GSA Government-wide Section 508 Accessibility Program

How to Fix Your Solicitation Documents

Creating solicitations documents that properly address Section 508 is a critical step to achieving an agency's Section 508 compliance. The content in your solicitation documents drives the rest of the acquisition process and is the first step in overall compliance. GSA has a Section 508 Solicitation Assessment Program to provide agencies with information about what can be done to improve compliance by sampling and assessing FedBizOpps (FBO) postings. If you received a letter about your FBO posting, this page can tell you how to fix the issues that were identified.

Table: FedBizOpps Assessment Criteria

Assessment Criteria How to fix
Subpart B How to identify Subpart B Technical Requirements
Subpart C How to identify Subpart C Functional Performance Criteria
Subpart D How to identify Subpart D Information, Documentation, and Support requirements
Ensure solicitation documents and attachments are all in an accessible format. How to creating accessible documents
Include Section 508 Evaluation Criteria as part of proposal evaluation How to include Section 508 Evaluation Criteria as part of proposal evaluation
Include Section 508 Inspection and Acceptance Criteria for ICT deliverables How to include Section 508 Inspection and Acceptance Criteria for ICT deliverables
Request Section 508 accessibility information from vendors (e.g. VPAT/GPAT) How to request Section 508 accessibility information from vendors
Do not ask the vendor to determine if Section 508 is relevant to your solicitation. Help on determining Section 508 relevance
Do not ask the vendor to determine if Section 508 exceptions apply to your solicitation. Help on determining Section 508 exceptions
Do not ask the vendor to determine the specific Section 508 requirements that apply to your solicitation. Help on determining Section 508 requirements
Do not ask the vendor for a certification of Section 508 compliance or conformance. Help on understanding Section 508 compliance

How to identify Subpart B Technical Requirements

Evaluation Criteria:Subpart B: For ICT contract deliverables include a general statement of applicability of Section 1194 Subpart B OR applicable technical sections (e.g. 1194.2x) or applicable provisions (e.g. 1194.2x(y)). What is Subpart B? The Section 508 Standards for Information and Communication Technology (36 CFR Part 1194) contains “Subpart B - Technical Standards.” Under Subpart B, there are six sections (1194.21-1194.26) that contain technical provisions related to making different technologies accessible. To Fix: You first need to determine if Section 508 applies to your solicitation by checking if the product or service meets the definition of Information and Communication Technology and making sure you do not meet the criteria of a general exception. If Section 508 applies, then you need to include at the very least a statement saying Section 508 applies in your solicitation document. To fully pass this criteria, you need to state which technical sections or provisions are applicable to your provision. The easiest way to do this is to check the BuyAccessible Quick Links for the product or service you are buying. The Quick Links generate a Government Product Accessibility Template (GPAT) which identify applicable Section 508 provisions. A requirements official is most qualified to do this, because they understand the technical features and requirements.

Solicitation Language Example:

"Section 508 Program Need: Requirements for accessibility based on Section 508 of the Rehabilitation Act of 1973 (29 U.S.C. 794d) are determined to be relevant for the following program need: Digital Camera. Application Software that is used for photo editing delivered with the Digital Camera is also subject to the requirements for accessibility based on Section 508 of the Rehabilitation Act of 1973 (29 U.S.C. 794d). Section 508 Requirements: Technical standards from 36 CFR part 1194 Subpart B have been determined to apply to this acquisition. Solicitation respondents must describe how their proposed Digital Camera deliverables meet at least those technical provisions identified as applicable in the attached Digital Camera Government Product/Service Accessibility Template (GPAT). Respondents must also describe how Application Software meets those technical provisions identified as applicable in the attached Application Software GPAT.” Top

How to identify Subpart C functional performance criteria

Evaluation Criteria: Subpart C: For ICT contract deliverables include a general statement of applicability of Section 1194 Subpart C OR specific provisions within 1194.31(x). What is Subpart C? The Section 508 Standards for Information and Communication Technology (36 CFR Part 1194) contains “Subpart C — Functional Performance Criteria.” Under Subpart C, there are six criteria, 1194.31(a)-1194.31(f). The requirements of this section are intended for overall product evaluation and for technologies or components for which there is no specific requirement under the technical standards in Subpart B. These criteria are designed to ensure that the individual accessible components work together to create an accessible product and are structured to allow people with sensory or physical disabilities to locate, identify, and operate input, control and mechanical functions and to access the information provided. To Fix: GSA’s BuyAccessible Team recommends always including a statement about Functional Performance Criteria in solicitations for Information and Communications Technology, along with the Technical Provisions from Subpart B (as described above) in solicitations for ICT.

Solicitation Language Example:

"Functional performance criteria from 36 CFR part 1194 Subpart C have been determined to apply to this acquisition. Solicitation respondents must describe how their proposed deliverables meet at least those functional performance criteria identified as applicable in the attached GPATs." Top

How to identify Subpart D information, documentation and support requirements

Evaluation Criteria:Subpart D: For ICT contract deliverables include a general statement of applicability of Section 1194 Subpart D OR specific provisions within 1194.41(x). What is Subpart D? The Section 508 Standards for Information and Communication Technology (36 CFR Part 1194) contains “Subpart D —Information, Documentation, and Support.” Under Subpart D, there are three criteria, 1194.41(a)-1194.41(c). These address access to all information, documentation, and support provided to end users (e.g., Federal employees) of covered technologies. This includes user guides, installation guides for end-user installable devices, and customer support and technical support communications. To Fix: As most products include documentation, GSA’s BuyAccessible Team recommends always including a statement about Subpart D Information, Documentation, and Support in your solicitiations for ICT.

Solicitation Language Example:

"Information, documentation, and support requirements from 36 CFR part 1194 Subpart D have been determined to apply to this acquisition. Solicitation respondents must describe how the information, documentation, and support proposed for deliverables meet at least the information, documentation, and support requirements identified as applicable in the attached GPATs." Top

Help on creating accessible documents

Evaluation Criteria: Ensure solicitation documents and attachments are all in an accessible format. Because the solicitation is issued via FebBizOpps, it is web-based internet information and therefore covered by 1194.22: Web-based intranet and internet information and applications. All documents and attachments associated with this solicitation should be in an accessible format. To Fix: The most common cause of this issue is paper documents that are scanned and attached to the FBO posting. To fix this, replace the scan with an electronic copy of the original file. To learn more about accessible documents visit: Create Accessible Documents and Other Resources. Top

How to include Section 508 Evaluation Criteria as part of proposal evaluation

Good Practice: Include Section 508 Evaluation Criteria as part of proposal evaluation. To Fix:Add a statement about Section 508 to your list of Evaluation Factors (see example below).

Solicitation Language Example:

Section 508 Evaluation Factors Responses to this solicitation will only be considered for award after it has been determined that the proposal adequately addresses the requirements for Section 508. Only proposals which contain adequate information to document their responsiveness to the Section 508 requirements (e.g. a completed GPAT, VPAT or equivalent and supporting documentation) will be eligible for any additional merit consideration. Top

How to include Section 508 Inspection and Acceptance Criteria for ICT deliverables

Good Practice: Include Section 508 Inspection and Acceptance Criteria for ICT deliverables. To Fix: Add a statement about Section 508 to your list of Inspection and Acceptance Criteria (see example below).

Solicitation Language Example

Section 508 Acceptance Criteria Electronic Documents delivered as a result of this solicitation will be accepted based in part on satisfaction of identified Section 508 requirements for accessibility. ICT delivered must include a completed GPAT, a sample of which is included as a part of this solicitation. Top

How to request Section 508 accessibility information from vendors

Good Practice: Request Section 508 accessibility information from vendors, e.g. Voluntary Product Accessibility Template (VPAT) or Goverment Product Accessibiltiy Template (GPAT) To Fix: Ask the Vendor to provide information about the accessibility of their products or services. You can do this by providing a GPAT, in which you list the provisions applicable to the product you are buying. The easiest way to get a GPAT is to check the BuyAccessible Quick Links for the product or service you are buying. The Quick Links generate a GPAT which identifies applicable Section 508 provisions. A requirements official is most qualified to do this, because they understand the technical features and requirements. If Vendors need help, you can refer them to the Vendor page. Some other articles that may help:

Solicitation Language Example

"Solicitation respondents must describe how their proposed deliverables meet at least those provisions identified as applicable in the attached Government Product/Service Accessibility Template (GPAT)."

Help on determining Section 508 relevance

Evaluation Criteria: Do not ask the vendor to determine if Section 508 is relevant to your solicitation. The determination whether or not Section 508 applies is the responsibility of the agency, as outlined in FAR 39.203, and can and should not be delegated to the vendor. To Fix: Determine if Section 508 applies to your solicitation by checking if the product or service meets the definition of Information and Communication Technology and making sure you do not meet the criteria of a general exception. If Section 508 applies, then you need to include at the very least a statement saying Section 508 applies in your solicitation document. Top

Help on determining Section 508 exceptions

Evaluation Criteria: Do not ask the vendor to determine if Section 508 exceptions apply to your solicitation. To Fix: The determination of a Section 508 exception is the responsibility of the agency and cannot be delegated to the vendor. Unless an exception from FAR 39.204 applies, acquisitions of ICT supplies and services must meet the applicable accessibility standards at 36 CFR part 1194. Top

Help on determining Section 508 requirements

Evaluation Criteria: Do not ask the vendor to determine the specific Section 508 requirements that apply to your solicitation. To Fix: The determination of Section 508 requirements is the responsibility of the agency as outlined in FAR 39.203. The agency should indicate the appropriate technical sections (e.g. 1194.2x, 1194.31 and 1194.41) and the appropriate provisions within these sections that apply. The easiest way to do this is to check the BuyAccessible Quick Links for the product or service you are buying. The Quick Links generate a Government Product Accessibility Template (GPAT) which identify applicable Section 508 provisions. A requirements official is most qualified to do this, because they understand the technical features and requirements. Top

Help on understanding Section 508 compliance

Evaluation Criteria: Do not ask the vendor for a certification of Section 508 compliance or conformance. To Fix: Section 508 Certification doesn't exist. Agencies are responsible to comply with Section 508 and assure that Information and Communication Technology products they make or buy conform the Section 508 standards. If you want to ask vendors for information about the accessibility of their products and services, ask for a Voluntary Product Accessibility Templates (VPAT) or require them to fill out a Government Product/Service Accessibility Template (GPAT). In the end the agency purchasing a product or service is responsible for determining if the deliverables meet their requirements.

Solicitation Language Example:

"Section 508 Program Need: Requirements for accessibility based on Section 508 of the Rehabilitation Act of 1973 (29 U.S.C. 794d) are determined to be relevant for the following program need: Digital Camera. Application Software that is used for photo editing delivered with the Digital Camera is also subject to the requirements for accessibility based on Section 508 of the Rehabilitation Act of 1973 (29 U.S.C. 794d). Section 508 Requirements: Technical standards from 36 CFR part 1194 Subpart B have been determined to apply to this acquisition. Solicitation respondents must describe how their proposed Digital Camera deliverables meet at least those technical provisions identified as applicable in the attached Digital Camera Government Product/Service Accessibility Template (GPAT). Respondents must also describe how Application Software meets those technical provisions identified as applicable in the attached Application Software GPAT.” Top