[Athen] WCAG 2.0 vs Desktop Software

[Zirkle, Kara]

Hello all,

Working with vendors in the procurement phase and referencing WCAG 2.0
level AA compliance I'm beginning to see some push back for desktop
software.  What do you consider an "acceptable" accessibility response and
documentation from a vendor in this case?

PS, please keep in mind the original VPAT I received was from 2014 and I've
asked for an updated version, notified the vendor of the updated standards
and used most of this email along with a manual accessibility report shared
with the vendor requesting a timeline for changes.  The vendor is just
hesitant to provide much of anything aside from an old VPAT.  This is a
common program used in higher education and is installed in most any of our
computer labs.  So to pull it and/or find an alternative is almost
impossible.  We have our internal processes that I know what I need to do
to complete the project and close it, but wanted to give it as an example
to get other peoples thoughts on the accessibility standards and
conversation with vendors around desktop software.  It seems as if keeping
it as a desktop rather than moving it to a cloud allows them to have a loop
hole of less accessibility standards to meet with the current way things
are written.


Since the new Section 508 standard is now in effect and reflects similar to
WCAG 2.0 we still use this as best practice.  While I understand software
is different from web-based applications and websites, many of the UI areas
of WCAG 2.0 still apply as best practice design.

With that said the new 508 standards are in effect, state the following
specific to software:

5. EXPANDED INTEROPERABILITY REQUIREMENTS

The existing standards require ICT to be compatible with assistive
technology—that is, hardware or software that increases or maintains
functional capabilities of individuals with disabilities (*e.g.,* screen
magnifiers or refreshable braille displays). However, in the past the
existing requirement resulted in ambiguity of application. For example,
some agencies interpreted the provisions of existing 36 CFR 1194.21
<https://www.federalregister.gov/select-citation/2017/01/18/36-CFR-1194.21>
(which
addresses software applications and operating systems) as applicable to
assistive technology itself. The ensuing confusion led, in some cases, to
unnecessary delay in procurements intended to provide reasonable
accommodations to employees under Section 501, creating a hardship for both
agencies and their employees with disabilities. The final rule provides
more specificity about how operating systems, software development
toolkits, and software applications should interact with assistive
technology. The final rule also specifically exempts assistive technology
from the interoperability provisions. The Board expects the final rule to
improve software interoperability with assistive technology, allowing users
better access to the functionalities that ICT products provide.
https://www.federalregister.gov/documents/2017/01/
18/2017-00395/information-and-communication-technology-ict-
standards-and-guidelines


I'd love to get other folks thoughts on the accessibility standard for
desktop software.



Kara Zirkle
Accessible Technology Specialist
Information Technology Services
Hoyt Hall, 312V
Oxford, OH 45056
Phone: 513-529-9006
Email: zirklek at miamioh.edu
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