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CSULB Year 2 Procurement Report, August 15, 2008

In compliance with the Americans with Disabilities Act of 1990 (ADA), Section 508 of the 1973 Rehabilitation Act (as amended in 1998), and California State University Coded Memorandum AA-2007-04, annual reporting of the implementation of the Accessible Technology Initiative is required of all CSU campuses. This report focuses on Priority Three: Accessible Electronic and Information Technology (E&IT) Procurement, due August 15, 2008.

The topics identified in this form address your original plan from 2007 and provide a narrative description of your progress as well as obstacles in achieving your goals. Please provide updates to your original plan, reporting on significant tasks that were completed; what you expect to accomplish next year; areas of difficulty and barriers to completion; and any comments on your observations and discoveries. You may provide any attachments that you believe are relevant to this report.

†Have you refined or changed your procedures from those you described in your 2007 plan?
If so, please explain.

Response

No changes have been made to the original ATI procurement procedures outlined in the university’s 2007 Procurement Plan.

1a. Accomplishments in 2007/2008

CSULB successfully implemented its ATI Procurement Plan, initially dealing with end-users on a one-to-one basis as CSULB Buyers were trained on the ATI requirements.
A CSULB procedural memo, PSS MEMO 08-03, was issued to all offices detailing the procedures. Central Purchasing Buyers received a more detailed version of this memo. (See Attachment 1.)

1b. Plans for 2008/2009

An additional procedural memo will be issued shortly to advise the campus community of the lowered $15,000 threshold. CSULB Purchasing Office will continue to support the initiative by providing advice and assistance to the campus community in meeting these goals. The Buyers will continue to receive training at monthly/quarterly Purchasing Staff Meetings. ATI requirements are incorporated into Quarterly Purchasing Workshops offered to the campus.

1c. Barriers to completion

The ATI procurement requirements are confusing, even for technical personnel. Though ATI compliance may be required at the federal level, the reality is that suppliers were mostly unaware of the requirements and confused (or at least managed to convey that impression). To have ATI requirements properly addressed seems to require more senior contact with vendor organizations than other procurements.

1d. Observations/discoveries

The assumption has been that this would be a requirement which could be simply inserted into a bid or request for proposal, forcing non-compliant suppliers to be eliminated through the competetive bid process. The reality at the campus is that the $50,000 threshold was below the formal bid limit for IT goods and services, and often our requirements are specifically based on compatibility or existing needs. Further, the instructions and forms necessary for the campus to comply with the process are, at the very least, challenging, if not sometimes overwhelming and confusing.

Please describe briefly the team involved in your 508 procurement process, and the roles and responsibilities of team members, especially if they have changed since you submitted your plan.† If you have had trouble identifying team members, please explain why and include your suggestions of solutions at the campus or Chancellorís Office level.

The CSULB Procurement Director and Purchasing Manager both participate in a strong ATI Steering Committee. The ATI Compliance Officer was named in December 2007, and has worked closely with Purchasing. The university has a dedicated IT Buyer who works closely with the campus’ Section 508 Compliance Officer and IT Department.

  • Evaluate the product using the sample E & IT Checklist.
  • Prepare specifications in accordance with the accessibility requirements.
  • Provide vendors with the applicable VPAT forms; review the VPAT submissions for accuracy.
  • Submit requisition package to the Purchasing Office which includes:
    • Adequate specification
    • CSU E & IT Checklist
    • Signed VPAT forms, verifying that the Section 508 Requirements have been met.
  • Coordinate with campus 508 Compliance Officer on problematic issues to ensure that accessibility requirements are adequate.
  • If a waiver or exemption is requested, provide all documentation and justifications to the Section 508 Compliance Officer for review and approval.
  • If exemption is approved, provide a remediation plan outlining how accessibility needs will be accommodated.

Campus Section 508 Compliance Officer Responsibilities:

  • Audit E&IT purchases for compliance with accessibility requirements.
  • Coordinate with the requestor and Purchasing and appropriate technical staff to resolve EIT issues.
  • Review and approve written justification for all exceptions and waivers to accessibility requirements. Review and approve all associated remediation plans to ensure compliance with accessibility needs.
  • Coordinate with the requestor, Purchasing and appropriate technical staff to develop accessibility specifications and criteria, as needed.
  • Participate in all Requests for Proposal (RFP) procurements; evaluate proposals for compliance with accessibility requirements against evaluation criteria.

Buyer Responsibilities:

  • Inform the requestor of campus requirements and direct them to campus resources for information and assistance.
  • Review requisition and associated documents for compliance with policies and procedures.
  • Include required terms and conditions in purchase orders/contracts.
  • Include proper instructions in solicitation documents to identify accessibility and documentations requirements to bidders.
  • Maintain the E & IT documentation with the appropriate purchase order.

2a. Accomplishments in 2007/2008

The CSULB Procurement Director and Purchasing Manager both participate in a strong ATI Steering Committee. The ATI Compliance Officer was named in December 2007, and has worked closely with Purchasing. The university has a dedicated IT Buyer who works closely with the campus’ Section 508 Compliance Officer and IT Department.

2b. Plans for 2008/2009

The Purchasing Department plans to continue its support of the ATI initiative, becoming more pro-active with end-users to include ATI considerations earlier in the process. Training will be offered through quarterly Purchasing Workshops.

2c. Barriers to completion

Confusion regarding technical requirements and the entire ATI process has been a barrier. There was confusion on the part of Purchasing buyers on what is and is not required to meet the ATI requirements. The end-user often fails to consider the ATI requirements.
There should be more system-wide training on the ATI procurement function.

2d. Observations/discoveries

Review of the Checklist, VPAT and waivers requires a technical expertise that has proved to be a challenge for all concerned. Continued training and familiarity will increase compliance and ease of filling out the required forms.

Please list the other significant roles of individuals involved in the 508 procurement process. Please briefly list the 508 procurement responsibilities of each.

Response

The entire CSULB ATI Steering Committee has provided excellent leadership, support and guidance to the 508 procurement process. The committee introduced the initiative via a campus-wide publicity and training program which explained the program and demonstrated the executive support to the process. The university’s ATI Executive Co-Sponsors/Co-Chairs of the ATI Steering Committee provided support and back-up to the Section 508 Compliance Officer.

3a. Accomplishments in 2007/2008

Purchasing met with the Beach Cert group on May 14, 2008, to explain the requirements. This is a group of some 60 technical personnel who are responsible for the majority of technical and lab purchases at the university. Their “buy-in” and cooperation are key to a successful ATI program. Feedback was positive and indicates recognition that the need to meet the ATI requirements has reached the end-user level.

3b. Plans for 2008/2009

With continued involvement and support from the ATI Steering Committee, Purchasing plans to coordinate the process more closely with both the Academic Technology and Administrative Technology groups. The Purchasing IT buyer will continue to meet with the Beach Cert group and other end-users to ensure that ATI specifications are included upfront in the procurement process. Training will be provided in quarterly Purchasing Workshops.

3c. Barriers to completion

Restricted timelines impede compliance, or the ability to comply with the requirements. In this implementation period, there was confusion about what is and is not exempted from the ATI review process.
For example, a better definition of an acceptable “back office” exemption would help considerably. CSU examples would be very helpful.

3d. Observations/discoveries

The Section 508 Compliance Officer needs a formal back-up to allow for vacations and absences. Additionally, adequate time needs to be built into the procurement process to allow for review by the Compliance Officer.
As the ATI thresholds are reduced, overall processing timelines will be greater.

How many procurements over $50,000 were made on the campus? Were you able to incorporate Section 508 requirements in all of them? If not, why not?
Response

There were 23 computer-related purchases which exceeded $50,000. Five of these procurements were for parts, such as for the university’s phone system, or were for renewal of existing software maintenance which automatically were exempted from ATI Compliance.

CSULB failed to incorporate the EIT Procurement Checklist in four ATI-required procurements which were basically for multiple low-dollar value computers, not formally bid and purchased off existing WSCA contracts. These were inadvertent omissions, some the result of not considering the sum effect of ordering multiple “off-the-shelf” items and all were made during a transition period to a complex policy. Subsequent review indicates that the computers purchased are ATI compliant.

CSULB failed to include ATI requirements in one RFP which was conducted at year-end for a small package tracking system because the initial estimates were well below the $50,000 ATI limit. (See Attachment 2.)

4a. Accomplishments in 2007/2008

CSULB incorporated procedures into 13 projects and has learned from the experience. The AT I requirement is becoming a “part of the procurement process” and not “in addition to”.

4b. Plans for 2008/2009

Continued Buyer training in the area of ATI compliance will be scheduled. The Purchasing Manager will meet with campus fiscal officers to promote the program on a regular basis and to inform the campus of the lowered threshold. The IT Buyer will continue to meet with the technical end-users across campus.
ATI compliance will be a major purchasing talking point across the campus.

4c. Barriers to completion

The time necessary to instruct suppliers on what and how to complete VPATs will continue to negatively impact the procurement process. More system-wide procurement training is needed.
A low initial cost estimate resulted in the failure to include ATI requirements in one Request for Proposal (RFP).

4d. Observations/discoveries

Suppliers are for the most part unaware of the ATI requirements. Getting to the right person and having them submit a complete VPAT is a challenge which will only get worse as the thresholds are lowered. Vendors need more time to respond to our requirements.

Of the procurements that did incorporate Section 508 requirements, how many resulted in an exception from the 508 requirements? Which exceptions have been used? Please provide an example or two, if you have any.
Response

Two ATI exemptions were approved by the CSULB 508 Compliance Officer:

  1. PO #24731 with Innovative Interfaces Inc. for an interface with the Library’s Automatic Storage and Retrieval System was exempted on the basis of Sole Brand procurement. The Library will accommodate students who cannot utilize the software; (within a year they are to purchase additional software which will make the initial purchase ATI compliant). (See Attachment 3.)
  2. PO #25505 with Software One Inc. for the purchase of anti-virus software. This approved exemption was made on the basis of an approved sole-source. (See Attachment 4.)

5a. Accomplishments in 2007/2008

The end-users, Purchasing and the 508 Compliance Officer cooperated through new and complex territory. Based on the above exemptions, we determined that the 508 Compliance Officer has to rely on the technical expertise of others. The Purchasing Manager and 508 Compliance Officer met with the Fiscal Officer for Information Technology to discuss the ATI review process. Based on that discussion, the EIT Procurement Checklist was modified to include approval or certification of facts by a technical, or subject matter expert, for the end-user.

5b. Plans for 2008/2009

Continued training. The Purchasing Manager, IT Buyer and the 508 Compliance Officer will continue their efforts to review the ATI procurement process, looking for ways to streamline the process and to improve communication with campus end-users.

5c. Barriers to completion

The university lacks the resources to conduct adequate market research and analysis’ this results in over-reliance on the VPAT, which are hard to acquire from vendors.

5d. Observations/discoveries

As the threshold value is reduced from $50,000 to $15,000, ATI procurements will become more cumbersome, and the sheer volume will have a drastic impact on the workload for all. Increased procurement timelines may negatively impact the classroom and student lab functions.
Once the ATI threshold is reduced below $15,000, monitoring campus-wide compliance will become an issue.

If there were exceptions, how many included a procedure to provide equally effective alternative access? Please attach one as an example.
Response
The exemption for Innovative Interfaces Inc. was approved on the basis of a sole-brand purchase and an approved alternative access plan. (See Attachment 3.)

6a. Accomplishments in 2007/2008

Purchasing staff and the requesting end-users collaborated to process the first ATI waiver.

6b. Plans for 2008/2009

Issuance of additional procedural memos and continued training through quarterly Purchasing Workshops.

6c. Barriers to completion

Time and lack of resources will continue to impede full compliance with ATI requirements. End-users find it difficult to conduct full market researches for sole-branded items.

6d. Observations/discoveries

Review of the exceptions and alternatives require an in-depth technical knowledge of highly technical specifications. The Buyer and 508 Compliance Officer must often rely on the expertise of the end-user.

What 508 procurement communication activities took place during the past year? Please describe the activities and attach any relevant documents or materials.
Response
The campus ATI Steering committee provided overall support for the ATI procurement process through a campus-wide advertising and training campaign. Presentations were made to the Academic Senate and other high-level executive groups.

7a. Accomplishments in 2007/2008

Purchasing added an ATI component to its quarterly Purchasing Workshops. Coded procedural memos were issued campus-wide, outlining the ATI requirements. The IT Buyer presented the ATI requirements at the May 14, 2008, Beach Cert meeting.

7b. Plans for 2008/2009

Continued training for buyers and end-users. Development of an ATI FAQ or ATI Tips Sheet(s) for end-users. The IT Buyer will continue to meet with IT technicians and other end-users.

7c. Barriers to completion

Time and resources continue to be a challenge. The implementation period for the PeopleSoft Finance Version 9.0 in conjunction with the lowered ATI threshold will tax CSULB’s purchasing resources.
Changing computer configurations present a challenge to obtaining VPATs. The CSULB IT Buyer has spent hours explaining the VPAT requirements to DELL who is a WSCA partner for computer purchases. Constant follow-up and constant review of what is submitted is required, making the purchase of computers an onerous process.

7d. Observations/discoveries

Full implementation of ATI is an ongoing, collaborative effort which will require expanded training, especially as the thresholds are lowered.

What 508 procurement communication activities took place during the past year? How many people were trained? What roles were they in? Please describe the activities and attach any relevant documents or materials.

Purchasing conducted an in-service for the eight central buyers.
Three CSULB buyers attended the PSSO conference and participated in the round table for ATI training
The IT Buyer attended the May 14, 2008, Beach Cert committee and advised between 50 and 60 academic and administrative IT technicians who have considerable roles in the development of technical specifications for their constituency.
Purchasing includes the ATI requirements in its Quarterly End-User Workshops.
Central Purchasing Buyers received in-service training and participated in a focus group meeting with Jim Tobias, a national accessibility expert, and Deborah Kaplan to help develop a “508 wizard” tool intended to assist a purchaser to identify appropriate 508 standards.

8a. Accomplishments in 2007/2008

Through the communication and training activities described above, the ATI procurement process is being incorporated into standard purchasing policies and practices.

8b. Plans for 2008/2009

The CSULB Purchasing website will be expanded to include more ATI information, making the forms more accessible.
Purchasing will develop an ATI FAQ Sheet.
Quarterly Purchasing Workshops will continue to highlight the ATI requirements.

8c. Barriers to completion

Lack of adequate resources and time are true obstacles to complete implementation.

8d. Observations/discoveries

Campus ATI procurement training will be an on-going effort which will need to accommodate different needs and requirements. The $50,000 ATI threshold impacted smaller, more technical campus user groups. With the ATI threshold at $15,000 in 2008/2009, a larger number of end-users who are generally less technically qualified will be involved, making ongoing training a key issue for Purchasing.
Issuing procedural memos and referring end-users to websites is not enough. The amount of information available to the end-user needs to be simplified to meet their immediate needs.

What activities took place to evaluate the implementation of 508? Please describe. What were the results?

Response

The Purchasing Manger and 508 Compliance Officer met to discuss the requirements and review process. Both the Procurement Director and Purchasing Manage participate in monthly discussions at the ATI Steering Committee Meeting.
The Purchasing Manager, 508 Compliance Officer and the Fiscal Officer for Information Technology conducted a “post award” evaluation of the ATI procurement process.

9a. Accomplishments in 2007/2008

A PeopleSoft query was developed to identify IT purchases in excess of $50,000.

9b. Plans for 2008/2009

The PeopleSoft Query will be modified to identify IT purchases of $15,000 or greater. Purchasing management will conduct quarterly reviews to ensure ATI compliance is successful.

9c. Barriers to completion

Purchasing deadlines and resources will continue to be a challenge, especially as the ATI threshold is lowered.

9d. Observations/discoveries

As our experience with the ATI requirements expands, the program will become more integrated into the campus procurement practice.

In what ways did implementation of your 508 Procurement Plan differ from what had been planned?† Why?

Response

Not applicable.

10a. Accomplishments in 2007/2008

Not applicable.

10b. Plans for 2008/2009

Not applicable.

10c. Barriers to completion

Not applicable.

10d. Observations/discoveries

Not applicable.

What additional resources would assist your campus in implementing 508 procurement objectives?

A list of approved computer models and peripherals, and a system-wide central library of acceptable standard VPATs for desktop computers would greatly facilitate the procurement process. To adequately train end-users, monitor and administer the AT I procurements, additional personnel will be required.
More system-wide procurement training is a necessity.

 

 
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