The Ultimate Guide to Choosing a Third-Party Auditor for Your VPAT Engagement

Potential customers frequently ask product developers to provide an Accessibility Conformance Report (ACR) based on a Voluntary Product Accessibility Template (VPAT).   It usually doesn’t take long for the developer to realize that the VPAT form is complex and contains language specific to the accessibility industry. This realization leads many developers to seek a third-party auditor’s assistance in auditing their product and creating an accessibility compliance report.

This VPAT engagement checklist contains common information a product developer should collect before contacting a third-party auditor to assist with completing a Voluntary Product Accessibility Template (VPAT).  Collecting this information will speed up the process and help your VPAT provider create an accurate proposal for an audit that will meet your requirements.

Getting Started

#1 List all products or domains.

Create a list of all products and product components. This list may contain domains for web-based technologies or individual applications for complex product offerings.

#2 Product Type

Auditors specialize in evaluating specific product types such as computer-based training, learning management systems, complex web applications, etc. Selecting an auditor with experience in your specific product type makes auditing more accurate and efficient.

A few examples of common product types are:

• • Brochure / Informational Website
  • Shopping / Retail Experience
  • Computer-Based Training (Lectora, Rise, Storyline, etc.)
  • Learning Management System (LMS)
  • Content Management System (CMS)
  • Law Enforcement Application
  • Banking / Investment Application

#3 Product Technology Profile

When you first speak with a third-party auditor, it’s important to understand their testing methodology, including the manual and automated testing tools they use. To do this, the auditor must clearly understand the technology being tested since testing tools can differ depending on the technology used.

• • Website
  • Web Application
  • Desktop Application: __ Windows, __ Mac, __ Linux, __ Other _______
  • Mobile App

#4 Due Date: __________

Many VPAT engagements are in response to a procurement event with a set timeline. Communicating your timeline needs is important, as not all auditing organizations can meet them. This can help you select an auditor who can meet your specific timeline requirements.

#5 Accessibility Standards Requirements

When you consult a third-party auditing firm, they will inquire if you know the technical accessibility standards your product must be audited against.    Technical standards requirements are frequently found in procurement documents.

If you’re unsure what standards to adhere to, auditing firms should be able to guide you to an appropriate accessibility standard for your product.

Frequently Cited Standards and Guidelines:

• • Web Content Accessibility Guidelines (WCAG) 2.0 Level A / AA – Associated with sales to the federal government, state government, public institutions of higher education, etc.
  • Web Content Accessibility Guidelines (WCAG) 2.1 Level A / AA – Associated with sales to entities not in the public sector or with explicit WCAG 2.1 requirements.
  • Section 508 – Required for all federal procurement opportunities, public sector opportunities, and products that include hardware. The third-party auditing firm can articulate other benefits and costs when considering Section 508.
  • EN 301 549 – European standard specifies accessibility requirements for public procurement of European ICT products and services. This standard is primarily used by public authorities, including government agencies, educational institutions, and healthcare organizations, when procuring products and services.

#6 Scope

To receive a price quote for an audit from a third-party auditing firm, they must first establish the scope of the audit. The scope can be determined by counting the number of pages on a web application or selecting strategically selecting pages to audit a large application.

To accurately demonstrate the size and complexity of your product during the initial conversation with the firm, you can use various methods such as a product demo, page printouts, or product documentation.

• • Product Demo – Rapidly running through an application is one way to efficiently facilitate a conversation with an auditor.
  • Page Printouts – Screen capturing the application pages can be a way to convey information quickly and can be included within the contract.
  • Product Manual – Providing documentation that clearly outlines the system can be used to create a scope. This tends to be a slow scoping process for the auditing firm as they must attempt to isolate features and functionality. Expect slower proposal turnarounds with this type of scope documentation.

#7 Special Conditions

Many industries have special requirements that will affect the audit. For example, the Texas Education Agency (TEA) requires the use of people with disabilities and specific audit requirements:

• • The home page people use to enter the site
  • One page with at least one table or form
  • One page with at least one informational image (e.g., a diagram, map, or graph)
  • One page from each component of the product
  • One page with interactive content

If you have special audit requirements communicate them clearly with your auditor.

• • Requires inclusion of people with specific disabilities:
    • Vision – Blind
    • Vision – Low Vision
    • Vision – Color Deficiency (Colorblind)
    • Mobility
    • Hearing
    • Cognitive
  • Completion of Additional Documentation
    • TEA Coversheet*
    • Conformance Letter*specific to Texas Education Agency

Other Considerations

The industry has seen a surge in organizations providing audit and VPAT services. Below are a few considerations when choosing your auditor:

• Scope: Be cautious of auditing firms that provide a cost without reviewing the scope of the audit. It’s important to remember that your product is unique, and your engagement should be tailored to its specific needs.
• Cost and timeline: Finally, consider the cost and timeline for the audit. Look for a firm that provides a detailed quote and timeline upfront. Be wary of firms that offer low prices or quick turnaround times, as this may indicate a lack of thoroughness or expertise.
• Expertise and Experience: It is important to choose a firm with expertise and experience in accessibility auditing. Look for a firm with a track record of working with various organizations and with experience auditing different types of Internet and Communication Technology (ICT) products and services.
• Knowledge of accessibility standards and regulations: Look for a firm familiar with accessibility standards and regulations, such as WCAG 2.1, EN 301 549, and Section 508. They should be able to provide recommendations and guidance based on these standards and regulations.
• Testing process: Ask about the firm’s testing process, including how they test for accessibility, how they report their findings, and how they prioritize issues. They should be able to provide a clear and transparent testing process.
• Accessibility testing tools: Ask about the tools and methods the firm uses for accessibility testing. They should use automated and manual testing tools to ensure thorough testing.
• Reporting and recommendations: When selecting a third-party auditing firm, make sure they provide a detailed report of their findings with clear and actionable recommendations for fixing accessibility issues. This will ensure that you clearly understand the necessary improvements and can take appropriate actions to address any issues.
• Overlays and Subscription Services: Be cautious of VPAT audits associated with products, like overlays or subscription services.   Industry experts have raised concerns about the effectiveness of such services.   Do your research before choosing such a service to create your Accessibility Compliance Report.

Creating an Accessibility Conformance Report (ACR) based on a Voluntary Product Accessibility Template (VPAT) can involve legal and reputational risks. By following this VPAT engagement checklist and working with a reputable third-party auditor, you can ensure that your product meets accessibility standards and regulations. Remember to consider the scope, cost, timeline, expertise, knowledge of accessibility standards and regulations, testing process, accessibility testing tools, and reporting and recommendations when selecting an auditing firm. With these considerations in mind, you can create an accurate and comprehensive accessibility compliance report that meets your specific needs and requirements.

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