Attachment_5_-_IT_Accessibility_Questionnaire.pdf

Attachment 5 - IT Accessibility Questionnaire

Service Provider Self-Assessment

1.0 – Executive Summary

2.0 - Instructions

3.0 – IT Accessibility Questionnaire

3.1 – Product or Service Overview

3.2 – Knowledge, skill and ability of the Service Provider

3.3 – Testing Methodology, Tools and Results

3.4 – Functional Performance Criteria Disclosure

3.5 – Applicable Technical Standards Disclosure

3.6 – Information, Documentation and Support Disclosure

3.7 – Operations and Maintenance

4.0 – FAQ’s

5.0 – Technical Standards Explanations

Section 1194.31 Functional Performance Criteria Section 1194.21 Software Applications and Operating Systems Section 1194.22 Web-based Internet information and applications Section 1194.23 Telecommunications Products Section 1194.24 Video and Multi-media Products Section 1194.25 Self-Contained, Closed Products Section 1194.26 Desktop and Portable Computers

6.0 – Attestation Letter: Attachment 1

1.0 – Executive Summary

The Office of the Comptroller of the Currency (OCC) requires all service providers to have the necessary knowledge, skills and abilities to effectively maintain accessibility within all Information Technology (IT) products and services delivered in order to ensure delivery to OCC will meet the needs of the end-users, including those with disabilities.

This publication is based on Section 508 of the Rehabilitation Act of 1973, as amended (29 U.S.C. 794d) which requires that when Federal agencies develop, procure, maintain, or use electronic and information technology, Federal employees with disabilities have access to and use of information and data that is comparable to the access and use by Federal employees who are not individuals with disabilities. Additionally, it requires that individuals with disabilities, who are members of the public seeking information or services from a Federal agency, have access to and use of information and data that is comparable to that provided to the public who are not individuals with disabilities

Once completed, this self assessment will be analyzed by OCC IT Accessibility Program (ITAP) personnel to provide OCC’s contracting officer with a preliminary assessment of the respondents IT Accessibility proficiencies, company knowledge, skill, ability, and tools to implement and maintain accessible solutions. In addition, any commercially available product or service will be evaluated and verified to determine its level of accessibility.

Explanation of terms, concepts, and other items related to IT accessibility requirements can be found in the Frequently Asked Questions (FAQ) section of this publication.

2.0 - Instructions

The self-assessment questionnaire must be filled out by staff responsible for, and knowledgeable of all products or services, management, operational, and technical standards related to IT accessibility that is being recommended as a response to OCC solicitations for an IT solution.

The OCC requires attestations for all self assessments made by its service providers. It is the responsibility of the service provider (respondent to the solicitation) to ensure that any commercially available product being offered or recommended is fully evaluated, and any supporting documentation, including 3rd party documentation provided by the vendor of the commercially available product is accurate.

Once completed, the questionnaire must be reviewed and approved by a senior officer of the organization. Sections 3.0 through 6.0 must be completed which includes a formal attestation letter (Appendix A), and must be submitted as part of any official response to the request for proposal, statement of work, and/or other contracting document.

For each commercially available product that is being recommended as part of a solution, Appendix B must be completed and submitted for review.

Please review the checklist in table 1 below to ensure completeness prior to final submission.

All questions within the self assessment have been completed.

Detailed comments have been provided where appropriate.

Self assessment has been reviewed and approved by knowledgeable staff.

Completion of Appendix B for each commercially available product has been completed and attached.

Attestation letter has been reviewed and signed by a senior officer of the organization.

3.0 – IT Accessibility Questionnaire

3.1 – Product or Service Overview Organizations must ensure that IT products or services used, maintained, developed or procured meet specific Functional Performance Criteria, Technical Standards and Information, Documentation and Support Criteria resulting in the accessibility for all end-users, including those with disabilities.

Response Comments Does the service provider propose an existing commercially available product or service as all-of or part-of the solution? (if yes, please list each)

Yes

1)

2)

3)

4)

No

Does the service provider propose either development activities or customization of any commercially available product or service included in the in the solution? (if yes, list each product or service)

1)

2)

3)

4)

3.2 – Knowledge, skill and ability of the Service Provider Organizations must maintain IT products and services that continually meet the needs of the existing and future workforce as well as members of the public, which includes individuals with disabilities. This requires service providers to the organization to have the knowledge, skills and abilities to develop and maintain accessibility within IT solutions.

Does the service provider have staff that has the knowledge, skill and ability to develop or customize existing commercial products to meet accessibility requirements as listed in the work statement?

Does the service provider have staff that is trained or proficient in the use of tools used by individuals with disabilities, commonly referred to as “Assistive Technologies” such as but not limited to screen readers, screen magnification, etc., who will be responsible for testing and verification of all delivered products and services?

3.3 – Testing Methodology, Tools and Results Organizations must ensure newly acquired or modified IT products and services meet IT Accessibility standards at all times. Test results must be predictable, measurable and repeatable.

Does the service provider have existing test criteria, procedures, etc., documented and followed specifically for the testing of accessibility requirements for all proposed solutions?

Does the service provider conduct their own testing and inspection of any proposed product and service for commercially available products or development activity to (1) validate the level of accessibility according to any documentation provided or created for the product, and (2) to ensure the level of accessibility is known and accurately represented in response to this solicitation?

Does the service provider use Assistive Technology (tools) commonly used by individuals with disabilities in their testing and verification activities?

(if so, please list all tools with version numbers)

Does the service provider use an automated (scan tool) method to evaluate any Web based solution being proposed? (if so, please list)

3.4 – Functional Performance Criteria Disclosure Organizations must specifically support Functional Performance Criteria for users identified by 36 CFR 1193.31 a-f, commonly accomplished by applying technical standards identified by 36 CFR 1194.21, 22, 23, 24, 25 and 26.

NOTE: All of these “Apply” – Please use the comments area to explain answers.

Does the service provider propose a product or service that meets the following criteria? - At least one mode of operation and information retrieval that does not require user vision shall be provided, or support for assistive technology used by people who are blind or visually impaired shall be provided.

At least one mode of operation and information retrieval that does not require visual acuity greater than 20/70 shall be provided in audio and enlarged print output working together or independently, or support for assistive technology used by people who are visually impaired shall be provided.

At least one mode of operation and information retrieval that does not require user hearing shall be provided, or support for assistive technology used by people who are deaf or hard of hearing shall be provided.

Where audio information is important for the use of a product, at least one mode of operation and information retrieval shall be provided in an enhanced auditory fashion, or support for assistive hearing devices shall be provided.

At least one mode of operation and information retrieval that does not require user speech shall be provided, or support for assistive technology used by people with disabilities shall be provided.

At least one mode of operation and information retrieval that does not require fine motor control or simultaneous actions and that is operable with limited reach and strength shall be provided.

3.5 – Applicable Technical Standards Disclosure Organizations must follow Technical Standards, used interchangeably regardless of type of technology, to meet the Functional Performance Criteria with rare exception. For instance, when Web solutions utilize dynamic technical approaches such as Flash, AJAX, DHTML, then both “Web & Software” standards would be applicable, interchangeably.

Identifying and Confirming Applicable Standards:

Does the service provider propose product or service that utilizes any of the following technologies? (check all that apply)

Software Applications, Operating System, Web Intranet or Internet interfaces.

If Yes: Applicable Standards include: 36 CFR 1194.21, 22, & 24.

Telecommunications Products (Including but not limited to “Servers”, “Routers”, “Switches”, etc.)

If Yes, Applicable Standards include: 36 CFR 1194.23

Video and Multimedia products (Including support materials such as training as well as part of the solution)

If Yes, Applicable Standards include: 36 CFR 1194.21, 22 & 24

Self Contained, Closed Products (Including but not limited to printers, copiers, kiosks, etc)

If Yes, Applicable Standards include: 36 CFR 1194.21, 22, 23k & 25

Desktop and Portable Computers

If Yes, Applicable Standards include: 36 CFR 1194.21, 22, 23k & 26

NOTE: Detailed descriptions and explanations are to be explained Attachment 2 for all applicable standards identified above.

3.6 – Information, Documentation and Support Disclosure Organizations must ensure that information, documentation and support services are delivered in an accessible format to those with disabilities, manageable within internal records management systems, and publishable through both Intranet or Internet as needed.

Does the service provider ensure that all documents delivered including administrative documents, product documentation, and all other documents created and delivered will be in electronic format? (if yes, list types of files: PDF, HTML, .DOC, ect.)

Does the service provider ensure all electronic documents meet the technical standards of 36 CFR 1194.22 and the Functional Performance Criteria defined in 36 CFR 1194.31?

(if yes, please describe how this is tested and verified)

Does the service provider have capabilities to communicate with end-users with speech and hearing disabilities in all help-desk or support activities using Teletypewriter (TTY)?

3.7 – Operations and Maintenance Organizations must ensure that operations, updates and modifications, including regression issues to IT services maintain accessibility and comply with all Technical Standards, Functional Performance Criteria and Information, Documentation and Support Criteria.

Does the service provider have processes and procedures that include an evaluation and assurance that new upgrades and modifications to existing IT products and services meet accessibility requirements?

Does the service provider have processes and procedures that monitor existing IT products and services that have content routinely updated or changed such as a Web based interface to ensure accessibility is consistently maintained?

4.0 – FAQ’s

(1) Why does OCC require its service providers to complete this self assessment questionnaire? The Rehabilitation Act of 1973, as amended requires that all Electronic and Information Technology (EIT) procured, developed, maintained or used by OCC meets specific Technical Standards, fulfills specific Functional Performance Criteria, and makes Information, Documentation, and Support services available to individuals with disabilities.

(2) As a service provider, why is it required that we conduct our own testing, including third party vendors we propose within a solution? It is highly recommended that any product you recommend as part of your solution meets requirements outlined in a solicitation. Accessibility is a significant part of those requirements and ultimately the service provider selected will be expected to meet the requirements as documented.

(3) Why do some standards titled “software” apply to a “web” deliverable? Existing standards were written when most Web applications were static or simple HTML. In later years, the Web became much more dynamic to deliver information and functionality in a method that would not meet “Functional Performance Criteria” by using “Web” standards alone. Failing to meet the Functional Performance Criteria would prohibit the use of the application within Federal service. Cross-referencing standards has proven to overcome challenges and meet the Functional Performance Criteria, allowing for the newer technologies to be used.

(4) What if this is a new topic to me and it’s unknown how accessible a product or service is? If selling to the Federal Government is desired, then it is highly recommended that you seek knowledge, whether is from a third party company who specializes in this field. Accessibility is a law that affects all of Government IT systems, not just OCC.

5.0 – Technical Standards Explanations

FUNCTIONAL PERFORMANCE CRITERIA ALWAYS APPLIES

Section 1194.31 Functional Performance Criteria Criteria Supporting Features Remarks and explanations

(a) At least one mode of operation and information retrieval that does not require user vision shall be provided, or support for Assistive Technology used by people who are blind or visually impaired shall be provided.

(b) At least one mode of operation and information retrieval that does not require visual acuity greater than 20/70 shall be provided in audio and enlarged print output working together or independently, or support for Assistive Technology used by people who are visually impaired shall be

(c) At least one mode of operation and user hearing shall be provided, or support for Assistive Technology used by people who are deaf or hard of hearing shall be provided

(d) Where audio information is important for the use of a product, at least one mode of operation and information retrieval shall be provided in an enhanced auditory fashion, or support for assistive hearing devices shall be provided.

(e) At least one mode of operation and user speech shall be provided, or support for Assistive Technology used by people with disabilities shall be provided.

(f) At least one mode of operation and fine motor control or simultaneous actions and that is operable with limited reach and strength shall be provided.

1194.21 – APPLIES to Software Applications, operating systems AND Web-based applications that use non-static HTML approaches such as but not limited to AJAX, DHTML, Flash, etc.

Section 1194.21 Software Applications and Operating Systems

Criteria Supporting Features Remarks and explanations

(a) When software is designed to run on a system that has a keyboard, product functions shall be executable from a keyboard where the function itself or the result of performing a function can be discerned textually.

(b) Applications shall not disrupt or disable activated features of other products that are identified as accessibility features, where those features are developed and documented according to industry standards. Applications also shall not disrupt or disable activated features of any operating system that are identified as accessibility features where the application programming interface for those accessibility features has been documented by the manufacturer of the operating system and is available to the product developer.

(c) A well-defined on-screen indication of the current focus shall be provided that moves among interactive interface elements as the input focus changes. The focus shall be programmatically exposed so that Assistive Technology can track focus and focus changes.

(d) Sufficient information about a user interface element including the identity, operation and state of the element shall be available to Assistive Technology. When an image represents a program element, the information conveyed by the image must also be available in text.

(e) When bitmap images are used to identify controls, status indicators, or other programmatic elements, the meaning assigned to those images shall be consistent throughout an application's performance.

(f) Textual information shall be provided through operating system functions for displaying text. The minimum information that shall be made available is text content, text input caret location, and text attributes.

(g) Applications shall not override user selected contrast and color selections and other individual display attributes.

(h) When animation is displayed, the information shall be displayable in at least one non-animated presentation mode at the option of the user.

(i) Color coding shall not be used as the only means of conveying information, indicating an action, prompting a response, or distinguishing a visual element.

(j) When a product permits a user to adjust color and contrast settings, a variety of color selections capable of producing a range of contrast levels shall be provided.

(k) Software shall not use flashing or blinking text, objects, or other elements having a flash or blink frequency greater than 2 Hz and lower than 55 Hz.

(l) When electronic forms are used, the form shall allow people using Assistive Technology to access the information, field elements, and functionality required for completion and submission of the form, including all directions and cues.

1194.22 – APPLIES to all Web based information and applications. This includes ALL documentation presented in proprietary format such as PDF, MS Word/PowerPoint/Excel, etc.

Section 1194.22 Web-based Internet information and applications

Criteria Supporting Features

Remarks and explanations

(a) A text equivalent for every non-text element shall be provided (e.g., via "alt", "longdesc", or in element content).

(b) Equivalent alternatives for any multimedia presentation shall be synchronized with the presentation.

(c) Web pages shall be designed so that all information conveyed with color is also available without color, for example from context or markup.

(d) Documents shall be organized so they are readable without requiring an associated style sheet.

(e) Redundant text links shall be provided for each active region of a server-side image map.

(f) Client-side image maps shall be provided instead of server-side image maps except where the regions cannot be defined with an available geometric shape.

(g) Row and column headers shall be identified for data tables.

(h) Markup shall be used to associate data cells and header cells for data tables that have two or more logical levels of row or column headers.

(i) Frames shall be titled with text that facilitates frame identification and navigation

(j) Pages shall be designed to avoid causing the screen to flicker with a frequency greater than 2 Hz and lower than 55 Hz.

(k) A text-only page, with equivalent information or functionality, shall be provided to make a web site comply with the provisions of this part, when compliance cannot be accomplished in any other way.

The content of the text-only page shall be updated whenever the primary page changes.

(l) When pages utilize scripting languages to display content, or to create interface elements, the information provided by the script shall be identified with functional text that can be read by Assistive Technology.

(m) When a web page requires that an applet, plug-in or other application be present on the client system to interpret page content, the page must provide a link to a plug-in or applet that complies with 1194.21(a) through (l).

(n) When electronic forms are designed to be completed on-line, the form shall allow people using Assistive Technology to access the information, field elements, and functionality required for completion and submission of the form, including all directions and cues.

(o) A method shall be provided that permits users to skip repetitive navigation links.

(p) When a timed response is required, the user shall be alerted and given sufficient time to indicate more time is required.

Section 1194.23 Telecommunications Products

Criteria Supporting Features Remarks and explanations

(a) Telecommunications products or systems which provide a function allowing voice communication and which do not themselves provide a TTY functionality shall provide a standard non-acoustic connection point for TTYs. Microphones shall be capable of being turned on and off to allow the user to intermix speech with TTY use.

(b) Telecommunications products which include voice communication functionality shall support all commonly used cross-manufacturer non-proprietary standard TTY signal protocols.

(c) Voice mail, auto-attendant, and interactive voice response telecommunications systems shall be usable by TTY users with their TTYs.

(d) Voice mail, messaging, auto-attendant, and interactive voice response telecommunications systems that require a response from a user within a time interval, shall give an alert when the time interval is about to run out, and shall provide sufficient time for the user to indicate more time is required.

(e) Where provided, caller identification and similar telecommunications functions shall also be available for users of TTYs, and for users who cannot see displays.

(f) For transmitted voice signals, telecommunications products shall provide a gain adjustable up to a minimum of 20 dB.

For incremental volume control, at least one intermediate step of 12 dB of gain shall be

(g) If the telecommunications product allows a user to adjust the receive volume, a function shall be provided to automatically reset the volume to the default level after every use.

(h) Where a telecommunications product delivers output by an audio transducer which is normally held up to the ear, a means for effective magnetic wireless coupling to hearing technologies shall be provided.

(i) Interference to hearing technologies

(including hearing aids, cochlear implants, and assistive listening devices) shall be reduced to the lowest possible level that allows a user of hearing technologies to utilize the telecommunications product.

(j) Products that transmit or conduct information or communication, shall pass through cross-manufacturer, non-proprietary, industry-standard codes, translation protocols, formats or other information necessary to provide the information or communication in a usable format.

Technologies which use encoding, signal compression, format transformation, or similar techniques shall not remove information needed for access or shall restore it upon delivery.

(k)(1) Products which have mechanically operated controls or keys shall comply with the following: Controls and Keys shall be tactilely discernible without activating the controls or keys.

(k)(2) Products which have mechanically the following: Controls and Keys shall be operable with one hand and shall not require tight grasping, pinching, twisting of the wrist.

The force required to activate controls and keys shall be 5 lbs. (22.2N) maximum.

(k)(3) Products which have mechanically the following: If key repeat is supported, the delay before repeat shall be adjustable to at least 2 seconds. Key repeat rate shall be adjustable to 2 seconds per character.

(k)(4) Products which have mechanically the following: The status of all locking or toggle controls or keys shall be visually discernible, and discernible either through touch or sound.

Section 1194.24 Video and Multi-media Products Criteria Supporting Features Remarks and explanations

(a) All analog television displays 13 inches and larger, and computer equipment that includes analog television receiver or display circuitry, shall be equipped with caption decoder circuitry which appropriately receives, decodes, and displays closed captions from broadcast, cable, videotape, and DVD signals. As soon as practicable, but not later than July 1, 2002, widescreen digital television (DTV) displays measuring at least 7.8 inches vertically, DTV sets with conventional displays measuring at least 13 inches vertically, and stand-alone DTV tuners, whether or not they are marketed with display screens, and computer equipment that includes DTV receiver or display circuitry, shall be equipped with caption decoder circuitry which appropriately receives, decodes, and displays closed captions from broadcast, cable, videotape, and DVD signals.

(b) Television tuners, including tuner cards for use in computers, shall be equipped with secondary audio program playback circuitry.

(c) All training and informational video and multimedia productions which support the agency's mission, regardless of format, that contain speech or other audio information necessary for the comprehension of the content, shall be open or closed captioned.

(d) All training and informational video and multimedia productions which support the agency's mission, regardless of format, that contain visual information necessary for the comprehension of the content, shall be audio described.

(e) Display or presentation of alternate text presentation or audio descriptions shall be user-selectable unless permanent.

Section 1194.25 Self-Contained, Closed Products

(a) Self contained products shall be usable by people with disabilities without requiring an end-user to attach Assistive Technology to the product. Personal headsets for private listening are not Assistive Technology.

(b) When a timed response is required, the user shall be alerted and given sufficient time to indicate more time is required.

(c) Where a product utilizes touchscreens or contact-sensitive controls, an input method shall be provided that complies with §1194.23 (k) (1) through (4).

(d) When biometric forms of user identification or control are used, an alternative form of identification or activation, which does not require the user to possess particular biological characteristics, shall also be provided.

(e) When products provide auditory output, the audio signal shall be provided at a standard signal level through an industry standard connector that will allow for private listening. The product must provide the ability to interrupt, pause, and restart the audio at anytime.

(f) When products deliver voice output in a public area, incremental volume control shall be provided with output amplification up to a level of at least 65 dB. Where the ambient noise level of the environment is above 45 dB, a volume gain of at least 20 dB above the ambient level shall be user selectable. A function shall be provided to automatically reset the volume to the default level after every use.

(g) Color coding shall not be used as the only means of conveying information, indicating an action, prompting a response, or distinguishing a visual element.

(h) When a product permits a user to adjust color and contrast settings, a range of color selections capable of producing a variety of contrast levels shall be provided.

(i) Products shall be designed to avoid causing the screen to flicker with a frequency greater than 2 Hz and lower than 55 Hz.

(j) (1) Products which are freestanding, non-portable, and intended to be used in one location and which have operable controls shall comply with the following: The position of any operable control shall be determined with respect to a vertical plane, which is 48 inches in length, centered on the operable control, and at the maximum protrusion of the product within the 48 inch length on products which are freestanding, non-location and which have operable controls.

(j)(2) Products which are freestanding, non-location and which have operable controls shall comply with the following: Where any operable control is 10 inches or less behind the reference plane, the height shall be 54 inches maximum and 15 inches minimum above the floor.

(j)(3) Products which are freestanding, non-location and which have operable controls shall comply with the following: Where any operable control is more than 10 inches and not more than 24 inches behind the reference plane, the height shall be 46 inches maximum and 15 inches minimum above the floor.

(j)(4) Products which are freestanding, non-location and which have operable controls shall comply with the following: Operable controls shall not be more than 24 inches behind the reference plane.

Section 1194.26 Desktop and Portable Computers

(a) All mechanically operated controls and keys shall comply with §1194.23 (k) (1) through (4).

(b) If a product utilizes touchscreens or touch-operated controls, an input method shall be provided that complies with §1194.23 (k) (1) through (4).

(c) When biometric forms of user identification or control are used, an alternative form of identification or activation, which does not require the user to possess particular biological characteristics, shall also be provided.

(d) Where provided, at least one of each type of expansion slots, ports and connectors shall comply with publicly available industry standards

6.0 – Attestation Letter: Attachment 1

1. To the best of my knowledge, statements made in response to the Office of the Comptroller of the Currency’s “IT Accessibility Self Assessment” dated _____________ are accurate;

2. Statements made in response to the Office of the Comptroller of the

Currency’s “IT Accessibility Self Assessment” were made by knowledgeable and qualified professionals in the internal control structure of my organization;

3. The undersigned attests to the completeness and accuracy of the applicable responses made in support of submitting Office of the Comptroller of the Currency’s “IT Accessibility Self Assessment.”

4. The undersigned has authority to legally bind ________________ and has been authorized to do so.

Corporate Officer (Signature) Witness (Signature)

Printed Name/Title Printed Name/Title

Date Date