# Presentation: 735197

## Consideration of ODIN and Section 508

- Bankcard Training
- November 2006
- Arthur Beller

## Topics

- Bankcard Holder
- Approving Official
- References
- See Backup Material for details on
- IT, EIT, and Imbedded IT
- Consideration of ODIN
- Section 508

## Bankcard Holder

- Properly identify information technology (IT) and electronic and information technology (EIT)
- If you are an order taker, ensure that the individual with the requirement identifies to you
- IT and EIT

## Bankcard Holder

- Consideration of ODIN applies to IT and EIT
- Determine whether to purchase from ODIN
- KDP-KSC-P-1838
- Document reason to not purchase from ODIN
- Order Log Comments
- If you are an order taker, ensure that the individual with the requirement provides to you
- ODIN due diligence statement
- Price data comparisons (if ODIN due diligence statement is “ODIN: Purchase of IT item from other sources is in the best interest of the government.”)

## Bankcard Holder

- Section 508 applies to EIT
- Perform market research
- Determine compliance
- Document EIT and compliance
- Order Log radio buttons
- Document market research
- Order Log Comments, or
- Bankcard files
- If you are an order taker, ensure that the individual with the requirement provides to you
- EIT and Section 508 compliance determination
- Market research records

## Approving Official

- Check for the proper identification of IT and EIT
- Consideration of ODIN applies to IT and EIT
- Check reason to not purchase from ODIN
- Order Log Comments

## Approving Official

- Section 508 applies to EIT
- Check EIT determination and compliance determination
- Order Log radio buttons
- Check market research documentation
- Order Log Comments, or
- Bankcard files

## References

- Consideration of ODIN
- KDP-KSC-P-1838 Consideration of ODIN as the Source of Information Technology
- Section 508
- http://section508.nasa.gov/
- SATERN: PROC-001-05 NASA Purchase Card Program
- Sample Procedure Form
- ODIN Catalog

## Backup Material

- IT, EIT, and Imbedded IT
- Consideration of ODIN
- Section 508

## Section: IT, EIT, and Imbedded IT

- Definitions
- Examples
- Reference
- Guidance

## FAR Definition: IT (1 of 3)

- “Information technology” means
- any equipment, or interconnected system(s) or subsystem(s) of equipment,
- that is used in the automatic acquisition, storage, manipulation, management, movement, control, display, switching, interchange, transmission, or reception
- of data or information by the agency.

## FAR Definition: IT (2 of 3)

- 	(1) For purposes of this definition, equipment is used by an agency if the equipment is used by the agency directly or is used by a contractor under a contract with the agency that requires—
- (i) Its use; or
- (ii) To a significant extent, its use in the performance of a service or the furnishing of a product.
- 	(2) The term “information technology” includes computers, ancillary equipment, software, firmware and similar procedures, services (including support services), and related resources.

## FAR Definition: IT (3 of 3)

- 	(3) The term “information technology” does not include any equipment that—
- (i) Is acquired by a contractor incidental to a contract;
- (ii) Contains imbedded information technology that is used as an integral part of the product, but the principal function of which is not the acquisition, storage, manipulation, management, movement, control, display, switching, interchange, transmission, or reception of data or information.
- For example, HVAC (heating, ventilation, and air conditioning) equipment, such as thermostats or temperature control devices, and medical equipment where information technology is integral to its operation, are not information technology.

## FAR Definition: EIT (1 of 2)

- “Electronic and information technology (EIT)” has the same meaning as “information technology” except EIT also includes
- any equipment or interconnected system or subsystem of equipment
- that is used in the creation, conversion, or duplication of data or information

## FAR Definition: EIT (2 of 2)

- The term EIT, includes, but is not limited to
- telecommunication products
- such as telephones
- information kiosks and transaction machines
- worldwide websites
- multimedia
- office equipment
- such as copiers and fax machines

## GSA Wizard

- A web-based tool to help users determine and document Section 508 requirements that apply to a particular E&IT acquisition
- http://www.buyaccessible.gov/

## GSA Wizard Categories: EIT

- Audio / Visual Product
- Communication Device
- Computer and Office
- Electronics
- Miscellaneous

## GSA Wizard Examples: EIT

- Audio / Visual Product
- Headset
- Microphone
- Projector

## GSA Wizard Examples: EIT

- Communication Device
- Phone
- Telephone Answering Machine
- Telephone Headset
- Walkie Talkie

## GSA Wizard Examples: EIT

- Computer and Office

| - Computer Accessories | - PDS / Cell phone |
| --- | --- |
| - Copier | - PDA holder / charger |
| - Desktop Computer | - Printer / Plotter |
| - Digital Camera |  Scanner |
| - Digital Sender |  Server |
|  Fax | - Software and Operating Systems |
| - Handheld / PDA | - Thin Clients |
| - Laptop / Notebook Computer | - Workstation Computer |

## GSA Wizard Examples: EIT

- Electronics
- Computer Monitor
- Converter or Set top Box
- DVD
- Network Device
- Printer / Plotter
- R/F Modulator
- TV
- VCR

## GSA Wizard Examples: EIT

- Miscellaneous
- Bar Code Reader
- Dictaphone

## Examples: not EIT

- Cables
- Connectors
- Incidental hardware such as nuts and bolts
- Internal computer case components such as
- cards
- memory
- hard drives
- Products that a technician, not a user, would normally access for set up and configuration

## Reference: Section 508

- _[Section 508 of the Rehabilitation Act](http://www.section508.gov/index.cfm?FuseAction=Content&ID=14)__ requires that when Federal agencies develop, procure, maintain, or use electronic and information technology, they shall ensure that this technology allows: _
- Federal employees with disabilities to have access to and use of information and data that is comparable to that by Federal employees who are not individuals with disabilities, unless an undue burden would be imposed on the agency, and
- Individuals with disabilities, who are members of the public seeking information or services from a Federal agency, to have access to and use of information and data that is comparable to that provided to the public who are not individuals with disabilities.

## Guidance: EIT

- Will Federal employees need to interact with a product in order to have access to and use of information and data ?
- Will members of the public seeking information or services from a Federal agency need to interact with a product in order to have access to and use of information and data ?
- A “Yes” to either question means the product is generally EIT.

## FAR Definition: Imbedded IT

- Information technology that is used as an integral part of the product
**but the principal function of which is not the acquisition, storage, manipulation, management, movement, control, display, switching, interchange, transmission, or reception of data or information. **
- For example, HVAC (heating, ventilation, and air conditioning) equipment, such as thermostats or temperature control devices, and medical equipment where information technology is integral to its operation, are not information technology.

## Examples: Imbedded IT

## Guidance: Imbedded IT

- If imbedded IT requires an IT security plan then it is recategorized as IT.
- In general imbedded IT is not EIT.

## Section: Consideration of ODIN

- KDP-KSC-P-1838
- Objectives
- Diligence
- Flow
- Predicates
- Notes with examples

## Objectives

- Ensure effective implementation and control of Administrative IT at the Center
- Ensure that ODIN is considered as the primary source for platforms with ODIN equivalents (desktops, laptops, workstations, and network printers), and for the augmentation of ODIN seats.

## Slide 31

## Statement Predicates: non ODIN Procurement

## Statement Predicates: non ODIN Procurement

## Note 1: Administrative IT (1 of 2)

- This category includes
- systems
- applications
- information
- that support NASA's daily activities, such as
- electronic mail
- forms processing
- networking
- management reporting

## Note 1: Administrative IT (2 of 2)

- Administrative information includes, but is not limited to
- electronic correspondence
- briefing information
- project/program status
- infrastructure design details
- pre-decisional notes
- vulnerability descriptions
- passwords
- internet protocol addresses
- Organizations run various applications—from problem reports to configuration management tools—on administrative IT systems.

## Examples: Not Administrative IT

- Laboratory specific IT
- Mission specific IT

## Note 2: ODIN Platforms

- ODIN platforms are essentially computers.
- Examples are desktops, laptops, workstations, and network printers.
- The current list of ODIN platforms is PC, Apple, UNIX, Printers, and PC Tablet.
- Printer platforms intended for network applications are included for consideration.
- Server platforms are excluded from consideration.
- Information is available at the KSC ODIN Home Page, http://odin/Default.htm.
- Consult with your ODIN Organizational Representative or with Office Automation Services as needed.

## Note 3: ODIN Waivers

- The waiver process for machines is documented in KDP-KSC- P-3313 ODIN Waiver Process.
- Typical waivers are for maintenance only (MA) machines, network attached device (NAD) machines, and standalone machines.
- Both new and replacement machines require waivers.
- Approved ODIN Waivers are maintained by Office Automation Services.
- The hardware upgrades, internal and external peripherals, and software associated with these machines are included in the waiver.

## Note 4: ODIN Exclusion List

- Communication equipment external to ODIN workstations.
- ADP supplies
- Includes all supplies, materials, parts, components, assemblies, publications and equipment ordinarily consumed or expended within one year, which do not meet the criteria for capitalization.
- Excludes charges for software purchases, licenses and leases.
- IT training material

## Examples: ODIN Exclusion List

- Communications equipment external to ODIN workstations
- External fax modem
- ADP Supplies
- Printer paper
- Toner cartridges
- Transparencies
- Blank media

## Note 5: Due Diligence (1 of 2)

- If a determination is made to create a purchase request, follow KDP-KSC-P-1519, Purchase Request Process, and select the NASA IT PR Document type.
- If a determination is made to create a bankcard acquisition, follow KDP-KSC-P-1652, Bankcard Acquisitions by Noncontracting Personnel.

## Note 5: Due Diligence (2 of 2)

- Requisitioners shall annotate the purchase requisition header or the bankcard comments field with the statement corresponding to their exit path through the process flow:
- 1) ODIN: IT item is not administrative IT.
- 2) ODIN: ODIN waiver has been initiated for IT item.
- 3) ODIN: IT item is not for augmentation of ODIN Seat.
- 4) ODIN: IT item is covered by documented, approved ODIN waiver.
- 5) ODIN: IT item is on the exclusion list.
- 6) ODIN: IT item is not available from ODIN.
- 7) ODIN: Purchase of IT item from other sources is in the best interest of the government.

## Guidance: Annotation

- ODIN due diligence statement goes in Comments
- Choose only ONE statement
- Corresponds to your earliest exit from the flow
- There are 7 statements
- Example
- ODIN: 1) IT item is not administrative IT.

## Note 6: Best interest of the Government

- "In the best interest of the Government" allows the requisitioner to use judgment when the cost from ODIN is greater than the cost from other sources.
- Specifically if the item is external to a machine, and the ODIN cost exceeds 20% of the best commercial price, then it is clearly "in the best interest of the Government" to purchase from other sources.

## Section: Section 508

- SATERN: PROC-001-05 NASA Purchase Card Program: Section 508 portion
- Sample Procedure Form
- Technical Standards

## PROC-001-05: Section 508

- Did you know that when procuring, developing, maintaining or using Electronic and Information Technology (EIT) that agencies must ensure that
- employees with disabilities have access to and use of information and data that is comparable to that for other employees; and
- members of the general public with disabilities seeking information or services from an agency have access to and use of information and data that is comparable to that for members of the public without disabilities?

## PROC-001-05: Section 508

- Section 508 (found at 29 U.S.C. 794d) refers to a section in the Rehabilitation Act of 1973, which was amended by the _[Workforce Investment Act of 1998](http://www.usdoj.gov/crt/508/508law.html)__ (P.L. 105-220). _
- Its primary purpose is to provide access to and use of Federal executive agencies' EIT by individuals with disabilities.
- The statutory language of Section 508 can be found at http://www.section508.gov.

## PROC-001-05: Section 508

- Starting April 1, 2005, micro-purchases (generally those purchases made through the P-Card process) will be required to conform with Section 508 of the Rehabilitation Act.
- EIT includes information technology and equipment or interconnected systems or subsystems of equipment that is used to create, convert, or duplicate data or information.

## PROC-001-05: Section 508

- EIT also includes, but is not limited to:
- Software applications, and operating systems
- Web based information or applications
- telecommunications products
- video and multimedia products
- self contained – closed products
- such as information kiosks, calculators, and fax machines
- desktop and portable computers

## PROC-001-05: Section 508

- More detail of the kinds of products and accessibility standards related to these products and services may be found in the document entitled "*Section 508 for Purchase Card*" found on the NASA 508 homepage at: http://www.section508.nasa.gov/.

## PROC-001-05: Section 508

- There area a limited number of exceptions.
- Items/services acquired with the purchase card should be for commercially available items.
- Exceptions will rarely if ever be appropriate.
- In addition, you are not required to fundamentally alter your needs in order comply with Section 508.

## PROC-001-05: Section 508

- For more information go to the "*Guide to Section 508 Standards for Electronic and Information Technology*" website
- 	(http://www.access-board.gov/sec508/guide/index.htm)
- 	which provides an explanation of the various criteria in easy to understand language.
- Also contact your 508 Coordinator in your Center CIO's office.

## PROC-001-05: Section 508What are the Steps for Cardholders? (1 of 3)

- Do I have an EIT requirement?
- Which of the Access Board Standards apply?
- For assistance see:http://www.access-board.gov/sec508/guide/index.htm

## PROC-001-05: Section 508What are the Steps for Cardholders? (2 of 3)

- 3.	Conduct market research – call vendors, visit vendor Internet sites, other government agencies, etc.
- Is there a 508 compliant product available in the commercial market place?
- Commercial item and none or some (but not all) of the access board standards can be met in time to satisfy requirements?
- Obtain technical assistance of Center 508 coordinators when necessary.
- ODIN catalog
- Links to vendor Section 508 information

## PROC-001-05: Section 508What are the Steps for Cardholders? (3 of 3)

- 4.	Acquire 508 compliant commercially available goods/services as appropriate.
- 5.	Document in the Comments Section of your order log and/or other files the sources contacted and whether EIT acquired items are 508 compliant or whether market research indicates that no 508 compliant (or only partially compliant) products or services are commercially available in time to meet your delivery requirements.
- Keep copies of all documentation with your purchase card records.

## Sample Procedure Form

- Sample Procedure for Purchase Card E&IT Purchases
- http://www.grc.nasa.gov/WWW/Purchase/Documents/BCMarketResearch22.doc
- <KSC link>

## PROC-001-05: Section 508Help Desk (1 of 3)

- The purpose of the Help Desk is to provide NASA personnel and contractors (e.g., Engineers, Software/Web Developers, etc.) with a facility to request information and assistance in complying with Section 508 of the Rehabilitation Act.
- The Help Desk is available via email to provide information and research regarding Section 508 compliance requirements and to coordinate requests for 508 compliance reviews.

## PROC-001-05: Section 508Help Desk (2 of 3)

- The Help Desk is not intended to replace the market research and similar activity required by NASA policies nor is it intended to replace Center resources, but to assist Centers in areas in which they are having difficulty complying with Section 508 requirements. The E-mail address is Section508Help@hq.nasa.gov.

## PROC-001-05: Section 508Help Desk (3 of 3)

- For specific technical inquiries, the Center 508 Coordinators should be contacted.
- Arthur Beller
- (321) 867-2759
- Arthur.E.Beller@nasa.gov
- Isolda Galiana-Liang *(Alternate/Backup)*
- (321) 861-2235
- Isolda.I.GalianaLiang@nasa.gov

## Technical Standards: Categories

- Software Applications and Operating Systems (1194.21)
- Web-based Intranet and Internet Information and Applications(1194.22)
- Telecommunications Products (1194.23)
- Video and Multimedia Products (1194.24)
- Self Contained, Closed Products (1194.25)
- Desktop and Portable Computers (1194.26)

## Example: Voluntary Product Accessibility Template (VPAT) (Partial)