G.12 - May an agency exempt an acquisition from the requirements of Section 508 if such procurement is undertaken to comply with the Government Paperwork Elimination Act (GPEA)?
No. Agency efforts undertaken to comply with GPEA are not exempt from Section 508. EIT developed, procured, maintained or used to meet the objectives of GPEA must also meet the requirements of Section 508, i.e., comply with the Access Board's standards where applicable.
GPEA, which was enacted in October 1998, requires agencies generally to provide for the optional use and acceptance of electronic documents and signatures and electronic record keeping, when practicable, by October 21, 2003. OMB annually requires agencies to submit plans describing how they are implementing GPEA; the most recent OMB request was issued on September 24, 2001. In that request, OMB describes factors that agencies should consider in their planning, and among those factors is customer relationship management, including accessibility standards. OMB guidance on implementing GPEA (Memorandum M-00-10, April 2000) can be found on the OMB website.
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