Accessibility Progress Report | Department of Health Care Policy and Financing

Accessibility standards applied

The Colorado Department of Health Care Policy and Financing (HCPF) is committed to ensuring digital accessibility for people with disabilities. We are continually improving the user experience for everyone, and applying the relevant digital accessibility standards, as developed by the Governor’s Office of Information Technology (OIT).

Such standards are in conformance with the technical standards provided by:

World Wide Web Consortium (W3C) Web Content Accessibility Guidelines (WCAG) 2.1 Level AA or higher
Section 508 of the U.S. Rehabilitation Act of 1973 Chapters 3,4,6
and following C.R.S. 24-85-101 to 24-85-104, ARTICLE 85 (CO HB21-1110)

More on Legal Requirements

State of Colorado Requirements: HB21-1110

On June 30, 2021, Colorado HB21-1110 strengthened Colorado’s laws protecting individuals with disabilities from discrimination. HB21-1110 requires that public entities make their information and communication technology (ICT) accessible. The Governor’s Office of Information Technology (OIT) established Technology Accessibility Rules that define compliance and identify obligations for public entities. On May 9th, 2025, updated Technology Accessibility Rules, 8 CCR 1501-11 were adopted to amend existing rules and emphasize progress over strict technical conformance for technology accessibility and more clearly align with federal laws.

Federal Requirements

Title II of the Americans with Disabilities Act (ADA)

Title II of the ADA mandates that governments ensure that people with disabilities have equal opportunities to benefit from their programs, services, and activities. In practice, this means that governments must engage in effective communication, provide reasonable modifications and/or accommodations, facilitate access, and adhere to applicable standards. These steps help to ensure that individuals with disabilities can fully participate in all aspects of civic life. In April 2024, the Department of Justice published updated rules under Title II of the ADA regarding Nondiscrimination on the Basis of Disability: Accessibility of Web Information and Services of State and Local Government Entities. The rule establishes clear accessibility standards for digital resources, including websites and mobile applications. The requirements of 89 FR 31320 are very similar to HB21-1110 and are based on WCAG conformance.

Section 508 of the Rehabilitation Act

The Rehabilitation Act of 1973 was amended in 1998 to include accessibility requirements for electronic and information technology (EIT). While Section 508 is generally applicable to federal agencies, many governmental entities (including HCPF) have incorporated Section 508 compliance into their own accessibility processes. In addition, recipients of federal funds may have Section 508-specific requirements. In practice, efforts to comply with Title II and HB21-1110 typically result in compliance with Section 508 requirements.

Accessibility Maturity

HCPF is between the launch and integration phase, with the launch reflecting that planning has been initiated and some activities have been undertaken. HCPF has a plan to prioritize, evaluate, remediate, and continuously improve every digital touchpoint within our services, programs, and activities. Below, you will find some of the milestones completed, measures that the Agency is undertaking, as well as near-term, mid-term, and long-term goals.

Milestones

February 2022: HCPF created a core project team.
March 2022: HCPF completed development of an OIT accessibility plan
June 2022: HCPF completed budgetary request for funding
April 2023: HCPF began team staffing
November 2023: HCPF approved organizational change management plan
May 2024: Communications to all staff for deployment of digital accessibility
October 2024: Completed governance planning
December 2024: Completed IT Product Roles
December 2024: HCPF successfully implemented an accommodation request process and provided solutions to two requests within a few days
April 2025: HCPF successfully transitioned its Provider Services Call Center to the most accessible solution available from Optum (built on Salesforce)
May 2025: A Digital Accessibility Standard Operating Procedure (SOP) was adopted to establish policy and procedure for all employees, temporaries, and contractors for the creation, publishing, procurement, and management of accessible digital content across the Department to ensure that content is accessible to individuals with disabilities.
June 2025: Most PDF documents that are published on the hcpf.colorado.gov website have been remediated (not re-uploaded) by Allyant, SIPA-approved remediation vendor

Progress by Asset Type

Websites

HCPF uses three platforms for websites: Drupal, managed by Tyler Colorado and SIPA, Google Sites, and SharePoint. HCPF contributes content to these resources but cannot independently resolve issues that exist on the platforms. Such issues are monitored by OIT and placed in a queue for remediation with the platform vendors. Below are our accessibility numbers as reported by Siteimprove for the 7 HCPF owned public websites:

Average accessibility score as of 6/6/2025: 94.5% (+5.2 points since January 2025)
Individual scores as of 6/6/2025:
- Health First Colorado: 97.5% (+5 pts since January 2025)
- Colorado.gov/health: 95.7% (+3.7 pts since January 2025)
- Health First Colorado Enrollment: 94.3% (+2.5 pts since January 2025)
- Colorado Medicaid Recovery: 94.1% (+4.6 pts since January 2025)
- Intelliride: 93.8% (+5.2 pts since January 2025)
- Health Care Policy & Financing (Main Portal): 95.9% (+8.8 pts since January 2025)
- Health Insurance Buy-In Program: 90.3% (+6.9 pts since January 2025)

In Progress: Continue to monitor user-contributed content and platforms for potential accessibility and seek resolution with appropriate vendors as applicable. Maintain a 90+ average accessibility score, and a score of 90+ for all HCPF-owned websites individually.

Goal	Status
Address the backlog of documents publicly available on HCPF’s main portal, many of which predate HB21-1110	In Progress: a total of 5168 files have been externally remediated as of 05/30/2025, or about 111,164 PDF pages. Another 7612 pages remain in the queue for remediation, for a project completion targeted before the end of Q3 of 2025.
Inventory existing and new documents and implement an agency-wide progress tracking system for documents	Completed: Inventory and Progress Tracking Tool has been developed internally. Subject Matter Experts (SMEs) have been designated to be in charge of inventorying documents for their respective offices. An implementation plan has been drafted to direct SMEs in that endeavor. In Progress: Most HCPF offices have started a document inventory to address files hosted on internal websites and storage solutions.
Ensure staff training for common types of documents	In Progress: Internal training has been developed and is in the final stages of review before a release targeted for the end of June 2025. Completed: a bank of external training, including training developed by OIT, has been developed and posted onto the HCPF intranet website. More specific training will be added to it as time goes on.

Goal

Status

Address the backlog of documents publicly available on HCPF’s main portal, many of which predate HB21-1110

In Progress: a total of 5168 files have been externally remediated as of 05/30/2025, or about 111,164 PDF pages. Another 7612 pages remain in the queue for remediation, for a project completion targeted before the end of Q3 of 2025.

Inventory existing and new documents and implement an agency-wide progress tracking system for documents

Completed: Inventory and Progress Tracking Tool has been developed internally. Subject Matter Experts (SMEs) have been designated to be in charge of inventorying documents for their respective offices. An implementation plan has been drafted to direct SMEs in that endeavor.

In Progress: Most HCPF offices have started a document inventory to address files hosted on internal websites and storage solutions.

Ensure staff training for common types of documents

In Progress: Internal training has been developed and is in the final stages of review before a release targeted for the end of June 2025.

Completed: a bank of external training, including training developed by OIT, has been developed and posted onto the HCPF intranet website. More specific training will be added to it as time goes on.

Applications

HCPF has a variety of web applications in use including subscription-based services, custom vendor-developed solutions, and OIT-developed solutions. In situations in which full compliance is not feasible, HCPF has implemented a robust accommodation process to ensure users who need access have an equally effective alternative. Below are some of the steps undertaken by HCPF:

Inventory all digital applications: complete and ongoing (99 products)
Collect and review VPATs/ACRs: in progress (38 VPATs collected)
Produce Accessibility Risk Assessment Reports: in progress (33 risk assessment completed)
Create individual accommodation plans for each product that is not fully compliant: in progress
Medicaid Call Center - Accessibility Evaluation and SalesForce Remediation
- Now that testing is complete, HCPF has a list of items to remediate. Staff are currently evaluating which remediations can be handled in-house by our certified Salesforce System Administrators, and which items will need to be sent to Salesforce because they are out of the box items. The team met with Salesforce’s accessibility team, and they are very open and receptive to receiving these remediation items and working with us to get these out of the box features that came back needing remediation fixed. Their normal process for handling these requests is to schedule them into their regularly scheduled build schedule (which is on a quarterly release, typically).

Barriers

HCPF continues to assess third-party applications that are not currently under contract to ensure accessibility.
Continued monitoring and inventoried digital assets are constrained due to personally identifiable information and personal health information and security requirements.
Challenges in some digital accessibility instances occur due to no readily available solution for issues. Some testing solutions and resolutions are constrained until technological or digital solutions can be created.
Available internal resources and technological barriers with the Drupal file storage system create challenges for re-uploading remediated documents to the main HCPF website.

Next Steps

HCPF will establish a process to re-upload remediated versions of the most clicked documents onto its main website in accordance with its web team’s availability and resources.
HCPF will continue to work with vendors and internal staff to identify processes and alternatives to replace inaccessible solutions.
HCPF will continue to engage with the Governor’s Office of Information Technology, internal stakeholders, third parties and other state agencies engaged in accessibility compliance, remediation, and ownership of ICT assets.
HCPF will continue to inventory relevant digital assets through policies, procedures, and communications.