Level Access hosted an ‘encore’ of our popular webinar, Navigating VPAT® 2.0: A Guide for Vendors yesterday; the original session took place on October 4, 2017, the day the Information Technology Industry Council (ITI) released the final VPAT® 2.0 Template. Questions unanswered during both webinars have been addressed in this blog post. For more information, the webinar slide deck, transcript, and recorded presentation are available here: Encore Webinar: Navigating VPAT® 2.0: A Guide for Vendors.
Q: Is it true that if someone does not follow the essential requirements of VPAT® 2.0 that they should not call it a VPAT ?
A: Yes, this is essentially true. “Voluntary Product Accessibility Template®” and “VPAT®” – including the template format – are Federally Registered Service Marks of the ITI. VPAT® 2.0 users agree not to deviate materially from the template format provided by ITI, and to use the service mark (“®”) where appropriate. In order for vendors and suppliers to call their report a VPAT, the report must meet the “Essential Requirements” provided by ITI in the official VPAT® template. These include:
- Inclusion of the registered service mark (i.e., “VPAT®”);
- Accessible format (e.g. Word®, HTML, PDF®);
- Minimum of one applicable standard/guideline or any combination of the three;
- Required content (report title, VPAT® heading, name of product/version, product description, date, contact information, notes, evaluation methods used, applicable standards/guidelines, terms, tables for each standard/guideline);
- WCAG Conformance Tables;
- Conformance Levels;
- Remarks and Explanations.
Q: Are VPAT® 1.0 reports still valid to use after January 18, 2018, the date that ITI states that VPAT® 1.0 is being discontinued?
A: ITI states that VPAT® 1.0 is to be discontinued as of January 18, 2018. This means that ITI will no longer be hosting VPAT® 1.0 on their website. While this is the case, some agencies or entities procuring ICT may require that a vendor or supplier provide a VPAT® 1.0 format report. So, vendors or suppliers should provide VPATsin the format requested by the buyer, until all agencies and entities procuring ICT have migrated their procurement processes to VPAT® 2.0.
Q: Can vendors or suppliers add additional info to their VPAT and still call it a VPAT? For example, a summary table listing all the WCAG requirements and a “yes” or “no” for supports on a single page so users don’t have to read the entire document to get an overall picture.
A: As long as the Essential Requirements stated by ITI are met, adding some additional information may be acceptable if it meets the needs of the vendor/supplier and the agency or entity procuring the ICT product or service. However, vendors and suppliers should try to use the standard content elements described in Essential Requirements (e.g. Notes) – avoiding the addition of new content sections – where possible. If new content sections beyond essentially required content are added, the vendor/supplier should always meet ITI’s Essential Requirements for VPATs and also be consistent in its implementation of their VPATs.
Q: How should vendors and suppliers handle a VPAT for an ICT product or service (e.g. web-based application or website) that is updated very frequently?
A: Obviously, vendors and suppliers should use some discretion and careful judgement here, as it is usually not practical or feasible to update VPATs with every small or frequent update to a product or service. We advise that vendors and suppliers create new VPATs when new, official versions of a product or service are released into market. In VPATs for products and services that offer frequent, minor updates to content or functionality not considered a new “version” of the product or service, care should be taken to write the VPAT in a way that takes into account such minor or frequent updates. For websites or web-based software products or services being constantly updated, this could mean making a new VPAT when there are redesigns, major functionality changes, new content sections, etc. Also, we advise that vendors and suppliers develop internal policies, standards and guidelines for VPAT creation and update to ensure their teams implement a consistent approach that takes into account the needs of agencies and entities who are your customers.
Q: Is there anything different about scoring or conformance levels in VPAT® 2.0?
A: Scoring is the same between VPAT® 1.0 and VPAT® 2.0, except that VPAT® 2.0 does not include a rating of “Supports with Minor Exceptions.” As indicated in the VPAT® 2.0 Essential Requirements, Item #6 (Conformance Levels), the following Conformance Levels are standard from ITI:
- Supports: The functionality of the product has at least one method that meets the criterion without known defects or meets with equivalent facilitation.
- Supports with Exceptions: Some functionality of the product does not meet the criterion.
- Does Not Support: The majority of product functionality does not meet the criterion.
- Not Applicable: The criterion is not relevant to the product.
- Not Evaluated: The product has not been evaluated against the criterion. This can only be used in WCAG 2.0 Level AAA.
If any variation from these standard levels is used, place a note to that effect in the “Notes” section (a required section). Also, if a vendor does vary from these definitions, it is recommended they be consistent on all VPATs for all of their products and services.
Q: When documenting conformance to W3C® WCAG 2.0 success criteria that do not apply to the product or service in question, VPAT® 2.0 best practices state that “a response may include ‘Supports’ where one might otherwise be inclined to use ‘Not Applicable’. Is this up to the discretion of the organization producing the VPAT?
A: Yes, an organization can use the recommended best practice, or decide to use a rating of “Not Applicable” and provide Remarks to explain the rating. This is in keeping with guidance from W3C® in WCAG 2.0 Understanding Conformance: “Conformance to a standard means that you meet or satisfy the ‘requirements’ of the standard. In WCAG 2.0 the ‘requirements’ are the Success Criteria. To conform to WCAG 2.0, you need to satisfy the Success Criteria, that is, there is no content which violates the Success Criteria. Note: This means that if there is no content to which a success criterion applies, the success criterion is satisfied.” Whichever approach your organization decides to use, it is important to be consistent across all your VPATs.
Q: When are the Functional Performance Criteria applicable in VPAT® 2.0, Section 508, Chapter 3 Section of the Accessibility Conformance Report?
A: Per the Access Board, Chapter 3 Functional Performance Criteria only apply when: (1) There is not a technical standard for the situation; (2) When a standard is not fully supported; or (3) When equivalent facilitation is used. However, we do not recommend removing the Functional Performance Criteria Section if all applicable technical standards are fully supported; Instead, consider placing “Not Applicable – Technical Standards Fully Supported” next to each Functional Performance Criteria. In most cases, there is almost always parts of ICT that aren’t covered under the technical standards and most products don’t fully conform and thus practically speaking must organizations will want to continue to report on the Functional Performance Criteria.
Q: Are there concerns that, in trying to cover so many requirements / guidelines, that the VPAT® 2.0 will be too extensive, causing organizations to have challenges producing them correctly or with consistency and quality?
A: This is a concern, and the way to address this concern is to ensure organizations using VPAT® 2.0 have a clearly defined approach, process and authoring guidelines in place in their organization. In addition, we advise that organizations train any staff who are responsible for producing or maintaining VPATs. Because VPATs can become part of legally-binding quotes, bids, proposals and contracts, we advise that your legal counsel or staff be involved in reviewing typical VPAT language or standard remarks authoring guidance.
Q: For a large enterprise with hundreds of assets, what criteria would you use to determine which need a VPAT?
A: Implementing a VPAT process at scale will necessarily involve a phased approach. Some criteria that are important to consider when determining which assets need a VPAT include: (A) Products and services that are most sold to Federal Government agencies complying with Section 508 using VPAT in their procurement processes; (B) Products and services that are most sold to other Non-Federal Government customers using VPAT in their procurement processes (e.g. State Government agencies, etc.); (C) Products and services your company is offering in the market that are “flagship” or core; (D) Products or services your company may offer that could be subject to WCAG conformance to support your company’s own compliance efforts.
Q: In the VPAT® 2.0 Accessibility Conformance Report section of the template, is the approach to providing a conformance rating and writing remarks basically the same as for VPAT® 1.0, or are there material changes to the approach companies should take?
A: Generally speaking, yes. ITI, in the Essential Requirements and Best Practices, provides guidance on writing good remarks and explanations, including: information regarding the testing of the criteria; information on application dependencies to support accessibility; how customers can find more information on accessibility issues (e.g. support method, bug ID, etc.); and known workarounds for accessibility issues. In addition, Level Access advises clients to state the following (in order listed here) in remarks column: how the product meets the criteria; list of any exceptions to the product meeting criteria; support via equivalent facilitation; support when combined with compatible assistive technology; pointers to third party maintained/related information or pointers to additional information.
Q: Is it considered a best practice to include all components of a product such as its web application user interface, documentation and authoring tools into a single VPAT® 2.0 document, or should they be separated?
A: In general, it is a best practice to include the components of a product or service that are typically licensed or sold as a single item in a single VPAT. For example, if an authoring tool is always sold with another component that is runtime file viewer, the VPAT for the authoring tool should include the runtime file viewer component as well. For product documentation and support services, organizations sometimes provide a common site for accessibility documentation, common formats for documentation, and common support services. In this case, it is often a best practice to provide a separate VPAT for the product documentation and support services, and then provide consistent references to the support documentation and services from each product or service’s VPAT .
Q: Will the VPAT ever become mandatory?
A: Although originally intended as a tool to facilitate government market research on ICT with accessible features, the VPAT has come to be viewed by the wider procurement community as an accessibility standards conformance report.
Since VPAT® 2.0 incorporates not only the Section 508 Refresh provision, but also the EN 301 549 provisions and W3C ® WCAG 2.0 Success Criteria, the VPAT® 2.0 may likely become more prevalent throughout the technology industry. While this is the case, creation of VPATs is still a voluntary process; that is, technology product or services vendors can choose to use the format.
While VPATs are indeed voluntary statements, we advise that organizations understand the particular scenarios in which their customers or constituents may ask for a VPAT as part of a procurement, general inquiry regarding accessibility, or other business process.
Q: The US Access Board seemed to indicate they will not update the 508 standards when WCAG 2.1 comes out. Does this mean you’ll update the WCAG section of the VPAT but not the 508 section?
Participant Comment: (partial answer) The Access Board has the OPTION to refresh the 508 standards to refer to the WCAG 2.1, but updating or refreshing 508 is NOT automatic.
A: The Access Board has the option to refresh the 508 standards to refer to the WCAG 2.1, but updating or refreshing 508 is not automatic. We recommend you refer to the Access Board website and the ITI website for further information.
Q: When documenting conformance to Section 508 Support Documentation (602.3), do we have to do a completely separate VPAT to cover that as well as company websites where Support Documentation and Services are accessible?
A: For support documentation, for the chapter 6 of 508 Refresh, the provisions are about making sure that that documentation is accessible and meets the provisions of chapter 6. When you ask about company websites, I’m wondering if this is meaning the support documentation related to chapter 6, then you do report in chapter 6 on support mechanisms and support documentation. If that includes a way to deliver that or format, certainly that is included in chapter 6.
Q: How much detail do you need to go in to for the remarks section?
A: In conversations ITI had with the federal section 508 interagency group, one concern about VPATs generally – referring to the VPAT® 1.0 experience – was that was that they often were authored by what the group characterized as “good writers.” What they meant by that or implied by that is that individuals that perhaps were more on the sales side were very good at drafting responses that seemed to respond to a question or a particular aspect or subsection of 508 and didn’t necessarily get to the basic element of whether a feature was truly accessible and conformed to the particular requirement.
The VPAT remarks section is designed for vendors to provide further explanation or clarification regarding the level of conformance to that particular requirement. For example, if assistive technology was the bridge, so to speak, to rendering a product fully accessible for people with certain disabilities, the necessity of using AT would be clarified in the remark’s section. How much information you put in there is really a judgment call in terms of how you desire to position your VPAT® relative to the solicitation. On the other hand, on the other side of the negotiation, the government agency may expect certain types of information or levels of detail in the remarks column. ITI has not specified what level or degree of information a vendor must provide. You need to use your best judgment and provide information that will be responsive to the solicitation and enable you to be competitive. We have assumed that you have expertise on how to present your technology and exercise appropriate judgment accordingly.
Q: Assuming we met all of the essential requirements, can we otherwise reformat for company standards, font, color format? And WCAG for guideline or table. What about that?
A: ITI would urge vendors to use the VPAT format as is. Our goal is to create as consistent an experience as possible for purchasers and thereby remedy some of the criticism we have heard regarding how some vendors have used VPAT® 1.0. If every vendor decided that they would “customize” the VPAT according to internal schema, or even to extract the information generated through use of the VPAT format but then not call it a VPAT, for whatever reason, this would risk making it difficult for government acquisition officials to utilize product Accessibility Conformance Reports to conduct comparisons between offerings. For this reason, we strongly discourage “customization” or alteration of the template, and the resulting output. We also encourage government buyers to request conventional VPAT ACRs.