Understanding the VPAT®
You may come across the Voluntary Product Accessibility Template (VPAT) as you research vendors of digital materials and technologies and consider their products for procurement. The VPAT is meant to help U.S. federal government agencies determine how well the products they purchase meet the Section 508 accessibility standards. Many organizations outside the federal government now require the submission of a VPAT in their procurement process, especially if they receive any kind of federal funding. This includes K-12 schools and institutions of higher education.
Start with general information about the VPAT, then review a sample Accessibility Conformance Report (ACR) similar to one a vendor would submit for your consideration. Each section of the sample ACR (which is just a filled out VPAT) includes comments to help you understand the information you would find in that section of an ACR.
Benefits of the VPAT®
The VPAT can assist you in your reviews of digital materials and technologies because it can
- Provide a standard format for you to determine and compare the accessibility of multiple products in the bidding process. For example, if your district is accepting proposals for a learning management system, you can collect the VPATs from several vendors to help you compare how well each product supports a specific accessibility feature such as captions or transcripts for videos.
- Help you prepare for your discussions about accessibility with vendors. The review of a product's VPAT can help you identify questions you need to ask the vendor to ensure your procurement decision is based on the best information available.
- Document accessibility claims from vendors in order to promote accountability. Your contracts can include language requiring vendors to submit an accurate and up to date VPAT as a condition of purchase. If inaccuracies are identified later as a result of students experiencing access barriers, the documentation in the VPAT can inform your efforts to resolve the identified issues.
- Increase awareness of accessibility standards and promote best practices among vendors and developers.
Limitations of the VPAT®
When using the VPAT® as a source of information about the accessibility of a product, be aware that
- Just because a vendor produces a VPAT for a product doesn’t mean that the product is in compliance with accessibility standards.
- The quality of a VPAT is limited by the expertise of the person completing it. Some companies have accessibility experts on staff while others designate people who may not have the necessary knowledge and skills to produce an accurate VPAT.
- Versions of the same product can significantly differ. When receiving a VPAT, confirm that it matches the product being considered for purchase. The date on the VPAT should also be consistent with the release of the product.
You should combine your review of the VPAT with other strategies and tools to ensure you are procuring accessible digital materials and technologies. We highly recommend usability testing with learners who have unique access needs as a way to get a more well-rounded picture of the accessibility of a given product.
Explore the VPAT® with a sample ACR
The VPAT® includes two major sections. The first section includes extensive instructions for completing the VPAT, including essential requirements, best practices, and frequently asked questions. Upon completion, the vendor removes the instructions, leaving only the Accessibility Conformance Report (ACR). The ACR is what is made available to you as documentation of a product’s conformance to Section 508 and other accessibility standards.
In the remainder of this section, you will explore a VPAT’s ACR from a fictional company called Online Learning Systems that develops and markets an online learning management system for schools under the name Online Learning Environment.
Online Learning Systems Accessibility Conformance Report (Exemplar)
Based on VPAT® Version 2.4, Revised Section 508 Edition
Name of Product: Online Learning Environment 2.0
Report Date: January 10, 2019
Product Description: Online Learning Environment is a learning management system (LMS) educators can use to author and deliver online learning courses.
Contact Information: accessibility@onlinelearningsystems.com (John Doe, Accessibility Manager)
Notes: This VPAT reflects the update of Online Learning Environment to version 2.0 on December 15, 2020.
AEM Center Notes on Date & Contact Information
The contact information should point to someone who is not only familiar with the product’s features but also its support for a variety of accessibility features. Ideally, it should be someone on the accessibility team. The information in this section should be as specific as possible to help the person reading the VPAT determine which version of the product the VPAT covers and when it was last updated.
Evaluation Methods Used
Online Learning Systems contracted with Accessibility Audit Company to conduct a full third-party audit of the Online Learning Environment platform upon launch. Additional testing of updated components was conducted when Online Learning Environment was updated to version 2.0. Testing was performed with both an automated accessibility checker as well as a range of assistive technologies and web browsers: JAWS 18 and Internet Explorer 11; NVDA and Firefox 60; VoiceOver and Safari 11. Keyboard-only testing was also performed.
AEM Center Notes on Evaluation Methods
This section should include both automated as well as manual testing methods used to determine the product’s accessibility. Keep in mind that automated tools can only capture about 25-30% of accessibility errors, while testing with assistive technology will depend on both the capabilities of the tool as well as the skill of the person doing the testing. A variety of methods, both manual and automated, will provide a thorough and more robust evaluation.
Applicable Standards & Guidelines
This report covers the degree of conformance for the following accessibility standards/guidelines:
| Standard/Guideline | Included in Report |
|---|---|
| Web Content Accessibility Guidelines 2.0 | Level A (Yes) Level AA (Yes) Level AAA (No) |
| Revised Section 508 standards published January 18, 2017 and corrected on January 22, 2018 | Yes |
AEM Center Notes on Applicable Standards & Guidelines
The Web Content Accessibility Guidelines (WCAG) are the international accessibility standard. WCAG has three levels of conformance:
- Level A is the minimum level of accessibility a product should have. Not meeting Level A will result in significant barriers for people with disabilities that could keep them from using the product at all.
- Level AA is the level of accessibility required in most national laws, such as the revised Section 508 in the U.S. It refers to a level of accessibility that should be reasonable to attain.
- Level AAA is the highest level of accessibility, but it may not always be attainable due to the nature of some websites and applications.
On this VPAT®, Online Learning Systems states that their product Online Learning Environment 2.0 will meet WCAG at Level AA, which is required by most national laws and recommended as a target level for procurement decisions. Because the three levels build on each other, conformance at Level AA also means meeting Level A.
The latest version of WCAG is WCAG 2.1, which includes additional success criteria for mobile accessibility and for improving the experience for people with low vision and those with cognitive and learning disabilities. WCAG 2.1 is backward compatible with WCAG 2.0, and includes all of the WCAG 2.0 criteria.
Section 508 is the U.S. federal law that requires government agencies to provide people with disabilities equal access to electronic and information technology. Section 508 was updated in 2017 to include WCAG by reference. Because Online Learning Systems has chosen to report conformance to the updated Section 508 standards, conformance to WCAG is also necessary. This is best practice in VPAT® development. However, note the version of WCAG referenced in the updated Section 508 is 2.0 instead of 2.1.
The following table summarizes which version of WCAG apply to specific editions of the VPAT®:
| WCAG 2.1 | WCAG 2.0 |
|---|---|
|
VPAT® 2.4 EU (for Europe) VPAT® 2.4 INT (incorporates all of the standards) |
VPAT® 2.4 Section 508 |
The body of the ACR is a series of tables with columns that correspond to the specific criteria being evaluated, the level of conformance, and any remarks that provide additional explanation. The conformance levels for VPAT® 2.4, the version of the template as of February 2020, are as follows:
- Supports: The functionality of the product has at least one method that meets the criterion without known known defects or meets with equivalent facilitation.
- Partially supports: Some functionality of the product does not meet the criterion.
- Does not support: The majority of the product does not meet the criterion.
- Not applicable: The criterion is not relevant to the product.
- Not evaluated: The product has not been evaluated against the criterion. This can be used only in WCAG 2.0 Level AAA.
Examples from Online Learning System’s ACR for Online Learning Environment 2.0:
Table 1 - Success Criteria, Level A
| Criteria | Conformance Level | Remarks and Explanations |
|---|---|---|
| 1.1.1 Non-text Content Also applies to: Revised Section 508
|
Web: Supports Authoring Tool: Supports | Web: Alt text is used for all icons and images throughout Online Learning Environment 2.0. Authoring Tool: For images imported by a course builder, alt text can be provided by the author. |
Table 2: Success Criteria, Level AA
| Criteria | Conformance Level | Remarks and Explanations |
|---|---|---|
| 1.2.4 Captions (Live) Also applies to: Revised Section 508
|
Web: Does Not Support | Web: The video conferencing component in Online Learning Environment 2.0 does not support live captioning. This functionality is on the roadmap for a planned spring 2019 release. |
AEM Center Notes on Conformance Tables
For the Level A table, Online Learning Systems has reported that alternative text for the images and icons is not only available in the Online Learning Environment interface (“Web: Supports”), but can also be provided for any images course authors import into their courses (“Authoring Tool: Supports”).
For the Level AA table, a feature of Online Learning Environment 2.0 does not support a criterion, but the vendor has provided helpful information on when the specified feature will be available for review and testing.
The rest of the Online Learning Environment 2.0 VPAT would follow a similar pattern. Vendors can choose to leave out a table from their ACR if that level of conformance will not be reported. This is typically done for WCAG Level AAA.
To further streamline the VPAT by reducing the number of pages in the ACR, separate editions corresponding to individual standards (WCAG, Section 508 and the European EN 301 549 standard) are now available for download from the Information Technology Industry Council. ITI is the industry group that maintains the VPAT.
Legal Disclaimer
The availability of some of the features described in this document will vary according to the selected license type of Online Learning Environment 2.0.
AEM Center Notes on Legal Disclaimer
The legal disclaimer is easy to overlook, as it comes at the end of the ACR following a number of long tables. A vendor may use this disclaimer to explain certain limitations that have not been mentioned elsewhere on the ACR. In this case, Online Learning Systems has reported that different licenses of their product are available, and the feature set will vary according to the license.
Conclusion
The VPAT® was developed to provide a standard reporting format and make it easier for procurement departments to conduct a preliminary assessment of a product’s conformance to accessibility standards. However, as a voluntary report, there are a number of limitations of the VPAT that should be kept in mind. The VPAT should thus be one component of a robust procurement process that also involves in-depth conversations with vendors, testing with assistive technology users, and regular reviews to make sure the information provided is up to date.