[This document was drafted by group of public sector accessibility experts in hopes of developing a dialogue to improve the quality of Section 508 reporting and procurement processes. There is a cover letter we encourage you to share with your accessibility colleagues. You can also leave comments here or there to indicate your opinion and support. Feel free to share this material.]
The Voluntary Product Accessibility Template, or VPAT, is a tool used to document the accessibility of information and communication technology (ICT) products. It was developed by the Information Technology Industry Council to assist vendors in reporting on compliance with federal accessibility requirements in Section 508. Section 508 (originally of the Rehabilitation Act) requires federal agencies to procure, develop, maintain, and use accessible ICT for their employees and members of the public) VPATs are produced by ICT vendors, and are used as a primary assessment tool by ICT customers to assess the levels of accessibility for commercial off the shelf (COTS) offerings.
The main content of the VPAT is a table of the technical provisions contained in Section 508, with fields to provide statements on the product’s conformance against each provision, and additional, more specific detail. While the VPAT does offer a way to communicate information about accessibility, ICT customers in the public sector (including non-federal agencies such as state governments, universities, and libraries) have found the current VPATs to be problematic due to the inconsistency of response language from organization to organization, and the lack of supporting information that describes how the responses are determined. These shortcomings, in many cases, compromise VPATs’ ability to serve as a credible tool to assist with making good product procurement decisions.
The Section 508 regulations are under significant revision (“508 Refresh”); therefore, the current VPAT will need significant changes to synchronize with the technical revisions. Given the history, use, and problems associated with the current VPAT forms, Federal and non-federal customers, especially those responsible for procuring accessible ICT products, should be able to take advantage of the refresh opportunity to propose a set of enhancements for consideration in the development of the next generation VPAT template.
A group of non-federal public sector accessibility professionals in state government, universities, colleges, and libraries has been meeting to discuss the current VPAT and this opportunity, and has produced this document. We offer it to others on both sides of the accessibility equation for consideration and use as a way to improve the structure of the accessibility dialogue necessary to both vendor and customer. We believe that the enhancements proposed below are both reasonable and necessary, and will help ensure greater accuracy of VPATs, which will ultimately improve customers’ ability to make better procurement decisions with regard to ICT accessibility.
The proposed recommendations are:
- An open process for developing the VPAT replacement. The development of a replacement for the VPAT should be held in public, open to wide participation and full dialogue.
- Accessibility information as public information. A recommendation that VPAT information should be widely available, not available only upon request. The product accessibility information should not be subject to any claims of proprietary intellectual property. The Template title should not contain the word “voluntary.”
- A tool, not a form. Instead of the current static VPAT form, accessibility information should be published in such a way as to facilitate product comparisons, procurement process management, and other customer-side processes. It should be easy to create a paper document or a digital version that is time-stamped. The tool should embed and/or be linked to contextual training resources for both vendors and customers.
- More accurate information. Currently, VPATs vary too widely in quality from vendor to vendor. There is little consistency to how vendors complete the VPAT and communicate about it. The new tool should help vendors improve and standardize the quality of the information.
- Better coverage for customer-configured platforms, authoring tools, and add-ons. Many software products are either heavily configured by the customer (e.g., personnel management systems) or are tools used to create content (authoring tools, e.g., document formatting and publishing software). Browsers and other tools are often supplemented by plugins. The accessibility reporting required for these products should go beyond basic user accessibility, into issues and best practices for accessible configuration or authoring as applicable. When an ICT product generates content, such as reports, web page templates, or other documents, vendors should clearly describe how the product enables accessible content. This description should be separate from the information about the accessibility of the product itself. When a primary or major function of the ICT product is enabling access to content, VPAT will facilitate separate reporting on accessibility of the content.
- Breakouts for each interface. The revised VPAT should be designed to facilitate separate reporting on each interface set or grouping, such as administrator interface, end-user interface, etc.
- Additional information. The revised VPAT should include information or links to other relevant information such as specific barrier workarounds, AT compatibility solutions, and any remediation plans.
- Specific template minimum requirements (a. and either b. or c.).
a. A checkbox for a statement that insufficient validation had been performed to accurately complete the template in whole or part
b. A vendor statement of certification attesting to the accuracy of the completed VPAT based on the results of generally accepted accessibility validation practices and methods
c. A description of the validation method and tools including specific test platform information These should include, in detail, all hardware make(s)/model(s) and configuration(s), operating system(s), browser(s), other software, and assistive technologies used to obtain the information contained in the VPAT.