The original purpose of a Voluntary Product Accessibility Template (VPAT) was to provide United States federal agencies a tool to determine how compliant a software application, web application, or piece of hardware was to Section 508 of the Rehabilitation Act of 1973, as a requirement of the Federal Acquisition Regulation procurement process (FAR 39.2).

Since December of 2000 when the law went into full effect, more institutions and organizations outside of the federal government have used this document to assist their purchasing departments in choosing their software application, web application, and hardware.

Unfortunately, because this document is technically voluntary, there is no standard for how detailed a VPAT should be or what kind of content must be verified. This lack of standardization means that vendors have been able to pick and choose what they test, how their product is tested, and ultimately how detailed the issues in the VPAT are written.

The Information Technical Industry Council (ITIC), the organization that developed the VPAT, states the following about what purchasers should look for in the document:

“We believe that the best way to characterize conformance to an accessibility standard is by addressing the “degree of conformance.” This metric, also referred to as “best meets,” was introduced by the U.S. General Services Administration (GSA) with the publication of the initial Section 508 standards. The approach encouraged manufacturers to provide detailed standards conformance information on a criterion-by-criterion basis, enabling prospective purchasers to evaluate whether a product may still meet essential accessibility objectives even if it is not fully conformant with technical requirements.”

Basically, a VPAT that has valid “Supports with Exceptions” is not a bad thing for a vendor to state, as long as the reasoning behind the exceptions are sound.  A “Supports with Exceptions” tells purchasers that yes, there is an issue with a particular feature, but it does not impact the overall ability of someone with a disability to use the product.  Demonstrating the knowledge of feature accessibility in the VPAT likewise says to a purchaser that the vendor has obviously taken some time to evaluate their product such that they do know there are features that may cause issues.

A good VPAT will also identify what assistive technologies or methods were used to determine accessibility.  This tells the purchaser what the best tools to use with the product are, especially if concerns are voiced later if different tools are used. Identification of methods, like using MSAA Object Inspector in addition to an automated tool, tells purchasers that issues identified in the VPAT have been cross checked in more than one way, supporting their validity. A VPAT based on automated test results or even just testing with an assistive technology can miss several issues.

To conclude, a blanket “Supports” VPAT that lacks comments or has very general comments – e.g., “Some of our form fields do not have labels” – should be a red flag to any purchaser. Superficially, this type of VPAT looks great, but the purchaser may find several issues once the product is purchased.  Whereas, the VPAT that has a few clearly defined “Supports with Exceptions” that explain what the issues are and defines how the issues were found, gives purchasers a clearer idea of what they are buying.

To learn more about the VPAT, check out the following resources:

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