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GSA / openacr

OpenACR is a digital native Accessibility Conformance Report (ACR). The initial development is based on Section 508 requirements. The main goal is to be able to compare the accessibility claims of digital products and services. A structured, self-validated, machine-readable documentation will provide for this.
https://gsa.github.io/openacr/
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Support procurement officer evaluations in the comparison tool #177

Open mgifford opened 2 years ago

mgifford commented 2 years ago

The exceptions are pretty clearly laid out in the Section508.gov's Determine ICT Exceptions page.

It would be useful to include a link to this, if vendors are claiming that the product/service is an exception. It would also be useful to highlight that an ACR can only be done on an existing product/service. The point of an ACR is to influence procurement decisions. Contracting could ask for a conformance report at the end of the contract (and probably should) but that should be distinct from a OPAT and should be focused on the accessibility needs of the client as expressed in the contract.

Some departments also have a grading system that is implemented informally to evaluate the quality of a VPAT. The criteria is contract-specific, but generally its: A: VPAT 2.0 or higher B: for the most recent version/release C: filled out to instructions associated with the VPAT or RFP D: provides sufficient detail in the notes and comments

Some of this could be highlighted in the comparison tool.

bruce-usab commented 2 years ago

if vendors are claiming that the product/service is an exception

This is an important consideration because (mostly) it should be left to the government procuring official to determine that an exception is applicable.

Of course, the vendor might know the regs better than the fed. Having the ACR mention, for example, that the product would always be located in spaces that are frequented only by service personnel for maintenance, repair, or occasional monitoring of equipmentcould be useful.

Some departments also have a grading system that is implemented informally to evaluate the quality of a VPAT

If any of these sort of protocols are robust enough to be public facing, that would be great.

The criteria is contract-specific, but generally its...

Just to be clear, on this thread, your A/B/C/D are factors which can be graded (maybe even pass/fail). (That is, the list is not reflective of a letter grade assigned.)

mgifford commented 2 years ago

Thanks for this feedback @bruce-usab I do think that the UI could include something to remind the procurement officers about the exception is soley at the disgression of the government and not a choice for the vendor. Do you know where that decision would be recorded? Would that be part of the DHS's DART program?

I don't know that the VPAT evaluations are robust enough. That said, I don't see why if government departments are using them already that the grading criteria aren't public. People need to know how they are going to be evaluated for a transparent procurement process.

Even if it is as simple as, saying that ACRs will be evaluated and marked to see that a preference is given to: A: the latest ITI release of VPAT (or eventually OPAT) B: the most recent ACR for the version of the product being evaluated in the procurement C: complies or exceeds the instructions given in the ACR or RFP D: provides sufficient detail in the notes and comments to determine the impact for the RFP

If vendors knew that this mattered and might make the difference in winning/losing a bid they might pay more attention.

mgifford commented 2 years ago

There is some interesting guidance from AccessibilityOZ on evaluating VPAT that might have some relevant ideas https://www.accessibilityoz.com/2019/09/how-to-read-a-vpat/