Plan Your Procurement Strategy
Once you secure executive buy-in for an accessible ICT procurement program, your planning can begin. This section of Buy IT! offers background on the following key steps in shaping a procurement strategy:
- Define Your Target Users
- Determine Your Technical Standards for Accessibility
- Define Your Purchasing Needs
- Assemble and Educate Your Purchasing Team
- Develop Procurement Policies for Accessibility
Define Your Target Users
When defining target users of the technology you procure, consider the needs of the widest array of users. Think about the diverse ways that people use technology and accessibility features.
While it was once common practice to buy and implement products designed for the “average user,” more and more organizations are realizing that the “average user” only exists as a statistic. In practice, real employees need the ability to customize their tools to their individual needs. And as noted in the previous section, waiting to discover post-purchase that some employees can’t use a product results in costly and inefficient retroactive accessibility fixes.
According to the UN Convention on the Rights of Persons with Disabilities (CRPD)(link is external), this practice of designing “products, environments, programs and services to be usable by all people, to the greatest extent possible, without the need for adaptation or specialized design” is known as universal design (UD). UD goes beyond making sure things are accessible to people with disabilities and instead addresses the functional abilities of the widest possible user base. Review the chart below for details on the technical standards that inform universal design.
By following universal design practices, you’ll ensure a diverse and productive workforce by creating more usable products for everyone, including people with disabilities.
Determine Your Technical Standards for Accessibility
Even if you’re new to the world of accessible technology, you’ve probably heard terms that relate to accessibility standards and regulations—like “508 compliant” and “WCAG 2.0.” A key part of planning your procurement strategy is understanding the standards and regulations your organization’s products should aim to meet.
If you are a U.S. federal agency or a company that sells products to the federal government, your decisions will be shaped by laws and regulations that mandate compliance with accessibility standards, such as Section 508 of the Rehabilitation Act. But accessibility is about much more than compliance. Employers who want to apply the business case for accessibility in a meaningful way should ensure they are compliant with the relevant laws and regulations, but also work toward improving the ease of use and universal user experience.
Whether you are a public sector agency or a private company, you cannot go wrong with first basing your ICT requirements on the Web Content Accessibility Guidelines (WCAG) 2.0, which are incorporated by reference in the Section 508 refresh. WCAG 2.0 was developed in cooperation with individuals and organizations around the world, with the goal of proving a single shared standard for web content accessibility that meets the needs of individuals, organizations, and governments internationally.
To determine the accessibility standards in your own procurement policies, begin by reviewing the history and structure of three common standards for accessibility:
- The U.S. federal government’s Section 508 of the Rehabilitation Act (Section 508)
- The international Web Content Accessibility Guidelines (WCAG) 2.0
- The European Standard “EN 301 549”
|Section 508||WCAG||EN 301 549|
|Purpose||To provide accessibility standards that allow people with disabilities to use any ICT that the government develops, procures, maintains, and uses.||To provide a single shared standard for web content accessibility that meets the needs of individuals, organizations, and governments internationally.||To provide accessibility requirements suitable for public procurement of ICT products and services in Europe. Specifies the Functional Accessibility Requirements applicable to ICT products and services.|
|Compliance Rules||Mandatory compliance: Federal government required to comply||Voluntary compliance: public agencies not required to comply||Voluntary compliance in the U.S.: public agencies not required to comply|
|Who does this apply to?||U.S. federal agencies, or vendors selling to the federal government||Anybody, worldwide||European public agencies, or vendors selling to those agencies|
|Content||Technical requirements that ensure covered hardware, software, electronic content, and support documentation and services are accessible to people with disabilities||12 guidelines that are organized under 4 principles: perceivable, operable, understandable, and robust||Accessibility requirements for ICT products and services, and a description of the test procedures and evaluation methodology for each accessibility requirement.|
|Relation to other standards||ICT covered by Section 508 must now conform to WCAG 2.0 Level A and Level AA criteria.||WCAG does not cover all ICT – just web content – but is now a compliance standard for Section 508.||Developed to be in close harmony with Section 508.|
For a deeper dive on the details of these standards—and to determine which standards your products should aim to meet—access the following resources:
- PEAT’s Technical Standards for Workplace Technologies
- The Global Initiative for Inclusive ICT’s (G3ict) Guide to Implementing Priority ICT Accessibility Standards: Critical Technical Specifications to Support Digital Inclusion(link is external) (Note: This resource was written for the “Smart Cities for All” project, but the content is applicable to any group interested in implementing ICT accessibility via a public procurement)
- Web Content Accessibility Guidelines (WCAG)(link is external)
- Section508.gov(link is external)
- EN 201 549(link is external)
Define Your Purchasing Needs
Any procurement planning should include a comprehensive review of your company’s business requirements and overall purchasing needs. Performing this type of needs assessment at the outset of your planning phase empowers you to look ahead and plan your purchase strategically. For example, consolidating your future purchasing needs may drive improved prices through economies of scale. It can also simplify the process of creating an accessible workplace because you’ll be addressing all needs in an orderly fashion.
Assemble and Educate Your Purchasing Team
Once you have defined and prioritized your needs, your procurement leader can identify a team of stakeholders to help guide the ICT purchasing process—and to then educate that team on your organization’s accessibility mindset. This team should include individuals from across the organization who have an interest in the needed product/service. This is especially true at the federal level, where integrated procurement teams (IPTs) composed of representatives from IT, policy, finance, operations, legal, program, and procurement have come together to lead acquisitions. These teams define the project scope and requirements, develop the solicitation, and evaluate the responses. The IPT method of procurement has been shown to reduce procurement lag time, lead to more innovation among vendor respondents, increase outcomes-oriented focus, and create more leadership buy-in.
Develop Procurement Policies for Accessibility
With your standards set, needs assessed, and procurement team in place, you’re ready to start developing your organization’s procurement policies for accessibility. The following checklist from the Technology Accessibility Playbook(link is external) lays out some general steps to ensuring accessibility needs are identified and addressed in the acquisition planning process:
- Identify and understand your company’s acquisition policies and procedures used to acquire technology.
- Determine if adequate consideration of technical standards is already included in these policies and procedures. If they are not, work with the appropriate stakeholders to change this.
- If these standards haven’t previously been part of your acquisition process, you may be missing out on the advantages of including accessibility in your organization’s regular business procedures. Read G3ict’s Guide to Adopting an Accessibility Procurement Policy(link is external) for more information. The guide discusses the benefits of embedding ICT into your policies and introduces other concepts you may want to adopt into your procedures.
- If you are working with Section 508 requirements, be sure to familiarize yourself with the Revised Section 508 Roadmap(link is external). This Roadmap, developed by the U.S. Federal Government Revised 508 Standards Transition Workgroup and GSA, shows how to integrate the recently refreshed standards into an existing 508 Program.
- Develop criteria for when and how accessibility and technical requirements, exceptions, terms and conditions, evaluation methods, acceptance criteria, and related proposal response requirements are included in solicitations.
- Ensure Contracting Officers know what to expect from the Requiring Officials related to Section 508 requirements.
- Ensure the Requiring Office includes the appropriate accessibility requirements in the solicitation language.
- Ensure Requiring Officials know when and who to contact for accessibility guidance.
- An excellent starting point for setting your evaluation criteria is NASCIO’s Policy Driven Adoption for Accessibility (PDAA)(link is external)method.
- Establish a formal accessibility compliance determination process. Use the process to document compliance decisions. Support decisions with relevant accessibility artifacts (Market Research, VPATs, Section 508 Exceptions, test results, and “best meets” determinations.)
- Provide for independent expert reviews of accessibility exception and vendor accessibility claims prior to award.
- Use a risk based model to determine when independent testing is required to validate vendor conformance claims.
- Provide authority to the Accessibility Program Team to stop any contract or application that puts the company at significant risk.
- Create a governance process to ensure accessibility conformance is an evaluation factor in award decisions.
- Provide a process to track and monitor accessibility assurance activities and accessibility compliance determinations for all company technology procurements.
- Develop a process for planning and implementing an “alternative means” when a fully accessible solution is not procured.