Micro-purchases and Section 508 Requirements
Page | 8
Review Information You Obtain
Next, review the information you obtain. For micro-purchases, this activity will primarily consist of gathering
and comparing the ACR or VPAT
TM
for the options you are considering. Your job here is to identify which option
best meets the accessibility requirements you defined in Step 2.
As a best practice, try to find at least two possible solutions, gather the ACRs/VPATs
TM
, and compare their
quality. The attention to detail in how a vendor documents the accessibility of their products is a great
indicator of how well you can ‘trust’ what is documented. As you review them, consider:
• Is there a clear indication that the VPAT
TM
was authored by a third party?
• Is there detailed information about the exact type of testing and what evaluation methods were used?
• Are there positive examples of how a product supports a specific success criterion?
• Does the vendor publicly display their VPAT
TM
?
Source: How to Read a VPAT: Assessing Accessibility Conformance Reports, Brian McNeilly, University of Washington, USA, Sina
Bahram, Prime Access Consulting, Inc., USA
Scoring ACRs
ACRs include categories rated as “meets”, “partially meets”, and “does not meet” requirements. Assign a
value to each of those ratings, then tally the scores, paying greatest attention to accessibility elements most
pertinent to the requirements you defined in Step 2.
Of the products that meet the business need, your agency is obligated to pick the item that meets Section 508
accessibility requirements. Document your research, to compare solutions and find one that is the best fit for
your agency including at a minimum vendor name, version, and model number, and a description of how the
solution will/will not meet your business need.
Evaluating ACRs is not easy for a novice. Do not be afraid to seek help from
your Section 508 Program
Manager.
The Best Meets Exception
The 'Best Meets' exception provides a mechanism to help agencies balance business needs and obligations to
procure ICT and conform to the Revised Section 508 Standards when an alternative that fully conforms is not
available.
If there are technically acceptable solutions available in the marketplace, you must select one of those
solutions (FAR 39.203(c)(1)). You cannot choose a different solution and claim an exception (e.g., "best meets"
or "undue burden").
If your market research does not uncover any technically acceptable options, you can claim exceptions and
select a different solution. Of the alternatives that meet your business need, you’ll still need to select the
alternative that best meets the Section 508 requirements. You'll also need to provide documentation of your
market research as justification.
If the product is not accessible, you must determine an alternative way to provide access. The ICT must be
accessible and usable by everyone. For example, if Mary couldn’t find a multifunction machine that provided
all necessary accessibility at the machine’s touchpad, that machine would need to be equally accessible from a
desktop application.