A VPAT, or Voluntary Product Accessibility Template, is a document that may let you know – before you’re locked into making a purchase – how easily people with disabilities can use a technology-based product or service.
If your organization, school or company routinely purchases information and communication technology (ICT), you may be legally obligated to ensure that it’s accessible (free of barriers for users with disabilities). Some of the standards and regulations that may apply to you include Sections 508 and 504 of the Rehabilitation Act, Web Content Accessibility Guidelines (WCAG), the Americans with Disabilities Act and laws in various jurisdictions, both local and international. You may also be compelled to abide by a company or university policy on accessibility. Or you may realize that making a point of buying products that are barrier-free is a way to ensure your organization doesn’t exclude the 19% of the population with disabilities.
How can you be positive, though, that technology is accessible before you make the choice to acquire it? That’s where a VPAT can guide you. The VPAT (you can see a sample VPAT here) is prepared by the vendor and shared with potential customers. It lists the accessibility criteria of various laws and indicates whether or not their product supports each of these criteria. If a criterion is not fully supported, a separate “comments” column is used for additional remarks or explanations.
The VPAT is designed to let you know whether or not a product conforms with specific accessibility standards, and whether or not you’re in compliance with the law if you purchase it. Most importantly, a VPAT will tell you whether your clients, employees, customers or students with disabilities may be able to use this product easily or not.
A VPAT is useful when it’s completed properly and accurately. Unfortunately, not every VPAT provides instant answers to all your questions. Here are some of the stumbling blocks you may encounter while procuring accessible ICT, and how you can address them in order to get the most out of a VPAT.
The vendor doesn’t have a VPAT available and hasn’t heard of it.
Just because a vendor doesn’t know what a VPAT is doesn’t mean they’d be unwilling to complete one. They may realize it’s a business advantage to be able to supply a high-quality VPAT, especially if the document demonstrates full conformance with technical accessibility requirements. There are other organizations, not just yours, that seek accessible ICT to accommodate as many end users as possible. (Even if the product currently contains barriers, there’s a good chance that once the vendor learns more about VPATs, they will make accessibility a priority.)
If your vendor hasn’t heard of a VPAT, steer them towards the templates and supporting resources produced by the Information Technology Industry Council (ITIC)1. The VPAT 2.1 report form, available here, incorporates up-to-date requirements from the recent 2017 refresh of Section 508, as well as the Web Content Accessibility Guidelines (WCAG) 2.0 and the new European standard, EN 301 549 (“Accessibility requirements suitable for public procurement of ICT products and services in Europe”).
The vendor knows what a VPAT is but refuses to complete one.
A “Voluntary” Product Accessibility Template is just that – voluntary. A vendor can decline the opportunity to submit one. This might be the point at which you move on in your procurement process. In fact, depending on your accessibility policy, you may have no choice but to seek out the competition instead.
On the other hand, it might be helpful to understand the reason why the vendor is reluctant to cooperate. They may be concerned about releasing proprietary information. If your organization is comfortable signing a non-disclosure agreement, that may solve the problem. But often, vendors are worried they don’t know enough about digital accessibility requirements and won’t fill out the VPAT correctly, or they’re simply intimidated by the entire process.
If you’re still interested in doing business with the vendor, recommend they consult with a third party that has the expertise to complete the VPAT on their behalf. A professional third-party partner will also be unbiased.
The VPAT is incomplete or the information is out of date.
The information contained in a VPAT is self-disclosed by the vendors. Even if the vendor willingly signs a contract stating that the document is accurate, there’s no guarantee that it actually is. In the end, you may be unwittingly purchasing an inaccessible product.
Some vendors don’t know enough about digital accessibility to fill out a VPAT properly or thoroughly. Or perhaps the VPAT describes an outdated version of the product. Sometimes, the vendor is reluctant to be overly forthcoming about the accessibility problems of their ICT. What if it hurts their product’s reputation, or costs them sales?
If you aren’t confident about the reliability of the VPAT, ask your vendor about the testing methods they used, and whether or not they worked with independent accessibility experts who understand the criteria of various laws. You can also ask for a demo copy of the product so that your own trusted accessibility partner can carry out hands-on testing. As another safeguard, incorporate into your purchasing agreement the level of accessibility stated on the VPAT.
The VPAT has been completed, but it shows accessibility gaps.
What if the VPAT shows that the product does not actually meet the technical requirements for accessibility? It’s important to be able to assess how serious these issues are. You may find some clues in the comments section. Here, you may learn that the accessibility problems are in fact quite limited, and that there are ways to avoid them when using the product. For example, a drop-down menu might not be accessible using only the keyboard, but there may be a workaround – another way to make those same menu selections using the keyboard.
You can ask the vendor to supply a timeline for various barriers to be removed. Depending on the situation, a temporary exception might be acceptable, as long as improvements are being made and an accessible alternative is available in the meantime. It’s also possible that a specific digital barrier can be remedied relatively easily by the vendor. If, however, there’s not enough detail in the comments area for you to make a judgment, it’s better to be safe than sorry. Seek an independent accessibility evaluation, ask the vendor to provide a roadmap for when non-accessible areas are to be fixed, or choose a different product.
You aren’t sure how to interpret a VPAT.
Procurement officers don’t always have the expertise to know whether the accessibility barriers reported are minor and easily remedied, or major and difficult to remove. They may not even be sure a VPAT has been filled out properly. The truth is, Product A is not necessarily more accessible than Product B just because the VPAT comprises a shorter list of problems. Or the severity of the problems listed may be more risk.
As we’ve discussed, vendors may lack the experience, the willingness or even the trustworthiness to complete a VPAT accurately. Again, this is a situation in which a partner that specializes in digital accessibility can be an extremely valuable resource and ally. Experts can help you interpret the VPAT and advise you about any accessibility problems.
When you make every effort to ensure that the ICT you purchase is as accessible as possible, you’re not just meeting your legal and company obligations. You’re demonstrating that you are inclusive and welcoming of everyone you serve, employ or do business with – whether or not they happen to have disabilities. Do what you can to get value out of a VPAT. You’ll find that it will be well worth it.
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- VPAT ITI, 2018