**SUMMARY OF ATTACHMENTS TO TREASURY ACQUISITION BULLETIN, AB 02-10,
ON**

**\"Implementation of Section 508 of the Rehabilitation Act of 1973,
1998 Amendments\"**

**(Revised 8/2/01)**

1.  **Section 508 Determination and Findings for Purchase Requests**

This key tool is for the requiring official to complete even before he
completes his Purchase Request. It walks the customer through the
process of determining whether he has a procurement requirement subject
to Section 508. This form assumes no prior knowledge of Section 508 by
the customer. The customer is required to certify as to his
determination and findings.

Attachments to this Determination & Findings (D&F) document include:
Attachment A, EIT Commercial Non-Availability Certification; Attachment
B, EIT Undue Burden Exception Determination and Certification; and,
Attachment C, Section 508 Decision Tree for Procurement Requestor
Processing.

Attachment A, the EIT Commercial Non-Availability Certification, may
also be used as a standalone document for the requiring official to
document non-availability if receipt of proposals indicates that he was
mistaken to have certified that compliant products were available at the
time of submitting his purchase request.

Attachment B, the EIT Undue Burden Exception Determination and
Certification, would be completed when compliance with any part of the
standards would impose an undue burden. This would typically be
determined either before the completion of the Purchase Request, or
during offer/proposal evaluation.

Attachment C, Section 508 Decision Tree for Procurement Requestor
Processing, graphically portrays the decision process formatted in the
D&F. It may prove most useful to walk a customer through the decision
tree to achieve a general grasp of the decision process before s/he
reviews the text documents of the package.

NOTE: This D&F form should be widely distributed as soon as possible to
procurement customers in order to encourage early understanding of their
responsibilities in implementing Section 508.

2.  **Draft Statement-of-Work (SOW) Section**

This is a self-contained SOW section for insertion in Section C of the
solicitation for other than indefinite delivery indefinite quantity
(IDIQ) contracts. It is a synthesis of both the draft FAR final rule and
the Architectural and Transportation Barriers Compliance Board final
rule (36 CFR Part 1194, Electronic and Information Technology
Accessibility Standards). Although there are 65 separate technical
elements listed under the six standards under Subpart B of the rule,
plus functional performance criteria and other requirements, rarely
would all of them apply to a single EIT product or service. However,
because they are interrelated, they must all be stated together for
cross-reference purposes. This also serves educational purposes.

The SOW Section is rather robust in order to make it easier for vendors
to understand & comply with this new requirement. An alternative would
be to use the SOW Section as written except only make reference to the
Access Board final rule technical provisions, leaving out the full text.
The sequence of this SOW Section is identical to the sequence of the
content of the Access Board Final Rule so that easy cross-reference is
possible. Also, the numbering of the standards and technical provisions
is identical to the Access Board final rule.

3.  **Indefinite Delivery Indefinite Quantity (IDIQ) Contracts**

Since IDIQ contracts themselves are not subject to Section 508 but
ordering against them is, some special considerations exist for them.
This section enables the contracting officer to better manage changes to
Sections C, L and M reflective of the unique status of IDIQ contracts,
including a suggested Section C provision.

4.  **Draft Solicitation Section M Section 508 Technical Evaluation**

This narrative statement provides some guidance on conducting the
proposal technical evaluation vis-à-vis the accessibility standards on
other than IDIQ requirements. An Excel spreadsheet tool has been
developed to assist the contractor in submitting his proposal, and the
customer and contracting officer in evaluating it. It can be used
regardless of the solicitation\'s overall technical evaluation method.
Like the SOW, although the offeror may find several technical provisions
\"not applicable,\" the whole spreadsheet needs to be provided to the
offeror and returned by him due to the interrelationships of the
standards.

The spreadsheets may also be used by the purchase requestor during
market research to more easily assess the comparative compliance of
products.

**5.** **Draft Proposed Treasury Section 508 Clauses**

The representation clause attests to the completeness and accuracy of
the Solicitation Section M Section 508 Technical Evaluation Excel
spreadsheet submission. The representation clause should not be used for
IDIQ solicitations since both compliant and non-compliant supplies and
services may be offered in response to them.

The Warranty clause protects the Government against products found to be
out of compliance with Section 508 as stipulated in the contract, and
provides remedies for correction or replacement.