Greetings From CommonLook
Welcome to the December issue of the CommonLook Accessibility Newsletter!
Most human resources and healthcare professionals know, December means that open enrollment season is in high gear. Therefore, this month’s Industry Spotlight features Healthcare and Accessibility.
November was marked by CommonLook’s attendance at Accessing Higher Ground in Westminster, Colorado. Attendees shared insights and challenges as it relates to hgher ed and accessibility. Our client profile discusses how the University of Idaho addresses their compliance needs.
Quick. Easy. Painless. Free. Not usually the words associated with ensuring accessibility and compliance of electronic documents, as anyone tasked with the job will tell you. That’s CommonLook PDF Validator! Our tool is the only checker that allows you to check your electronic documents against WCAG 2.0 AA, Section 508, PDF/UA, and HHS standards! Best of all? It’s free! Read more and request your free download.
As always, we welcome your suggestions for upcoming topics and would like to know what you think of the CommonLook Accessibility Newsletter.
We Hope You Enjoy!
The CommonLook Accessibility Newsletter Team
February 27 – March 4, 2017
Manchester Grand Hyatt Hotel
San Diego, California
Join our weekly webinars that explore leading tools and approaches for managing PDF and Section 508 or WCAG 2.0 AA accessibility at the author, quality assurance and enterprise levels.
By now, it’s certainly no surprise that accessibility for persons with disabilities is an issue of major concern for users of information communications and technology (ICT). Many implementers have been aware of accessibility’s particular significance in certain vertical markets such as education, financial services, and the public sector.
Health care and accessibility are innately linked. There is a natural relationship between accessibility and health issues, as a significant number of applicants and beneficiaries for health care also possess a disability as a result of their health issues. Permanent or temporary disability is frequently a symptom of illness, disease, or injury.
Because of this close relationship between health and accessibility, it should come as no surprise that the Patient Protection and Affordable Care Act (ACA) places a high level of importance on the accessibility of electronic information for persons with disabilities. In addition to the operational standards which a Qualified Health Care Providers (QHP) must meet, the ACA goes to great lengths to specify technical requirements a QHP must satisfy when it comes to providing services that are accessible to persons with disabilities, are non-discriminatory, and are available to persons with Limited English Proficiency (LEP).
As it has done in previous annual letters to Issuers in the Federally Facilitated Marketplace (FFM), the Centers for Medicare and Medicaid Services (CMS), in the Chapter entitled Consumer Support and Related Issues has a section devoted to what it calls Meaningful Access (In the 2015 Letter dated March 14, 2014 this is Chapter 6, Section 4, on page 44).
The Meaningful Access section describes the measures QHP issuers in the Federally Facilitated Marketplace (FFM) are encouraged to take to comply with the requirements that they ensure meaningful access by limited-English proficient (LEP) speakers and by individuals with disabilities.
QHP issuers must ensure access for individuals with disabilities, including through the provision of auxiliary aids and services. CMS notes that all web content or communications materials produced by the FFM and its contractors – including text, audio or video, will conform to applicable standards related to section 508 of the Rehabilitation Act and, where applicable, the Americans with Disabilities Act and section 504 of the Rehabilitation Act. CMS expects that QHP issuers will ensure meaningful access to at least the following items which it designates as essential documents:
- Applications (including the single streamlined application);
- Consent, grievance, and complaint forms, and any documents requiring a signature;
- Correspondence containing information about eligibility and participation criteria;
- Notices pertaining to the denial, reduction, modification, or termination of services, benefits, non payment, and/or coverage;
- A plan’s explanation of benefits or similar claim processing information;
- QHP ratings information;
- Rebate notices; and
- Any other document that contains information that is critical for obtaining health insurance coverage or access to care through the QHP.
In short, any document a QHP may choose to issue electronically falls under the Meaningful Access requirement.
The annual CMS letter isn’t simply a friendly reminder of a QHP’s obligation to provide meaningful access. The Accessibility standards for a QHP are codified in Title 45 of the Code of Federal Regulations (CFR) – “Exchange Establishment Standards and Other Related Standards Under the Affordable Care Act” in Chapter 155 Sections 205 and 230, and in Chapter 156 Section 250.
Furthermore, QHP issuers are reminded that meaningful access requirements spelled out in 45 CFR 155.205(c), 155.230(b), and 156.250, as well as the discrimination prohibitions at 45 CFR 156.200(e), are independent of other obligations QHPs may have. For example, QHP issuers that receive federal financial assistance are subject to Title VI of the Civil Rights Act of 1964, section 504 of the Rehabilitation Act of 1973, and section 1557 of the ACA (the civil rights provision of the Affordable Care Act). As a result, QHPs have separate responsibilities under the law not to discriminate on the basis of race, color, national origin, sex, age and disability, in providing access to their services.
While all this sounds intimidating, there’s no need to be overwhelmed by all of these rules, references, guidelines, citations, and acronyms.
NetCentric Technologies and its CommonLook brand of document accessibility products and services make it easy to produce content that complies with all of the accessibility requirements of the Affordable Care Act. Not only does NetCentric have the technical expertise for making documents compliant with the various accessibility regulations, we have extensive experience providing these services to numerous customers in the health care industry including regulatory agencies, health care deliverers, pharmaceutical manufacturers, and health insurance providers. Our CommonLook PDF Global Access has successfully been applied to every conceivable type of document, notice, and form with the result being an assurance that the content complies fully with all of the document accessibility requirements established by the government for compliance with the Patient Protection and Affordable Care Act.
University of Idaho
You’d be hard-pressed to find a college administrator who doesn’t support accessibility, at least in theory. But program implementation, not simply an expression of support, is the test that colleges and universities must pass. In academia, the term “accessibility” is a bit of a double-edged sword. While everyone is quick to agree on the benefits accessibility provides to the educational community, the term also brings to mind a number of high-profile lawsuits involving higher education institutions over the last few years and the trials and tribulations those institutions went through to correct the situations.
As a result, implementing accessibility is thought of much like a trip to the dentist’s office – it’s a necessity and in your best interest, but the experience is regarded as so uncomfortable, it’s often put off indefinitely. If one inaccessible coursework document is the equivalent of a single cavity, imagine being assigned the job of performing fillings for thousands. That’s one heck of a toothache.
Because it’s been so difficult to get the patient into the dentist’s chair, so to speak, a number of regulatory provisions have been enacted to encourage educational institutions to provide accessible instructional materials. These include the Americans with Disabilities Act requirement that higher education institutions ensure any digital platform being used for credit-bearing courses is accessible, as well the provisions of Section 504 of the Rehabilitation Act which forbids discrimination against persons with disabilities on the part of institutions and programs receiving Federal financial assistance. Even with such enforcement mechanisms in place, a fair amount of educational institutions manage to avoid taking care of their accessibility toothache.
Some But Not All
While there is still much progress to be made in the world of higher education, there are those institutions that have taken bold measures to tackle the accessibility initiative head-on, whose enlightened faculty are serving as pioneers and role models for their academic peers. One such trail-blazer can be found in a small town called Moscow – not the one in Russia, but the one in northern Idaho – which also happens to be the home of the University of Idaho.
Meet Shawn Wright.
Shawn Wright works for the Center on Disabilities and Human Development at the University of Idaho and oversees the web development of the Idaho Training Clearinghouse. The Idaho Training Clearinghouse (ITC) is funded by the Idaho State Department of Education Special Education Division and is designed to link school professionals and parents with special education training opportunities and resources across the state. As one might imagine, accessibility is a priority for this group. On a routine basis, the ITC provides a large assortment of accessible electronic documents, PowerPoint presentations, and PDF files to its constituents. “We are working hard to ensure that our documents meet the highest level of accessibility,” says Shawn.
Led by Shawn, the ITC has implemented several measures to address accessibility. “We made a decision this year to work with our newly designed Learning Management System and to begin an SOP (Standard Operating Procedure) process that would check our syllabi, registration forms, PowerPoint, PDF handouts, and quizzes for accessibility,” Shawn says. Like other colleges and universities, UI was tasked with finding a vendor whose products would help the university meet ADA requirements. Their evaluation of vendors in the accessibility space led them to NetCentric Technologies and the CommonLook suite of tools. “We were familiar with remediation tools and software applications and we decided to test CommonLook and to participate in a training session to see if we could implement the software smoothly. The CommonLook software is so user friendly and after participating in a training session on the software, we decided to go with the product. We started with a class in Autism Supports and remediated and validated the coursework using CommonLook Office Pro and CommonLook PDF Global Access. We were delighted with the results.”
Putting Procedures into Practice
For many schools, the most daunting part of undertaking an accessibility initiative involves the challenge of implementing procedures and establishing a workflow that incorporates the tools into an efficient system for producing accessible content. For Shawn and other accessibility stakeholders at the ITC, it is currently a work in progress.
“That’s where we are at this point,” says Shawn. “We are introducing the software and discussing the workflow. This is a process that will take time but we understand the importance of making sure our work is accessible. We are hopeful that our constituents will jump on board and we hope to provide introductory training and demonstrations for our constituents, as well the University faculty.”
As with any new technology, training ensures that once a solution is identified, it is actually used properly and in a way that yields the promised benefits. After selecting the CommonLook tools, Shawn made the decision to invest in the software’s accompanying training classes. “The training is excellent and invaluable. Upon completing training, the end user has an awareness and confidence that allows them to begin utilizing the software to high degree of immediate success,” he says.
Leading by Example
Shawn’s work at the ITC and the CDHD at the University of Idaho serves as a useful prototype for other organizations that are concerned with accessibility, whether or not they are within the realm of higher education. “We are delighted with the ease of use of the CommonLook software and we are equally delighted with how we have been able to train our web coordinators and interns on implementing the software, as well,” says Shawn. “The measurability speaks for itself in the quality of the accessibility of the remediated documents. I am very pleased with where we stand and where we are going in making sure our documents are accessible to all, thanks to the CommonLook software applications.”