CVAA – Product Responsibilities

As discussed in the CVAA Recordkeeping article, as part of implementing a CVAA conformance program, organizations are required to keep extensive records on development activities related to accessibility. For most organizations that SSB works with the ultimate responsibility for ensuring conformance with the CVAA (and 255) requirements – generally 47 CFR 14 – sits with individual products. For most products, SSB recommends a four step approach for collecting documents from the individual products in a format that satisfies the requirements for 47 CFR 14.31 Record-keeping.


Step One – Regulatory Coverage Questionnaire

To begin this process, SSB recommends that organizations develop a basic questionnaire that covers all the potential product features that are covered under the CVAA. This questionnaire provides a series of questions that determine if any functionality of the product or service falls under the scope of the CVAA. If the product or service has functionality that answers “yes” to any of questions, the product must complete a more extensive CVAA compliance and record keeping process for the covered functionality. If the product or service answers “no” to all questions, then the completed questionnaire can be submitted to the organization’s record-keeping repository and the product can exit the process.

The regulatory coverage questionnaire must account for all the functionality covered under the CVAA and 255 so that the product can then complete a related evaluation process and produce the required documentation. As an example, the following questions would be included to determine if a product falls under the record keeping requirements of the CVAA:

  • Is the product a fixed-line telephone or telephone-like device?
  • Is the product a mobile telephone?
  • Does the product or service provide for text messaging, instant messaging, e-mail or other text based communication?
  • Does the product provide for voice based communication?
  • Does the product provide for video based communication?
  • Does the product provide for the distribution of video content over the Internet?
  • Does the product provide for video playback?

Products that answer “yes” to any of these questions have covered functionality. For such covered functionality, the products would then need to complete three core accessibility activities as part of developing accessible products:

  • Design Audit – Products need to complete a design audit to ensure that they address or have considered all requirements that can be derived for the general and performance obligations of the CFR. Generally, these will be the requirements if 47 CFR 14 Subpart C.
  • Functional Accessibility Evaluation – A functional validation of the product by individuals with disabilities.
  • Accessibility Features – Develop an accessibility features document that describes the manner in which the accessibility requirements are supported in the product.

For more information on the products and services that are covered under the CVAA, please consult the CVAA – Covered Products and Services page.

Required Documentation

Regulatory Coverage Questionnaire – A completed functionality questionnaire for the product. This questionnaire will indicate if the product needs to complete additional steps in the process.


Step Two – Design Checklist

The design checklist provides a list of best practices that a system must implement to be usable by people with disabilities and meet the Implementation Requirements of the relevant regulations. The core criteria used for this are the relevant portions of the CFR that relate to the CVAA, including 47 CFR 6, 7, 14 and 79. Such checklists will cover all of the best practices related to the technology platform used in the product.

For each requirement defined in the design checklist, a product must define the approach for achieving conformance. These requirements, addressed as a whole, will ensure the product addresses the accessibility, usability and, as applicable, compatibility requirements of the CVAA. For each specific accessibility best practice that is applicable to a product, a designation should be provided of one of the following:

  • Native Implementation – The best practice will be addressed directly in the product.
  • Accessibility API – The best practice will be addressed by implementing an operating system or platform level accessibility API.
  • Third-party – The best practice will be addressed through the use of nominal cost third-party accessibility solutions.
  • Non-Achievable – Conformance with the best practice is “not achievable” as defined by the CVAA. Note: This generally will require secondary documentation surrounding the determination of non-achievability.
  • Not Applicable – The best practice is not applicable in the context of the product.

Upon completion of the checklist, the product will have a list of all the accessibility best practices that must be supported in the product and the manner in which this support should be provided.

The actual normative evaluation checklists will tend to be fairly long as they must define and require sign-off on any potential accessibility issues. SSB provides these as part of AMP and, if you need to develop such checklist, we strongly encourage you to contact us to get a demo of AMP.

It is important to note that as part of the requirements of the CVAA, products must ensure that accessibility is considered and evaluated as early as possible in the product development life cycle. Specifically, products are directed to complete an accessibility evaluation as part of the design phase of the product (47 CFR 14.20(b)), and to ensure that the accessibility requirements defined for the product are addressed as early as possible in the development process.

Required Documentation

Design Checklist – A completed design checklist for the product.


Step Three – Functional Accessibility Evaluation

A functional assessment of the product provides for user testing of the product by individuals with disabilities. In essence, the functional evaluation of the system is intended (i) to ensure user input into the product development process and (ii) to provide validation of the use of the system in supported assistive technologies. During the functional assessment of the product, a set of core use cases are executed by individuals with disabilities to determine if users can complete core tasks in the system. The use cases are constructed as simple acceptance tests performed by users of assistive technologies and are intended to reflect a representative set of “core tasks” that are performed by users of the system. The functional assessment should be completed in conformance to the use case testing methodology provided as part of SSB’s Unified Audit Methodology.

Required Documentation

Use Case Results – Upon completion of the Functional Accessibility Evaluation, products will have a set of completed use case results and user notes on the usability of the entire system from individuals with disabilities. These results, along with the accessibility checklist, should be used to develop or update the Accessibility Features document for the product.

Functional Support Level Documentation – The completed use cases and any manual testing will inform the creation of support level documentation identifying the level of support that is provided for each of the functional performance objectives described in 47 CFR 14.21. This support documentation should include the date of testing, describe the testing methodology including disability types covered and list the applicable regulations.


Step Four – Accessibility Features

As a product begins to be fully developed, the issues defined for implementation in the Design Checklist are implemented, and the Functional Accessibility Evaluations are completed, products must create an Accessibility Features document that defines the set of accessibility features implemented in the final product.

Required Documentation

Accessibility Features – A description of the accessibility features provided in the product. This description should contain a discussion of the enhancements made to the product to support accessibility.

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