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Voluntary Product Accessibility Template (VPAT) Review

Criteria 1194.31 - Functional and Perfomance Criteria

This section covers information provided in some of the other sections in a more broad base. It does however ask questions specific to hearing and motor skills that is not widely covered in many of the sections.

The CSU reviews this section in relation to functionality regardless of that the product or service. The subsections below will contain the following:

  • The text of the section 508 criterion
  • Explanation of what the criterion is asking along with resource links if available
  • Cross reference information if applicable
  • Verification notes we give our campuses for reviewing VPAT's
  • Information on how this looks like it will overlay into the Section 508 Refresh
Criteria Resources

Criteria 1194.31(a)

At least one mode of operation and information retrieval that does not require user vision shall be provided, or support for Assistive Technology used by people who are blind or visually impaired shall be provided.

Clarification:

  • This section is confirming previously stated support criteria from sections above.  It allows the vendor to add any additional information.
  • Proper coding must be used in order for assistive technology to properly read structured tables, labeled frames, and forms.
  • Section 508 refresh
    • 302.1 Functional Performance - Without Vision

Cross References:

  • Section 508 - 1194.21(a) and 1194.22

Verification Notes:

  • When Supports is chosen look for the following information in Remarks and Explanation column:
    • A statement that does not contradict the remarks and explanations in section 1194.21.
    • A statement that does not contradict the remarks and explanations in section 1194.21.
  • When Supports with Exceptions is chosen look for the following information in Remarks and Explanation column:
    • What is the impact of the user’s inability to complete any core functions of the application due to the exception or lack of support for this criterion.
  • Note that for responses that include Supports with Exceptions and Not Supported drive the completion of the elements of the Accessibility Road Map and information to users on the Accessibility Statement.

Criteria 1194.31(b)

At least one mode of operation and information retrieval that does not require visual acuity greater than 20/70 shall be provided in audio and enlarged print output working together or independently, or support for Assistive Technology used by people who are visually impaired shall be provided.

Clarification:

  • Product support for those with low vision (e.g. support for scaling text size to 200%, substituting font/background color, Tooltips for controls, etc.). Product allows text scaling (e.g. em units, percentages, or named fonts vs. pixels)
  • Section 508 refresh
    • 302.2 Functional Performance - With Limited Vision
    • WCAG 1.4.4 Resize text

Verification Notes:

  • When Supports is chosen look for the following information in Remarks and Explanation column:
    • A statement that reflects that the entire application was tested to verify that the text size can be raised to 200% without any loss of functionality or formating.
  • When Supports with Exceptions is chosen look for the following information in Remarks and Explanation column:
    • What is the impact of the user’s inability to complete any core functions of the application due to the exception or lack of support for this criterion.
  • Note that for responses that include Supports with Exceptions and Not Supported drive the completion of the elements of the Accessibility Road Map and information to users on the Accessibility Statement.

Criteria 1194.31(c)

At least one mode of operation and information retrieval that does not require user hearing shall be provided, or support for Assistive Technology used by people who are deaf or hard of hearing shall be provided

Clarification:

  • This section is confirming previously stated support criteria from sections above.  It allows the vendor to add any additional information.
  • Confirm if there is video or any other audio in the product.
  • Section 508 refresh
    • 302.4 Functional Performance - Without Hearing
    • 407.8 Operable Parts - Audio Signaling

Cross References:

  • Section 508 - 1194.21(a) and 1194.22(b)

Verification Notes:

  • When Supports is chosen look for the following information in Remarks and Explanation column:
    • A statement that does not contradict the remarks and explanations in section 1194.21.
    • A statement that does not contradict the remarks and explanations in section 1194.21.
  • When Supports with Exceptions is chosen look for the following information in Remarks and Explanation column:
    • What is the impact of the user’s inability to complete any core functions of the application due to the exception or lack of support for this criterion.
  • Note that for responses that include Supports with Exceptions and Not Supported drive the completion of the elements of the Accessibility Road Map and information to users on the Accessibility Statement.

Criteria 1194.31(d)

Where audio information is important for the use of a product, at least one mode of operation and information retrieval shall be provided in an enhanced auditory fashion, or support for assistive hearing devices shall be provided.

Clarification:

  • This section is confirming previously stated support criteria from 1194.22(b) above.  It allows the vendor to add any additional information.
  • Think about hearing aids and their difficulty filtering out background noise.
  • Section 508 refresh
    • 302.5 Functional Performance - With Limited Hearing

Cross References:

  • Section 508 - 1194.22(b)

Verification Notes:

  • When Supports with Exceptions is chosen look for the following information in Remarks and Explanation column:
    • What is the impact of the user’s inability to complete any core functions of the application due to the exception or lack of support for this criterion.
  • Note that for responses that include Supports with Exceptions and Not Supported drive the completion of the elements of the Accessibility Road Map and information to users on the Accessibility Statement.

Criteria 1194.31(e)

At least one mode of operation and information retrieval that does not require user speech shall be provided, or support for Assistive Technology used by people with disabilities shall be provided.

Clarification:

  • This section is confirming previously stated support criteria from sections above.  It allows the vendor to add any additional information.
  • Remember to consider people with stutters and who have had strokes.
  • Section 508 refresh
    • 302.6 Functional Performance - Without Speech

Cross References:

  • Section 508 - 1194.21 and 1194.22

Verification Notes:

  • When Supports is chosen look for the following information in Remarks and Explanation column:
    • A statement that does not contradict the remarks and explanations in section 1194.21.
    • A statement that does not contradict the remarks and explanations in section 1194.21.
  • When Supports with Exceptions is chosen look for the following information in Remarks and Explanation column:
    • What is the impact of the user’s inability to complete any core functions of the application due to the exception or lack of support for this criterion.
  • Note that for responses that include Supports with Exceptions and Not Supported drive the completion of the elements of the Accessibility Road Map and information to users on the Accessibility Statement.

Criteria 1194.31(f)

At least one mode of operation and information retrieval that does not require fine motor control or simultaneous actions and that is operable with limited reach and strength shall be provided.

Clarification:

  • Does the product support alternative pointing devices. Examples voice recognition, on screen keyboard, visual trackers, keyboard only.
  • This criterion goes beyond screen readers. Vendors tend to respond about screen readers and stop. 
  • Section 508 refresh
    • 302.7 Functional Performance - With Limited Manipulation
    • 302.8 Functional Performance - With Limited Reach or Strength

Cross References:

  • Section 508 - 1194.21(l)

Verification Notes:

  • When Supports with Exceptions is chosen look for the following information in Remarks and Explanation column:
    • What is the impact of the user’s inability to complete any core functions of the application due to the exception or lack of support for this criterion.
  • Note that for responses that include Supports with Exceptions and Not Supported drive the completion of the elements of the Accessibility Road Map and information to users on the Accessibility Statement.