If you are making a micro-purchase, simplified acquisition procedures from FAR Part 13 typically apply. These procedures exist to reduce administrative costs and to promote efficiency and economy in contracting. Product accessibility and Section 508 should still be considered, but the time you spend on it should be reasonably proportional to the cost of the product. FAR 39.204 talks balancing appropriate accessibility due diligence with micro-purchases:
- "...for micro-purchases, contracting officers and other individuals designated in accordance with 1.603-3 are strongly encouraged to comply with the applicable accessibility standards to the maximum extent practicable."
Government buyers always have to make a decision based on the best value to the government. Some things to consider when making a micro-purchase are:
- Is the time you are spending on market research reasonable considering the price of the item?
- Is there an accessible version of the product available for a reasonable price?
- If you are buying a single product, who is the user? If your intended user has a disability, and the product is not full accessible, can a reasonable accommodation be made? If the intended user of this product does not have a disability, you still have to consider accessibility. Someone with a disability may use the product in the future, or a current user may benefit from accessibility features.
- Does the accessibility information you have apply to the version of the product you intend to buy?
- Are you using a multiple award schedule (MAS) or Indefinite Delivery contract? If so, then there should be accessibility information available from the contract holder (FAR 39.203(2). If this requirement was documented in the contract, ask for the accessibility information. If this information is not available, you can advise the contract holder of their responsibility.
- Are you planning to additional quantities of this item in the future? If so, it may be worth spending more time finding an accessible solution now.
Tools, Guidance, and Resources
BuyAccessible Wizard The BuyAccessible Wizard allows you to indicate if you are making a "micro-purchase", then guides you through a few simple steps to:
- Determine if the product you are buying meets the definition of ICT.
- Determine if any exceptions apply.
- Conduct Market Research.
- Indicate intended purchase
- If the intended product is not fully compliant, document the reasons for selection.
Vendor Accessibility Resource Center (VARC) You can search for accessibility information about your intended purchase using the VARC directly. VARC is an alphabetic list of companies' websites with links to their product or service accessibility information. Copy and save your research for due diligence. Quick Links Quick Links for micro-purchases provide you with a GPAT which identifies the applicable Section 508 provisions for a number of standard ICT deliverables. You can use the Government Product Accessibility Template (GPAT) to ask the vendor to indicate how well their product addresses those requirements. When the vendor fills in a GPAT, it becomes part of your market research for documentation purposes. Training Course: Micro-Purchases and Section 508 This course is designed for anyone involved in making purchase card micro-purchases. You'll gain an overview of the requirements of section 508 of the Rehabilitation Act and how they apply to micro-purchases. Upon completion you will be able to: Explain the requirements of section 508 and how they apply to micro-purchases, describe the responsibilities of Requiring Officials and Approving Officials in relation to micro-purchases, determine if a micro-purchase is Information and Communication Technology (ICT), Review the Access Board standards and determine which apply to your micro-purchase, and determine how to select products that meet the section 508 standards. This course is now hosted at FAI (FAC 047). (15 minutes). Roles and Responsibilities: Approving Official (AO) Roles and responsibilities for Approving Officials of purchase card programs.