Yes. Section 508 applies when Federal agencies “develop, procure, maintain, or use electronic and information technology.” Even if the agency is simply procuring a new version of an existing product, Section 508 applies. Section 508 requirements must be considered in the Brand Name justification and in the “or Equal” decision. It is a best practice to include Section 508 requirements in solicitation documentation for Brand Name or Equal, otherwise how are vendors able to propose products or services that equals the brand name? Since agencies are required to document the justification for other than full and open procurement, it should not add any significant effort to include that Section 508 documentation in your solicitation.
It would also be useful to request a Voluntary Product Accessibility Template (VPAT) from all bidders. Brand Name updates can change accessibility features, so it is always good to get the most current data. Further, accessibility information is needed from Brand Name alternatives to determine if they are in fact equal in terms of their accessibility and usability.