Voluntary Product Assessment Template (VPAT) Information

Why do we procure accessible Information & Communication Technology (ICT) at CMS?

Section 508 of the Rehabilitation Act of 1973 (29 USC § 794d) requires that all information and communication technology (ICT) that CMS develops, procures, maintains or uses is accessible to persons with disabilities.  
 

How does CMS evaluate ICT?

CMS reviews accessibility information contained in the Accessibility Conformance Report (ACR) which is produced from a completed Voluntary Product Accessibility Template (VPAT). The ACR provides details on the accessibility standards of ICT as well as insight into any potential accessibility issues that may prevent a particular product or service from meeting Section 508 Standards and/or Web Content Accessibility Guidelines (WCAG). 
 

What is the VPAT?

The VPAT is a document that captures accessibility specifications of ICT. The ACR, generated from the completed VPAT, assists the procurement community with assessing the level of accessibility conformance during the market research and proposal evaluation stages. It also provides internal CMS Section 508 stakeholders with key insights on a vendor's reported 508 compliance level for a solution targeted for procurement and/or formal testing. 

It is CMS’ policy to request and review the ACR for all newly purchased or developed ICT including new versions or releases. CMS requires that VPATs meet WCAG 2.1 (or higher) Level A/AA criteria. 
 

Quick Facts & Tips to Assist You in Completing a VPAT:

• Know which version of the VPAT CMS accepts. There are four editions of the VPAT:

  • •  Section 508 – The Revised Section 508 Standards (CMS approved) 

  • • WCAG – Web Content Accessibility Guidelines (CMS approved) 

  • • EU – European Union’s Accessibility Requirements (NOT CMS approved) 

  • • INT – Incorporates all three of the above standards (CMS approved, but CMS will only review WCAG and Section 508 information) 

• Indicate the appropriate criteria conformance level on the VPAT: supported, partially supported, not supported, not applicable or not evaluated.
• Complete each line and column in the table section when filling out the VPAT. The offeror should provide information in the remarks and evaluation column, as well as detailed remarks to support their responses.

• Be sure to fill in every line of the VPAT. If a line is not applicable, note “Not Applicable” and provide a detailed explanation in the Remarks and Evaluation column as to why that criterion does not apply.

   

VPAT Tutorial:

If you need assistance in completing a VPAT, please view the video: How to Complete the VPAT.
 

CMS Section 508 Procedures for Evaluating and Remediating ICT:

• In accordance with agency procedures, CMS will assess all newly developed or procured ICT, and pre-existing ICT.
• For high-risk procurements (any ICT which is public-facing, available to the public via electronic communication channels, and/or ICT which is internal to CMS staff or contractors), a completed ACR is required prior to completion of the procurement; low-risk procurements (such as reports, charts, and/or training materials) only require a completed HHS accessibility checklist.
• The CMS vendor or developer must provide a completed ACR using the Section 508 Voluntary Product Accessibility Template (VPAT) prior to testing or releasing ICT into the CMS production environment.
• CMS only will approve ICT that we have reviewed and determined to be Section 508 compliant, or the Section 508 Program Manager may grant an exception, in accordance with established CMS procedures.
• All non-compliant ICT in the CMS production environment must have an established remediation plan or an approved exception.