EIT product directly.”

  14. Example 3 • Onsite Response for Computer Servers • Solicitation Language: “The Section 508 standards applicable to this contract/order are identified in the below: Subpart A - General1194.1 Purpose.1194.2 Application.1194.3 General exceptions.1194.4 Definitions.1194.5 Equivalent facilitation.”

  15. Example 3 (cont.) “Subpart B - Technical Standards 1194.21 Software applications and operating systems. 1194.22 Web-based intranet and internet information and applications. 1194.23 Telecommunications products. 1194.24 Video and multimedia products 1194.25 Self contained, closed products. 1194.26 Desktop and portable computers. Subpart C - Functional Performance Criteria 1194.31 Functional performance criteria. Subpart D - Information, Documentation, and Support 1194.41 Information, documentation, and support.”

  16. Example 4 • Web-based Training • Solicitation Language: • “Section 508 of the rehabilitation Act requires that Federal agencies’ electronic and information technology is accessible to people with disabilities. The {training} must be Section 508 compliant. Specifically, the end product must be conformant with all applicable provisions, including: 1194.22 Web-based internet and intranet information and applications 1194.31 Functional performance criteria 1194.41 Information, documentation and support”

  17. Example 5 • IDIQ for Web development and Services • Solicitation Language: • “The following standards have been determined to be applicable to this contract:1194.22 Web-based intranet and internet information and applications.1194.24 Video and multimedia products.1194.31 Functional performance criteria.1194.41 Information, documentation, and support.” No other information was given…….

  18. Example 6 • Web Conferencing Service • Solicitation Language: • Listed the Applicable Section 508 Provisions • Specific provisions listed from Subparts B/C/D • Addressed Section 508 in the: • Solicitation Evaluation Factors • Acceptance Criteria • Requested a VPAT • Had accessible documents/attachments

  19. USE CASE Here is an example of our system at work and how the new criteria effected outcomes

  20. Solicitation: Add-on to Software Service • Jan. 2009 - only mention of section was found in the following statement: “Accessibility of content: Content must be accessible in accordance with Section 508 (29 U.S.C. 794d). It is the responsibility of the content provider to familiarize themselves with Section 508 requirements and ensure that their content meets these requirements.”

  21. Solicitation cont. • Under our old criteria they snuck in as minimally compliant • We provided them with suggestions on: • What Provisions they should have included • A link to the BuyAccessible Wizard • We referenced the FAR and stated they were minimally compliant

  22. New Solicitation, Same Language • Jun 2010 another solicitation, same agency, same kind of solicitation, same software service • Same Language • This time, new assessment criteria led to FAIL • Our feedback to the agency: • Why the language did not work • What their responsibilities were • What provisions should have been considered • We stated that they were not in alignment with their FAR requirements

  23. Another Solicitation, New Language • Sep 2010, another solicitation (sources sought this time), same agency, same kind of solicitation, same software service • NEW Language: “Accessibility of content: All electronic content must meet Section 508 Guidelines. See the more specific requirements below regarding Section 508 Compliance. “ • And they provided specific provisions from all three sections, accessibility evaluation criteria, accessibility acceptance criteria, a GPAT

  24. Third Solicitation Assessment • Under our new criteria, the following feedback was provided: “Outstanding work! While we usually don't assess Sources Sought request on FedBizOpps we made an exception in your case because of you exceptional work. It is extremely rare that we see anyone address Section 508 requirements in Sources Sought but it appears to have captured every aspect. … I would like to commend you on your diligence and congratulate you on a job well done!“

  25. Last Solicitation • Oct 2010 yet solicitation for a dictionary web site for that same service. • Under our new assessment criteria another home run, this time a four bagger. • Their response was straight out of GSA’s BuyAccessible Wizard! They included statements on: • Section 508 Compliance • Section 508 Program Need • Section 508 Product Requirements • Section 508 Evaluation Factors (including a GPAT) • Section 508 Acceptance Criteria

  26. Conclusion: Assessment is Working for Some Agencies • The assessment process is able to directly affect how EIT is procured by federal agencies. • It is really quite easy for an agency to implement these practices into their process, but they may need a push from assessment • Assessment feedback does lead to an open dialogue with agencies

  27. What to do when your agency receives a failing grade? • Schedule a call or Session with GSA’s BuyAccessible team and the requiring and contract staff involved • Encourage the use of the BuyAccessible Wizard and Quick Links • Assess your agency’s solicitations before they are released to FedBizOpps.

  28. What is your role as a Section 508 Coordinator? Group Discussion

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