Vendor VPAT Help

Vendors are required to submit some form of Section 508 documentation for any given ICT product, usually a VPAT, the resultant report now more commonly known as an Accessibility Conformance Report.   Every and any report should have:

  1. A proper Header listing a product description, who is responsible/author (Contact Information) for the Accessibility Conformance Report and at least an email address or telephone number,  and what tools were used to assess the product.
  2. A sensible and complete Chapter 3 section (1194.31 in the old form) with all contributing data found in Tables 1 and 2 (1194.21 to 1194.26 in the old form).   Further assessment using Sections Chapter 4 and Chapter 5 are desired but not required.
  3. A commitment to support the product through at least telephone support in Chapter 6 (1194.41 in the old form).

ICT is generally a visual experience.   Therefore, an alternate experience to serve the blind is a top priority.   A secondary priority, and sometimes conjunction with the visual, is to provide navigation (usually tabs and hotkeys) not using a mouse.  

Functional Performance Criteria

When working with vendors to get a clear assessment of a product's accessibility, campus reviewers should first consider how accessible the product is in a general sense.   Assuming the vendor has completed Chapter 3 (Functional Performance Criteria) in the new 2.X VPAT template, the answers should be visible. On the old VPAT form, that section, but not as robust, was 1194.31.

Chapter 3 on the new form is as follows:


Conformance Level

Remarks and Explanations

302.1 Without Vision



302.2 With Limited Vision



302.3 Without Perception of Color



302.4 Without Hearing



302.5 With Limited Hearing



302.6 Without Speech



302.7 With Limited Manipulation



302.8 With Limited Reach and Strength



302.9 With Limited Language, Cognitive, and Learning Abilities



From this general assessment, why compliance cannot be met should be found in the Tables sections of the VPAT.  Most current software has a web interface, so the WCAG sections of the 2.X VPAT, Conformance Criteria for Level A (required compliance), Level AA (desired compliance), and Level AAA (optional compliance) could be read to see where improvements can be made.

Once a product's documentation is worthy of being posted, assuming either compliance or non-compliance,  it is posted to the Cal State LA ACR Repository web page. Non-compliant products need to have an accompanying EEAAP (Equally Effective Alternative Access Plan), form 4821, included. When VPATs do not get submitted, it is assumed that the product is not compliant, and again an EEAAP must be provided.   All EEAAPs are subject to review and re-write.

Follow Up Procedures

Virtually all products can be corrected or improved over time via re-programming or changes in manufacture. Vendors should be aware that the CSU is serious about accessibility, and products achieving superior accessibility will be preferred in the procurement process. Many vendors have done just so. The CSU provides a template for vendors to show development timelines for accessibility improvements.

For additional information on CSU Accessible Procurement policies visit the CSU ATI Procurement Policy webpage.