Last week, the U.S. Department of Education, Office for Civil Rights (OCR) released its Annual Report to the Secretary, the President, and the Congress for Fiscal Year 2019 (PDF), announced in a July 29, 2020 press statement. The report, which is a 44-page untagged PDF, highlights improved outcomes for students with disabilities and touts the creation of a National Web Accessibility Team, tasked with a protocol of "[v]erifying document accessibility." The report is not accessible.
As a federal agency, the OCR is required by Section 508 of the Rehabilitation Act to produce public-facing content that is accessible. In 2017, Section 508 was revised to clarify that by January 2018, covered websites, electronic documents, and software must comply with Web Content Accessibility Guidelines (WCAG) 2.0.
The OCR's report violates key aspects of WCAG and presents a learning opportunity regarding very common and highly-preventable accessibility barriers to avoid.
To be usable by people who use assistive technology like screen readers, PDFs have to be tagged, the process by which the intended structure, the correct reading order, and graphical elements are identified. By failing to be tagged, the report does not meet even a minimum level of accessibility.
The report also fails to meet minimum color contrast requirements outlined in WCAG; fails to present adequate text alternatives for graphical content, like figures, charts, and graphs; and fails to make best use of document properties like Document Title.
Collectively, these barriers create a document that cannot be considered accessible, with or without the use of assistive technology.
Among other things, the Annual Report includes statistics about the number of complaints resolved during fiscal year 2019, information about policy and regulatory changes, and protocols and results of the newly-formed National Web Accessibility Team. It also includes some historical figures comparing the first three years of the Trump Administration to the prior administration.
Secretary of Education Betsy DeVos says in the press statement:
"Despite the media's efforts to ignore OCR's track record under this Administration, the facts speak for themselves: Because of the hard work at the Office for Civil Rights, more students are getting results, and institutions are being held accountable."
It's an unfortunate fact that this report can't be confidently or independently used by many members of the public or students with disabilities; however, there are key lessons to take away for others interested in delivering accessible PDF documents:
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