**Treasury Section 508 Purchase Cardholder Guidance**

**(Revised 3/6/02)**

**Introduction:** Section 508 is a new law with accompanying regulations
that requires that the federal government only purchase \"electronic and
information technology\" goods and services that provide for
accessibility by individuals with disabilities among federal employees
and the public. This law has numerous benefits for the federal
government, the public at large, and individuals with disabilities, such
as the blind and the deaf. **Effective June 25, 2001, Section 508
affected how you may use your purchase card to buy \"electronic and
information technology\" products and services.**

1.  **What is covered by Section 508 as \"electronic and information
    technology?\"**

This term has a broad formal definition in Section 508. For our
purposes, you can consider it as including anything of an electronic
nature or anything that can in any way be considered information
technology. This includes data systems and equipment, all forms of Web
sites, telecommunication products such as telephones, office equipment
such as copiers and fax machines, computers, monitors, printers,
software, firmware, and computer peripheral equipment. It is difficult
to identify any form of electronic or information technology service or
physical product that would not be included. (Refer to the Treasury
Office of Procurement Web page on Section 508 at
[www.treas.gov/procurement/508](../www.treas.gov/procurement/508) for
the formal definition and more details.)

2.  **What is the Section 508 [exception]{.underline} for
    micro-purchases?**

If the card is used for a *[one-time,]{.underline}*
*[open-market]{.underline}* purchase of *[\$2,500 or less]{.underline}*
and the action occurs *[prior to January 1, 2003]{.underline}*, the
action will **[not]{.underline}** be covered by Section 508. However,
buyers are strongly encouraged to comply with the Section 508
accessibility standards to the maximum extent practicable.

However, if the purchase occurs on or after January 1, 2003, it
**[will]{.underline}** be covered. Also, if the card is used to pay any
amount for an order placed against an existing contract (such as an
indefinite-quantity contract), the action **[will]{.underline}** be
covered. (See question #4 below for examples of \"indefinite quantity
contracts.\")

**3. Does the Section 508 micro-purchase exception cover
[all]{.underline} purchases under \$2,500?**

No. The exception is for a *[one-time]{.underline}* purchase that
*[totals \$2,500 or less]{.underline}*, made *[before January 1,
2003]{.underline}*, on the *[open market]{.underline}* as opposed to
under an existing procurement action. A software package that costs
\$1800 is not a micro-purchase if it is part of a \$3,000 purchase
requirement \-- or a \$3,000,000 purchase requirement.

**4. Beginning June 25, 2001, did Section 508 cover micro-purchases made
against the Federal Supply Schedule, Government-Wide Acquisition
Contracts (GWACs), multi-agency contracts, IDIQ contracts, Blanket
Purchase Agreements (BPAs), and Blanket Ordering Agreements (BOAs)?**

Yes, because they are not micro-purchases made on the
*[open]{.underline}* market. However, the contracting officers
responsible for these contracts are required to have the contractors
provide a list of the conforming and non-conforming products being
offered to make your purchasing easier. So, you will be able to easily
proceed with your purchase of conforming products.

**5.** **How do I know whether the \"electronic and information
technology\" product that I want to buy is conforming to Section 508?**

The best way for the foreseeable future to determine whether a
particular product is Section 508 conforming is to have the seller
certify to you in writing whether it is conforming, which means fully
satisfies all technical provisions of the Section 508 Access Board final
rule. Over time, more and more products and services will become
conforming. The commercial marketplace will not want to lose business
opportunities with the government since the government must try to buy
conforming products and services. For some time, you may be able to
identify only [partially]{.underline} conforming products and services.
In these cases, you must purchase the most conforming product or service
that meets your needs.

Under \"Buy Accessible\" on the GSA Section 508 Web site
(<http://www.section508.gov/buy_accessible/main.cfm>), a partnership
between government and industry, the [Information Technology Industry
Council (ITI)](http://www.itic.org/) is hosting a [Voluntary Product
Accessibility Template](http://www.itic.org/policy/access_0106.htm) on
their site. It allows vendors who choose to participate the ability to
copy the template and complete it to describe how a particular product
or service they offer conforms to Section 508 Access Board standards.
This template would be placed on the vendor\'s accessible web site, and
the link to the template provided to the Buy Accessible database.

**6. If I cannot find a Section 508 conforming product or service at the
micro-**

**purchase level under an existing contract and none exists in the open
market, would it be better to buy a non-conforming product from the open
market under the available micro-purchase exception?**

Generally, yes, if the price and other factors are reasonable and it
meets your needs. This is because there may be significant Section 508
paperwork and possibly time involved if you buy the non-conforming
product or service under an existing indefinite quantity acquisition
vehicle for which you cannot take advantage of the exception.

**7.** **If I am procuring EIT under a GSA contract, costing \$2,500\
or less, using the purchase card, am I required to complete a
Determination & Finding (D&F) since the micro-purchase exception does
not apply? If so, what do I do with the completed Determination &
Finding since there will be no procurement order prepared?**

If you are using the purchase card under the conditions stated (the GSA
contract is an indefinite delivery indefinite quantity (IDIQ) not itself
subject to Section 508), the D&F would have to be completed. Retention
location of the D&F is a local bureau procurement matter, however, it
needs to be appropriate for audit and review purposes. One practical
place for it would be with the monthly purchase card order log, which
would have the receipt and summary information about the specific
purchase. (Refer to the Treasury Office of Procurement Web page on
Section 508 at
[www.treas.gov/procurement/508](../www.treas.gov/procurement/508) for
more details.)

**8. What do I have to do if I have to make an \"electronic and
information technology\" micro-purchase?**

First, you need to ensure that you are sufficiently familiar with the
requirements of Section 508 compliance so that you are proceeding
appropriately. This brief overview that you are reading may suffice, or
you may need to contact your procurement office or refer to the Treasury
Office of Procurement Web page on Section 508 at
[www.treas.gov/procurement/508](../www.treas.gov/procurement/508).

Second, you need to do some market research to determine whether your
required product or service exists in the commercial marketplace in
conforming form through existing contracts. (This may be done by phone,
over the Internet, or by other means.) If a conforming product or
service is not available through an existing contract, you should
purchase the requirement from the open market while attempting to
acquire the most conforming product that meets your overall needs.

If you were to decide that you still wanted to purchase the partially
conforming or non-conforming product through an existing contract, you
would be required to complete considerable paperwork possibly requiring
significant additional time. Contact your bureau procurement office if
you choose this more difficult option.

9.  **Why is the micro-purchase exception temporary?**

The Federal Acquisition Regulation (FAR) provides an exemption for
micro-purchases until January 1, 2003. Program officials (that is, end
users) conduct many micro-purchases with the help of government-wide
purchase cards. The temporary exception reflects the difficulty program
officials face in identifying conforming products before industry
manufacturing and labeling of conforming products becomes commonplace.
By the time this exception expires, many products are expected to
conform with the standards, and may be so labeled by the manufacturer.
In the meantime, contracting officers and purchase cardholders are
strongly encouraged to comply with the applicable Section 508
accessibility standards, to the maximum extent practicable, in buying
products and services.

**WANT MORE INFO???** If you would like more details about Section 508
standards or requirements, in general or as relates to procurement
activity, please refer to the Treasury Office of Procurement Web page on
Section 508 at
[www.treas.gov/procurement/508](../www.treas.gov/procurement/508). There
is considerable additional federal government information on Section 508
at [www.section508.gov](http://www.section508.gov/).