II. Accessibility as a Sound IRM Practice
A. Adopting Accessibility as a Sound IRM Practice
Identifying how the functions of an organization and the activities of its people can be augmented by electronic information tools has become an important responsibility for managers and information resource planners. Responding to these needs ensures that the information tools acquired will advance agency missions and the information proficiency levels of its workforce. For people whose disabling condition(s) make them more reliant upon information resources, responsiveness to their needs ensures that their skills are effectively utilized by the organization. Pub.L. 102-569, Section 508 (see Appendix F) addresses this mission level requirement. The intent of the law is to:
- Ensure that people with disabilities can access and use the same data bases and application programs as other people;
- Ensure that people with disabilities shall be supported in manipulating data and related information resources to attain equivalent end results as other people;
- Ensure that when electronic office equipment is part of a telecommunications system, that people with disabilities can transmit and receive messages in a manner that supports their disabilityrelated needs and provides the capability to communicate with other users of the system.
Pub.L. 100-542 (see Appendix F) serves to reinforce and make more explicit agency responsibilities to ensure telecommunications access to current and future services by people with hearing or speech impairments. In response to the requirements of this law, GSA also established the Federal Information Relay Service (FIRS) to accommodate the communication needs between users of Telecommunications Device for the Deaf (TDD) and users with access to standard telephones only (see Appendix D). Federal offices equipped with both telephones and TDDs are able to initiate and receive TDD calls independent of FIRS. The U.S. Government TDD directory and new building signage identifying public use TDDs (Appendix D) represent two additional statutorybased activities designed to ensure that deaf and hearing people have access to the tools they need to communicate with one another.
The Federal Information Resource Management Regulation (FIRMR) (Appendix G), and related FIRMR Bulletins C8 and C10 (Appendix H) implement Pub.L. 102-569 and Pub.L. 100542. The electronic equipment and telecommunications systems referred to in these statutes are equivalent to the Federal Information Processing (FIP) resources defined in the FIRMR. The FIRMR requires that agencies provide FIP resource accessibility to individuals with disabilities. Accessibility to FIP resources is achieved by the acquisition and application of information technology that readily accommodates the functional limitations of people with disabilities. The agency designated senior official (DSO) is primarily responsible for ensuring FIP resource accessibility. GSA has instituted a procedure to advise agencies to follow its accessibility regulations when granting delegations of procurement authority for information technology resources. GSA's procurement management review program also targets agency compliance with accessibility regulations as a review subject.
Accessibility is becoming integral to IRM, in a manner similar to security planning. Examples of activities include: incorporating access requirements into internal IRM policies and the 5Year IRM Plan, developing agency procurement vehicles that include accessibility, integrating accessibility practices into enduser support services, and hosting accessible technology fairs.
As the establishment of accessible information environments becomes an important agency goal, IRM provides agencies with a tool to: 1) recruit the most qualified applicants, 2) better utilize the skills of current employees, and 3) improve the delivery of information services to all citizens. This approach ensures that people with disabilities receive equivalent and integrated information services, equipment, training, and technical support as people without disabilities. It also ensures that citizens with disabilities will be able to access automated public information services that are being developed by agencies. Today, people become "handicapped" primarily by environments that are unresponsive and inflexible to their needs and not by their differing levels of vision, hearing, or mobility functioning.
B. Establishing Accessibility Support Services
User support centers and other technical support services are broadening their functions to include accessibility. The goal is to ensure full access, integration, and continuity of support to people with disabilities using information resources. This includes both employees and citizens. Individual(s) responsible for these support services may want to consider the following activities when integrating access into their support programs:
Listen to User Needs
Assess Needs Conduct a survey to determine unmet needs of agency personnel who could benefit from accommodation tools. Consider several means of contacting users including IRM newsletters and questionnaires on electronic bulletin boards. Avoid undue emphasis on disability identification which may inadvertently exclude users such as those with agerelated vision problems who could benefit from screen magnification. Inventory Accommodation Tools Develop and maintain an inventory of accommodation products and techniques being used by employees with disabilities. Accommodation tools used to provide public access to information resources should also be identified. An inventory is a useful starting point for determining needs when upgrading existing hardware or software or preparing to procure a new system.
Know the Technology
Develop Access Skills Spend time with current users of accommodation tools and learn their techniques. Visit and network with technical counterparts in other agencies who are providing accommodation services. Participate in access training and conferences. Become familiar with popular access hardware and software configurations, skills and documentation needed for troubleshooting with users.
Develop Industry Resources Become familiar with resources for product information or demonstration of computer and telecommunications access products (Appendices C, D, and E). When visiting information technology shows, inquire how accessibility has been provided within the products, systems, and services.
Show the Way
Advertise Access Highlight new accessibility services available through IRM and agency publications and electronic communication resources.
Conduct Consultations Assist managers and employees to identify needed tools and sources of supply. Use integrated requirements contracts that include accessibility when available.
Demonstrate Technology Include accommodation technology in agency sponsored technology shows to increase agency awareness of the tools readily available for providing accessibility. Purchase representative examples of common accommodation solutions for demonstration in the agency's user support center.
Cultivate Integration and Innovation
Participate in Procurement Assist procurement teams by providing the accommodation skills needed to address accessibility requirements in agency Requests for Proposals (RFPs). Invite participation by a knowledgeable person with a disability to the procurement review team that reads RFPs prior to their release. Accessibility related items that others may overlook may be more easily identified by a review team member who has a disability (Appendices A and B).
Beta Testing When beta testing a technical solution, either hardware or software, include people with disabilities on the test team. People using accommodation equipment to access the system may find small problems and areas of concern prior to other users since they are interfacing with the system differently.
Automate Information Services Provide assistance during planning and installation of agency systems that help direct or handle incoming phone calls. This will ensure that the systems can be effectively used by employees and citizens with disabilities. Deaf individuals can be readily accommodated by ensuring that recorded spoken information is also provided in text form in a manner accessible by a TDD.
GSA's Clearinghouse on Computer Accommodation (COCA) provides assistance to agencies in all aspects of accessibility management, from demonstration of enhancement capabilities in their demonstration center to briefings that assist agencies establish their own support capabilities. COCA also hosts meetings with agency counterparts and conducts workshops. Appendix C provides a listing of other Federal government resources.
C. Acquisition Planning for Accessibility
In the past, few resources were available to managers who felt unprepared to respond to information access needs reported by employees with disabilities. Although costeffective enhancements to meet most access requirements were available, their existence was not well known and utilization was poor. Today, IRM is responding to the need to ensure that people with disabilities have equal opportunities to access and become proficient users of information resources. The responsibility is outlined in the FIRMR (Appendix G). The IRM commitment to action is being expressed primarily through the establishment of internal policy, access support services, and procurement vehicles to ensure integrated access.
Integrated procurement that include accessibility products and services represent the most desired approach for ensuring the full access, integration, and continuity of support required by agencies and the employees they are accommodating. As strategies for acquiring information technology increasingly emphasize the need for software and hardware portability, interoperability, and off the shelf availability, access products provide real examples of these qualities and the benefits obtained.
Throughout an acquisition, beginning with the needs assessment and requirements analysis, the accommodation needs of people with disabilities should be addressed. Functional specifications for alternative input and output capabilities need to be developed. If available, an inventory of current accommodation equipment being used in the agency would facilitate this process. The functional specifications developed should enable the vendors to decide how to best provide the capabilities needed. There are many combinations of commercially available hardware, firmware, and software that can be proposed by the prospective vendors. Using this process of functional specification, the needs of most current and future employees can be effectively met through the specific indefinite quantity and indefinite delivery line item offerings of the contract. Any "technology refreshment" clauses in integrated procurement should be inclusive of accommodation products and services. In this manner, integrated contracts can be readily responsive to the majority of current and anticipated accommodation needs. When an individual's needs cannot be effectively met by the products offered on the contract, the individual should have the opportunity to waive the line item product(s) offered and purchase the product(s) needed through the multiple schedule award or open market. In preparation for supporting an individual in this situation, a contract provision should be included to obtain consultation services to identify and implement an appropriate accommodation. IRM commitment to the integrated approach outlined above will ensure that the accessibility, tools, technical support, and training needs of current and prospective employees with disabilities will be accommodated in the new information environment being planned.
Acquiring access tools for an individual must be done in a timely manner. If the agency has implemented an integrated contract that includes accommodation products and services, the individual should participate in the decision concerning which specific items offered through the contract should be ordered to meet their needs. If there is a functional reason why only one specific product can be used and it is not available through an agency contract, a specific make or model justification is needed for the procurement. Even though there may be several accommodation solutions that are generically the same, such as large print display software or hardware, the small differences in the various products can be extremely important to the individual. Many of the accommodation specific products available are being offered through multiple distributors. Calling the product manufacturer directly may be the easiest way to determine the vendors servicing each specific geographical area. Determining several distributors of a product will be helpful in obtaining several price quotations on the item. Different distributors may also offer different levels of service for the same product. In a few cases, a specific item may be available only from the manufacturer. It is then necessary to write a justification for the sole source procurement just as it would be for a nonaccommodation item. There are several accommodation products listed on the GSA Multiple Awards Schedules. In many agencies, it is a simpler process to purchase items from the Multiple Awards Schedule. Many of the accommodation vendors are also 8(a) vendors or qualify as a Small or Disadvantaged Business.
This process of identification and provision of tools should be repeated whenever specific needs change. These needs may arise due to new job responsibilities, a change in the condition necessitating an accommodation, or a change in the technology available. If accommodation products are being acquired to augment an existing workstation, or the workstation is being purchased through a different vendor than the accommodation vendor, there are technical considerations that should be reviewed prior to making the purchase. This is true also if several different accommodation products are being purchased to function together on the same workstation. Appendix A contains specific technical considerations that need to be taken into account prior to acquiring accommodation products.
Additional Considerations
Training, documentation, and maintenance needs must also be taken into consideration. Appropriate training and documentation contributes significantly to the user's productivity with the new products.
Training
Training may be as simple as having the vendor install the equipment and showing the enduser and their onsite support personnel how to use the equipment, or how to get started in the tutorial if one is provided. More indepth training may also be required depending on the nature of both the application systems and the accommodation solution being used. During the acquisition planning stage, it should be determined if any training is included in the purchase price, and if that alone will be sufficient or if additional training will be needed. The training considerations included in Section III may be helpful. In integrated contracts including accessibility, the training needs of users with disabilities should be fully incorporated into the overall training plan. Additional training line items may be required to provide for training specific to the accommodation products being used. In addition, the integrated contract should be clear that physical access to the training facility is also a requirement.
Documentation
Providing accessible documentation may include providing documentation in braille, large print, cassette tape, or on diskette. During the acquisition planning process it may be possible to determine the preference of the individual if the acquisition is for an individual or a specific group of individuals. In integrated contracts including accessibility, the documentation needs of people with disabilities should be fully incorporated with the overall documentation requirements. A clause may be included to require the vendor to furnish documentation in the appropriate accessible format upon request. The agency may want to require all vendors replying to the specific request for proposal to submit samples of their accessible documentation. Rather than requiring potential vendors to provide all forms of documentation, some agencies have been asking only for documentation on an ASCII disk. The benefit of requiring documentation in ASCII format is that it can then be readily converted into braille or large print as needed in a minimum amount of time for a reasonable cost. There are several service providers and organizations that specialize in producing braille and/or large print documents. By starting with an ASCII disk rather than printed material that needs to be transcribed, agencies realize a significant savings on alternative format production costs. A combination of document formats may also be preferred in some cases. For example, some braille users may want only the introductory sections of documentation and any tables of frequently used commands produced in braille and the remainder of the documentation available on diskette.
Maintenance
Maintenance of the accommodation products is often forgotten until a product fails. As with the other considerations, maintenance needs to be thought of during the acquisition process, rather than as an afterthought. For many individuals using accommodation products, the entire system becomes unusable to them if their accommodation product fails. Additionally, the individual may be the only person in their area using a specific product so that sharing of resources may not be a viable alternative as it often is for nonaccommodation equipment. What type of maintenance agreement is needed may depend on the nature of the job responsibilities the individual has, the location of the equipment, the number of other individuals in the area using similar equipment, and the vendor responsiveness when repairs are needed. In some cases, onsite maintenance may be preferred while in other situations it may be preferable to send the equipment to the vendor for repair. If accommodation equipment is being used for a critical function within the group, purchasing backup equipment may be an option to consider. Integrated contracts including several levels of maintenance services such as: 1) 4 hour response, onsite, 2) 24 hour repair or replace, onsite, and 3) 48 hour return, depot maintenance, should offer the same options for accommodation products.
or go on to section 3
COCA Handbook Section 2 / modified September 2, 1994