**Summary of Treasury Section 508 Guidance Changes As Issued August 7,
2001**

Note: The **EIT Accessibility Standards Evaluation Spreadsheet
(4/25/01)** had no changes. The **revised Treasury Procurement Section
508 Q&A (Rev. 7/25/01)** and **Solicitation Section M Section 508
Technical Evaluation (Rev. 7/25/01)** were issued 7/26/01 and are
unchanged from that time. **The Section 508 Purchase Cardholder Guidance
(Rev. 8/2/01)** and **Section 508 PIM Summary of Attachments** were
modified only for minor clarifications. The **Treasury Department
Procurement Section 508 Q&A\'s (Rev. 7/25/01)** was initially issued in
June, was revised with input from the Working Group of the Section 508
Interdepartmental Steering Committee, and was reissued 7/26/01. Its
numerous changes deserve review.

  -------------------------------------------------------------------------------------------------------------------------------------------------------------------------
  **Changes**                                        PIM on    D&F for    Commercial         Undue    Decision   IDIQ        Solicitation   SOW   Clauses   Power-Point
                                                     Section   Purchase   Non-Availability   Burden   Tree       Contracts   Section M                      Training
                                                     508       Requests   Cert               Cert                                                           Presenta-tion
  -------------------------------------------------- --------- ---------- ------------------ -------- ---------- ----------- -------------- ----- --------- ---------------
  1\. Minor clarifications                           X         X          X                  X        X          X           X              X     X         X

  2\. Deleted \"subcontracts\" on p. 2 as a          X                                                                                                      X
  categorical acquisition exception to Section 508                                                                                                          
  since deliverables of a subcontract to the federal                                                                                                        
  government, whether indirect or direct, are                                                                                                               
  subject to Section 508. (The PIM is reissued as                                                                                                           
  PIM 01-04, Revision A.)                                                                                                                                   

  3\. Undue Burden explanation expanded.                                                                                                                    X

  4\. Reformatting                                                                                    X                                                     

  5\. Section 3 (e) modified to alert Purchase                 X                                                                                            
  Cardholders that if they are exercising the                                                                                                               
  micropurchase exception, they do [not]{.underline}                                                                                                        
  need to complete the \"Section 508 Determination                                                                                                          
  and Findings for Purchase Requests.\"                                                                                                                     

  6\. New Section 4 added to eliminate from further            X                                      X                                                     
  Section 508 consideration EIT for which no Access                                                                                                         
  Board technical provisions apply, e.g.,                                                                                                                   
  motherboards.                                                                                                                                             

  7\. Section 8 added in order to allow for and                X                                      X                                                     
  emphasize the possibility that an agency may need                                                                                                         
  to complete an undue burden determination on                                                                                                              
  commercial products.                                                                                                                                      

  8\. Revision of Sections 7 and 8 on the 7/25/01              X                                      X                                                     
  revision documents in order to simplify and                                                                                                               
  clarify the process and documentation steps.                                                                                                              

  9\. Warning added just above the certification re:                      X                                                                                 
  conditions triggering the need for an undue burden                                                                                                        
  certification.                                                                                                                                            

  10\. Language from Section 508 Interdepartmental                        X                                                                                 
  Steering Committee procurement FAQ\'s at                                                                                                                  
  [www.section508.gov](http://www.section508.gov/)                                                                                                          
  added under \"Approach\" at the beginning of the                                                                                                          
  \"Addendum\" to provide more guidance on how to                                                                                                           
  work with the Access Board technical provisions.                                                                                                          

  11\. Access Board rule subpart 1194.5 on                                X                                                                                 
  Equivalent Facilitation added to the \"Addendum\"                                                                                                         
  that provides the Access Board technical                                                                                                                  
  provisions.                                                                                                                                               

  12\. Access Board rule subpart 1194.5, which                                                                                              X               
  provides the Access Board technical provisions on                                                                                                         
  Equivalent Facilitation, added as section A.5.                                                                                                            

  13\. The 2^nd^ level certifying official changed                                           X                                                              
  from \"Immediate Supervisor or Manager of the                                                                                                             
  Certifier\'s Office\" to \"Senior Agency                                                                                                                  
  Official\" to broaden the applicability and to                                                                                                            
  better reflect the trend of organizations within                                                                                                          
  and outside Treasury to require higher level                                                                                                              
  certifiers. Added a position title line.                                                                                                                  

  14\. Changed the last paragraph of the suggested                                                               X                                          
  solicitation Section C language to require that a                                                                                                         
  vendor, on 30 days notice from the government,                                                                                                            
  make every effort to upgrade a product not fully                                                                                                          
  satisfying Access Board technical provisions to                                                                                                           
  one that does meet the provisions. It previously                                                                                                          
  stated that the government could request the                                                                                                              
  upgrade on the refresh cycle or exercise of the                                                                                                           
  option year.                                                                                                                                              

  15\. A note added under \"C. Functional                                                                                                   X               
  Performance Criteria\" (1194.31) to explain the                                                                                                           
  role and use of the section, using points from the                                                                                                        
  Section 508 Interdepartmental Steering Committee                                                                                                          
  procurement FAQ\'s at                                                                                                                                     
  [www.section508.gov](http://www.section508.gov/) .                                                                                                        

  16\. RADICALLY revised per the Section 508                                                                                 X                              
  Interdepartmental Steering Committee procurement                                                                                                          
  FAQ\'s (especially E.2) at                                                                                                                                
  [www.section508.gov](http://www.section508.gov/)                                                                                                          
  and direct consultation with the Steering                                                                                                                 
  Committee\'s Working Group staff. Has major                                                                                                               
  implications for procurement evaluations of                                                                                                               
  products and resulting awards. Contract example                                                                                                           
  included. Simplistically stated, Section 508                                                                                                              
  considerations could determine the awardee among                                                                                                          
  offered products meeting minimum agency needs.                                                                                                            
  -------------------------------------------------------------------------------------------------------------------------------------------------------------------------