I agreeto Idea Build 508 into procurement processes
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Build 508 into procurement processes

As I understand it (and please correct me), including 508 in the paperwork for a given ICT procurement is not an absolute requirement, but more of an option on the part of whoever is doing the purchasing. It should go the other way -- 508 is part of the paperwork unless the purchaser can plausibly state a reason for exemption.

Continuing on, every other 508 step should be documented as well, such as requesting a VPAT, receiving it, reviewing it, etc., all the way down to explaining the purchasing decision in 508 terms.

All of this information should be subjected to oversight, leading to improvements in 508 training and other systemic actions.

Any government-wide (or even agency-wide) initiatives on digitizing ICT procurement and management should include 508 elements as needed.

Submitted by Jim Tobias 2 years ago

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Comments (5)

  1. Each Federal department or agency, including the United States Postal Service is subject to the Federal Acquisition Regulation (FAR) and should use it as guidance for developing their procurement policies and procedures.

    http://www.section508.gov/index.cfm?fuseAction=1998Amend

    DEVELOPMENT, PROCUREMENT, MAINTENANCE, OR USE OF ELECTRONIC AND INFORMATION TECHNOLOGY.--When developing, procuring, maintaining, or using electronic and information technology, each Federal department or agency, including the United States Postal Service, shall ensure, unless an undue burden would be imposed on the department or agency, that the electronic and information technology allows, regardless of the type of medium of the technology--

    Undue burden is very hard to prove as the cost of making a product compliant should be more than the budget of the entire agency

    2 years ago
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    1. Jim Tobias Idea Submitter

      Yes, of course they are subject to 508 via FAR, on paper. The problem is that so many procurements do not include any reference to 508, because there is no process that enforces it. If it were impossible to buy ICT without including a full 508 review or a well-documented request for an exemption or exception, compliance would improve. That's the point -- not the law, but the enforcement mechanism.

      As others have pointed out, "use" is actually more important than procurement. How can we enforce 508 at the level of "use"? That's another question.

      2 years ago
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      0 Disagreed
  2. I agree there is definitely a gap in the process.

    But Section 508 is a congressional law signed by the President.

    2 years ago
    0 Agreed
    0 Disagreed
  3. Jim Tobias Idea Submitter

    I'm guessing that right now, there are a dozen or more initiatives to automate or digitize ICT procurement and management, inside agencies, and at a higher level such as GSA or FAR. I will supplement this idea by recommending that whoever is in charge of managing 508 spend some effort getting onto (or in front of) the teams working on advanced ICT management, so that 508 can be built into them.

    2 years ago
    0 Agreed
    0 Disagreed
  4. Jim, whether the 508 aspects are required to be couched on proposal requests or not, I believe our current administration is moving the herd in that direction. I am seeing much attention to it on the DoD side. I believe all of the regulation and processes are in place in government acquisition; enforcement though, needs some teeth.

    2 years ago
    0 Agreed
    0 Disagreed