GSA Government-wide Section 508 Accessibility Program

ICT Products Specified by Brand Name or Equal

Section 508 requirements apply to Brand Name or Equal acquisitions. RFPs for ICT products specified by Brand Name or Equal are required by FAR 11.104(b) to include a description of the physical and functional performance characteristics an “equal” item must meet. This description must include appropriate Section 508 accessibility requirements from the Access Board Standard (36 CFR Part 1194), unless the product function meets the criteria for a general exception. Review the information below and use available BuyAccessible tools, resources, and guidance to help you meet these responsibilities.

Section 508 Due Diligence for Brand Name or Equal Acquisitions

Consider Section 508 when Identifying Brand Name Items
The program requiring authority should identify appropriate Section 508 accessibility requirements and conduct market research to understand if the identified Brand Name product meets them. If the product does not meet accessibility requirements, explore other products to determine one that best meets the applicable Section 508 requirements.

Document Section 508 in your RFP: Four Steps
There are four important considerations when developing the requirements for these RFP solicitations. Generally the Requiring Authority should lead these activities, while the Contracting Office should make sure they has been performed and appropriately documented in the solicitation and resulting contract.

  1. Determine How Section 508 Applies
    • Identify specific deliverables and distinguish each ICT deliverable subject to Section 508.
    • Assess each deliverable for a Section 508 exception and provide detailed justification if making an exception claim.
  2. Identify Specific Section 508 Requirements for Each ICT Deliverable
    • Document the functions, features, and physical or performance characteristics that an "equal" item must meet.
    • Based on those features and functions, identify applicable technical and functional performance requirements from the Access Board Standard (CFR 1194).
  3. Consider Section 508 Requirements When Evaluating Proposals
    • Document how Section 508 requirements will be included in proposal evaluation.
    • Request vendor accessibility information be included as part of the proposals
  4. Assess Section 508 requirements When Accepting ICT Deliverables
    • Document Section 508 requirements as inspection/acceptance criteria for ICT deliverables.
    • Make sure that Section 508 requirements are met!

Don't Forget Section 508 for ICT Information, Documentation, and Support
Make sure to consider requirements from the Access Board Standard CFR 1194 Subpart D for ICT information and documentation, as well as vendor support.

Common Mistakes in Section 508 Due Diligence

  • Not considering Section 508 requirements when identifying a Brand Name product.
  • Not conducting accessibility market research for a Brand Name product.
  • Not documenting the physical and functional performance characteristics an “equal” item must meet.
  • Making a general mention of Section 508, but not identifying specific requirements from CFR 1194 that apply.
  • Not requesting vendor accessibility information.
  • Not documenting Section508 exception determinations.
  • Not considering Section 508 requirements for ICT information, documentation, and support.

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