By Ernie Crawford, Crawford Technologies
Since the 1990s, the internet has become a staple in most Americans’ lives for personal communications and commercial transactions. Most businesses of any size advertise their products and services online, and organizations across all industries increasingly are engaged in some form of e-commerce, including various types of electronic bill presentment and payment. This phenomenon is not limited to just retailers, either. Insurance companies, healthcare organizations, banks and other financial institutions also rely on electronic communication channels for initial outreach, customer onboarding and retention, invoicing and billing, correspondence, etc.
Perhaps the most notable – and attractive – feature of websites and related electronic media is that they are primarily a visual medium, quick and convenient to read and understand. However, this feature has proven to be problematic for the 15 to 20 percent of the U.S. population that is blind or partially sighted, including a growing number of Baby Boomers. Over recent years, there has been a 400 percent increase in demand letters to businesses and a 37 percent increase in Department of Justice (DOJ) lawsuits related to website accessibility. Reportedly, the DOJ has considered requiring that online businesses provide alternative means of communication – at least telephone access – for visually impaired individuals.
To further drive the point home for healthcare companies, the Affordable Care Act includes a non-discrimination clause in Section 1557, which has been interpreted to require healthcare organizations to provide documents in formats required by their customers.
Obstacles To Accessibility
At this time, only 3 to 4 percent of online documents are actually made accessible to visually impaired individuals, and this is mainly because many organizations wait for a customer request before they will convert a document to an accessible format. In addition, many organizations do not advertise the fact that they can provide accessible documents, so many customers don’t realize that they’re available.
While a healthcare organization may think this “upon request” approach has advantages in terms of saving document processing time and expense, it also has serious drawbacks. One is that it inconveniences the customer, who has to initiate a request to get their documents in a format that they can access with an assistive device or in some other manner, such as braille or large print.
Another challenge with this approach is the time lag it imposes on the customer. In one case, when a customer received a printed bill and called to request that it be sent to them in braille, the braille document was finally received after two more billing cycles had passed. Neither the customer nor the company benefited from this approach, which slowed payment and required extra customer service attention to resolve the “late” payments.
Privacy is also an issue. When customers are accessing sensitive personal information, such as their health records or insurance documents, they should not be put in a position of having to ask someone they know to read a document to them or have a call center representative offer to read it over the phone. All customers want the ability to conduct their own affairs. Proactively making your organization’s documents accessible will show respect for your customers’ privacy and desire for independence.
Issues To Consider
Reworking an existing website to make it accessible in numerous common formats requires special knowledge and skills that go beyond those of typical website designer. In some cases, the platforms that websites are built on don’t handle accessibility very easily, and in any event require significant efforts from designers to make an accessible site. It is also important to remember that both the website and the documents available on it need to be made accessible. As a result of these factors, healthcare providers and insurers may have to reach beyond their current workforce to obtain the necessary expertise to make their websites and documents accessible.
In developing an accessible website, designers must familiarize themselves with the specific industry standards applicable to accessible websites. The World Wide Web Consortium (W3C) has established the primary international standard for accessibility on the web, called the Web Content Accessibility Guidelines (WCAG). WCAG 2.0, published in 2008, provides comprehensive guidelines regarding how to make a website accessible, including the documents accessed through it.
The documents on a website include static documents, usually PDF files that convey generic information, and personalized documents which contain customer-specific personally identifiable information (PII) and personal health information (PHI) data. Strategies for making both types of documents accessible need to be implemented, and will normally involve different tools and processes. Documents that include complex tables, graphs, PII and/or PHI are typically more complex than for other document types. As a result, time to market with these accessible documents can be significantly slower than static content documents.
For all these reasons, automating the process of creating accessible documents is the preferred way to go to avoid an ongoing and costly production burden for the organization. Automation also avoids the lag time involved if documents are made accessible only upon request – and solutions are available that can provide significant support to simplify the process of converting documents to accessible formats for blind or visually impaired individuals.
For example, in one case, an insurance company decided to offer invoices to visually impaired customers in both Accessible PDF and Accessible HTML5 formats, since their customers already relied on e-presentment for their communications. The company recognized that although Accessible HTML5 might be a preferred format for documents such as invoices, multi-page communications such as explanations of benefits (EOB) are better suited to Accessible PDF. The solution they found automated the conversion from their existing archived formats to Accessible PDF and Accessible HTML5 with complete document integrity, while ensuring that all information was an exact match to the original, in the proper read order, and could be easily consumed with assistive technology.
Citing the 2016 National Health Interview Survey, the American Foundation for the Blind notes that 25.5 million American adults age 18 and older have reported experiencing vision loss, such that they have trouble seeing, even when wearing glasses or contact lenses, as well as individuals who reported that they are blind or unable to see at all. As the Baby Boomer generation ages, this number can only be expected to grow.
Organizations taking a proactive approach to online accessibility are more likely to gain and keep loyal customers in the growing population with vision loss. Many of them have significant spending power and neglecting their needs may not only slow your company’s customer communications efforts and billing cycles, but result in losing customers or failing to attract them in the first place. Like anyone else, many individuals with vision loss will select the businesses they interact with, including insurers and other health-related organizations, based on how easy it is to work with them.
Sidebar: Courts Divided On The Law
In 2017, courts in various jurisdictions in the U.S. heard a number of cases where visually impaired plaintiffs argued that publicly-accessed retail websites rightfully fall under the terms of the Americans with Disabilities Act (ADA) of 1990, as “places of public accommodation” and, therefore, website owners and sponsors should be required to provide accessibility to the visually impaired, just as, for example, brick-and-mortar stores are required to allow wheelchair access. For the most part, the suits were brought against food service companies offering online ordering as well as retailers that do business either in part or exclusively online.
To date, different courts have ruled both in favor and against these claims, depending on the defendant’s specific type of business and its physical and/or virtual facilities. In one case the court ruled that the ADA’s definition of “a place of public accommodation” applies only to organizations that do business in a physical structure as well as online; yet in other cases, the ruling was just the opposite.
While the debate continues, the wiser course may be to prepare now to offer improved online accessibility for blind and partially sighted consumers.
About The Author
An electronic document industry pioneer, Ernie Crawford is President/CEO and founder of Crawford Technologies. One of only a small number people worldwide with M-EDP (Master Electronic Document Professional) designation, Ernie has more than 30 years of senior marketing and management experience in the high-volume electronic printing market.