I frequently receive questions asking how to review an Accessibility Conformance Report (ACR) based on one of the four Voluntary Product Accessibility Templates (VPAT) versions. At Microassist, I teach both a four-hour and eight-hour course on purchasing, which includes interpreting an ACR. As anyone who has attempted to interpret one of these attestations will tell you, the task of interpretation will vary in complexity depending on the type of product, VPAT version, and the quality of the answers provided by the vendor. This article will discuss the first step in the evaluation process and determine if the ACR is credible enough to be evaluated. This process is applicable for all versions of the VPAT: WCAG, 508, EU, INT.
In my most recent commentary for Mealey’s® Litigation Report, I wanted to provide evaluators with a series of quality checks to aid in the determination process. The full commentary provides guidance for reviewing key sections of the completed ACR for signals that would call into question the credibility of the attestation. The following questions can serve as a preliminary checklist for gauging a report’s accuracy.
Credibility Checklist for Quality Review
- Did the vendor remove the instructions from the ACR?
- Does the ACR significantly deviate from the original VPAT template, or are the required sections missing?
- Does the ACR Name of Product/Version match the proposed solution?
- Does the product description include all components required for the solicitation?
- Is the report date less than {your organization criteria} months? (Recommendation is no less than 12 to 18 months)
- Did the vendor adequately describe how the product was tested for accessibility (Manual and Automated Testing)?
- Did the vendor use a knowledgeable third party to perform the audit?
- Did the vendor claim WCAG AAA compliance?
- Did the vendor use standard terms for every success criteria?
Download the Full Mealey Article
For more detail around each checklist item and examples to look for during the review process, download the accessible, PDF re-print of the full article.
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Editor’s Note: This post is adapted from the article, “A Credibility Checklist for the Voluntary Product Accessibility Template”, originally published in the May 2022 issue of Mealey’s® Litigation Report: Cyber Tech & E-Commerce. Mealey’s is a subscription-based information provider and division of LexisNexis.
Why Accuracy Matters When Evaluating a VPAT/ACR Response?
Electronic information and communication technology (ICT) products and services sold to government agencies must be accessible. This holds true for federal agencies through Section 508 of the Rehabilitation Act. State and local governments frequently pass laws and implement policies based on Section 508. The challenge of procuring technology that complies with these regulations is a daunting task for public-sector organizations. A VPAT and Accessibility Conformance Report is frequently the mechanism used to ensure accessibility compliance.
A VPAT is a document used by purchasers to gauge the accessibility of hardware, software, or online products and services during a procurement process. Vendors create VPATs for their products. To meet the needs of purchasers, a VPAT must be accurate. Creating an accurate VPAT requires the vendor to be knowledgeable about accessibility standards and how they affect users with disabilities.
The VPAT must be interpreted against accessibility standards by the procurement team. Without accessibility knowledge on both ends of the transaction, both vendors and agencies are at risk of entering into contracts for non-accessible products and services.
Purchasing Accessible Technology Resources
- Webinar Event: Navigating VPAT Requirements for Vendors (Recording)
- Understanding Digital Accessibility in the Procurement Process
- New Course: Understanding the VPAT Analysis and Determination Process
- VPAT: The Ultimate Buyer’s Guide
About the Author: Hiram Kuykendall
Hiram Kuykendall is the chief technology officer for Microassist, with over 25 years of in-depth accessibility experience, including application development, training development, and organizational governance. His expertise extends to a diverse set of public and private organizations, such as federal government, state government, institutions of higher education (private and public), financial institutions, technology, retail and other commercial sectors. Hiram is an avid speaker and frequent contributor to LexisNexis, Mealey’s Litigation Report for Cyber Tech and E-Commerce.
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