Procurement & Payments

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EIT Procurement Checklist for Section 508 Compliance


Complete this section with summary information about the product.


1. Identify the category or categories of the requested product by initialing appropriate boxes.

2. Conduct a market analysis for 508 Compliance as described below (unless the product meets one of the conditions described in 3.D. on the checklist).

a. Research available products. 

b. Collect from each vendor a current Voluntary Product Accessibility Template (VPAT) for the product.  If the vendors do not have an existing completed VPAT, provide a blank VPAT to the vendors to complete and return to you.  Go to the CSU Accessible Electronic and Information (E&IT) Procurement website to locate this form.

      • Select “CSU Guide to Completing the Voluntary Product Accessibility Template (VPAT)”

Note: The standards for the appropriate category must be addressed in the VPAT (i.e. for software applications Section 1194.21 must be completed, for web based applications, Section 1194.31 must be completed, etc.).  In addition to the applicable section for the product (referred to as Subpart B), the Functional Performance Criteria (Section 1194.31 referred to as Subpart C) and Information documentation and support documentation standards (Section 1194.41 referred to as Subpart D) must be completed in the VPAT. 

c. Complete your Market Analysis for 508 Compliance.  Evaluate the VPAT to determine the various products for accessibility; Test the products to ensure they meet the standard and/or contact other CSU campuses to see if they have tested the products for compliance. 

      • Select the IT product that most closely meets all the requirements for accessibility.

d. Exemptions:  Exemptions, although rare, may be applicable and fall into two groups.

General Exemption: The E&IT Procurement Checklist is still required but in these instances VPAT(s) do not have to be attached to the E&IT Procurement Checklist, nor is a market survey required. The campus has identified the following general exemptions:

      • Product that was previously purchased and the product is still conformant (e.g., desktop computer contract)
      • Back office exemption (equipment that does not require human interaction such as servers and communication closet equipment)
      • Fundamental alteration for cell phones, PDAs, pagers, hand-held devices

Special exemptions may encompass commercial non-availability, undue burden, excessive cost or fundamental alterations to the product in order to comply with accessibility requirements. Refer to E&IT Procurement Special Exception Documentation for instructions.  If the requestor determines the purchase requests merits a special exemption as a result of the market analysis, this form and documentation are required in lieu of this E&IT Procurement Checklist.

3. Once the market analysis is completed or a general exemption identified, initial the applicable box in Section 3 of the checklist.  Attach the VPAT and analysis documentation used for the determination (except in the case of a general exemption).


The Requestor must sign the form and forward the E&IT Procurement Checklist, along with all documentation to the E&IT Officer for review and approval or disapproval. 

If the E&IT Officer approves the E&IT Procurement Checklist, a copy of the approved E&IT Procurement Checklist must be provided to Purchasing & Contract Administration (supporting documentation is not required). The purchase cannot be made without an approved E&IT Procurement Checklist.