Procurement Appendix A(1)
Question-by-Question Results from the Component Questionnaire
1. Does your component use any disability-related language in contracts for electronic and information technology?a. Choose the most appropriate answer:
____ i. always
____ ii. often
____ iii. sometimes
____ iv. seldom
____ v. neverb. If your component uses any standard disability-related language in your contracts, give the language:
__________________________________________________________ __________________________________________________________ __________________________________________________________ __________________________________________________________
Question 1 was designed to determine the frequency of use and quality of agencies' language incorporating disability accessibility issues into EIT procurement contracts. Due to an ambiguity in the question, however, the following data cannot be interpreted as an indication of how many agencies already address disability accessibility in their procurement contracts for EIT. Most of the instances in which agencies cite some language actually refer to general nondiscrimination employment provisions and hiring preferences for disabled veterans.
Response (a): agencies always incorporating accessibility into mainstream EIT procurement
Only 22 of 144 components of cabinet level or large agencies (2.9%*) and 1 of 19 components of mid-sized agencies (7.2%*) always incorporate disability-related language into their standard procurement contracts. Two of 21 small agencies (15.9%*) and 2 of 22 very small agencies (4.5%*) also chose this response.
Response (b): agencies often incorporating accessibility into mainstream EIT procurement
Eight of 144 components of cabinet level or large agencies often incorporate disability-related language into their procurement contracts for EIT (2.6%*), while only 2 of 19 mid-sized agencies (7.7%*) do so. Two of 21 small agencies (13.8%*) and 3 of 22 very small agencies (4.8%*) also chose this response.
Response (c): agencies sometimes incorporating accessibility into mainstream EIT procurement
Twenty-eight of 144 components of cabinet level and large agencies (31.2%*) and 4 of 19 components of mid-sized agencies (13.1%*) responded that they sometimes incorporate accessibility issues into their procurement contracts for EIT. Three of 21 small agencies (10.6%*) and 3 of 22 very small agencies (15.5%*) also chose this response.
Responses (d) and (e): agencies seldom or never incorporating accessibility into mainstream EIT procurement
Ninety-two of 144 components of cabinet level or large agencies (63.3%*) either seldom or never incorporate disability-related language into their procurement contracts for mainstream EIT.
Only 2 of 19 components of mid-sized agencies (9.2%*), 1 of 21 small agencies (2.7%*), and 2 of 22 very small agencies (19%*) indicated that they seldom include disability-related language in their procurement contracts for EIT.
All 10 remaining components of mid-sized agencies (62.7%*), 13 remaining small agencies (57%*), and 12 remaining very small agencies (56.2%*) indicated that they never incorporate disability-related language into their procurement contracts.
2. How does your component ensure that acquisition of electronic and information technologies will be conducted in a manner that assures users with disabilities will have equal access to and use of the same data bases, operating systems, application programs, and telecommunication systems as their non-disabled colleagues?
Choose the most appropriate answer:
____ a. My component has an Information Technology ("IT") office that follows an approved reviewing process that meets this objective.
____ b. My component has a reviewing process but no established IT office to meet this objective.
____ c. My component is in the process of approving a draft reviewing process and assigning an IT office to be responsible for the reviews to meet this objective.
____ d. My component is drafting a review process to meet this objective.
____ e. My component addresses this issue on an ad hoc basis.
Good contract language will be meaningless unless there is some mechanism to ensure that contract specifications have been met. Question 2 asks whether agencies have established adequate reviewing processes to ensure that people with disabilities can actually use EIT products that are procured by agencies.
Response "a:" agencies meeting this goal
Only 17 of 144 components of cabinet level and large agencies (4.1%*) and 2 of 19 components of mid-sized agencies (4.6%*) have Information Technology offices that follow approved reviewing processes to make certain that acquisition of mainstream EIT will be conducted in a manner that ensures that users with disabilities will have equal access to and use of the same data bases, operating systems, applications, and telecommunication systems as other users. Two of 21 small agencies (5.6%*) and 2 of 22 very small agencies (8.6%*) also chose this response.
Response "b:" agencies using another method to achieve the objective
Only 12 of 144 components of cabinet level and large agencies (0.7%*) reported that they maintain a reviewing process to ensure acquisition of accessible EIT, but that this reviewing process is not integrated into a mainstream IT office. No small or mid-sized agencies chose answer "b." Only 2 of 22 very small agencies (4.1%*), both agencies' primary focus is on the civil rights of persons with disabilities, chose this response.
Response "c:" agencies in the final stages towards meeting this goal
Only two components of all those surveyed chose response "c" to question 2, representing less than 0.1% of employees of cabinet level and large agencies and 8.8% of employees in very small agencies. At the time of the survey, in other words, few agencies had already drafted reviewing processes that were ready for approval.
Response "d:" agencies planning to meet this goal
Additional agencies reported that they were planning to draft such review processes to address accessibility issues during the acquisition of mainstream EIT products and systems, including 9 of 144 components of cabinet level and large agencies (15.3%*) and 2 of 19 components of mid-sized agencies (13%*). Only one small agency (13.3%*) and one very small agency (5.1%) chose this response.
Response "e:" agencies addressing this issue on an ad hoc basis, if at all
The remaining components responded that they address this issue on an ad hoc basis, if at all. This included 107 of 144 components (79.8%*), 15 of 19 components of mid-sized agencies (82.4%*), 18 of 21 small agencies (81.1%*), and 16 of 22 very small agencies (73.4%*).
Some of these agencies indicate in their overall agency reports that they have standard policies. For example, one agency states that it has the following policy in place: "[Our agency's] offices acquiring information technology resources shall ensure that requirements of employees with disabilities are identified during the analysis of requirements and determination of needs phases of the procurement planning process."
3. How does your component identify the requirements of users with disabilities in order to achieve integrated solutions during acquisition planning and procurement?
Choose the most appropriate answer:
____ a. My component has a policy in place to involve users with disabilities or persons knowledgeable about disability access issues in the planning phase of acquisitions to assist in the procurement process by defining requirements and establishing Functional Performance Specifications (FPS) to appropriately describe the desired deliverables and access strategies. My component also involves users with disabilities in the evaluation of proposed solutions.
____ b. My component uses the FPS, however it has not established this as an official policy.
____ c. My component is developing policies and procedures to address this matter.
____ d. My component is reviewing alternative strategies to address this matter, including (explain):
____ e. My component addresses this issue on an ad hoc basis.
Agencies must have guidelines against which they measure an EIT product's accessibility to persons with disabilities. People with disabilities or people with knowledge about disability accessibility issues should be involved in developing these guidelines. Question 3 asks whether agencies have established such guidelines and, if so, whether they consulted with end-users with disabilities or others who are knowledgeable about disability accessibility issues in the process.
Response "a:" agencies meeting this goal
Very few components maintain formal policies to involve users with disabilities (or others who are knowledgeable about disability accessibility issues) into the planning phase of EIT acquisitions by involving them when drafting bid specifications and when evaluating submitted EIT products. Only 11 of 144 components of cabinet level and large agencies (0.8%*) already accomplish this goal. No mid-sized or small agencies have formal policies to involve users with disabilities in their procurement processes. Only 2 of 22 very small agencies (4.1%*) maintain such formal policies; both agencies' primary mission is to further the civil rights of persons with disabilities.
Response "b:" agencies meeting this goal through informal methods
Almost an identical number of components reported that they have an informal practice of involving users with disabilities during the earliest stages of EIT acquisition. Six of 144 components of cabinet level and large agencies (1.7%*) reported that they informally involve persons with disabilities into their acquisition of EIT. One mid-sized agency (4.1%*), one small agency (2.6%*), and one very small agency (2.1%*) all reported the same.
Response "c:" agencies developing policies to meet this goal
A few components reported that they are in the process of developing formal policies and procedures to involve users with disabilities into their acquisition of EIT. These include 8 of 144 components of cabinet level and large agencies (0.9%*), 1 mid-sized agency (0.1%*), 1 small agency (13.3%*), and 3 of 22 very small agencies (17.4%*).
Response "d:" agencies reviewing alternative strategies to address this matter
Few components indicated that they are exploring alternative strategies rather than involving users with disabilities in their procurement practices and policies. These include 6 of 144 components of cabinet level and large agencies (1.1%*) and 2 of 21 small agencies (5.4%*).
Some of the alternatives employed by these components include: seeking advice from other components within the same agency or other agencies; using surveys (presumably of users with disabilities) prior to procurement; relying on GSA's compliance with section 508 in its existing contracts; or addressing EIT accessibility issues on a case-by-case basis.
Response "e:" agencies addressing this issue on an ad hoc basis
The vast majority of components indicated that they address this issue on an ad hoc basis, if at all. These include 117 of 144 components of cabinet level and large agencies (95.5%*), 17 of 19 components of mid-sized agencies (95.8%*), 17 of 21 small agencies (78.7%*), and 16 of 22 very small agencies (76.4%*).
4. Does your component maintain a list of programs that provide training for management, procurement, and technical personnel on how to meet the accessibility needs of end users with disabilities and the many methods available to meet those requirements?
Choose the most appropriate answer:
____ a. Yes, my component maintains such a list. The list is updated periodically and is made available to all employees.
____ b. No, however, my component is in the process of announcing such a list in the near future.
____ c. No, however, my component is obtaining the information required to develop a list of this nature and the list will be announced when this data gathering is completed.
____ d. No, however, my component has plans to develop such a list.
____ e. No, however, my component is reviewing alternatives to developing such a list.
____ f. No, however, my component identifies appropriate training sources as needed.
A lack of training of management and IT professionals regarding disability accessibility issues can often result in problems for end-users with disabilities. Additionally, mainstream training vendors who are not sufficiently aware of disability accessibility issues may not be able to provide adequate training for users with disabilities, such as where the customer uses keyboard alternatives to "point and click" mouse commands, or where he or she uses the mainstream product in conjunction with assistive technology. Question 4 inquires as to whether agencies have made a list of appropriate training resources.
Response "a:" agencies maintaining lists of accessibility training resources
Relatively few agencies maintain lists of EIT accessibility training resources for management, procurement, and technical personnel on how to meet the accessibility needs of end users with disabilities. These include 13 of 144 components of cabinet level and large agencies (5.9%*). No mid-sized agencies chose response "a." Only one small agency, representing 3.0% of employees in small agencies, indicated that it maintained a list of EIT accessibility training resources. Likewise, only one very small agency, representing 1.0% of employees in very small agencies, chose this answer.
Response "b:" agencies announcing such a list in the near future
Only 1 component of a cabinet level or large agency (0.2%*) indicated it will announce a list of EIT accessibility training resources in the near future.
Response "c:" agencies gathering information
Only 5 of 144 components of cabinet level and large agencies (0.4%*) indicated that they are in the process of gathering the information required to develop a list of training resources. No mid-sized or small agencies chose this response. Only 2 very small agencies indicated that they are in the process of gathering information to develop such a list (13.9%*).
Response "d:" agencies planning to develop such a list
Relatively few agencies have plans to develop a list of EIT accessibility training resources. These include 4 of 144 components of cabinet level and large agencies (1.1%*), 1 component of a mid-sized agency (0.1%*), and 1 small agency (13.3%*). None of the very small agencies has a plan to develop such a list.
Response "e:" agencies reviewing alternatives to developing such a list
A small number of agencies are reviewing alternatives to developing a list of EIT accessibility training resources. These include 5 of 144 components of cabinet level and large agencies (15.4%*), no mid-sized or small agencies, and only 1 very small agency (0.7%).
Response "f:" agencies identifying appropriate training sources only when needed
Almost all agencies maintain a reactive posture and identify appropriate training resources only when needed. These include 121 of 144 components of cabinet level and large agencies (77%*), 18 of 19 mid-sized agencies (99.9%*), 19 of 21 small agencies (83.7%*), and 18 of 22 very small agencies (84.4%*).
5a. Are your agency's acquisitions subject to the Federal Acquisition Regulation (FAR)?
Choose the most appropriate answer:
___ a. Yes. Our agency's acquisitions are subject to FAR.
___ b. Our agency's acquisitions are not governed by FAR, but we use it (formally or informally) as guidance for procurement policies and procedures.
___ c. No. Our agency has established policies and procedures that are independent of the FAR.
The Access Board's section 508 standards will be incorporated into the Federal Acquisition Regulation (FAR). Agencies complying with the FAR will, accordingly, automatically have the section 508 standards incorporated into the procurement mechanisms. Agencies which do not follow the FAR will have to independently modify their procurement policies and procedures to incorporate the section 508 standards. Question 5a asks agencies to identify whether they follow the FAR.
Response "a:" agencies covered by the FAR
Most agencies in all size categories are covered by the Federal Acquisition Regulation (FAR). These include 138 of 144 components of cabinet level and large agencies (79.2%*), 16 of 19 components of mid-sized agencies (79.4%*), 18 of 21 small agencies (92.2%*), and 18 of 22 very small agencies (85.7%*).
Response "b:" non-FAR agencies using the FAR for policy guidance
About half of the agencies that are not required to follow the FAR use it for policy guidance. These include 1 component of a cabinet level or large agency (less than 0.1%*), 2 mid-sized agencies (5.5%*), 3 small agencies (7.8%*), and 2 very small agencies (8.2%).
Response "c:" non-FAR agencies not using the FAR for guidance
The remaining agency and components are not required to follow the FAR and do not use it for policy guidance. These include 5 of 144 components of cabinet level or large agencies (20.8%*), 1 mid-sized agency (15.1%*), no small agencies, and 2 very small agencies (6.1%*).
5b. If your agency's acquisitions follow the FAR (formally or informally), has your component established a strategic plan for meeting its electronic and information technology needs -- including, among other things, accommodations for individuals with disabilities -- pursuant to OMB Circular A-130, as required by section 39.101 of the FAR?
____ a. Yes, my component has an established strategic plan which addresses accessibility issues, that has been approved and distributed to all appropriate offices. Prior to the acquisition of any electronic and information technology the RFP's are reviewed for compliance.
____ b. Yes, my component has an established strategic plan which addresses accessibility issues but there is no review process to ensure that RFP's are in compliance.
____ c. No, however, my component does have a draft strategic plan that will meet the stated objectives when approved.
____ d. No, however, my component is developing and drafting a strategic plan which will meet the stated objectives.
____ e. No, however, my component is in the process of defining its electronic and information technology needs and, when this is defined, accessibility guidelines will be addressed.
____ f. No, however, even though my component does not have a strategic plan, we address accessibility issues on an ad hoc basis.
___ g. Not applicable. Our agency's acquisitions are not subject to FAR.
For many years, the FAR has incorporated by reference some general language requiring agencies to incorporate disability accessibility issues into their strategic plans regarding procurement of mainstream information technology. Question 5b asks agencies whether they have been complying with these requirements.
Response "a:" agencies maintaining a strategic plan that includes reviewing the accessibility of EIT products before acquisition
Of the agencies required to comply or voluntarily complying with the FAR (FAR agencies), comparatively few tend to maintain a strategic plan that includes reviewing the accessibility of EIT products before acquisition. This includes 14 of 144 components of cabinet level or large agencies (3.3%*), no mid-sized agencies, only 2 of 21 small agencies (5.8%*), and 2 of 22 very small agencies (12.9%*).
Response "b:" agencies maintaining a strategic plan to meet the EIT needs of persons with disabilities, but without any review process in place
Comparatively more large FAR agencies maintain strategic plans to meet the EIT needs of persons with disabilities but do not have any type of formal review process in place to determine whether EIT products submitted for procurement actually meet the bid requirements. Ten of 144 components of cabinet level and other large agencies (1.6%*) chose response "b," compared with no mid-sized or small agencies, and, in the very small agency category, only 1 of 22 agencies (3.5%).
Response "c:" agencies reviewing a draft strategic plan to meet this goal
Very few FAR agencies of any size have already drafted and are about to review a strategic plan to incorporate the EIT needs of persons with disabilities. Only 2 of 144 components of cabinet level agencies chose this response (0.1%*). No mid-sized or small agencies chose this response. One of 22 very small agencies (9.3%*), indicated that it was reviewing a draft strategic plan to integrate EIT needs of persons with disabilities into its mainstream EIT acquisition processes.
Response "d:" agencies developing a strategic plan to meet this objective
More FAR agencies plan to develop a strategic plan to meet this objective, including 14 of 144 components of cabinet level and large agencies (20.1%*) and 3 of 19 components of mid-sized agencies (20.3%*). One agency in each of the small (3.0%) and very small (5.1%*) agency categories chose this response.
Response "e:" agencies in the initial stages of defining EIT needs
Relatively more of the smaller FAR agencies are in the initial stages of defining their EIT needs as they relate to persons with disabilities than is true of the larger FAR agencies. Fifteen of 144 components of cabinet level and very large agencies (15.3%*) and 2 of 19 components of mid-sized agencies (8.5%), compared with 7 of 21 small agencies (47.5%*) and 4 of 22 very small agencies (21.3%*).
Response "f:" agencies addressing accessibility issues on an ad hoc basis, with no strategic plan
Close to half of the FAR agencies participating in this survey address EIT accessibility issues on an ad hoc basis, with no strategic plan, contrary to the FAR's requirements. These include 87 of 144 components of cabinet level and large agencies (59.6%*), 13 of 19 components of mid-sized agencies (56.1%*), 10 of 21 small agencies (42.2%*), and 11 of 22 very small agencies (47.9%*).
Response "g:" agencies which are not required by the FAR to establish a strategic plan
The remaining agencies are not required by the FAR to maintain a strategic plan that incorporates the needs of persons with disabilities, nor do they look to the FAR on a voluntary basis for policy guidance.
1. This document is available on the Department of Justice's section 508 Web site (www.usdoj.gov/crt/508). People with disabilities may request copies in Braille, large print, or on computer disk by calling 1-800-514-0301 (voice) or 1-800-514-0383 (TTY).