section 508 acquisition tools focus group

Section 508 Acquisition Tools Focus Group

19 April 2006

2

Introduction

Buy Accessible Release and Distribution Update

19 April 2006

4

Buy Accessible Wizard Release Status

• Release 2.0 in production since Nov 1– E&IT product micro-purchases

• Relevance, market research…source selection– E&IT product ‘macro-purchases’

• Relevance, applicability and market research– Support for E&IT-related services

• Relevance and market research• Section 508 considerations for specific E&IT-related service

deliverables

• Release 2.1 β on test bed since late Jan

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Wizard 2.1 Updates

• Name “Commercial Availability Template”– Now called “Market Research Worksheet”

• Use of the word “Detailed” – Now just “Product Accessibility Information”

• Agency Name as optional login field– Supporting GSA metrics for Wizard use

• Bug fixes, spelling errors, and such– e.g. “Do you intended to acquire …”

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Buy Accessible Data Center Release Status

• Data Center Release 1.0 in production Nov 1– Initial releases supporting COTS E&IT products– Initial support for E&IT-related service providers– User feedback on activity of registered information

• Data Center R 1.1 β on test bed since late Jan– Data Center administration user interface

• Review vendor registration information– Multi-value vendor status indicator

• Approved, Pending, and … Denied (!)

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Wizard Deployment OptionsWizard for use by any federal agency via GSA hosted Internet

application – No local user data storage functionality– Local data save via browser file save as function– No agency data management capability

Wizard for deployment to any federal agency as an Intranet application – Agency hosted Wizard user data store

• Supports users save / pause / resume / review functionality• Supports user data save / sharing – mySQL or Oracle• Allows agency Section 508 acquisition management reporting

– C&A letter available to all agencies– Centrally distributed / supported via Wizard Support Website

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Benefits• The Wizard …

– is easy and efficient to use– supports effective Section 508 compliance– provides consistent and complete compliance documentation

• With Intranet configuration …– Wizard information is reusable– aggregate management compliance reporting is possible

• Extensive Beta Deployment Testing– “The manual process took over a week; the Wizard took less than 20

minutes … and the Wizard identified other applicable provisions from the standard the use missed with the manual process.”

– “The Buy Accessible Wizard is easy to use. All I have to do is be able to provide my system requirements, and the Buy Accessible Wizard will provide a report of the 508 requirements that need to be considered when purchasing new E&IT.”

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• Visit the Wizard Product Support Websitehttp://buyaccessible.aticorp.org/index.html – Click on “Request to Download Current Version” and

complete the form– This will generate an e-mail to Skip Crane– Skip will contact you, walk through the Deployment

Planning Guide with you, and send you the FTP download information

– Skip tracks agency implementations and coordinates with personnel in key roles

Getting Started with Intranet

10

Review Previous Meeting Notes

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Highlights from Last Meeting

• How to factor in commercial availability to decide that some accessibility provisions are mandatory and some nice to have? – These requirements are applicable but have not

yet been determined to be available.– It is also important to consider the intended use;

whether a requirement is mandatory or optional may depend on the program mission or other program requirements, but …

12

Highlights from Last Meeting

• Our intent is to provide solicitation language to support 508 requirements. – However, in practice other weighting factors must

also be considered. Should the Wizard consider other program requirements as well as the applicable Section 508 provisions?

• No – just acknowledge that they exist– Should we put in some caveat about overall

requirements vs. those from Section 508?• Yes – some standard text ‘boilerplate’

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Highlights from Last Meeting

• E&IT-related service deliverables – agreed to change the following names:– E&IT task performance deliverable

• E&IT support (labor hours)– Custom E&IT product deliverable

• Custom E&IT end product– Information Content deliverable

• Information Content

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Highlights from Last Meeting• Discussion on the different types of contracting

methods outlined in the FAR:– Simplified Acquisition Procedures– Sealed Bidding– Contracting by Negotiation– Special Contracting Methods

• However, these different methods make little difference for Section 508 compliance– Section 508 responsibilities of the Contracting Officer are

basically the same in each case

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Highlights from Last Meeting• The Contracting Officer must:

– Ensure that the requiring official has considered Section 508 as a requirement

– Incorporate appropriate Section 508 considerations in solicitation documents and subsequent contracts

– Ensure that Undue Burden isn’t misused

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Highlights from Last Meeting• Based on standardized contract formats the

location of requirements for credit card purchases, purchase orders, task or delivery orders against a basic agreement and full contracts may be different.– But the content should be basically the same

• May also have related ‘baseline’ tasks such as testing or standardized acceptance criteria

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Break

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What is Buy Accessible?

• A System of Component Applications– Acquisition Wizard– Data Center– Glossary*– Taxonomy*

• Technical Architecture• Known Technical Issues

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Buy Accessible Wizard• Web-enabled application providing Section 508 acquisition

support for agency buyers– Users may include contracting officers as well as program

requiring officials and micro-purchasers• Step-by-step through Section 508 requirements

– Requirements from the law, the standard, and the FAR in context of a standard acquisition process

• Interacts with Data Center for market research– Requests accessibility information about E&IT-related companies,

products, and services

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Buy Accessible Data Center• Web-enabled application providing accessibility

information support for industry E&IT producers– Users include E&IT product manufacturers and VARS as

well as E&IT-related service providers• Manages references to vendor maintained data

– Users decide how specific the references will be • Interacts with Wizard for market research

– Responds to requests for accessibility information about E&IT-related products and services

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Buy Accessible Glossary

• *Not yet a single independent component– Currently Wizard and Data Center glossaries– Actually two sets of terms and definitions that

are only slightly out of sync• Working to unify and harmonize glossary content

• *No current application code or API– Simple HTML files displayed via client browser

• Working to implement as web component

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Buy Accessible Taxonomy

• *Independent, but not yet a component– Serves as Wizard and Data Center taxonomy– ‘ad hoc’ E&IT product and E&IT-related

service taxonomies crafted by our group• Working to adopt international Standard UNSPSC

• *No current application code or API– Currently a text file loaded at compile/runtime

• Working to implement as web component

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Buy Accessible Continuous Improvement

• Unified independent glossary web service– active design (web service) / development

• Usability of E&IT taxonomy interface– active development (UNSPSC web service)

• Wizard user data local file save– active development (XML schema)

• Buy Accessible activity status publication– active design (Wizard agencies) / development

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Buy Accessible Continuous Improvement

• Wizard user feedback on status of session– active design (% complete) / development

• E&IT-related services and ‘in situ’ activities– open discussion / research (UNSPSC)

• IT acquisition and agency IT infrastructure– open discussion

• Data Center feedback on agency activity– open discussion

Beyond Needs Assessment: Support for Solicitation

5 April 2006

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Requiring vs. Contract Offices• Requiring Office Responsibilities

– Identify program mission and basic need– Specify technical / performance requirements

• Determine Section 508 relevance & applicability• Prioritize / trade off requirements analysis

– Identify / obtain necessary funding– Determine how to best acquire

• In-house development, from other government sources, use of outside contractors, …

– If contracted, then forward to Contract Office

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Requiring vs. Contract Offices• Contracting Office Responsibilities

– Determine appropriate contract vehicle• Credit card, purchase order, order against existing

agreement, compete a new agreement, …– Ensure Requiring Official duties are done

• Specific Section 508 requirements• Testing and acceptance criteria

– Incorporate program specifics into the standard solicitation and contract documents

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Agency Requiring Office

• In acquiring information technology, agencies shall identify their requirements pursuant to OMB Circular A-130, including consideration of security of resources, protection of privacy, national security and emergency preparedness, accommodations for individuals with disabilities, and energy efficiency.– FAR 39.101 (b)

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Agency Requiring Office

• When acquiring EIT, agencies must ensure that– (1) Federal employees with disabilities have

access to and use of information and data that is comparable to the access and use by Federal employees who are not individuals with disabilities; and …

• FAR 39.201 (c)

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Agency Requiring Office

• When acquiring EIT, agencies must ensure that– (2) Members of the public with disabilities

seeking information or services from an agency have access to and use of information and data that is comparable to the access to and use of information and data by members of the public who are not individuals with disabilities.

• FAR 39.201 (c)

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Agency Contracting Office

• When developing an acquisition strategy, contracting officers should consider the rapidly changing nature of information technology through market research (see Part 10) and the application of technology refreshment techniques.– FAR 39.101 (b)

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Requiring and Contract Offices

• Contracting and program office officials are jointly responsible for assessing, monitoring and controlling risk when selecting projects for investment and during program implementation. – FAR 39.102 (a)

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Break

FAR Contract Types, Solicitation Provisions, and Contract Clauses

5 April 2006

35

Federal Acquisition Regulation

• Organization of FAR Subchapters– A : General– B : Competition and Acquisition Planning– C: Contracting Methods and Contract Types

• Part 13—Simplified Acquisition Procedures • Part 14—Sealed Bidding • Part 15—Contracting by Negotiation • Part 16—Types of Contracts • Part 17—Special Contracting Methods

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Federal Acquisition Regulation

• Part 16—Types of Contracts– 16.1 Selecting Contract Types – 16.2 Fixed-Price Contracts – 16.3 Cost-Reimbursement Contracts – 16.4 Incentive Contracts – 16.5 Indefinite-Delivery Contracts – 16.6 Time-and-Materials, Labor-Hour, and Letter

Contracts – 16.7 Agreements

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Section 508 and the FAR

• A – G: …• H: Clauses and Forms

– Part 52—Solicitation Provisions and Contract Clauses

• 52.1 Instructions for Using Provisions and Clauses • 52.2 Text of Provisions and Clauses • 52.3 Provision and Clause Matrix

– Part 53—Forms

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Types of Procurements and Associated Solicitation

Documentation 5 April 2006

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Types of E&IT Procurements

• Definite Quantity, Definite Delivery, ‘Stand Alone’ Contracts– RFQ/RFP, Subsequent Single Award– Preliminary RFI (optional)– RFQ for specific E&IT products

• Mandatory vs. optional Section 508 requirements?• Accessibility vs. other program requirements?

– RFP for specific E&IT services• SOW vs. SOO?

42

Types of E&IT Procurements

• Indefinite Quantity, Indefinite Delivery, ‘Umbrella’ Contracts (pre-FASA)– Single Award, Subsequent Delivery Orders– Preliminary RFI (optional)– Work Orders for specific E&IT Products

• Mandatory vs. optional Section 508 requirements?• Accessibility vs. other program requirements?

– Task Orders for specific E&IT services• SOW or SOO?

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Types of E&IT Procurements

• Indefinite Quantity, Indefinite Delivery, ‘FASA’ Contracts (FAR 16.5)– Multiple Award, Subsequent Work Orders– Preliminary RFI (optional)– Delivery Orders for specific E&IT Products

• Mandatory vs. optional Section 508 requirements?• Accessibility vs. other program requirements?

– Task Orders for specific E&IT services• SOW or SOO?

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Types of E&IT Procurements

• Indefinite Quantity, Indefinite Delivery, ‘GSA Schedule’ Contracts (FAR 8.4, 38)– Multiple Award, Subsequent Work Orders– Preliminary RFI (optional)– Delivery Orders for specific E&IT Products

• Mandatory vs. optional Section 508 requirements?• Accessibility vs. other program requirements?

– Task Orders for specific E&IT services• SOW or SOO?

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Types of E&IT Procurements

• Which differences matter for the Section 508 compliance process?

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Solicitation Documentation

• What are the ‘standard’ formats for solicitation documents?– Which ones are associated with which type of

procurement? • Where do Section 508 ‘considerations’ fit in

the solicitation documents?– Technical Requirements– Acceptance Testing and Evaluation– Others?

Integrating Buy Accessible with the Broader Acquisition Environment

5 April 2006

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Buy Accessible Integration

• Integration with the federal acquisition environment– Integration at the component level, e.g. Wizard

with GSA Acquisition Planning Wizard (APW), Data Center with FAS GSAdvantage! and/or NASA SEWP

– Integration at the information level, e.g. Wizard user acquisition information with DoJ Survey, Data Center company information with IAE CCR/BPN

Next Steps

5 April 2006

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What’s Next?

• Buy Accessible Wizard and Data Center– New project phase, objectives, technical goals– After market research and needs assessment,

what now for Buy Accessible?…Solicitation!• Focus Group Meeting Schedule

– New goals; additional focus group members?• More representation from the contracting office!

– Next meeting planned for May 9, 2006

Thank You

Back Up Slides

53

Federal Acquisition Regulation

• Organization of FAR Subchapters– A : General– B : Competition and Acquisition Planning– C: Contracting Methods and Contract Types– D: Socioeconomic Programs– E: General Contracting Requirements– F: Special Categories of Contracting– G: Contract Management– H: Clauses and Forms

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Final FAR Rule For Implementing Section 508

• This final rule implements the Access Board's regulations by— – Including the definition of the term "electronic

and information technology," a term created by the statute;

– Incorporating the EIT Standards in acquisition planning, market research, and when describing agency needs; and

– Adding a new Subpart 39.2.

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Section 508 and the FAR• A : General

– Part 2: Definitions of Words and Terms• 2.101Definitions.

– Electronic and information technology (EIT) has the same meaning as "information technology" except EIT also includes any equipment or interconnected system or subsystem of equipment that is used in the creation, conversion, or duplication of data or information. The term EIT, includes, but is not limited to, telecommunication products (such as telephones), information kiosks and transaction machines, worldwide websites, multimedia, and office equipment (such as copiers and fax machines).

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Section 508 and the FAR• A : General• B : Competition and Acquisition Planning

– Part 7: Acquisition Planning• 7.103 Agency-head responsibilities

– (o) Ensuring that acquisition planners specify needs and develop plans, drawings, work statements, specifications, or other product descriptions that address Electronic and Information Technology Accessibility Standards (see 36 CFR part 1194) in proposed acquisitions (see 11.002(e)) and that these standards are included in requirements planning, as appropriate (see Subpart 39.2).

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Section 508 and the FAR• A : General• B : Competition and Acquisition Planning• C: Contracting Methods and Contract Types

– Part 10: Market Research• 10.001 Policy

– (a)(3)(vii) Assess the availability of electronic and information technology that meets all or part of the applicable accessibility standards issued by the Architectural and Transportation Barriers Compliance Board at 36 CFR part 1194 (see Subpart 39.2).

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Section 508 and the FAR• A : General• B : Competition and Acquisition Planning• C: Contracting Methods and Contract Types

– Part 11: Describing Agency Needs• 11.002 Policy

– (f) In accordance with Section 508 of the Rehabilitation Act of 1973 (29 U.S.C. 794d), requiring activities must prepare requirements documents for electronic and information technology that comply with the applicable accessibility standards issued by the Architectural and Transportation Barriers Compliance Board at 36 CFR part 1194 (see Subpart 39.2).

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Section 508 and the FAR• A : General• B : Competition and Acquisition Planning• C: Contracting Methods and Contract Types

– Part 12: Acquisition of Commercial Items• 12.002 Market research and description of agency need

– (d) Requirements documents for electronic and information technology must comply with the applicable accessibility standards issued by the Architectural and Transportation Barriers Compliance Board at 36 CFR part 1194 (see Subpart 39.2).

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Section 508 and the FAR

• A : General• B : Competition and Acquisition Planning• C: Contracting Methods and Contract Types• D: Socioeconomic Programs• E: General Contracting Requirements• F: Special Categories of Contracting

– Part 39: Acquisition of Information Technology

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Section 508 and the FAR

• Part 39: Acquisition of Information Technology– 39.201 Scope of subpart.– 39.202 Definition.– 39.203 Applicability.– 39.204 Exceptions.

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39.201 Scope of subpart.• (a) This subpart implements Section 508 of

the Rehabilitation Act of 1973 (29 U.S.C. 794d), and the Architectural and Transportation Barriers Compliance Board Electronic and Information Technology (EIT) Accessibility Standards (36 CFR part 1194).

• (b) Further information on Section 508 is available via the Internet at http://www.section508.gov.

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39.201 Scope of subpart.• (c) When acquiring EIT, agencies must

ensure that—– (1) Federal employees with disabilities have access to

and use of information and data that is comparable to the access and use by Federal employees who are not individuals with disabilities; and

– (2) Members of the public with disabilities seeking information or services from an agency have access to and use of information and data that is comparable to the access to and use of information and data by members of the public who are not individuals with disabilities.

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39.202 Definition• Undue burden, as used in this

subpart, means a significant difficulty or expense.

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39.203 Applicability• (a) Unless an exception at 39.204

applies, acquisitions of EIT supplies and services must meet the applicable accessibility standards at 36 CFR part 1194.

• (b)(1) and so on (and on and on…)– See http://www.acqnet.gov/far/

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39.204 Exceptions• The requirements in 39.203 do not

apply to EIT that—• (a) and so on (and on and on…)

– See http://www.acqnet.gov/far/

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Modular Contracting

• Modular contracting” means use of one or more contracts to acquire information technology systems in successive, interoperable increments. – FAR 39.002

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Modular Contracting

• Modular contracting is intended to reduce program risk and to incentivize contractor performance while meeting the Government’s need for timely access to rapidly changing technology. – FAR 39.103 (a)

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Modular Contracting

• When using modular contracting, an acquisition of a system of information technology may be divided into several smaller acquisition increments …– FAR 39.103 (b)

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Modular Contracting

• The performance requirements of each increment should be consistent with the performance requirements of the completed, overall system within which the information technology will function and should address interface requirements with succeeding increments– FAR 39.103 (c) (2)