CSULB Year 2 Procurement Report, August 15, 2008

CSULB successfully implemented its ATI Procurement Plan, initially dealing with end-users on a one-to-one basis as CSULB Buyers were trained on the ATI requirements.
A CSULB procedural memo, PSS MEMO 08-03, was issued to all offices detailing the procedures. Central Purchasing Buyers received a more detailed version of this memo. (See Attachment 1.)

An additional procedural memo will be issued shortly to advise the campus community of the lowered $15,000 threshold. CSULB Purchasing Office will continue to support the initiative by providing advice and assistance to the campus community in meeting these goals. The Buyers will continue to receive training at monthly/quarterly Purchasing Staff Meetings. ATI requirements are incorporated into Quarterly Purchasing Workshops offered to the campus.

The ATI procurement requirements are confusing, even for technical personnel. Though ATI compliance may be required at the federal level, the reality is that suppliers were mostly unaware of the requirements and confused (or at least managed to convey that impression). To have ATI requirements properly addressed seems to require more senior contact with vendor organizations than other procurements.

The assumption has been that this would be a requirement which could be simply inserted into a bid or request for proposal, forcing non-compliant suppliers to be eliminated through the competetive bid process. The reality at the campus is that the $50,000 threshold was below the formal bid limit for IT goods and services, and often our requirements are specifically based on compatibility or existing needs. Further, the instructions and forms necessary for the campus to comply with the process are, at the very least, challenging, if not sometimes overwhelming and confusing.

The CSULB Procurement Director and Purchasing Manager both participate in a strong ATI Steering Committee. The ATI Compliance Officer was named in December 2007, and has worked closely with Purchasing. The university has a dedicated IT Buyer who works closely with the campus’ Section 508 Compliance Officer and IT Department.

The Purchasing Department plans to continue its support of the ATI initiative, becoming more pro-active with end-users to include ATI considerations earlier in the process. Training will be offered through quarterly Purchasing Workshops.

Confusion regarding technical requirements and the entire ATI process has been a barrier. There was confusion on the part of Purchasing buyers on what is and is not required to meet the ATI requirements. The end-user often fails to consider the ATI requirements.
There should be more system-wide training on the ATI procurement function.

Review of the Checklist, VPAT and waivers requires a technical expertise that has proved to be a challenge for all concerned. Continued training and familiarity will increase compliance and ease of filling out the required forms.

Purchasing met with the Beach Cert group on May 14, 2008, to explain the requirements. This is a group of some 60 technical personnel who are responsible for the majority of technical and lab purchases at the university. Their “buy-in” and cooperation are key to a successful ATI program. Feedback was positive and indicates recognition that the need to meet the ATI requirements has reached the end-user level.

With continued involvement and support from the ATI Steering Committee, Purchasing plans to coordinate the process more closely with both the Academic Technology and Administrative Technology groups. The Purchasing IT buyer will continue to meet with the Beach Cert group and other end-users to ensure that ATI specifications are included upfront in the procurement process. Training will be provided in quarterly Purchasing Workshops.

Restricted timelines impede compliance, or the ability to comply with the requirements. In this implementation period, there was confusion about what is and is not exempted from the ATI review process.
For example, a better definition of an acceptable “back office” exemption would help considerably. CSU examples would be very helpful.

The Section 508 Compliance Officer needs a formal back-up to allow for vacations and absences. Additionally, adequate time needs to be built into the procurement process to allow for review by the Compliance Officer.
As the ATI thresholds are reduced, overall processing timelines will be greater.

There were 23 computer-related purchases which exceeded $50,000. Five of these procurements were for parts, such as for the university’s phone system, or were for renewal of existing software maintenance which automatically were exempted from ATI Compliance.

CSULB failed to incorporate the EIT Procurement Checklist in four ATI-required procurements which were basically for multiple low-dollar value computers, not formally bid and purchased off existing WSCA contracts. These were inadvertent omissions, some the result of not considering the sum effect of ordering multiple “off-the-shelf” items and all were made during a transition period to a complex policy. Subsequent review indicates that the computers purchased are ATI compliant.

CSULB failed to include ATI requirements in one RFP which was conducted at year-end for a small package tracking system because the initial estimates were well below the $50,000 ATI limit. (See Attachment 2.)

CSULB incorporated procedures into 13 projects and has learned from the experience. The AT I requirement is becoming a “part of the procurement process” and not “in addition to”.

Continued Buyer training in the area of ATI compliance will be scheduled. The Purchasing Manager will meet with campus fiscal officers to promote the program on a regular basis and to inform the campus of the lowered threshold. The IT Buyer will continue to meet with the technical end-users across campus.
ATI compliance will be a major purchasing talking point across the campus.

The time necessary to instruct suppliers on what and how to complete VPATs will continue to negatively impact the procurement process. More system-wide procurement training is needed.
A low initial cost estimate resulted in the failure to include ATI requirements in one Request for Proposal (RFP).

Suppliers are for the most part unaware of the ATI requirements. Getting to the right person and having them submit a complete VPAT is a challenge which will only get worse as the thresholds are lowered. Vendors need more time to respond to our requirements.

Two ATI exemptions were approved by the CSULB 508 Compliance Officer:

1. PO #24731 with Innovative Interfaces Inc. for an interface with the Library’s Automatic Storage and Retrieval System was exempted on the basis of Sole Brand procurement. The Library will accommodate students who cannot utilize the software; (within a year they are to purchase additional software which will make the initial purchase ATI compliant). (See Attachment 3.)
2. PO #25505 with Software One Inc. for the purchase of anti-virus software. This approved exemption was made on the basis of an approved sole-source. (See Attachment 4.)

The end-users, Purchasing and the 508 Compliance Officer cooperated through new and complex territory. Based on the above exemptions, we determined that the 508 Compliance Officer has to rely on the technical expertise of others. The Purchasing Manager and 508 Compliance Officer met with the Fiscal Officer for Information Technology to discuss the ATI review process. Based on that discussion, the EIT Procurement Checklist was modified to include approval or certification of facts by a technical, or subject matter expert, for the end-user.

Continued training. The Purchasing Manager, IT Buyer and the 508 Compliance Officer will continue their efforts to review the ATI procurement process, looking for ways to streamline the process and to improve communication with campus end-users.

The university lacks the resources to conduct adequate market research and analysis’ this results in over-reliance on the VPAT, which are hard to acquire from vendors.

As the threshold value is reduced from $50,000 to $15,000, ATI procurements will become more cumbersome, and the sheer volume will have a drastic impact on the workload for all. Increased procurement timelines may negatively impact the classroom and student lab functions.
Once the ATI threshold is reduced below $15,000, monitoring campus-wide compliance will become an issue.

Purchasing staff and the requesting end-users collaborated to process the first ATI waiver.

Issuance of additional procedural memos and continued training through quarterly Purchasing Workshops.

Time and lack of resources will continue to impede full compliance with ATI requirements. End-users find it difficult to conduct full market researches for sole-branded items.

Review of the exceptions and alternatives require an in-depth technical knowledge of highly technical specifications. The Buyer and 508 Compliance Officer must often rely on the expertise of the end-user.

Purchasing added an ATI component to its quarterly Purchasing Workshops. Coded procedural memos were issued campus-wide, outlining the ATI requirements. The IT Buyer presented the ATI requirements at the May 14, 2008, Beach Cert meeting.

Continued training for buyers and end-users. Development of an ATI FAQ or ATI Tips Sheet(s) for end-users. The IT Buyer will continue to meet with IT technicians and other end-users.

Time and resources continue to be a challenge. The implementation period for the PeopleSoft Finance Version 9.0 in conjunction with the lowered ATI threshold will tax CSULB’s purchasing resources.
Changing computer configurations present a challenge to obtaining VPATs. The CSULB IT Buyer has spent hours explaining the VPAT requirements to DELL who is a WSCA partner for computer purchases. Constant follow-up and constant review of what is submitted is required, making the purchase of computers an onerous process.

Full implementation of ATI is an ongoing, collaborative effort which will require expanded training, especially as the thresholds are lowered.

What 508 procurement communication activities took place during the past year? How many people were trained? What roles were they in? Please describe the activities and attach any relevant documents or materials.

Purchasing conducted an in-service for the eight central buyers.
Three CSULB buyers attended the PSSO conference and participated in the round table for ATI training
The IT Buyer attended the May 14, 2008, Beach Cert committee and advised between 50 and 60 academic and administrative IT technicians who have considerable roles in the development of technical specifications for their constituency.
Purchasing includes the ATI requirements in its Quarterly End-User Workshops.
Central Purchasing Buyers received in-service training and participated in a focus group meeting with Jim Tobias, a national accessibility expert, and Deborah Kaplan to help develop a “508 wizard” tool intended to assist a purchaser to identify appropriate 508 standards.

Through the communication and training activities described above, the ATI procurement process is being incorporated into standard purchasing policies and practices.

The CSULB Purchasing website will be expanded to include more ATI information, making the forms more accessible.
Purchasing will develop an ATI FAQ Sheet.
Quarterly Purchasing Workshops will continue to highlight the ATI requirements.

Lack of adequate resources and time are true obstacles to complete implementation.

Campus ATI procurement training will be an on-going effort which will need to accommodate different needs and requirements. The $50,000 ATI threshold impacted smaller, more technical campus user groups. With the ATI threshold at $15,000 in 2008/2009, a larger number of end-users who are generally less technically qualified will be involved, making ongoing training a key issue for Purchasing.
Issuing procedural memos and referring end-users to websites is not enough. The amount of information available to the end-user needs to be simplified to meet their immediate needs.

A PeopleSoft query was developed to identify IT purchases in excess of $50,000.

The PeopleSoft Query will be modified to identify IT purchases of $15,000 or greater. Purchasing management will conduct quarterly reviews to ensure ATI compliance is successful.

Purchasing deadlines and resources will continue to be a challenge, especially as the ATI threshold is lowered.

As our experience with the ATI requirements expands, the program will become more integrated into the campus procurement practice.

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