HHS cannot accept ICT without proper documentation of the accessibility of the features of the product or services being offered. Note: The verbiage requires you, as a vendor to maintain your solution to the accessibility indicated on your submission. Remediation to your claimed accessibility is the vendor’s responsibility, at no additional cost to the government.
ICT vs. EIT
In various places throughout HHS procurements and other Federal agencies’ contracting documents, you will see references to “EIT” (Electronic and Information Technology) and “ICT” (Information and Communications Technology). HHS considers these terms to be interchangeable, and “EIT” should always be interpreted to be “ICT” in any HHS procurement or grant.
The HHS PAT
Doing Business with HHS? You will likely see a reference in your contract to the HHS PAT (Product Accessibility Template). Submission of this form is often required as part of a solicitation response, and failing to submit may be grounds for disqualification of a submission.
- A VPAT version 2.0 or later, filled out to instructions, is considered to meet the HHS PAT requirement. The form can be downloaded from https://www.itic.org/policy/accessibility/vpat.
- You must fill out all standards that the solicitation indicates are applicable, even if you consider them not applicable to YOUR solution’s features. If you claim a standard as not applicable, you will need to detail WHY the standard is not applicable (e.g. “Our solution does not include multimedia, so the captioning requirement is not applicable”).
- VPATs/HHS PATs are evaluated on both Quantitative (all applicable standards filled out) and qualitative (quality and detail of information provided) factors. Detail is important here
You can always submit additional information, such as a description of your accessibility programs and partnerships, or of QA processes you may have for accessibility.