What is a Section 508 VPAT and Who Needs One?

  • 26.01.2023
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    What is Section 508?

    Section 508 is part of the 1998 amendment to the U.S. Rehabilitation Act of 1973 that requires all federal information and communication technology (ICT) to be accessible to people with disabilities, regardless of whether these people work for the federal government or not.

    This section of the Rehabilitation Act prohibits discrimination on the basis of disability in federal programs or programs receiving federal aid or employment. It obligates federal agencies to provide their employees, as well as members of the public who have disabilities, access to information comparable to that available to other people.

    The section establishes requirements for ICT developed, maintained, procured, or used by the federal government and its agencies. It applies to all federal organizations when they develop, procure, maintain, or use electronic and information technology (EIT).

    The updated Section 508 accessibility standards include scoping and technical requirements for ICT in order to ensure accessibility and usability by people with disabilities.

    What is a VPAT?

    A VPAT, or voluntary product accessibility template, is a standardized prototype document that is filled out by a manufacturer or vendor of an ICT product or service to illustrate the degree to which the product or service conforms to the established accessibility standards.

    The Information Technology Industry Council (ITI) created the VPAT in partnership with the General Services Administration (GSA) in 2001 to help strengthen compliance with accessibility requirements by providing the basis on which the general issue of matching ICT product features could be hinged.

    The VPAT is available in four editions: the VPAT WCAG (Web Content Accessibility Guidelines): WCAG 2.1 or ISO/IEC 40500, the Section 508 VPAT, the European Union (EU) VPAT, and the VPAT International (INT).

    The VPAT WCAG anchors the criteria and technical requirements for making web content more accessible to people with disabilities, as well as to older people whose abilities change due to age. The WCAG standards provide a benchmark or common definition for accessible digital content.

    The Section 508 VPAT details how information technology (IT) products and services adhere to the revised Section 508 accessibility standards. If the acquisition of a certain technology will place an unreasonable strain on the organization, the Section 508 Accessibility Standards take these conditions into account.

    The alternate formats may include, but are not limited to, Braille, the American Standard Code for Information Interchange (ASCII) text, large print, recorded audio, and electronic formats.

    Alternate methods are different means of providing information, including product documentation, to people with disabilities. These may include, but are not limited to, voice, fax, relay service, TTY, internet posting, captioning, Braille, text-to-speech synthesis, and audio description.

    The great thing about the VPAT Section 508 document is that you don’t have to worry about decoding the technical requirements as stipulated in the Section 508 Accessibility Standards. That is because ITI has done the decoding of the standards and itemized the Section 508 accessibility requirements in the 508 VPAT.

    The Section 508 VPAT also contains the WCAG requirements for making web content accessible. This means that if you have an ICT product or service consisting of hardware and digital content, you don’t have to fill out a separate VPAT Section 508 accessibility conformance report (ACR) and a WCAG VPAT ACR. The Section 508 VPAT allows you to document the accessibility of your digital content in a single document.

    The EU VPAT is used to document the accessibility of ICT products and services that are publicly procurable in Europe, while the VPAT INT is used to document the accessibility of products and services that are publicly procurable internationally.

    Both the VPAT INT and the EU VPAT contain the accessibility criteria and technical specifications for accessible digital content, as is also provided in the VPAT WCAG. The VPAT-INT incorporates all the accessibility criteria and technical specifications in the other three accessibility standards.

    The VPAT process is complicated. Let us handle it for you.

      Who needs a Section 508 VPAT?

      All organizations governed directly or indirectly by this section are required to complete or update a VPAT. These organizations include all U.S. federal agencies and any government agency that receives financial aid from the federal government. Any private company operating as a contractor for any U.S. federal agency also needs a Section 508 VPAT.

      Given that all these federal and government agencies are required by law to develop, procure, maintain, or use EIT that is accessible to people with disabilities, it follows that if you are a manufacturer or vendor of an ICT product or service and you want any of these organizations to procure it, you need to create or update a VPAT for the product or service.

      Creating or updating a Section 508 VPAT ACR

      Regardless of whether you are a small and micro enterprise (SME) or a large corporation, your ICT products or services must be VPAT compliant to participate in the procurement processes of the federal organizations and those of the entities receiving funding from the federal government.

      To create or update your VPAT ACR, you need to:

      • Download the appropriate edition of the VPAT from the ITI website.
      • Identify the sections of the Technical Standards that apply to your product or service. When doing this, please note that sometimes, more than one set of Technical Standards tend to be applicable. So study the entire VPAT document.
      • Analyze each relevant section of the VPAT to determine whether your product or service fulfills the specified criteria.
      • Select the conformance level that best describes your product or service from the five categories, namely, “supported,” “partially supported,” “not supported,” “not applicable,” and “not evaluated.”
      • Explain in detail how your product or service complies with or fails to comply with the relevant accessibility requirements.
      • Go back to the VPAT document’s Summary Table and document the overall level of compliance associated with your product or service in each of the applicable sections.
      • Ensure you fill out every line and column in the VPAT’s table section.
      • Ensure that the Remarks and Evaluation column contains detailed explanations that support the accuracy of the answers you have provided.
      • Check through the completed VPAT ACR to ensure every fillable part is duly completed.

      Once you have gone through the document to ensure there are no mistakes and that every fillable section is completed, you can publish the VPAT ACR on your company’s website or provide an accessible link directing interested parties to where they can access the document.

      Need help with creating or updating your Section 508 VPAT?

      You can learn to create or update your VPAT ACR by reviewing a Section 508 VPAT example or by calling (626) 486-2201 to schedule an appointment with our VPAT accessibility experts, who will provide you the help you need. Our consultations are always free!