Supplier Accessibility (VPAT/ACR) Compliance

Purpose

The County of Orange is committed to ensuring that all members of the public can access and use digital services and information.

IT Procurement: Accessibility Requirements for Suppliers & Contractors

When procuring or contracting public-facing information technology (IT) products or services, such as websites, software, or mobile applications, suppliers and contractors must comply with updated accessibility regulations under Title II of the Americans with Disabilities Act (ADA), as issued by the U.S. Department of Justice (DOJ).

To support the County’s accessibility objectives, suppliers must submit a current Accessibility Conformance Report (ACR), based on the Voluntary Product Accessibility Template (VPAT). This requirement applies to all web content and mobile applications, regardless of creation date, unless specifically exempted.

Suppliers and contractors must ensure their digital products and services meet the Web Content Accessibility Guidelines (WCAG) 2.1, Level AA standards when they are developed, provided, managed, or maintained for the County.

County of Orange VPAT Process for IT Procurement:

1. Evaluation & Selection

County staff must review the supplier’s VPAT/ACR to evaluate how well the product or service aligns with accessibility standards while fulfilling the County’s operational needs. The supplier’s VPAT/ACR is reviewed by the County’s Accessibility Coordinator.

To ensure compliance with accessibility standards, County staff shall review the supplier’s VPAT/ACR as part of the procurement evaluation process to assess alignment with accessibility standards and business requirements:

Review includes validation by subject matter experts
The ACR is evaluated as supporting documentation, not sole evidence of compliance
High-risk or public-facing systems may require additional review or demonstration

As part of this process, the County evaluates reported accessibility using the following standardized conformance levels:

Supports: The feature fully meets accessibility requirements and can be used without barriers (e.g., full keyboard accessibility).
Partially Supports: Some aspects meet accessibility requirements, while others do not; limitations and user impact must be clearly identified.
Does Not Support: The feature does not meet accessibility requirements and may present barriers, particularly if the functionality is critical.
Not Applicable: The criterion does not apply to the product or feature being evaluated.
Not Evaluated: The criterion has not been assessed, typically in relation to WCAG Level AAA requirements.

2. Pre-Contract Accessibility Testing

Prior to awarding a contract for any IT product or service contract, the County’s Accessibility Coordinator conducts accessibility testing to verify compliance and ensure usability for individuals with disabilities.

3. Contract Renewal Requirements

For renewals of existing IT products or services:

Suppliers must provide an updated ACR/VPAT
Suppliers must disclose any known accessibility issues
Updated remediation timelines must be provided, where applicable

These materials are reviewed by the County’s Accessibility Coordinator. Accessibility performance may be considered as part of contract renewal decisions.

Resources

Commitment to Digital Accessibility

The County of Orange incorporates VPAT review into its IT procurement process to help ensure that all digital products and services are accessible to individuals with disabilities. By adhering to WCAG 2.1, Level AA, the County affirms its commitment to creating a digital environment that is inclusive and user-friendly digital environment for the community.

This guidance supports suppliers and contractors in producing digital content that meets accessibility standards and aligns with the County’s mission to provide equal access for all.

For questions or support regarding accessibility requirements, please contact the County of Orange’s Accessibility Coordinator.