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.
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 has successfully implemented an accommodation request process and has successfully provided solutions to two requests within a few days
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 12/13/2024: 89.3%
- Individual scores as of 12/13/2024:
- Health First Colorado: 92.7%
- Colorado.gov/health: 92%
- Health First Colorado Enrollment: 91.8%
- Colorado Medicaid Recovery: 89.5%
- Intelliride: 88.6%
- Health Care Policy & Financing (Main Portal): 87.1%
- Health Insurance Buy-In Program: 83.4%
In Progress: Continue to monitor user-contributed content and platforms for potential accessibility and seek resolution with appropriate vendors as applicable. Achieve 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 vendor has been selected to remediate over four thousand documents in batches. The contract is currently going through procurement with help from SIPA. The first batch of documents to go out for remediation is targeted for the first quarter 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. In Progress: an implementation plan is being drafted that will help and direct SMEs in that endeavor. Targeted for release early 2025. |
| Ensure staff training for common types of documents | In Progress: internal training is being developed and will be made available to all staff. Targeted for release in the first quarter of 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 (27 VPATs collected)
- Produce Accessibility Risk Assessment Reports: in progress (24 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
- OIT has been leading the vendor selection process and project work for Salesforce testing. The HCPF Salesforce team identified four major phases of work for different profile views within the system that are unique. Phase 1 work is completed and Phase 2 kicks off on December 17, 2024. Phase 1 results returned issues with aspects of the system that are out of the box or native features within Salesforce, so the team will submit what are called “Idea” requests to Salesforce directly, and will ask the OIT Salesforce enterprise team to advocate for those changes for all Orgs Statewide since the likelihood of all Orgs being pinged for the same things are high. The only other option to fix those would be to implement custom code to change what we can, however limiting the amount of custom code to prevent daunting maintenance and limit security vulnerabilities in the future is our standard practice. The small number of items that can be handled by HCPF’s System Administrators will be worked into the normal work schedule for remediation.
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.
Next Steps
- 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.