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Requiring Business Partners to Provide Accessible Documents

Do you work for an agency that provides services through grantees or other partner organizations? If those partner organizations provide documents that will be posted to your agency's website, how do you ensure that the content they provide is accessible?

Requests for Proposal (RFP), grant notices, trainings, status reports - if you have business partners that produce these types of documents, and you host them on your website, the documents must meet Section 508 accessibility requirements. Here are some simple steps (with examples!) to ensure your business partners deliver accessible documents.

Simple Steps to Accessibility

How can you make sure that your business partners follow federal accessibility law when they produce content for you to publish? Important (and easy to implement!) steps you should take when entering a business relationship include:

  1. Clarify expectations - Include accessibility requirements in any documents that outline the terms of your business relationship (e.g., RFPs or grant notices). Including accessibility requirements up-front will put business partners on notice that they need to provide accessible content deliverables. If documents aren’t accessible, you can reject the submission and return the documents for remediation.
  2. Standardize - There are many different approaches to writing acquisitions and contracts, including grants. Develop standardized language for your organization that clearly explains your requirements to contractors, grantees, and other organizations. You can find plug-and-play boilerplate language in the Accessibility Requirements Tool (ART).
  3. Train - Consider providing training to business partners, so they learn to self-evaluate and can improve the quality of their submissions.

The Power of Plain Language

When requirements are technical, wordy, and do not clearly explain their purpose, it can be difficult for partners to understand exactly what’s required of them. Here’s an example of poorly-written requirements:

“At a minimum, solicitation respondents must succinctly indicate and explain or justify to what extent and how their proposed EIT deliverables meet or, in some cases, are not applicable to at least those specific technical provisions, functional-performance criteria, and information, documentation, and support requirements listed in 36 CFR 1194.21, 1194.22, 1194.24, 1194.31, and 1194.41, respectively, of the associated accessibility information for each deliverable.”

Good practice is to ensure requirements are clear, so both parties understand what is expected:

“All tasks for testing of functional and/or technical requirements must include specific testing for Section 508 compliance. Teams must document applicable standards evaluated, and document acceptable testing. The Agency reserves the right to test information and communication technology (ICT) functional and/or technical requirements to determine Section 508 compliance. Our agency uses DHS Section 508 Compliance Test Process for Applications to make that determination. Inaccessible documents received and determined to not be compliant will be returned to the submitter for remediation without being posted to the website.”

Full Inclusion for All People

Below is an example of how your agency can communicate its commitment to accessible electronic and information technologies:

Our agency is committed to making its electronic and information technologies accessible to individuals with disabilities by meeting or exceeding the requirements of Section 508 of the Rehabilitation Act.

We require business partners (grantees, vendors) to ensure all electronic information and communication technology (ICT) systems, applications, web content, reports, and deliverables be accessible to people with disabilities (per Accessibility Requirements (Section 508) and best practices (W3C WCAG 2)).

Where not fully compliant with the technical standards, partners should be prepared to:

  • Provide clear points of contact to help users obtain alternate formats;
  • Plan to fix any non-compliant items in coordination with vendor, development, or integration teams; and
  • Work with project staff to develop accommodation plans, should users not be able to gain access or use the system due to non-conformance with the Section 508 technical standards.

Identify a partner representative, as appropriate to the system, document, or electronic content provided to us. Statements should notify end-users that, if they require assistance, or wish to report a complaint related to the accessibility of any content on the website, please email <insert program help desk or point of contact (POC) here> and ask that, if applicable, please include the web address or URL and the specific problems encountered.

Documentation Guidance

Electronic documents, such as training, user guides, ongoing status reports, and invoicing, must be accessible. While the accessibility of a specific format may influence the accessibility of specific document types, the best practice is to consult the Web Accessibility Initiative’s Web Content Accessibility Guidelines 2.0 Level AA and test appropriately.

Adobe PDF Accessibility

There are many products that produce PDF formats, and PDFs support many different types of content. Although Adobe is not the only vendor, they are the most commonly used. Vendors should appropriately tag PDF documents.

PDF documents must be tagged, to be accessible. To check for “Tagged PDF”:

  1. Open the Document Properties (File > Properties > Description) or run the Accessibility Full Check.
  2. If “Tagged PDF: No” is found in Document Properties, or if “Tagged PDF” fails in the Accessibility Full Check, then the PDF is not tagged.

Is My Agency Compliant?

IT Accessibility Standards as outlined in Section 508 of the Rehabilitation Act of 1973, as amended (29 U.S.C. §794d), and the Revised 508 Standards, do not provide a required way to test for conformance. Best practice is to consult the Web Accessibility Initiative’s Web Content Accessibility Guidelines 2.0 Level AA to develop test plans and integrate techniques into development processes to support accessibility in the IT documents, products or services.

Vendors and individuals testing for accessibility may be interested in the DHS Section 508 Compliance Test Process for Applications, which defines a consistent, repeatable process for standardized accessibility testing and evaluation. Should any disagreement occur on what is acceptable, this process can determine technical conformance of any IT deliverable.

Learn More

Learn more about buying accessible products and services. Contact Norman Robinson, IT Change Control Board Manager, US Department of State, at RobinsonN@state.gov with questions about this article.