Many customers come to Level Access with the goal of getting a VPAT for their product. (Often that happens sometime between April and July when the Federal sales team for the company is trying to close contracts prior to the end of the government fiscal year and realizes they need a VPAT to get through the procurement process.) The primary focus in most of these situations is generally not to improve the level of compliance or accessibility of the product but, instead, to produce an accurate VPAT to ensure the product can (i) be procured by the Federal government and (ii) the company doesn’t make any claims that may subject it to legal action at a future date.
So knowing the lay of the land the question remains – how do you actually get a VPAT? Essentially there are two options here and it comes down to whether you want to certify the Section 508 compliance of your product internally or have a third party do a VPAT audit. (Hint: Unless you have a dedicated accessibility group with experience creating VPATs you probably don’t want to do the certification work internally.) But before we get into that, let’s answer the simple question: what is a VPAT?
What is a VPAT?
VPAT stands for “Voluntary Product Accessibility Template,” a document template created by the Information Technology Industry Council (ITIC) to report the level of compliance of their software products to interested parties – generally U.S. Federal Government agencies. The VPAT template is owned and maintained by the ITIC and a version of it can be downloaded from their site.
At its most basic you can think of a VPAT as a public statement of the level of Section 508 compliance of an IT product. It’s important to note that a VPAT is not an up or down statement of compliance – it’s a report on the overall level of compliance of an application – so detail and specificity of the individual claims are important.
Is VPAT required?
The Section 508 standards require that when completing procurements the Federal government research and weigh the level of Section 508 compliance of all competing products – adding consideration for accessibility to the procurement process. In practice, this means that your legal obligation as a firm generally is not to provide a product that is 100% 508 compliant – something that arguably could be impossible to do – but rather ensure that your VPAT accurately reflects the current level of compliance of your product. As long as you are accurately representing the level of compliance of your product you have generally fulfilled your obligation in the procurement process.
(Disclaimer: Level Access does not provide legal advice. If you would like legal advice on your Section 508 requirements, we recommend speaking with your in-house or external counsel. What we do provide is excellent working knowledge of your on the ground operating requirements under Section 508 based on our extensive experience working from both the public sector and private sector sides of the procurement process.)
So the question of “how do I get a VPAT” is probably more accurately stated as “How do I accurately state the level of Section 508 compliance of my product?” Essentially you have two options for that: do it internally or have a third party develop it for you.
Why you need Level Access for Section 508 Compliance
Organizations that want to create a VPAT internally must complete a Section 508 audit of the application you wish to create a VPAT for. While you can train internal teams to create a VPAT – as noted above the legal obligation for most organizations – takes significant accessibility domain knowledge and is something that most organizations don’t have access to internally. Although creating a VPAT internally is an option, having a third party create a VPAT for you lends more credibility to the information contained in the VPAT.
Many organizations initially research Section 508 with the goal of bringing all VPAT creation activities in-house. (What could be so hard – there are only sixteen paragraphs?) After gaining a full understanding of the challenges involved in Section 508 testing (Oh, I didn’t notice the functional requirements…) opt to use an external vendor to create VPATs for them.
If your organization does, however, have a team that understands accessibility and the ins and outs of Section 508 compliance then the most important decision you can make relating to the creation of your VPAT is what accessibility auditing infrastructure you want to put in place to support the auditing. This solution should provide you the ability to test against all the Section 508 requirements including the technical requirements (§1194.21-§1194.26), (ii) functional performance criteria (§1194.31), and (iii) information, documentation, and support requirements (§1194.41) in a single location. To that end, Level Access manufacturers and recommends AMP, the Accessibility Management Platform which provides cost-effective infrastructure for auditing Section 508 compliance. When you complete a full audit of an application in AMP one of the report formats provided is the VPAT which allows you to publish VPATs directly from AMP.
How would I get a VPAT from Level Access?
To create a VPAT, Level Access completes an audit of your application with the scope varying based on your needs to provide a determination of compliance and enough data to create a VPAT. This ensures a proper compliance baseline is established with all applicable portions of the Section 508 standards including the (i) technical requirements
(§1194.21-§1194.26), (ii) functional performance criteria (§1194.31), and (iii) information, documentation, and support requirements (§1194.41).
Each audit report identifies and prioritizes all accessibility errors within the system, defines the method for addressing the issues, and documents the system’s overall compliance with Section 508. The audits are used to improve the compliance of the system and create a VPAT as well as being escrowed for reporting purposes in the event of legal action or complaints against your customers in the future.
To get more information on having Level Access create a VPAT for your application you can contact us at (800) 889-9659, e-mail our sales team at firstname.lastname@example.org or complete our contact us form on the site. Once we hear from you we can set up some time to discuss your accessibility needs with you.
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