To: - California State University, Bakersfield · Web viewCALIFORNIA STATE UNIVERSITY...

CALIFORNIA STATE UNIVERSITY BAKERSFIELD

Accessible Electronic and Information TechnologyProcurement Plan

(Accessible Technology Initiative)

1 CSUB ATI Procurement Plan 8/10/07

CSUB Accessible Electronic and Information Technology Procurement Plan

IntroductionThe technical standards of Section 508 provide criteria specific to Electronic & Information Technology (E&IT) acquisitions. E&IT includes information technology and any equipment or interconnected system or subsystem of equipment that is used in the creation, conversion, or duplication of data or information. The term E&IT includes, but is not limited to, computers, software, telecommunications products (such as telephones), information kiosks and transaction machines, World Wide Web sites, multimedia, and office equipment such as copiers and fax machines. The term does not include any equipment that contains embedded information technology that is used as an integral part of the product, but the principal function of which is not the acquisition, storage, manipulation, management, movement, control, display, switching, interchange, transmission, or reception of data or information. For example, HVAC (heating, ventilation, and air conditioning) equipment such as thermostats or temperature control devices, and medical equipment where information technology is integral to its operation, but are not considered to be E&IT type of products that fall under Section 508 requirements.

California Government Code Section 11135 requires the CSU to purchase E&IT products and services that conform to the requirements of Section 508 of the Rehabilitation Act of 1973, as amended. It is important to note that the CSU academic mission strongly embraces support for individuals with disabilities. In December 2004, the CSU Board of Trustees issued a policy on “Disability Support and Accommodations – Executive Order (EO) 926.” The policy charged the CSU to “document and make explicit the system- wide policies for the disability support and accommodation program and to engender monitoring and full compliance with all of the disability support and accommodations elements noted herein.”

StrategyIt will be a challenge for CSU, Bakersfield (CSUB) to meet the aggressive timeline set out by the Accessible Technology Initiative (ATI), but the campus recognizes it must do so to comply with federal and state laws. CSUB recognizes, however, that our real goal is assuring all E&IT procurements account for evaluation and consideration of accessibility for those with disabilities. In this regard, CSUB will continue to be a leader in the system, as we have consistently demonstrated in our current instructional and informational technology methods of procurement.

Teams have been, or will be, created to address the priorities outlined in this Procurement Plan. A steering committee reporting to the Cabinet, and the President, will coordinate efforts to assure that the required policies, procedures, and internal audits are in place. It is important to remember that CSUB already has expertise and resources in place to assist with the implementation of this ATI Procurement Plan. (e.g., faculty and other staff who are currently working with Services for Students with Disabilities, such as Information Technology Services, and others to provide accessible E&IT materials)

CSUB must incorporate Section 508 standards as it develops or acquires new E&IT resources if such are commercially available, and their purchase does not result in an undue burden or fundamental alteration. Thus, this Procurement Plan includes guidelines for research, evaluation,



documentation, and verification, where appropriate, and determination of exemptions and/or exceptions related to E&IT procurement of goods and services.

The CSUB ATI Procurement Plan also identifies various roles and responsibilities of those who will be associated with the implementation process. As you go through this Procurement Plan, you will see mention of two key roles, (1) the Designated Section 508 Compliance Officer, and (2) the Designated E&IT Technician. Please note, these key roles may, in the future, be designated to an individual, or group of individuals, who will then be responsible for the requirements associated with those roles.

Ultimately, successful implementation of the CSUB ATI Procurement Plan will need to be a campus-wide collaborative effort which will include administrators, faculty, support staff, and students. Once implemented, this plan will be reviewed, updated, and revised at least once every six-months until such time as all deadlines have been met.

There are seven (7) components of this plan and they are as follows: Component 1: Research, Evaluation, Documentation, Verification Where

Appropriate, and Determination of Exceptions Related to E&IT.

Component 2: Process for Determining Undue Burden and Fundamental Alteration Sections 508 Defines Undue Burden as a Product that Causes “Significant Difficulty or Expense” to the Organization.

Component 3: Procedures for Providing Equally Effective Alternative Access for EI&T Acquisitions that are Approved for Exceptions or that are Not Yet Subject to the E&IT Accessibility Procurement Process.

Component 4: A Communication Process and Training Plan to Educate the Campus Community about Section 508 Procurement Requirements and the Established Procedures.

Component 5: An Evaluation Process to Measure the Effectiveness of the Plan.

Component 6: The Identification of Roles and Responsibilities Associated with the Above Process.

Component 7: Milestones and timelines that conform to dates required by Coded Memo AA-2007-04 and Coded Memo AA-2007-13.

Component 8: CSUB – ITSS Current Implementation Strategy and Listing of 508 Compliant Products Used On Campus

ATI Procurement Process Flowchart

As you read through each component of this ATI Procurement Plan, please keep in mind that this is an initial plan for implementation. And, components, or certain items within each component, may either need to be added onto, or revised in the future. However, any and all revisions, or modifications, made in the future must be made in accordance with Section 508 guidelines, and in accordance with Government Code 11135, and CSU Executive Order 926.



Component 1: Research, Evaluation, Documentation, Verification Where Appropriate, and Determination of Exceptions Related to E&IT.

I) Core Functions of ATI Section 508 Procurement : Create functional requirements for purchasing a product. Conduct market research to determine the availability of a product to meet the functional

requirements. Evaluate products to determine the degree of compliance with Section 508 requirements

and identifying the one that best meets these requirements. Verify Section 508 actions and authorize exemptions, if any. Require all vendors to submit Section 508 compliance documentation (e.g., a completed

VPAT or vendor checklist). Document Section 508 accessibility evaluations and conclusion.

II) Outline of Procurement Process :The requirements of applicable laws and regulations for the acquisition of goods and services by the CSU are defined within the CSU Policy Manual for Contracting and Procurement ( http://www.calstate.edu/CSP/crl/policy/policy04-02-07.doc). These CSU policies and procedures will be updated to include the requirements for the acquisition of E&IT products. Formal Competitive Procurements - E&IT procurements that are subject to formal

competition requirements will require the Requestor to conduct market research with regard to the commercial availability of accessible products. This information will be used to develop formal solicitation documents, which will require vendors to submit Section 508 compliance documentation. The Requestor and the designated Campus Section 508 Compliance Officer, with assistance from the Buyer, will determine the information that firms will be required to submit to document the degree of compliance with Section 508 requirements and the criteria and its relative weighting that will be used to evaluate the documents submitted. Section 508 standards constitute an additional set of requirements to be evaluated and will be considered among all other procurement requirements in reaching an award decision. All other requirements are still relevant and will be evaluated as well. CSUB will then purchase the commercial product that provides the greatest degree of compliance while still satisfying other legal, policy and functional requirements.

Procurements Below the Formal Competitive Threshold – These E&IT procurements require the Requestor to perform market research with assistance, as needed, from the designated E&IT Technician and designated Section 508 Compliance Officer. Once conforming E&IT products have been identified, or an exemption has been approved, the Requestor will submit the Section 508 documentation along with a Purchase Requisition Form to the Buyer to complete the purchase in accordance with applicable procurement policies and procedures. Based on the results of the market research conducted, or the proposals that are evaluated, the E&IT products will fall within one of the following categories:


http://www.calstate.edu/CSP/crl/policy/policy04-02-07.doc


a. All products that meet the functional requirements are 508 conformant (meets all the applicable standards): The Buyer may then purchase any of the products evaluated in accordance with applicable procurement policies and procedures.

b. The products evaluated meet Section 508 requirements to varying degrees: (Note: The schedule for the implementation of E&IT acquisitions equal to or below $50,000 is scheduled for no later than September 1, 2008. The policies and procedures that govern these acquisitions have not yet been finalized.) Nonetheless, these policies and procedures will require that Section 508 standards and all other applicable procurement laws and regulations be followed in determining which E&IT product will be procured.

c. Product previously purchased and is still conformant: The E&IT product was previously determined to be conformant and there is no reason to believe that the status has changed. The Buyer may purchase the product in accordance with applicable procurement policies and procedures.

d. Approved Exemption: The E&IT product falls within one of the exemptions (see “Exemptions” below that have been approved.) The Buyer may purchase the product in accordance with applicable procurement policies and procedures.

III) Exemptions: Net Cost Increase Exemption: The CSU has a specific exemptions based in

California's Government Code Section 11135(c)(2). This Government Code section states: "... In clarifying that the California State University is subject to paragraph (2) of subdivision (d), it is not the intention of the Legislature to increase the cost of developing or procuring electronic and information technology. The California State University shall, however, in determining the cost of developing or procuring electronic or information technology, consider whether technology that meets the standards applicable pursuant to paragraph (2) of subdivision (d) will reduce the long-term cost incurred by the California State University in providing access or accommodations to future users of this technology who are persons with disabilities, as required by existing law, including this section, Title II of the Americans with Disabilities Act of 1990 (42 U.S.C. Sec.12101 and following), and Section 504 of the Rehabilitation Act of 1973 (29 U.S.C. Sec.794)." This section of the Gov. Code exempts the CSU from Section 508 requirements if it can be determined that in the procurement of accessible E&IT product will increase the cost to the CSU. Note: CSU Procurement policies and procedures incorporating Section 508 requirements, including Gov. Code Section 11135 (c)(2) exemption, are in the process of development and are not yet finalized. These policies and procedures will incorporate the following guidelines:a. Research - Conduct cost analysis to determine the net cost to the campus in

procuring a product that conforms to Section 508 standards.b. Evaluation - Evaluation of the cost analysis must factor in the long-term reduction

in cost incurred by CSUB in providing access or accommodations to future users of this technology who are persons with disabilities.

c. Documentation – Cost analysis and supporting documentation



d. Verification - Cost analysis should also be review by other appropriate departments with insight to the cost elements contained within the cost analysis – such as Human Resources and Accounting.

e. Determination – The Requestor, the designated E&IT Technician, Buyer, and designated 508 Compliance Officer shall be included in the process to determine that the proof of an increase of expense to CSUB is justifiable and supportable.

Commercial Non-Availability Exemption: When acquiring E&IT products or services CSUB is only required to comply with those standards that can be met with E&IT products that are available in the commercial marketplace in time to meet delivery requirements. CSUB need not acquire a noncommercial item in these cases solely to satisfy 508 standards. Commercial non-availability must be addressed on an individual standard basis, and CSUB cannot claim a commercial product as a whole is non-available just because it does not meet all the applicable standards. In such cases CSUB shall follow applicable procurement policies and procedures to purchase the product that best meets 508 standards or best value criteria.a. Research - Conduct market research and product evaluation.b. Evaluation - Review the viability of using alternative accessible products.c. Documentation - Maintain documentation of products evaluated.d. Verification - Requestor should review market research with designated E&IT

Technician.e. Determination - Requestor and designated 508 Compliance Officer review

documentation.

Sole Brand Exemption: A sole brand is when only one product meets the functional specification required. A sole brand product should first be reviewed and approved in accordance with procurement policy and procedure for sole brand requests. An approved sole brand product is exempt from Section 508 requirements.a. Research - Conduct market research and product evaluation.b. Evaluation - Review the viability of using alternative accessible products.c. Documentation - Maintain documentation of products evaluated.d. Sole Brand Justification Form – Prepare Sole Brand Justification Form and

forward to designated 508 Compliance Officer for review.

Back Office Exemption: This pertains to a group of products that reside in either a telecommunication closet or data center. The products do not interact with people except when maintenance is required. An example is a server in a data center. If the server simply operates without human interaction, then the server qualifies as a back office exemption. If there is software running on the server that does have human interaction (e.g., Oracle), then the software is not exempt.a. Research - Determine location and function of product.b. Evaluation - Review possibility of interaction of product by CSUB personnel.c. Documentation - Product functional requirements/specifications.d. Verification - Requestor only.e. Determination - Requestor and designated 508 Compliance Officer review

documentation.



Fundamental Alteration Exemption: This exemption to Section 508 requirements is discussed in Component 2 below.

Undue Burden Exemption: This exemption to Section 508 requirements is discussed in Component 2 below.

Other Exemptions: In addition to the exemptions above, Section 508 provides for other types of exemptions that may be granted. Request for exemptions will be reviewed on a case-by-case basis and will be approved by the designated campus 508 Compliance Officer.

Component 2: Process for Determining Undue Burden and Fundamental Alteration Sections 508 Defines Undue Burden as a Product that Causes “Significant Difficulty or Expense” to the Organization.

I) Process for Determining Undue Burden :When determining if a product qualifies for an undue burden, the campus must consider the resources available to the program or component for which the product is being developed, procured, maintained, or used. Considerations should include the functionality needed from the product and the technical difficulty involved in making the product accessible. In addition, other considerations include compatibility with the campus or CSU infrastructure, including security, and any foreseen difficulty of integrating the product.

When an E&IT product or service qualifies as a potential undue burden, the requesting department, in coordination with the CSUB Office of Procurement must submit a request along with the Purchase Requisition documentation to the campus’s designated E&IT Technician and the designated Section 508 Compliance Officer for review and recommendation. The components of an Undue Burden request include: a. Description of the product and its function.b. Description of the undue burden, specifically: Applicable technical provisions of the

Section 508 standards; Specific provisions that cannot be met as a result of undue burden; All funds available for the purchase including the component for which the product or service is being acquired.

c. Estimated cost of acquiring a product that meets the applicable technical provisions along with an explanation of how costs were estimated.

d. Market research performed to locate items that meet the applicable technical provisions.e. Proposed method of alternate access and its estimated cost.f. Time schedule on when it will no longer be an undue burden to the organization; i.e.

product will be conformant.g. Resubmission of undue burden request every two years until the product is conformant.

The designated E&IT Technician and the designated Section 508 Compliance Officer will forward the undue burden request, along with their recommendation, to the campus President, or his designee. The campus President, or his designee, will have the final authority to approve or disapprove the undue burden request.



A copy of the final determination of the undue burden request shall be retained by the designated Section 508 Compliance Officer and also included in the Procurement file. The designated Section 508 Compliance Officer shall make these records available upon request.

Important Note: If an undue burden is approved, it is important to note that statutory obligations require that CSUB must provide alternative access, if necessary.

II) Process for Determining Fundamental Alteration :CSUB is not required to make changes in the fundamental characteristics of a product to comply with Section 508 accessibility standards. This does not apply to cosmetic or aesthetic changes. One example of fundamental alteration is pocket-size pagers. Adding a larger display to a small pager may fundamentally alter the device by significantly changing its size to such an extent that it no longer meets the purpose for which it was intended. Adding accessibility features would not generally be considered a fundamental alteration, if it did not have any significant effect on the standard mode of operation or its size or weight. As a general rule, fundamental alteration had been applied to hand-held devices.

However, technology in this area is rapidly revolving and an exemption granted for one procurement should not be automatically extended to future procurements. Many hand-held devices that were once exempt due to non-accessibility features are now accessible. As a result, the Requestor and designated 508 Compliance Officer must be cognizant of the technology in this field to ensure that the exemption is valid. The determination of fundamental alterations includes the following steps: a. Research - Determine the functional requirements and the specific need for the E&IT

product.b. Evaluation - Review the accessibility of the product and the impact of the accessible

product to the functional requirements.c. Documentation - Vendor product documentation.d. Verification - Requestor Only.e. Determination - Technician and 508 Compliance Officer review documentation.

Component 3: Procedures for Providing Equally Effective Alternative Access for EI&T Acquisitions that are Approved for Exceptions or that are Not Yet Subject to the E&IT Accessibility Procurement Process.

Human Resources, Services for Students with Disabilities and the designated Section 508 Compliance Officer will develop a plan for alternate access methods for persons who require such access. The plan will include:

A communications process with contact information for the articulation of access needs and accessibility issues from student, members of the public and employees with disabilities.

Protocol around 504/ADA accommodations including the process for providing access to E&IT resources.

The responsibilities of the department (that has the inaccessible technology) in providing access to either the technology or to the information resources provided by that technology (i.e. web application).

A process for filing a complaint regarding accessibility.



A feedback mechanism to evaluate the effectiveness of the solutions

When E&IT acquisitions are approved for exception, or are not yet subject to the E&IT accessible procurement process, the Requestor is responsible for notifying the designated Section 508 Compliance Officer that such a product was procured. The designated Section 508 Compliance Officer and Requestor in consultation with the appropriate offices will assess the potential impact on students, employees, and members of the public. For every exempted acquisition that is not for one person’s use, the requestor needs to articulate the process for how access will be provided to individuals with disabilities.

Component 4: A Communication Process and Training Plan to Educate the Campus Community About Section 508 Procurement Requirements and the Established Procedures.

I) Communication Process and Training :Communications is the methodology to explain or educate the campus on what Section 508 is, answer questions and address concerns. General Communications on Section 508 Overall:

a. Publish weekly, or monthly, or quarterly, articles on the campus web-page that include Section 508 issues.

b. Establish a Section 508 web-site that provides information and allows discussions of current issues.

c. Conduct a discussion forum so that people can interact and ask questions.d. Establish an e-mail address for questions and comments.

Communications for Specific Implementation Phases:a. Conduct seminars in the areas of most interest and confusion (e.g., PC labs, disability

labs, advocacy groups, etc.).b. Use the campus’s main web-site to communicate to keep CSUB community up to

date on the progress of ATI implementation.c. Conduct general seminars or town meetings to explain the overall impact of the

phase on the CSUB community.d. Send emails from the President to the CSUB community to explain the impending

process and how it will impact their areas of responsibility. The letter should provide time and dates of training and encourage the individuals to attend due to the importance of the process on the way they do business.

e. Send campus-wide email in advance of trainings to remind individuals to attend scheduled trainings.

Discussion Forums:a. Hold campus-wide discussion forums throughout the planning and implementation

process.b. Use this forum of communication to provide stakeholders with a role in the creation

and development of the ATI process.c. Some possible topics for discussion during the communication process:

What are Sections 504 and 508? How does Section 504 affect me, the individual?



How does Section 508 affect me, the individual? What is the schedule for implementing Section 508? What is the procurement process during the development process? What should CSUB do to avoid lawsuits, adverse actions and negative media

until the program is completely implemented? What are exemptions? Explain the rationale why that even after Section 508 is

implemented, products might not be conformant. Who will be affected by the Section 508? How?

Training Process:a. Training is the methodology to explain to or educate all individuals involved with the

Section 508 process.b. Some of the options for individuals to be trained are:

Overall Training:a. Designated Section 508 Compliance Officers Training:

i. Comprehensive block on the 508 Compliance Officer’s roles and responsibilities.

ii. Available resources and support sources.iii. The secrets on how to be a 508 Compliance Officer and what to

expect.iv. Better understanding of the law and exemptions.v. Discussion on his/her concerns and issues and possible solutions for

those concerns and issues.

b. Buyer Training (Procurement Office):i. Comprehensive training block on Section 508.

ii. Better understanding of the law and how it impacts procurement.iii. Buyer’s role and responsibilities in support of Section 508

compliance.c. Designated E&IT Technician Training (Relevant Departmental Offices):

i. Section 508 technical standards training.ii. How to know whether a standard has been met.

iii. Evaluating conformance.iv. Accessibility testing protocol.v. Technician’s role in the procurement process.

Training for Each Implementation:a. Requestors Training:

i. Requestor’s roles and responsibilities.ii. Available resources and support sources.

iii. Discussion on his/her concerns and issues and possible solutions for them.

b. Buyers, Requestors, Section 508 Compliance Officer(s) and Technicians:i. Training on Section 508 law and the overall process.

ii. How to process an E&IT Purchase Request, checklists and overall procedures review.



iii. How to conduct market research and how to evaluate the vendor documentation.

iv. Roles and responsibilities of others in the process.c. Designated Information Technology Services Training and Training for

Offices that will be Directly Affected by Section 508:ii. Overview on Section 508 compliance requirements.

iii. Implementation schedule review and how that schedule will affect others.

iv. The roles and responsibilities that campus upper management will have in the process (e.g., selection of Section 508 Compliance Officer(s), technical assistance, public support of the program, etc.)

d. Specialty Groups Training (Included are members such as students, faculty, staff and contractors):

i. Overview on Section 508 compliance requirements.ii. The Section 508 process tailored specifically to the specific audience.

iii. Roles and responsibilities of each group.iv. Implementation schedule overview.

Component 5: An Evaluation Process to Measure the Effectiveness of the Plan

I) Evaluation Goal :The goal is for 100% of acquisition requests to comply with Section 508 requirements. This goal is to be met by enforcing the process outlined in Component 1, above.

II) Components of Goal : Market Research: Review and verification of vendor product information. Section 508 Compliance Documentation: Review and verify conformance of the

product against vendor documentation. For large scale purchases, verification will also come from the completed testing protocol signed by the one charged with conducting conformance testing of the product.

Exemptions: As verified by the designated Section 508 Compliance Officer and appropriate approval signature(s).

Buyer Purchased E&IT Products as Outlined by the Section 508 Law: Verified through random sampling of purchase orders/contracts.

III) Evaluation Methodology :A self-check is to be performed by randomly selecting and reviewing a sample of E&IT acquisitions at least twice a year. The review will verify that the proper Section 508 documentation has been completed and included in the procurement files. Evaluation Criteria:

a. Requestor has conducted market research and an evaluation of the E&IT product for Section 508 standards conformance.

b. Buyer is only accepting E&IT Purchase Requests that have the proper Section 508 documentation.

c. E&IT products procured meet the requirements as outlined by the Section 508 law.



d. Measurement of effectiveness: The percentage of E&IT purchases on file with the proper documentation. Goal is 100%.

Component 6: The Identification of Roles and Responsibilities Associated with the Above Process

I) Responsibilities associated with the following roles are listed below: Requestor: This is the individual who is requesting the acquisition of an E&IT product

or service, and:a. Develops functional requirements for the requested products or services.b. Conducts market research to identify sources that meet the functional requirements.c. Determines which accessibility subcategories are applicable for the product.d. Evaluates the vendor responses to Section 508 compliance.e. Verifies Section 508 compliance information to be submitted.f. Provides Section 508 documentation for the acquisition file.g. Obtains designated Section 508 Compliance Officer review and approval (if

necessary) of Section 508 compliance determination.h. Provides the Purchase Request along with the approved Section 508 documentation

to the Buyer.i. Creates accurate and supportable functional requirements.j. Conducts in depth, accurate and complete market research and evaluation of vendor

Section 508 documentation.k. Participates in formal competition acquisitions by providing necessary information to

help develop formal solicitation documents that include criteria to evaluate product conformance and evaluation of the proposals.

l. Informs department responsible for Section 504 compliance, (Services for Students with Disabilities), on requirements for alternate access.

Designated Section 508 Compliance Officer: This is the person who:a. Assists staff, faculty, students, the public and other outside sources with Section 508

issues or questions.b. Assists Requestor in the review of E&IT Section 508 compliance documentation.c. Evaluates and in some instances approves exemption requests.d. Creates comprehensive ATI Section 508 program.e. Promotes the importance of Section 508 efforts.f. Oversees Section 508 training and communications.g. Assists with the resolution of non-conformant procurements and contractor product

problem and works to create win-win solutions.h. Ensures consistent implementation of Section 508 programs.i. Acts as liaison on Section 508 matters with campus’s executive management.j. Works with CSUB’s Services for Students with Disabilities Office on issues,

especially E&IT reasonable accommodation problems.k. Works with all relevant offices on campus to address accessibility issues for

students, employees and members of the public.

Recommended traits of a 508 Compliance Officer:



a. Recognized skill as a project manager, or organizer, or administrator.b. Does not have to be a Technician, but must have access to them.c. Must have appropriate delegated authority and management support.d. Must have a good grasp of Section 508 law and must also understand Section 504

law.e. Must understand CSUB and CSU policy, procedures and constraints.f. Must have access to Information Technology resources and/or be involved in

Information Technology planning and implementation meetings (to ensure Section 508 is considered in E&IT projects and procurements)

g. Should have a strong working relationship with the CSUB Services for Students with Disabilities Office, Campus Office of Procurement, CSU Office of General Counsel, Business & Administrative Services Office, the Cabinet, the Campus President, the Budget Office, Academic Affairs, and all other campus offices and departments, as applicable.

Buyer:a. This individual is responsible for the actual procurement of the E&IT product or

service.b. With respect to the ATI Section 508 requirements, the Buyer is responsible for

reviewing the ATI documentation to verify the proper approval has been obtained and the proper documentation has been submitted to be included into the procurement file.

c. Processes properly documented E&IT Purchase Requests.d. In regards to “c” above, considers only vendors for the acquisition who have

complied with Section 508 documentation requirements, as applicable.e. Purchases product per the market research and according to CSU policies and

procedures.f. Ensures that Section 508 requirements are contained in contracts awarded.

Designated E&IT Technician:a. The Designated E&IT Technician provides the interface between Section 508

requirements and technical specifications.b. The Designated E&IT Technician may perform in a general capacity such as

strategic planning of E&IT requirements or as a specialist such as in the evaluation of a particular E&IT product.

c. Technicians in the various areas of E&IT specialty may be assigned on an as needed basis or on a permanent basis to assist with Section 508 issues.

d. Assists Requestors with functional requirements and market research.e. Assists Requestors with evaluating vendor Section 508 documentation.f. Evaluates products with the Designated Section 508 Compliance Officer to

determine the technical credibility of an exemption.g. Works with the Buyer on technical questions and issues during the E&IT acquisition

process.h. Participates, as the Section 508 technical representative, in strategic planning of

campus E&IT requirements (e.g., software development, training, etc.).



i. Participates as the technical source in the resolution of accessibility issues of students, faculty, staff and the public.

j. Advises the Designated Section 508 Compliance Officer on technical matters as they relate to accessibility issues.

Recommended traits of the Designated E&IT Technician:a. Must be knowledgeable of the E&IT area and functions.b. Experience in E&IT products (e.g., PCs, data center devices, printers).c. Experience in E&IT development (to help with contractor contracts).d. Experience with and interest in accessibility products.e. Experience in assistive technology products and tools.f. Knowledge of Section 508 technical standards and how to test for conformance.

Component 7: Milestones and timelines that conform to dates required by Coded Memo AA-2007-04 and Coded Memo AA-2007-13

Required Timeline DueSubmission of E&IT Procurement Plan 8/10/07Develop and Begin to Implement E&IT Procurement Procedure for acquisitions greater than $50,000.

9/1/07

Develop and Implement E&IT Procurement Procedure for acquisitions greater than $2,500.Procard purchases exempted

9/1/08

Develop and Implement E&IT Procurement Procedure for all acquisitions greater than $2,500.

9/1/09

Develop and Implement E&IT Procurement Procedure for acquisitions less than or equal to $2,500.

9/1/10

I) September 1, 2007 Milestone (Implementation 9/1-07 – 12/31/07): Develop and Implement E&IT Procurement Procedure for acquisitions greater than $50,000.

Task Timeline Responsible PartyStart working on forms, procedures, instructions and training

6/15/07 Procurement, Section 508 Compliance Officer

Submission of E&IT Procurement Plan 8/10/07 CO, CSUB ATI CommitteeImplement E&IT Procurement Procedure for acquisitions greater than $50,000 and begin creating Communication Process

9/1/07 Procurement, Section 508 Compliance Officer, CSUB ATI Committee

Begin Creating “Train-the-Trainer” courses 9/17/07 Section 508 Compliance Officer, CSUB ATI Committee

Conduct “Train-the-Trainer” courses 10/1/07 Section 508 Compliance Officer

Begin scheduling training classes and notify individuals that need training


Fully define and implement Communication 10/22/07 Procurement, Section 508



Task Timeline Responsible PartyProcess. Compliance OfficerStart training key people in the ATI procurement processes


Create centralized ATI Special Resource Team that can help the Requestor(s) and 508 Compliance Officer with Section 508 legal process, answer questions, etc.


Review ATI Plan. Make any revisions, modifications and/or corrections. Submission of revised Plan to CO.


II) September 1, 2008 Milestone: Develop and Implement E&IT Procurement Procedure for acquisitions greater than $2,500,Procard purchases exempted:

Task Timeline Responsible PartyStart development of procurement policies 3/15/08 ProcurementStart development of procurement procedures

4/15/08 Procurement and Section 508 Compliance Officer

Start working on forms, instructions, training, and communications


Initiate communications with stakeholders 8/15/08 Procurement and Section 508 Compliance Officer

Start training of key people 8/15/08 Procurement and Section 508 Compliance Officer

Implement E&IT Procurement Procedure for acquisitions greater than $2,500, Procard purchases exempted

9/1/08 Procurement

III) September 1, 2009 Milestone: Develop and Implement E&IT Procurement Procedure for all acquisitions greater

than $2,500.Task Timeline Responsible Party

Start development of procurement policies 3/15/09 ProcurementStart development of procurement procedures






Implement E&IT Procurement Procedure for all acquisitions greater than $2,500

9/1/09 Procurement



IV) September 1, 2010 Milestone: Develop and Implement E&IT Procurement Procedure for acquisitions less than or

equal to $2,500.Task Timeline Responsible Party

Start development of procurement policies 3/15/10 ProcurementStart development of procurement procedures






Implement E&IT Procurement Procedure for acquisitions less than or equal to $2,500

9/1/10 Procurement

Component 8: CSUB – ITSS Current Implementation Strategy and Listing of 508 Compliant Products Used On CampusI) Introduction: Information Technology Services Support (ITSS) is committed to providing an environment that is responsive and accessible to students with disabilities. To ensure this environment, appropriate accommodations are provided for students with disabilities so that technologies in all ITSS computer laboratories are accessible, as required by law.II) Standards for ITSS Computer Labs Two sets of standards are implemented in ITSS computer labs. The minimal standard must be followed for all ITSS labs, and the enhanced standard is implemented in ITSS labs with more than 30 workstations. These include the following:

Minimum Standard:i. Screen reader software: Jaws

ii. Screen magnification software: ZoomTextiii. Sound Card: Windows compatibleiv. Accessible furniturev. 17” monitor minimum

Enhanced Standard *All minimum standards with the addition of:i. CCTV

ii. Scanneriii. Braille Printeriv. Voice Recognition Software

Note: ITSS continues to work closely with the Office of the Provost, the Vice-President for Student Affairs, the Department of Disabled Student Services, the Vice-President of



Business Administrative Services, the Assistant Vice-President of Information Technology Services, and the Department of Procurement to achieve campus wide desktop compliance.

Software and Operating Systems: Standards 1194.21Information Technology Services Support (ITSS) publishes recommended desktop computing standards for software and operating systems. The standards are kept current and available via the ITSS web page. Users will be able to select products and make purchasing decisions simply be referring to the recommended standards. ITSS will guarantee that products purchased from the recommended standards will work on the campus's networked environment. Voluntary Product Accessibility Templates (VPATS) are used to provide a sense of products overall level of compliance with Section 508 Standards. Websites and web applications: Standard 1194.22

E Learning Services, a division of Information Technology Services (ITS), began automated testing of administrative web sites in 2004. Since that time we have had an ongoing process of site maintenance and repair. Our recent purchase of Percussion Software's Rhythmyx web content management system will bring us into the next phase of accessibility. Going just beyond the Section 508 rules we hope to achieve accessibility and usability with all sites from the moment they are available on the web.Desktop and portable computers: Standard 1194.26

Information Technology Services Support (ITSS) publishes recommended desktop computing standards for hardware. The standards are kept current and available via the ITSS web page. Users will be able to select products and make purchasing decisions simply be referring to the recommended standards. ITSS will guarantee that products purchased from the recommended standards will work on the campus's networked environment. Voluntary Product Accessibility Templates (VPATS) are used to provide a sense of products overall level of compliance with Section 508 Standards. Information Technology Services Websites:http://www.csub.edu/IRTS/Standards/Software/

http://www.csub.edu/WebServices/accessibility.shtml

http://www.csub.edu/IRTS/Standards/Hardware/

List of Products: 508 Compliance Verified Via VPAT or other Means:

Hardware Section 1194.26

Description of Product 508 Compliance Per VPAT

Dell Optiplex 745 Computer Supports 508 with exceptions

Dell Precision 390 Computer Supports 508 with exceptions

Dell Latitude Laptops D620, D820, D630, D830 Supports 508 with exceptions

iMac Intel Core 2 Duo, Dual-Core Intel Xeon Mac Pro Supports 508 with exceptions

Apple MacBook, MacBook Pro


http://www.csub.edu/IRTS/Standards/Hardware/

http://www.csub.edu/WebServices/accessibility.shtml

http://www.csub.edu/IRTS/Standards/Software/


Supports 508 with exceptions

Imaging Section 1194.25

Xerox Phaser 4510N Supports 508 with exceptions

HP LaserJet 4250N Supports 508 with exceptions

Software OS Section 1194.21

Microsoft Windows 2000, XP Supports 508 with exceptions

Macintosh OS X 10.3, 10.4 Supports 508 with exceptions

Software Application Section 1194.21

Windows XP SP2 Operating System Supports 508 with exceptions

Microsoft Office 2003Service Pack 2

Word, Excel, PowerPoint, Access, Frontpage, Publisher,

Photo EditorSupports 508 with exceptions

Visual Studio.NET Basic, C+ +, J+ +, Foxpro, Interdev Supports 508 with exceptions

Maple 11 Laylinalg Plugin Supports 508 with exceptions

Minitab 15.1.1 Math application Supports 508 with exceptions

SAS 9.1.3 Stats application Supports 508 with exceptions

SPSS 15.0.1.1 Stats application Supports 508 with exceptions

Geometer’s Sketchpad 4.06 Math application Does not support 508

Firstclass 8.3 Communications Supports 508 with exceptions

MeetingMaker 8.5.3 Communications Supports 508 with exceptions

Internet Explorer 6.0 Communications Supports 508 with exceptions

Netscape 7.02 Communications Review of Product, In Progress

Putty Telnet application Supports 508 with exceptions

WS_FTPLe FTP application Review of Product, In Progress



Econ 5 Communications Review of Product, In Progress

Compass Math Testing application Review of Product, In Progress

Derive 2 Math application Review of Product, In Progress

Derive 3 Math application Review of Product, In Progress

Dbase 4 Database Review of Product, In Progress

Qbasic Programming Review of Product, In Progress

Zoomtext 9.1.1 ADA Software (screen magnifier)

Review of Product, In progress

Quicktime 7.3.2 Media player Does not support 508

Real Player 11 Media player Does not support 508

Power DVD 4.011 DVD player Does not support 508

Windows Media Player11.0 Media player Does not support 508

ArcGIS 9.2 Geography application Supports 508 with exceptions

McAfee 8.5 Anti-Virus application Does not support 508

Acrobat Reader 8.1 PDF Reader Supports 508 with exceptions

WinZip 8.0 Compression application Supports 508 with exceptions

Aleks 3.6 Plugin Math plugin Does not support 508

Testgen Plugin 3.0 Math plugin Does not support 508

Palisade Stat Tool 1.1 Math stats Does not support 508

Pearson Education XL Player Math plugin Does not support 508

Firefox 2.0.05 Communication Supports 508 with exceptions

Adobe Flash Player Media Player Review of Product, In progress

Adobe Shockwave Player Media Player Review of Product, In progress



PsychMate 2.0 Other Does not support 508

Jaws 7.0 ADA Software Supports 508 with exceptions

Dragon 6.0 ADA Software Supports 508 with exceptions

Duxbury Braille Translator ADA Software Supports 508 with exception

Kurzweil 3000 ADA Software Supports 508 with exceptions

Math XL Player Math Plugin Review of Product, In progress

Java 1.6.0 Java Plugin Review of Product, In progress

Crimson Editor 3.6.3.70 Other Review of Product, In progress

R 2.5.1 Math Stats Review of Product, In progress

Java JDK 6 update 2 Programming Review of Product, In progress

Adobe Illustrator 10.0.3 Graphic application Supports 508 with exceptions

Adobe PageMaker 6.5 Graphic application Supports 508 with exceptions

Adobe Photoshop 7 Graphic application Supports 508 with exceptions

Carrara Studio 2 Graphic application Review of Product, In progress

ClarisWorks 4.0 Word Processing Review of Product, In progress

Macromedia Director MX 9.0 Graphic application Review of Product, In progress

Fetch 4.03/3.03 FTP application Review of Product, In progress

Macromedia Dreamweaver MX 6.0 Graphic application Supports 508 with exceptions

Macromedia Fireworks MX 6.0 Graphic application In progress

Macromedia Flash MX 6.0 Graphic application Supports with exceptions

MicroGrade 4.1 Grade Tracking application Review of Product, In progress

QuarkXPress 6.52 Graphic application Review of Product, In progress



VersaTerm 5.06 Telnet application Review of Product, In progress

Virex 7 Anti-Virus application Review of Product, In progress

Voyager III Astronomy application Review of Product, In progress

IMovie Movie Editor Review of Product, In progress

IDVD Movie Editor Review of Product, In progress



ATI Procurement Process Flowchart:

Note 1: To qualify as a Single-User, the E&IT must be used only by the purchaser and not be placed in the public domain or used by students for research or instruction.

Note 2: The End-User initiates the Product Accessibility Process consisting of the following steps:

1. Pre-Purchase Product Accessibility Testing (whenever possible)2. Product Accessibility Checklist

a. E&IT checklist or VPAT completed by vendorb. Certification of compliance or non-compliance by Compliance Officerc. Procurement will notify vendor of Article 27. Americans with Disabilities Act (ADA) located in

the CSU General Provisions for IT Acquisitions prior to purchase.

Note 3: If post-purchase testing indicates that the product is not compliant, the product should not be implemented unless an Exception Waiver is obtained.



CSUB Electronic & Information Technology Purchase Form (Draft)(Must be completed for all E&IT purchases)

California Government Code 11135 requires the CSU to comply with Section 508 and to apply accessibility standards to electronic and information technology (E&IT) products and services that it procures. For more information about this requirement, please see (link). The general, technical and functional requirements of the procurement specifications drive the procurement process. Accessibility determination is conducted in the evaluation. E&IT products and services must meet the applicable accessibility standards unless an exception applies. If a campus determines that compliance with any provision of the accessibility standards is exempted, the campus shall maintain documentation in the acquisition file to support the procurement.

Requestor Department Phone Email Requisition #

Brief Description of Acquisition and Usage 1. Description (include purpose and location of where the technology will be placed and cost estimate of acquisition)

2. Describe how the end-users will be using this product or service?

Applicable Standards: What category of EIT is being acquired? Please check all that applies. Applicable Section 508 standards and the Guide to the Standards are provided as links for quick reference. (Links are not enabled yet.)___ Software and operating systems: Standard 1194.21 Guide ___ Websites and web applications: Standard 1194.22 Guide (Websites & web apps must also meet Standard 1194.21)___ Telecommunications products: Standard 1194.23 Guide

(Phones & technologies involved with information transmission such as television & DVD)___ Video & Multimedia products: Standard 1194.24 Guide

(Video and multimedia: Also includes standards for analog and digital TV displays, as well as stand-alone digital TV tuners and computer equipment that includes digital TV receiver or display circuitry)

___ Self-contained, closed products: Standard 1194.25 Guide (Copiers, fax machines, Kiosks, ATM machines, calculators are some examples.)

___ Desktop and Portable Computers: Standard 1194.26 Guide

Obtain Voluntary Product Accessibility Template (VPAT) (see link)A. Attach a copy of the VPAT with this form or provide the link from the vendor’s website containing the

VPAT. In some cases where the vendor does not have a VPAT and is in the process of completing the VPAT, the No VPAT Form can be completed. For formal bids the VPAT is required.

B. Informal bids will require information from at least three vendors.

___________________________________________________________________________________________ Signature of Requestor Printed Name Title/ Date

_____________________________________________________________________________________________For Office Use only:

__The product that met the greatest level of accessibility is approved for purchase.__The product was previously purchased and conformant. __ Only one product met the technical and functional specifications.__ No accessible version is available in the marketplace.__ For business reasons, the less accessible of the products is approved for purchase. (Include documentation)

Signature of 508 Compliance Officer Printed Name Title/ Date



APPENDIX A: California Government Code 11135CALIFORNIA CODESGOVERNMENT CODESECTION 11135-11139.8

11135. (a) No person in the State of California shall, on the basis of race, national origin, ethnic group identification, religion, age, sex, color, or disability, be unlawfully denied full and equal access to the benefits of, or be unlawfully subjected to discrimination under, any program or activity that is conducted, operated, or administered by the state or by any state agency, is funded directly by the state, or receives any financial assistance from the state. Notwithstanding Section 11000, this section applies to the California State University. (b) With respect to discrimination on the basis of disability, programs and activities subject to subdivision (a) shall meet the protections and prohibitions contained in Section 202 of the Americans with Disabilities Act of 1990 (42 U.S.C. Sec. 12132), and the federal rules and regulations adopted in implementation thereof, except that if the laws of this state prescribe stronger protections and prohibitions, the programs and activities subject to subdivision (a) shall be subject to the stronger protections and prohibitions.

(c) (1) As used in this section, "disability" means any mental or physical disability as defined in Section 12926.

(2) The Legislature finds and declares that the amendments made to this act are declarative of existing law. The Legislature further finds and declares that in enacting Senate Bill 105 of the 2001-02 Regular Session (Chapter 1102 of the Statutes of 2002), it was the intention of the Legislature to apply subdivision (d) to the California State University in the same manner that subdivisions (a), (b), and (c) of this section already applied to the California State University, notwithstanding Section 11000. In clarifying that the California State University is subject to paragraph (2) of subdivision (d), it is not the intention of the Legislature to increase the cost of developing or procuring electronic and information technology. The California State University shall, however, in determining the cost of developing or procuring electronic or information technology, consider whether technology that meets the standards applicable pursuant to paragraph (2) of subdivision (d) will reduce the long-term cost incurred by the California State University in providing access or accommodations to future users of this technology who are persons with disabilities, as required by existing law, including this section, Title II of the Americans with Disabilities Act of 1990 (42 U.S.C. Sec. 12101 andfollowing), and Section 504 of the Rehabilitation Act of 1973 (29U.S.C. Sec. 794).

(d) (1) The Legislature finds and declares that the ability to utilize electronic or information technology is often an essential function for successful employment in the current work world.

(2) In order to improve accessibility of existing technology, and therefore increase the successful employment of individuals with disabilities, particularly blind and visually impaired and deaf and hard-of-hearing persons, state governmental entities, in developing, procuring, maintaining, or using electronic or information technology, either indirectly or through the use of state funds by other entities, shall comply with the accessibility requirements of Section 508 of the Rehabilitation Act of 1973, as amended (29 U.S.C. Sec. 794d), and regulations implementing that act as set forth in Part 1194 of Title 36 of the Federal Code of Regulations.

(3) Any entity that contracts with a state or local entity subject to this section for the provision of electronic or information technology or for



the provision of related services shall agree to respond to, and resolve any complaint regarding accessibility of its products or services that is brought to the attention of the entity.

11136. Whenever a state agency that administers a program or activity that is funded directly by the state or receives any financial assistance from the state, has reasonable cause to believe that a contractor, grantee, or local agency has violated the provisions of Section 11135, or any regulation adopted to implement such section, the head of the state agency shall notify the contractor, grantee, or local agency of such violation and shall, after considering all relevant evidence, determine whether there is probable cause to believe that a violation of the provisions of Section 11135, or any regulation adopted to implement such section, has occurred. In the event that it is determined that there is probable cause to believe that the provisions of Section 11135, or any regulation adopted to implement such section, have been violated, the head of the state agency shall cause to be instituted a hearing conducted pursuant to the provisions of Chapter 5 (commencing with Section 11500) of this part to determine whether a violation has occurred.

11137. If it is determined that a contractor, grantee, or local agency has violated the provisions of this article, the state agency that administers the program or activity involved shall take action to curtail state funding in whole or in part to such contractor, grantee, or local agency.

11138. Each state agency that administers a program or activity that is funded directly by the state or receives any financial assistance from the state and that enters into contracts for the performance of services to be provided to the public in an aggregate amount in excess of one hundred thousand dollars ($100,000) per year shall, in accordance with the provisions of Chapter 4.5 (commencing with Section 11371) of this part, adopt such rules and regulations as are necessary to carry out the purpose and provisions of this article.

11139. The prohibitions and sanctions imposed by this article are in addition to any other prohibitions and sanctions imposed by law. This article shall not be interpreted in a manner that would frustrate its purpose. This article shall not be interpreted in a manner that would adversely affect lawful programs which benefit the disabled, the aged, minorities, and women. This article and regulations adopted pursuant to this article may be enforced by a civil action for equitable relief, which shall be independent of any other rights and remedies.


Date post:	29-Mar-2019
Category:	Documents
Upload:	dodat
View:	213 times
Download:	0 times

To: - California State University, Bakersfield · Web viewCALIFORNIA STATE UNIVERSITY...

Documents