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Understanding the VPAT®

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A Voluntary Product Accessibility Template (VPAT®) is used by vendors to report  the extent to which a digital material or technology product meets federal accessibility compliance standards for people with disabilities. As indicated by its title, a VPAT is voluntarily made available by vendors, making it a self-report.

The VPAT was developed as a standard format 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, both of which must comply with civil rights laws such as the Americans with Disabilities Act (ADA) and Section 504 of the Rehabilitation Act of 1973. You can learn more about these laws on our Laws, Regulations and Guidelines page.

What are some of the benefits of the VPAT®?

The VPAT® is just one source of information and it should be used in combination with other resources and strategies for determining the accessibility of a product. Requiring the VPAT in digital materials and technology reviews benefits purchasers because it can

  • Provide a standard format for determining and comparing the accessibility of multiple products under consideration in the bidding process. For example, if a district is accepting proposals for a learning management system, each product’s VPAT can be considered individually, and the collection of VPATs can be used to make a cross-comparison of product accessibility.
  • Offer an entry point to engage in discussions with vendors. While reviewing a VPAT, a procurement team can gather questions about the product. The AEM Center’s Is It Accessible? Questions to Ask is a helpful resource for preparing for conversations with vendors.
  • Document accessibility claims from vendors in order to promote accountability.  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 efforts to resolve the identified issues.
  • Increase awareness of accessibility standards and promote best practices among vendors and developers.   

What are some of the 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.
  • A review of a VPAT should be combined with other strategies and tools for ensuring the procurement of accessible digital materials and technologies. See Acquisition of AEM on the AEM Center website for more guidance on procuring accessible materials. Usability testing by learners who have unique access needs, such as AT users, is highly recommended.
  • 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.  
  • 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.

What does a VPAT® look like?

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 as documentation of a product’s conformance to Section 508.

In the remainder of this section, we will be referencing a VPAT’s ACR for a fictional company called Online Learning Systems that develops and markets an online learning management system for schools, called Online Learning Environment.

Online Learning Environment Accessibility Conformance Report (Exemplar)

Revised Section 508 Edition
VPAT® Version 2.3 -December 2018

Name of Product: Online Learning Environment 2.0
Product Description: Online Learning Environment  is a learning management system (LMS) educators can use to author and deliver online learning courses.  
Date: January 10, 2019
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, 2018.

Accessibility

Access for all people, including people with disabilities, to web environments.

View in glossary

Technology

Equipment or system where principal function is creation, conversion, duplication, control, display, interchange, transmission, reception, or broadcast of data.

View in glossary

Section 504

Prohibits discrimination against qualified individuals with disabilities. Written 504 plan used to guide provision of instructional services.

View in glossary

LMS (Learning Management System)

Software application or system that provides educational programs and their components.

View in glossary

Accessible Educational Materials (AEM)

Print- and technology-based educational materials designed to be usable across the widest range of individual variability.

View in glossary

Accessibility Standards

Current or revised electronic and information technology accessibility standards developed under Section 508 of the Rehabilitation Act.

View in glossary

AEM Center Notes on Date and 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 and Guidelines

This report covers the degree of conformance for the following accessibility standards/guidelines:

Standard Included in Report
Web Content Accessibility Guidelines 2.0, at http://www.w3.org/TR/2008/REC-WCAG20-20081211/ Level A (Yes)
Level AA (Yes)
Level AAA (No)
Revised Section 508 standards as published by the U.S. Access Board in the Federal Register on January 17, 2018

Corrections to the ICT Final Rule as published by the US Access Board in the Federal Register on January 22, 2018 
Yes

AEM Center Notes on Applicable Standards and 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 for most developers 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® 2.3 WCAG

VPAT® 2.3 EU (for Europe)

VPAT® 2.3 INT (incorporates all of the standards)

VPAT® 2.3 Section 508

The rest of the ACR focuses on how the product meets the specific requirements under each standard.

How is conformance to accessibility standards reported in the VPAT®’s ACR?

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® 2.3, the version of the template as of December 2018, are as follows:

  • Supports: The product has at least one method that meets the criterion without known issues.
  • 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 conformance level can only be used for WCAG 2.x 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
  • 501 (Web)(Software)
  • 504.2 (Authoring Tool)
  • 602.3 (Support Docs)
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
  • 501 (Web)(Software)
  • 504.2 (AuthoringTool)
  • 602.3 (Supporting Docs)
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.

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.  

Alt Tag (alternative text)

Brief description of a single image designed to be read by a screenreader as an alternative to the image.

View in glossary

AEM Center Notes on Conformance Tables and Legal Disclaimer

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.

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.