Procurement Training for Accessible EIT

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					Participant Guide for Accessible EIT Procurement Training 101

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Procurement Training for Accessible Electronic and
Information Technology
Participant Guide

Welcome to the CSU Accessible Technology Initiative Procurement Training for
Accessible Electronic and Information Technology. This training will present information
and resources on how to carry out the responsibilities of the California State University
in the procurement of accessible electronic and information technology. It will focus on
the Section 508 requirements and standards now codified in California Government
Code 11135.

Procurement training for Accessible Electronic and Information and Technology will
cover:

   1. Accessibility in Electronic and Information Technology (E&IT)
   2. Voluntary Product Accessibility Templates (VPATs) and How to Request
      Accessibility Information from Vendors
   3. CSU Procurement Steps and Documentation Responsibilities
   4. Accessible Procurement Scenarios
   5. Tools and Resources

When you are finished with this training module, you should understand:

       Legislative History of California Government Code 11135
       California State University E&IT Accessibility Procurement Policies
       Documentation Responsibilities for Procurement
       The Section 508 Requirements (Subparts A, B, C and D)
       How to Apply Section 508 Requirements in Procurement

The information provided in this training has been divided into the following seven parts:

Part   1:   Accessibility in Electronic and Information Technology (E&IT)
Part   2:   The Role of Assistive Technology in Providing Access
Part   3:   VPATs and How to Request Accessibility Information from Vendors
Part   4:   CSU Procurement Steps and Documentation Responsibilities
Part   5:   Accessible Procurement Scenarios
Part   6:   Tools and Resources
Part   7:   Glossary




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Participant Guide for Accessible EIT Procurement Training 101

Part 1: Accessibility in Electronic and Information Technology

Part 1 of the training outlines in detail what is meant by accessibility in electronic and
information technology. It covers the legislative history of California Government Code
11135, discusses the federal Section 508 requirements codified in the state statute and
explains why the requirements are needed. It answers the following questions:

       How is accessibility in electronic and information technology to be
        achieved?
       What are the Section 508 standards and why are they needed?

I. California Government Code 11135

Government Code 11135 provides protection from discrimination on the basis of
disability from any program or activity that is conducted, funded directly by, or receives
any financial assistance from the State of California. It brings into State law the
protection of Title II of the Americans with Disabilities Act which ensures accessibility to
government programs. It also codifies Section 508 of the Rehabilitation Act requiring
accessibility of electronic and information technology (E&IT).

Section 508 is part of the Rehabilitation Act that was amended in 1998 through the
Workforce Investment Act. It requires that electronic and information technology
developed, procured, maintained or used by the federal government to be accessible to
individuals with disabilities. The Electronic and Information Technology Accessibility
Standards promulgated by the U.S. Access Board provide the Section 508 accessibility
requirements for mainstream technology and services. These federal requirements are
codified in California Government Code 11135.

Section 508 uses the power of the purse to drive the market in the accessible design of
mainstream technology. It also seeks to enable mainstream technology to be
compatible with assistive technology. In some cases, the accessibility standards
require certain technology to be readily usable without the need for assistive devices.
This is because the accessibility standards apply universal design principles so that the
design of products and services can be usable by the greatest number of people
including individuals with disabilities. This approach significantly reduces the cost of
expensive customization for individuals with disabilities.

Many States across the country have adopted Section 508 as public policy or law. In
California, Section 508 was codified by Government Code 11135 by our State
Legislature in 2002 through S.B. 105. In 2003, the State statute was amended again by
S.B. 302 to specifically apply to CSU.

Effective January 1, 2004, Government Code 11135 requires CSU to comply with the
accessibility requirements of Section 508 and to also apply the U.S. Access Board
accessibility standards to the electronic and information technology products and
services that it buys, creates, uses and maintains.



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One difference between the California law and Section 508 is that Government Code
11135(d)(3) requires vendors who provide electronic or information technology or
related services to respond to accessibility complaints: any one who contracts with CSU
to provide E&IT “shall agree to respond to, and resolve any complaint regarding
accessibility of its products or services that is brought to the attention” of CSU. In this
regard, CSU must identify the complaint process for faculty, staff, students and
members of the public to communicate and resolve technology accessibility complaints
with the vendor. In addition, the law states that:

              [I]t is not the intention of the Legislature to increase the cost
              of developing or procuring electronic and information
              technology. The California State University shall, however,
              in determining the cost of developing or procuring electronic
              or information technology, consider whether technology that
              meets the standards [Section 508] . . . will reduce the long-
              term cost incurred by the California State University in
              providing access or accommodations to future users of this
              technology who are persons with disabilities, as required by
              existing law, including this section, Title II of the Americans
              with Disabilities Act of 1990 and Section 504 of the
              Rehabilitation Act of 1973. [citations omitted]

The general assumption of Section 508 is that procuring E&IT that is designed to
accessibility standards would be more efficient and would decrease the need for
specific expensive retrofitting in the long-term. Government Code 11135 declares the
intent of the legislation which is not to increase the long-term cost incurred by the CSU
in providing access or accommodations to future users of this technology who are
persons with disabilities.

CSU has developed policies, implementation procedures, training, and education
resources so that end-users and all relevant parties in implementing accessible
procurement can understand acquisition planning and contract solicitations for
compliance with Government Code 11135. This is addressed in Executive Order 926
and relates to the CSU Board of Trustees policy on disability support and
accommodations.

II. Section 508 Electronic and Information Technology Accessibility
Standards

The Section 508 Standards contain four sections:
       Subpart A- Covers Scope of Section 508 & Exceptions for when to Not Apply
                    these Standards
       Subpart B- Covers Fifty-Eight Technical Rules for E& IT
       Subpart C- Covers Six Functional Performance Criteria
       Subpart D- Covers Three Vendor Requirements for Information,
                    Documentation & Support



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A. Key Concepts

According to Cynthia Waddell, Section 508 subject matter expert, the rationale behind
the federal technical accessibility standards is at least three-fold:

       1. Apply Universal Design Principles (European Union “Design for All”) – To
          enable mainstream technology to be used by the largest number of people
          and thus reduce the cost of expensive customization for users with
          disabilities;

           For example: Before we knew about programming a website for accessibility,
           the City of San Jose had to provide a tape recording of their budget to a blind
           commissioner. The tape recording labor was extremely costly and labor
           intensive, for it had to explain the tables, charts and statistical data in addition
           to reading hundreds of pages. The end result was a tape recording that was
           not searchable. The solution was to place the budget up on the web in an
           accessible format – thereby enabling the commissioner to use his screen
           reader to audibly read the budget and to perform information search tasks.

       2. Design to a Standard to promote interoperability between mainstream
          technology and assistive computer technology; Interoperability is the ability of
          software and hardware on different machines from different vendors to
          exchange data. This is achieved by agreeing on a common set of standards.
          There are many different types of standards that vendors are encouraged to
          follow for different reasons. Section 508 standards are about accessibility.

       3. Create Marketplace Incentives- To use the power of the purse to drive the
          accessible design of technology. If you (the creator/designer of electronic or
          information technology) want to sell to the federal government and now to
          many state governments, you design to the 508 standards.

Today’s workshop includes a look at assistive technology where you will see these
principles at work. Another key concept is to understand that the technical rules for
accessibility seek to expose both content and functionality in technology so that
interoperability between assistive technology and mainstream technology can be
achieved. One example of this is the ability to have keyboard navigation for all
functions that are available to the mouse. By programming software to recognize that a
key stroke represents a mouse action, we expose the functionality originally reserved
for the mouse. Another example is in the requirement to add text to images and
graphics in accessible web design. If we add “alt” attributes to images on a website, we
expose content about the image to the screen reader so it can access it. As we look at
the technical standards, we will see how they work to expose both content and
functionality.

B. Definition
Codified in California Government Code 11135, the Section 508 E&IT Accessibility
Standards are published at 36 CFR Part 1194. Published by the U.S. Access Board,
the standards define “electronic and information technology” to include:

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              “[A]ny equipment or interconnected system or subsystem of equipment, that
              is used in the automatic acquisition, storage, manipulation, management,
              movement, control, display, switching, interchange, transmission, or reception
              of data or information.

The definition is broad and includes computer hardware, software, networks, and
peripherals as well as many electronic and communications devices commonly used in
offices and universities.

       1. Why is “Accessible” Not in Definition?

       The Section 508 standards explain the detailed technical and functional
       performance criteria that will determine whether or not a technology product or
       system is “accessible.” In general, an information technology system is
       accessible to individuals with disabilities if it can be used in a variety of ways that
       do not depend on a single sense or ability. For example, a system that provides
       output only in audio format would not be accessible to people with hearing
       impairments, and a system that requires mouse actions to navigate software or a
       website would not be accessible to people who cannot use a mouse because of
       a dexterity or visual impairment. For this reason, the accessibility standards for
       video and multimedia require captioning and the standards for software and the
       web require keyboard navigation.

       2. Section 508 – A Different Law

       Section 508 is different from the Americans with Disabilities Act (ADA) and
       Section 504 of the Rehabilitation Act. Section 508 focuses on the technology
       design whereas the ADA and Section 504 focuses on the individual’s need. In
       other words, Section 508 focuses on the overall accessibility of E&IT, not on
       providing accommodations at individual worksites. This is different from the ADA
       and Section 504 which requires CSU to provide reasonable accommodations,
       academic adjustments and auxiliary aids and services tailored to individuals with
       disabilities. However, even with an accessible system, individuals with
       disabilities may still need specific accessibility-related software or peripheral
       devices as an accommodation to be able to use it. For example, in order to use
       an accessible word-processing program, a person who is blind may need add-on
       software that reads text aloud. As mentioned earlier, Section 508 supports
       interoperability and compatibility between the mainstream technology used
       (word-processing program) and the software that reads text aloud (screen
       reader).


C. Overview- Technical Standards (Subpart B)
The Access Board Section 508 Standards have been established to help CSU and
vendors to determine whether or not a technology product or system is accessible.
There are sixty-five technical elements under these standards covering the following
categories of products and services in Subpart B:

       1. Software applications and Operating Systems;

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        2. Web-based intranet and Internet information and Applications;
        3. Telecommunications Products;
        4. Video and Multimedia products including television displays and computer
           equipment with display circuitry that receives, decodes and displays
           broadcasts, cable, videotape and DVD signals;
        5. Self-contained, closed products that have embedded software and include,
           but are not limited to information kiosks, information transaction machines,
           copiers, printers, calculators and fax machines; and
        6. Desktop and portable computers.

Key concepts revisited:

       For software and the web– we seek to expose the content as well as the
        functionality of the user interface elements so that assistive technology such as
        screen readers and other alternative input and output methods can operate.
       For telecommunication products- we seek to have no interference with the
        functionality and operation of TTY’s with interactive voice response systems and
        hearing aids. TTY’s are teletypewriters or telecommunication devices for the
        deaf.
       For video and multimedia products- we ensure that the audible content is visual
        and that for training products the visual content is audible;
       For Self-contained, closed products, we ensure that the products as a stand
        alone meet cross-disability functionality so that a person with visual, hearing,
        and mobility impairments can use it;
       For Desktop and portable computers- we ensure that the operational controls
        meet cross-disability requirements and that connection points are available for
        assistive technology.


D. Overview- Information, Documentation, and Support (Subpart D)
In addition, these standards in Subpart D include three requirements for Vendors to
provide Information, Documentation and Support; specifically:

   1. Product support documentation provided to end-users shall be made available in
      alternate formats upon request, at no additional charge;
   2. End-users shall have access to a description of the accessibility and compatibility
      features of products in alternate formats or alternate methods upon request, at
      no additional charge; and
   3. Support services for products shall accommodate the communication needs of
      end-users with disabilities.


E. Overview- Functional Performance Criteria (Subpart C)
The six functional performance criteria as outlined in Subpart C applies to those E&IT
that may not be designed to the technical standards but rather incorporate new
methods, design, or technologies to achieve accessibility (see Equivalent Facilitation
discussion below).


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Section 1194.31 Functional Performance Criteria.
   (a) At least one mode of operation and information retrieval that does not require user
       vision shall be provided, or support for assistive technology used by people who are
       blind or visually impaired shall be provided.
   (b) At least one mode of operation and information retrieval that does not require visual
       acuity greater than 20/70 shall be provided in audio and enlarged print output
       working together or independently, or support for assistive technology used by
       people who are visually impaired shall be provided.
   (c) At least one mode of operation and information retrieval that does not require user
       hearing shall be provided, or support for assistive technology used by people who
       are deaf or hard of hearing shall be provided.
   (d) Where audio information is important for the use of a product, at least one mode of
       operation and information retrieval shall be provided in an enhanced auditory
       fashion, or support for assistive hearing devices shall be provided.
   (e) At least one mode of operation and information retrieval that does not require user
       speech shall be provided, or support for assistive technology used by people with
       disabilities shall be provided.
   (f) At least one mode of operation and information retrieval that does not require fine
       motor control or simultaneous actions and that is operable with limited reach and
       strength shall be provided.


F. Overview- Application of Section 508 and Exemptions (Subpart A)

Subpart A of the U.S. Access Board regulations provides technical assistance for
federal government implementation of Section 508.

For the purposes of this training based on the State codification, this overview provides
guidance for understanding CSU procurement requirements. Subpart A outlines the
scope of Section 508 and explains the application of the following provisions: undue
burden, commercial availability, equivalent facilitation and the exceptions for not
procuring products conforming to the Section 508 standards.

Undue Burden:

      When developing, procuring, maintaining or using E&IT, CSU shall ensure that
       the products conform to the Section 508 standards unless it would be an undue
       burden. An undue burden means significant difficulty or expense. Undue burden
       is to be determined on a “case by case” basis and should be rarely invoked.
      If conformance to the standards would impose an undue burden, CSU shall
       provide individuals with disabilities with access to the information and data by an
       alternative means so that they can use the information and data.
      Should CSU determine that compliance with the Section 508 standards would
       impose an undue burden, documentation will be required. This is discussed in
       detail in Part 4 of this training.

   Example: The President’s Office decides to purchase a computer program that
   generates maps denoting regional demographics. The cost of acquiring an
   accessible version of the program would exceed the entire Operating Budget for the
   campus. This cost would be considered an undue burden. If the President’s Office

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   is to claim an undue burden so that it can procure the inaccessible version, it must
   document that exception, obtain the approval and signature of the official charged
   with making 508 exceptions and be prepared to provide the map demographic
   information in an alternative manner to users with disabilities.

Fundamental Alteration Exception:

       CSU is not required to alter its acquisition requirements to comply with
        Government Code 11135 if the alteration would be so fundamental that CSU
        would no longer be procuring E&IT that met its needs.
       This exception has to do with a change in the fundamental character or purpose
        of the product or service, not merely a cosmetic or aesthetic change.

    Example: The campus facilities department needs pocket-sized pagers for the
    grounds-keepers. Adding a large display to a small pager may fundamentally alter
    the device by significantly changing its size so that it no longer meets the purpose it
    was intended- to be a communication device that fits in a shirt or jacket pocket for
    portability.

Commercial Availability:

       When procuring a product, CSU shall procure products which conform to the
        standards when the products are available in the commercial marketplace or
        when they are developed in response to a CSU solicitation.
       CSU cannot claim a product is not commercially available because no product
        meets all the standards. If products are commercially available that meet some,
        but not all, of the standards, then CSU must procure the product that best meets
        the standards assuming all other factors are equal. .

    Example: Products from Vendor A, B and C meet CSU’s business requirements.
    Vendor A has an accessible product but because of vendor production issues, it
    cannot be delivered to CSU by the required date. Vendor B has a product that
    meets some of the accessibility requirements but not all of them as offered by
    Vendor A. Vendor C has a product that meets some of the accessibility
    requirements, but more than those offered by Vendor B. Assuming all things being
    equal in terms of meeting the business requirements, Vendor C’s product will be
    procured even though it is not fully accessible,

Equivalent Facilitation:

       Recognizing that future technologies may be developed or that existing
        technologies could be used in a particular way, equivalent facilitation provides
        for technology innovations that cause E&IT to fall outside the Subpart B
        technical provisions.
       The test for equivalent facilitation is whether or not the technology results in
        “substantial equivalent or greater access.”
       Subpart C (discussed below) provides the functional performance criteria for
        products falling outside of the technical provisions of Subpart B.

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    Example: An information kiosk that is not accessible to a person who is blind might
    be made accessible by incorporating a telephone handset connected to a computer
    that responds to touchtone commands and delivers the same information audibly
    that is provided on the screen.


Additional Exceptions for Not Procuring Section 508 Products:

       The E&IT involves intelligence activities;
       The E&IT involves cryptographic activities related to national security;
       The E&IT involves the command and control of military forces;
       The E&IT involves equipment as an integral part of a weapon or weapons
        system;
       The E&IT is for products to be acquired by a contractor incidental to a contract;
        and/or
       The E&IT is for products located in spaces frequently only by service personnel
        for maintenance, repair or occasional monitoring; and cannot be operated
        remotely. Examples from the U.S. Department of Commerce, NOAA are:
        Power supplies and electrical equipment; cabling and plugs; specialized back-
        end computers that do not provide a direct user interface such as hubs, routers,
        etc; and embedded software that has no direct interface to the end-user. See
        http://www.cio.noaa.gov/itmanagmenet/508_You_CD435.htm;
       California Government Code 11135: Not Increasing the Long Term Cost.




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Part 2: The Role of Assistive Technology in Providing Access
(Notes Page)




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Part 3: VPATs and How to Request Accessibility Information from
Vendors

Both Parts 3 and 4 address critical steps in the gathering of accessibility information
about E&IT products. In Part 3, the training addresses the use of Voluntary Product
Accessibility Templates. In Part 4, the training covers the CSU procurement policies
and steps.

This section of the procurement training addresses the following questions:
     How can we request/research for accessibility information from vendors?
     What should be communicated to requestors (purchasers) of electronic
       and information technology about accessibility requirements?

The Voluntary Product Accessibility Template (VPAT) is a form developed by the
Information Technology Industry Council (ITI) and the federal government so that
vendors could disclose the extent that their E&IT products and services conform to each
of the Section 508 technical standards. The form is designed to be completed in a
consistent format. In each VPAT, the vendor is expected to make specific statements in
simple and understandable language that addresses how their product or service meets
the Access Board standards.

A number of E&IT companies routinely produce VPATs, post them on their company
web sites and link them to the USGSA “Buy Accessible” web site. According to ITI,
feedback from the companies and government procurement officials suggest that:

  1.   VPATs significantly assist procurement officials in making preliminary
       assessments regarding the availability of commercial E&IT products and services
       by highlighting features that support the Section 508 criteria; and
  2.   VPATs will be of even greater value to the procurement official if E&IT vendors
       use consistent language when filling out a VPAT.
As a result of this feedback, ITI developed this form and suggested language for use
when filling out a VPAT to describe the supporting features of the Section 508
standards:
                                                                        TM
                            Supporting Features (second column on VPAT )

Supports                                                Use this language when you determine the
                                                        product fully meets the letter and intent of the
                                                        Criteria.

Supports with Exceptions                                Use this language when you determine the
                                                        product does not fully meet the letter and intent of
                                                        the Criteria, but provides some level of access
                                                        relative to the Criteria.

Supports through Equivalent Facilitation                Use this language when you have identified an
                                                        alternate way to meet the intent of the Criteria or
                                                        when the product does not fully meet the intent of
                                                        the Criteria.

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Supports when combined with Compatible AT                           Use this language when you determine the
                                                                    product fully meets the letter and intent of the
                                                                    Criteria when used in combination with
                                                                    Compatible AT. For example, many software
                                                                    programs can provide speech output when
                                                                    combined with a compatible screen reader
                                                                    (commonly used assistive technology for people
                                                                    who are blind).

Does not Support                                                    Use this language when you determine the
                                                                    product does not meet the letter or intent of the
                                                                    Criteria.

Not Applicable                                                      Use this language when you determine that the
                                                                    Criteria do not apply to the specific product.

Not Applicable - Fundamental Alteration Exception Applies           Use this language when you determine a
                                                                    Fundamental Alteration of the product would be
                                                                    required to meet the Criteria (see the access
                                                                    board standards for the definition of "fundamental
                                                                    alteration").


                                                      TM
 Remarks & Explanations (third column on VPAT )

 Feedback from procurement officials and customers shows that providing further explanation regarding features
 and exceptions is especially helpful. Use this column to detail how the product addresses the standard or criteria
 by:

       Listing accessibility features or features that are accessible;
       Detailing where in the product an exception occurs; and
       Explaining equivalent methods of facilitation (definition of "equivalent facilitation" See 36 CFR 1194.5.).


As we shall see in Part 4 of this training, the VPAT enables CSU to document
marketplace research obligations and to evaluate bids for determining the most
accessible product to procure as required under Government Code 11135. It also
provides CSU with a record for tracking accessible procurements.

See handouts for a copy of the VPAT form as well as an example of a vendor VPAT:
     Version 1.2 of the VPAT which can be found online at http://www.access-star.org/ITI-
       VPAT-v1.2.html;
     Example of Completed VPAT by Plantronics which can be found online at
       http://www.plantronics.com/media/government/VPAT1.pdf




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Part 4: CSU Accessible Procurement Steps and Documentation
Responsibilities

Part 4 of the training applies CSU policies for procurement of accessible electronic and
information technology. It is recommended that all campuses follow these steps and
documentation procedures. The following topics are addressed in this section:

       What are the CSU procurement steps?
       How does one apply and document the exceptions, including commercial
        non-availability, fundamental alteration and undue burden?
       How does one document the procurement?
       What tools and resources are available to assist?
       What does one do when there is a complaint about inaccessible products?


    See APPENDIX E for “10 Steps to Official Bids”




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Part 5: Accessible Procurement Scenarios

Part 5 provides various scenarios that demonstrate how to apply the Section 508
requirements in the procurement of goods and services.

I. Anita is a staff member and needs to buy a photocopier – What does she
need to know and what does she need to do?

Mary Cheng, ATI Director, meets Anita Short, a new employee in her department.

Mary: Hello! You must be Anita. I’m Mary. How’s your first day going so far?
Anita: It’s going well, thanks, although I have to buy a photocopier and I heard that it
must be accessible. I am not quite sure what that means and how to do this. Someone
said that I had to look at the Section 508 accessibility requirements for electronic and
information technology. But I don’t think a photocopier is E&IT.
Mary: Accessibility is a big part of work. Would you like me to help you out?
Anita: Oh, could you? That would be great.
Mary: Tell you what, let’s grab some coffee and I’ll explain what this is about.




John Smith, Technology Director, enters the coffee shop.

John: No fat decaf cappuccino, please.
Mary: Hi John! Come and meet Anita, a new employee in our department.
John: Nice to meet you, Anita.
Mary: John, I’m glad I bumped into you.
John: Oh, why’s that?
Mary: Anita needs to buy a new photocopier and I’ve forgotten whether or not a
photocopier falls under Section 508 as electronic and information technology. And if it
is, what category is it? I know that it is not hardware, software or multimedia. And the
photocopier will not be networked. What do you think?
John: A photocopier is considered electronic and information technology and it does
not matter whether or not it is networked. Using Section 508 language, it falls into the
classification of a self-contained, closed product.
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Anita: Ok. So why do I need to know what classification it falls into?
John: By knowing the classification, you will know what accessibility features the
product must have.
Anita: Wonderful! That means that in my order I can specify the accessibility
standards from the self-contained, closed product classification. I don’t need to do
anything else.
Mary: That’s not exactly true. You still need to follow the CSU accessible procurement
procedures. After determining which of the accessibility standards apply, you need to
conduct market research to determine the availability of photocopiers that conform to
these standards. One way to do that is to request VPATs from vendors.
Anita: What’s a VPAT?
Mary: A VPAT is a Voluntary Product Accessibility Template where a vendor discloses
the extent their photocopier meets the accessibility standards. You can ask a vendor
for one or you could get it off the vendor’s website or use the online buyaccessible
wizard.
John: And don’t forget to include in your specifications the Section 508 Subpart D
criteria- Information, Documentation and Support. This way you will get an accessible
operating manual as well as a description of the accessibility features.
Mary and Anita speaking at the same time: Thanks, John.

II. Harry is a faculty member and needs to buy a particular discipline-
specific software to be installed on the departmental instructional lab.

Harry and Erica are faculty members talking in the lab.




Harry: Guess what? I’ve got approval to buy that StarGazer software in the
instructional lab. Have you seen the latest version?
Erica: Yeah. Version 2.4.4.1 would be great to use for my mid-term exam. It seems to
have the required accessibility features.
Harry: Yes. I asked the vendor for their VPAT and the good news is that it has more
accessibility features than their competitor, StarWonder. They even have a help desk
set up that can communicate effectively with individuals with disabilities.

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Erica: JAWS, the screen reading software, is on the lab computer. Are there any
interoperability or compatibility problems with the operation of JAWS and Zoomtext?
We need to be sure our students with visual disabilities can use it. And what about
keyboard navigation? We have a student using a wheelchair that cannot use a mouse
because of his lack of fine motor control.
Harry: Those were some of the very first questions we asked. We have a committee
that includes users of assistive technology and they regularly test new products.
(Zoomtext worked fine. And JAWS had a few problems. We called the JAWS
developer, Freedom Scientific, and they told us the workarounds. They also said that
they were working on fixes for this problem in the next JAWS release. And as for the
keyboard navigation, we verified that functionality in the committee review because
StarGazer provides keyboard navigation equivalents for the mouse. This means that
our student who lacks fine motor control can use the software.
Erica: It sounds like we have my accessibility questions addressed.


III. Tom is a librarian and needs to purchase electronic content that
includes multimedia resources.

Tom is reviewing the CSU Accessible Procurement Steps and phones a CSU
Procurement Officer.




Tom: Eric, I am writing out the specifications for the multimedia resources solicitation
we discussed yesterday. Thank you for sending me the CSU Accessible Procurement
Steps.
Eric: You are very welcome. Can I help you with anything more?
Tom: How do I perform the market research. What is this about?
Eric: This is the step where you research the multimedia resources that meet your
business needs and learn about their Section 508 conformance.
Tom: I understand the VPAT. But many of these suppliers do not have VPATs. What
do I do?
Eric: If there is no VPAT available, ask the supplier to produce a VPAT or to provide
comparable documentation. You should also remember that you can use research
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Participant Guide for Accessible EIT Procurement Training 101

organizations, search Internet and supplier web sites and you can c ontact other libraries
that are already using the products to learn about any accessibility issues.
Tom: I’m glad I gave you a call. Thanks for the tip.

IV. Conchita, the ADA Coordinator for the campus has received a
complaint about the inaccessibility of the campus web-based registration
system for a student who is blind.

Conchita phones Legal Counsel to ask some questions. Attorney-client privilege is
waived for this conversation.




Conchita: Jack, I have an access complaint here from a student who is blind. She
claims that the campus web-based registration system is not accessible. The system is
new and was just purchased. I don’t know what to do. She also is saying this is a
Section 508 violation. Help! Isn’t Section 508 a federal government problem and not
my problem?
Jack: Take a look at Executive Order 926. The State Legislature amended our
government code and codified Section 508 under Government Code 11135. CSU must
now ensure the procurement of accessible electronic and information technology and
that includes the web-based registration system. The first step is the manager needs to
find out exactly what the problem is and document it. We need to verify that the student
did, in fact, encounter an accessibility problem and that this is not just a
misunderstanding or lack of proficiency with the assistive technology. If it appears to be
an accessibility problem, then the CSU complaint form should be filled out and then the
vendor will need to be contacted. We have a warranty clause in our contracts and there
is also a State of California statutory requirement that the vendor needs to address this
complaint.
Conchita: Ok. If we must work with the vendor and this is a contract performance
issue, then it seems that we need to handle this complaint differently from the ADA and
Section 504 complaints. The committee that does this is not that well versed in the
Section 508 requirements. Can we set a time to discuss how to address these types of
complaints on our campus?
Jack: Sure. I will be on campus tomorrow for the faculty senate meeting. Can we
meet afterwards.
Conchita: Thanks.




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Participant Guide for Accessible EIT Procurement Training 101

Part 6: Tools and Resources

This section provides tools and resources to support the California State University
effort to procure accessible electronic and information technology products and
services.

To read about CSU’s ongoing commitment to provide access to information resources
and technologies to individuals with disabilities, see the Executive Order 926 (EO 926) -
the CSU Board of Trustees Policy on Disability Support and Accommodations at
http://www.calstate.edu/eo/EO-926.html.

The mission of the Accessible Technology Initiative (ATI) is to help CSU campuses
carry out EO926 by developing guidelines, implementation strategies, tools and
resources. Visit the ATI website for resources at http://www.calstate.edu/accessibility.

For information about the ATI Work Plan involving web accessibility, instructional
materials accessibility and accessible E&IT procurement, see Coded Memo AA 2006-
41: “Access to Electronic and Information Technology for Persons with Disabilities”
dated September 29, 2006 at http://www.calstate.edu/acadAff/codedmemos/AA-2006-
41.pdf.

CSU Information for Vendors at the ATI website: www.calstate.edu/accessibility

CSU Guide to Voluntary Product Accessibility Template at the ATI website:
www.calstate.edu/accessibility

For technical assistance from the U.S. Access Board on the application of the Section
508 technical standards, see the following websites:

Guide to the Section 508 Standards for E&IT
http://www.access-board.gov/sec508/guide/index.htm

Section 508 Tutorial on Developing Accessible Software
http://www.access-board.gov/sec508/software-tutorial.htm

E-Learning: Conforming to Section 508
http://www.access-board.gov/sec508/e-learning.htm




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Participant Guide for Accessible EIT Procurement Training 101

Part 7: Glossary

Access Board. An independent Federal agency that develops and maintains
accessibility requirements for the built environment and for electronic and
information technology. Official name is the “Architectural and Transportation
Barriers Compliance Board.”

Alternate formats. Alternate formats usable by people with disabilities may
include, but are not limited to, Braille, ASCII text, large print, recorded audio, and
electronic formats that comply with this part.

Alternate methods. Different means of providing information, including product
documentation, to people with disabilities. Alternate methods may include, but
are not limited to, voice, fax, relay service, TTY, Internet posting, captioning, text-
to-speech synthesis, and audio description.

Assistive technology. Any item, piece of equipment, or system, whether
acquired commercially, modified, or customized, that is commonly used to
increase, maintain, or improve functional capabilities of individuals with
disabilities.

California Government Code 11135. State of California statute that prohibits
discrimination against people with disabilities in any program or activity that is
conducted, funded directly by, or receives any financial assistance from the State. This
section brings into State law the protection of Title II of the Americans with Disabilities
Act which ensures accessibility to programs; Section 504 of the Rehabilitation Act of
1973; and Section 508 of the Rehabilitation Act which requires the procurement of
accessible electronic and information technology. Requires that any entity that
contracts to provide electronic and information technology products or services shall
agree to respond to and resolve any complaint regarding the accessibility of products or
services provided.

Electronic and information technology (E&IT). Includes information
technology and any equipment or interconnected system or subsystem of
equipment, that is used in the creation, conversion, or duplication of data or
information. The term electronic and information technology includes, but is not
limited to, telecommunications products (such as telephones), information kiosks
and transaction machines, World Wide Web sites, multimedia, and office
equipment such as copiers and fax machines. The term does not include any
equipment that contains embedded information technology that is used as an
integral part of the product, but the principal function of which is not the
acquisition, storage, manipulation, management, movement, control, display,
switching, interchange, transmission, or reception of data or information. For
example, HVAC (heating, ventilation, and air conditioning) equipment such as
thermostats or temperature control devices, and medical equipment where
information technology is integral to its operation, are not information technology.

Information technology. Any equipment or interconnected system or
subsystem of equipment, that is used in the automatic acquisition, storage,
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Participant Guide for Accessible EIT Procurement Training 101

manipulation, management, movement, control, display, switching, interchange,
transmission, or reception of data or information. The term information
technology includes computers, ancillary equipment, software, firmware and
similar procedures, services (including support services), and related resources.

Operable controls. A component of a product that requires physical contact for
normal operation. Operable controls include, but are not limited to, mechanically
operated controls, input and output trays, card slots, keyboards, or keypads.

Rehabilitation Act of 1973. Federal civil rights law that prohibits discrimination
against persons with disabilities. This law applies to programs conducted by
Federal agencies, entities receiving Federal funds (such as colleges participating
in Federal student loan programs), Federal employment, and employment
practices of businesses with Federal contracts.

Section 504 of the Rehabilitation Act. Prohibits discrimination against persons
with disabilities in programs that receive Federal funds.

Section 508 of the Rehabilitation Act. Part of the Rehabilitation Act of 1973
that was expanded and strengthened in 1998 by creating binding, enforceable
standards for the accessible design of technology; requires electronic and
information technology developed, procured, maintained or used by Federal
government to be accessible to persons with disabilities.

Self Contained, Closed Products. Products that generally have embedded
software and are commonly designed in such a fashion that a user cannot easily
attach or install assistive technology. These products include, but are not limited
to, information kiosks and information transaction machines, copiers, printers,
calculators, fax machines, and other similar types of products.

Telecommunications. The transmission, between or among points specified by
the user, of information of the user's choosing, without change in the form or
content of the information as sent and received.

TTY. An abbreviation for teletypewriter. Machinery or equipment that employs
interactive text based communications through the transmission of coded signals
across the telephone network. TTYs may include, for example, devices known as
TDDs (telecommunication display devices or telecommunication devices for deaf
persons) or computers with special modems. TTYs are also called text
telephones.

Undue burden. Undue burden means significant difficulty or expense. In
determining whether an action would result in an undue burden, an agency shall
consider all resources available to the program for which the product is being
developed, procured, maintained, or used.




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Participant Guide for Accessible EIT Procurement Training 101

    CSU Procurement Training for Accessible E&IT Evaluation Form

Instructors: Cynthia Waddell & Mary Cheng                Location: Los Angeles, CA Date:
12/12/06

1. The Course:
                                              Strongly disagree       Strongly Agree
Objectives were achieved                                 1      2   3      4      5
The content was relevant to my job                       1      2   3      4      5
The training was well organized                          1      2   3      4      5
Materials were helpful (manual, slides, etc.)            1      2   3      4      5
Length of course was appropriate. Circle one: Too short Appropriate Too long
The difficulty of the course. Circle one: Too elementary Appropriate Too Advanced
An appropriate number of breaks. Circle one: Too few Appropriate       Too many

2. The Instructor: Cynthia Waddell
                                               Strongly disagree            Strongly Agree
Subject matter was well organized.                          1       2       3     4     5
Effectively kept discussions focused on relevant topics.    1       2       3     4     5
Created a positive environment.                             1       2       3     4     5
Was prepared and organized.                                 1       2       3     4     5

3. The Instructor: Mary Cheng
                                               Strongly disagree         Strongly Agree
Subject matter was well organized.                          1       2   3     4      5
Effectively kept discussions focused on relevant topics.    1       2   3     4      5
Created a positive environment.                             1       2   3     4      5
Was prepared and organized.                                 1       2   3     4      5

4. Assistive Technology Component
                                               Strongly disagree         Strongly Agree
The Assistive Technology Visual Disabilities                1    2      3     4      5
component was helpful.
The Assistive Technology Physical Disabilities              1    2      3        4     5
component was helpful.
The AT component helped me get a better                     1    2      3        4     5
understanding of the Section 508 standards.

5. Your knowledge/skill level of the subject matter:
                                                       None                          High
Knowledge/skill level before the course.                  1         2   3        4    5
Knowledge/skill level after the course.                   1         2   3        4    5

6. The Facilities:
                                              Strongly disagree             Strongly Agree
Were conducive to learning (temperature, layout,         1      2       3        4      5
location)

                                                                            Page 21 of 22
Participant Guide for Accessible EIT Procurement Training 101

          ****Please write any additional comments or suggestions on the back.****




                                                                      Page 22 of 22