Startups aiming for government contracts must ensure their PDFs are accessible. This guide explores key strategies and considerations for compliance.
A startup can invest significant resources toward securing a government contract, only to discover that the hurdle lies not in pricing, staffing, or product specification—but rather in the accessibility of their PDFs.
Even if a company’s website is compliant with screen reader standards and its product aligns with technical specifications, failure to provide accessible documents can jeopardize the contract. Items like unlabeled forms, improperly tagged reports, or manuals with scrambled reading orders could fail accessibility reviews by the government.
With the Department of Justice extending the deadline for state and local governments to comply with web and mobile accessibility requirements, startups have a unique opportunity to audit their documentation. This period of reprieve allows businesses to examine and rectify any potentially problematic files before they are reviewed during bidding processes.
Understanding the Scope of Accessibility Requirements
Legally, the onus of maintaining accessibility falls on public entities; however, vendors should not underestimate the impact of this obligation. The web content and mobile applications provided by these entities include documentation supplied via contracts or licenses.
The guidance from the DOJ clearly states that when a government hires a contractor for service delivery, it must ensure that all web content, including documents, meets Title II obligations. The pertinent question for vendors is not whether they are regulated, but rather, which components of their work will be utilized by the customer to deliver public services.
This can encompass a wide range of documents: from county benefit forms to software-generated transit reports, or public university manuals tailored for training. Essentially, documents created by a contractor continue to carry accessibility obligations—the responsibility doesn’t transfer merely by virtue of them being produced by a vendor.
Vendors should actively engage with their government customers about what constitutes “in scope.” For instance, is a brochure sent as an email included in the review or just forms that are publicly posted? Clarifying these details now can save significant headaches later.
Comprehensive Document Review
Often, companies will assess the documents included in their proposals and stop short of evaluating the entire service delivery process. It's vital to analyze all documentation that will reach users post-contract signing.
Consider the lifecycle of your service engagement. What types of files will be created, uploaded, or generated for the buyer? Assess each document's potential to impact citizens, students, or business owners. Key document types to evaluate include:
- Forms that users must fill out
- Reports and notifications generated by your software
- Instruction manuals and training materials
- Templates that the government will modify and publish
- Letters or statements sent regularly
- Meeting documents and presentations
- Scanned documents made available online
Additionally, whenever possible, include editable source files for each document. Correcting issues in a PDF is easier when you have access to the original editable file, be it a Word document or design file, allowing for straightforward corrections of headings, table structures, and descriptions.
Document ownership, publication location, and maintenance frequency are critical. Pay close attention to any documents necessary for service applications, information submissions, or deadline adherence, as these hold more significant consequences if they are not accessible. A simple brochure does not carry the same weight as a critical form that must be filled out accurately.
Following the guidance of StartupNation, ensure that accessibility checks are part of your overall offering alongside staffing levels and technical capability, as accessibility is not merely a checkbox but a critical component of successful delivery.
Some existing documents may qualify for exemptions under DOJ guidelines, particularly if they are pre-existing electronic files. However, it’s unwise to build your inventory around potential exemptions without confirming compliance, as updates can alter this status, and other ADA considerations may still apply.
Accessibility Issues in PDF Document Design
Visual checks of a PDF’s appearance alone can give a false sense of security. Just because a document looks well-formatted doesn't guarantee it functions effectively for assistive technologies. Issues such as missing tags, incorrectly labeled form fields, and improper reading orders can all contribute to accessibility failures.
Take, for instance, a two-column report. A sighted individual might read from left to right, completing one column before moving to the next; however, if the document structure is flawed, assistive technology might read across both columns simultaneously, resulting in incoherent or nonsensical text.
Key checks to perform during your accessibility review should include:
- Is the text selectable or is the document scanned as an image?
- Do headings, lists, and paragraphs present a logical structure?
- Is the reading order accurate and follows the intended narrative?
- Are informative images accompanied by useful alternative text?
- Do tables present clear relationships between headers and cells?
- Are links contextual enough to make sense independently of their surrounding text?
- Are all form fields properly labeled, described, and ordered for tab-access?
- Is every interactive element keyboard-accessible?
- Is the document's title and language specified?
Importantly, website accessibility does not automatically ensure document accessibility. While a company might have improved its page navigation or color contrast, many downloadable files may remain untouched.
Automated checking software can highlight certain defects, but even a completed audit doesn’t guarantee compliance. Software might identify a missing description for an image but cannot verify the description's effectiveness. It might also flag a flawed order of reading without recognizing that the order leads to confusion for the user. Always combine automated tools with manual reviews to ensure usability.
Integrating Accessibility into Project Workflow
The ideal strategy is to incorporate accessibility into your workflow long before a document becomes a PDF. During the bidding or discovery phase, inquire about the expectations surrounding accessibility. What standards does the buyer demand? What file types will be provided, and will the buyer require testing outcomes, an accessibility statement, or any specific review processes?
Once work commences, use an accessible source template. Establish clear heading styles, utilize straightforward table structures, provide concise link texts, and describe images while creating content. Attempting to repair formatting issues in a document after exporting typically increases workload and potential errors.
If multiple teams are responsible for creating or updating files, a collaborative document accessibility workflow can streamline responsibilities. Such workflows help everyone stay aligned on source preparation, checking, remediation, and approval steps.
The steps involved in setting up this process include:
- Scope the files: Define which documents will be included in the review and clarify the client's expectations.
- Create from an accessible source: Use templates that already incorporate appropriate structures for writers and designers.
- Test prior to delivery: Engage in a combination of automated and manual checks, and save the results as stipulated in the contract.
- Maintain accessibility: Keep the original source file available, assign responsibility for fixes, and retest documents post-revisions.
Special attention should also be given to recurring reports. Testing a template at the outset is valuable, but ongoing monitoring is crucial as generated data can disrupt formatting, create new table structures, and affect reading order. Always sample the final output.
If subcontractors contribute to content, ensure they are informed about applicable requirements, who is overseeing their files, and the protocol for making necessary corrections. A lack of clarity can lead to accessibility gaps during transitions that nobody addresses.
Remediating Existing Files
For many documents, the cleanest solution is to revisit the source and export a revised version. This approach maintains an editable file for future adaptations.
Other files may require direct remediation. This could include the necessity to add or correct tags, adjust headings, ensure a proper reading order, add alternative text for images, label forms, create bookmarks, and provide correct document properties.
Relying solely on publishing an accessible version alongside an inaccessible one does not meet DOJ benchmarks. Guidance dictates strict conditions under which alternate versions can replace primary content instead of ensuring accessibility.
For large collections of documents, prioritize those in active use over outdated materials. A frequently used benefits application must be accessible before considering old event flyers that garner little engagement. Maintain a log of what is tested, and review files that have undergone repairs after any significant updates.
Maximizing the Additional Time Before RFPs
Utilize this extension period strategically. Focus on one public-sector customer; compile a list of the five most likely files that will reach the public, and inquire about their expectations. Conduct a manual accessibility test on one of those files within the week.
You might be pleased to find the documents are already accessible. Conversely, you may uncover significant barriers, such as forms that can’t be completed without a mouse or reports that do not communicate meaning effectively through screen readers. Regardless of the outcome, take the findings to heart now rather than when a contract is about to be finalized.
Image by pressfoto on Magnific
The strategies discussed provide essential insights for startups looking to navigate the complexities of government contract accessibility requirements. The tasks may seem daunting, but proactive engagement and thorough reviews can pave the way for successful compliance and ultimately, more business opportunities.
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