September 10, 2024

VPATs and Section 508

Person using assistive technology

A Voluntary Product Accessibility Template (VPAT) is a standardized document that outlines how well a particular product or service conforms to Section 508 of the Rehabilitation Act, which mandates that all federal agencies—and institutions like public schools that receive federal funding—ensure that their electronic and information technology (EIT) is accessible to people with disabilities.

In the context of Section 508, VPATs serve as a tool to communicate a product’s accessibility features to potential buyers. They allow public institutions like schools to evaluate whether a technology solution will meet the needs of all users, including those with disabilities. The VPAT provides a detailed assessment of how compliant the product is with accessibility standards and highlights any areas that may need improvement.

Purpose of VPATs for Schools and Public Institutions:

For public institutions like schools, VPATs are critical during the procurement process. They offer a clear overview of a product's accessibility status, helping decision-makers determine whether it will provide equal access to students, staff, and parents with disabilities.

Schools must ensure that all the technology they use is compliant with Section 508, ensuring that individuals with visual, auditory, motor, or cognitive impairments can use digital tools as effectively as other users. A VPAT enables schools to:

Sections and Structure of a VPAT:

A VPAT is typically structured around accessibility standards such as the Web Content Accessibility Guidelines (WCAG 2.0 or 2.1) and Section 508. The document breaks down accessibility into specific categories and details how the product performs in relation to various criteria.

  1. Perceivable:
    • Text Alternatives: Are images and non-text content provided with alt text descriptions for users with visual impairments?
    • Time-Based Media: Are captions and transcripts provided for audio and video content?
    • Adaptable Content: Does the layout adapt to different screen sizes, allowing users to zoom or magnify content?
  2. Operable:
    • Keyboard Navigation: Can the product be fully navigated using just a keyboard, which is essential for users with motor impairments?
    • Input Assistance: Does the system provide error identification and suggestions to assist users?
  3. Understandable:
    • Readability: Is the text presented clearly, with appropriate reading levels and clear language?
    • Predictability: Does the interface behave in predictable ways, reducing the cognitive load on users with intellectual disabilities?
  4. Robust:
    • Compatibility with Assistive Technologies: Does the product work seamlessly with assistive devices like screen readers or Braille displays?

Each section of the VPAT is evaluated against different success criteria, and the product is rated for its compliance on a scale of:

Why VPATs Matter for Section 508 Compliance:

  1. Ensuring Legal Compliance: Section 508 requires schools and public institutions to use technology that is accessible to people with disabilities. Schools must demonstrate that they are making every effort to comply with these standards. A VPAT provides documented proof of a product’s accessibility features, helping schools meet their legal obligations.
  2. Promoting Inclusivity in Education: For students with disabilities, inaccessible technology can create significant barriers to learning. Without proper accommodations, these students may struggle to engage with digital content, complete assignments, or participate in classroom activities. By using VPATs to evaluate products, schools ensure that students with disabilities have equal access to the educational materials and tools they need to succeed.
    For example, a VPAT for an online learning platform would reveal whether the platform offers key accessibility features like screen reader compatibility or closed captions for videos. If these features are missing, the school might either request improvements or look for alternative products that better support students with disabilities.
  3. Mitigating Risk and Saving Time: Ensuring accessibility before purchasing technology reduces the risk of non-compliance with Section 508, which can lead to legal challenges and financial penalties. It also saves schools from having to make costly and time-consuming retrofits to products that don’t meet accessibility standards after implementation. By reviewing VPATs before making a purchase, schools can avoid these potential issues and ensure they’re making informed decisions.

How Schools Use VPATs to Select Accessible Products:

In a real-world scenario, consider a school district that is planning to invest in a new digital textbook platform. The district will request a VPAT from the vendor before purchasing the product. In this VPAT, the school would expect to see:

The school would use this VPAT to evaluate whether the product provides adequate accessibility. If the vendor’s product only partially meets Section 508 standards (e.g., missing captions or lacking support for screen readers), the school can request improvements before purchasing. Alternatively, they may choose another vendor that provides a more compliant solution.

VPATs and Vendor Accountability:

Requesting a VPAT from a vendor not only demonstrates a school’s commitment to accessibility but also holds vendors accountable for their product’s compliance with Section 508. When a vendor submits a VPAT, they’re effectively agreeing to transparency in their product’s accessibility features (or shortcomings). Schools can then use this document to either approve or disqualify a product based on its level of accessibility.

Moreover, schools can use the VPAT as a negotiation tool to request that vendors make improvements where necessary. If a product is found to be partially compliant, the school can ask the vendor to address specific issues—such as adding closed captions to video content or improving keyboard navigation features—before committing to a purchase.

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