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General.Zhukov

Section 508

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I work in Department of Health and Human Services (HHS).  The HHSAR covers Accessibility/Section 508 using language that I am increasingly convinced I don't understand.  Two part question.

HHSAR 339

(1) When conducting a procurement and employing the best value continuum, the solicitation shall include a separate technical evaluation factor developed by the contracting officer, requiring activity, and the Operating Division (OPDIV) Section 508 Official or designee.

  • The word "continuum" occurs only once in the FAR,  in 15.101.  I take HHSAR 339 (1) to mean that for any IT procurement either
    • If using FAR 15 procedures,  there must be a separate Accessibility/508 evaluation factor or 
    • If using 'best value,' there must be a separate Accessibility/508 evaluation factor.   And everything is 'best value.'

 

  • So far as I know, nobody in HHS actually follows either of these interpretations (check FBO if you don't believe me).  I've always considered this fact to be a case of ignoring an unreasonable regulation, but maybe I am misinterpreting the regs.  What do you think here?

(2) At a minimum, solicitations for supplies and services shall require the submission of a Section 508 Product Assessment Template (See http://www.hhs.gov/web/508 for the template). Solicitations for services shall include any other pertinent information that the contracting officer deems necessary to evaluate the offeror's ability to meet the applicable Section 508 accessibility standards.

 

A colleague recently was purchasing a RAM upgrade for some of our servers.  Along with the RAM itself, installation services and add-on warranty + maintenance.  She has found herself in the absurd situation of being told she must have a section 508 Product Assessment Template (PAT) for this purchase. 

She has asked me: A PAT for what?    I have no answer.  For RAM, which is an expensive hunk of metal and plastic? For installation services?  For warranty and maintenance - of RAM?  The warranty and maintenance is for the whole server, not some sub-component of it.  The server (and indeed the whole server farm) already has a comprehensive maintenance contract that is indeed 508 compliant. 

  • Does the HHSAR requirement for a PAT even make sense here?  If so, how?

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Maybe I'm grossly misunderstanding this, but wouldn't RAM for servers typically fall under an exception for Section 508, specifically that at FAR 39.204(d):

Quote

The requirements in 39.203 do not apply to EIT that--

. . . 

(d) Is located in spaces frequented only by service personnel for maintenance, repair or occasional monitoring of equipment;

Given that understanding, I don't know why any HHS policies relevant to Section 508 would apply. But I have no experience with HHSAR.

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