Digital Accessibility Policy


This policy addresses the responsibilities and processes for HealthPals’ electronic content and accessibility for individuals with disabilities. HealthPals is committed to making its electronic content accessible to its customers, staff, and all other individuals with disabilities participating or engaging in the programs and activities involving HealthPals.


HealthPals electronic content is to conform to the Web Content Accessibility Guidelines 2.0, Level A and Level AA standard. Where conformance with this standard is not technically feasible or would result in a fundamental alteration of the nature of the services provided through the electronic content, HealthPals will engage with the individual to provide an equally effective alternative.


This policy is applicable to all HealthPals organizations and business.



Oversight of this policy is managed by HealthPals Compliance in partnership with the HealthPals Legal, Information Technology, and Security offices.
HealthPals will:

  • Take appropriate actions to uphold the accessibility of electronic content.
  • Communicate this policy, and other applicable accessibility information and practices to electronic content users.
  • Respond to and resolve accessibility issues resulting from the development, use, maintenance, or purchase of the electronic content under their control.


HealthPals personnel responsible for existing electronic content, subject to the requirements and exceptions of the applicable laws, are to bring those resources into conformance with the WCAG Level 2.0, Level A and Level AA standard.

  • New electronic content under development and purchase, including any development and purchases for major revisions or updates of existing resources, are to conform to WCAG 2.0 Level A and Level AA.
  • For electronic content in which conformance with the WCAG 2.0, Level A and Level AA standard is not technically feasible or would result in a fundamental alteration of the nature of the services provided through the electronic content, HealthPals will provide an equally effective alternative.
  • HealthPals websites are to contain a mechanism for users to report accessibility barriers to HealthPals Compliance. This will include an accessible online form, email, or other contact information to report the accessibility barrier. The recommended location for this information is on the website's "Accessibility" page, and to provide a link to that page in the header or footer that persists on every page.

Exception Process

An exception to this policy may be requested through HealthPals Compliance. Exception requests must include a detailed description as to why conformance with the Policy is not technically feasible or would result in a fundamental alteration of the nature of the services provided through the electronic content. An exception request granted for specified electronic content is for a limited duration and will be reviewed on a periodic basis.

Implementation Assistance

Techniques for achieving accessibility, technical guidance, and best practices for electronic content are available from HealthPals Compliance. Such assistance may include, but is not limited to, website scanning and monitoring, manual code review, user testing with assistive technologies, accessibility tools and procedures for evaluating websites and web-based applications, accessibility solutions for mobile applications, and training and best practices for electronic content accessibility.

Responding to Accessibility Issues

Addressing the accessibility of electronic content is an ongoing process. Upon being notified of an accessibility issue with electronic content, a HealthPals employee must promptly:

  • Acknowledge the receipt of the issue in writing to the User reporting the issue, with a copy to HealthPals Compliance that identifies the date and the reported accessibility issue.
  • Consult with the HealthPals Compliance to determine appropriate next steps. These steps may include the following:
    • Recommendation of a resolution to the reported accessibility issue.
    • Determination of a reasonable timeline for resolution and, if appropriate, respond to the User reporting the issue of that expected timeline.
    • Communication with the User reporting the issue to determine if an alternate access solution is necessary while the accessibility issue is resolved.
    • Communication with the User reporting the issue with information as to the status of the accessibility issue if the resolution timeline is modified or changed.
    • Upon resolution of the issue, if appropriate, communicate the status to the User reporting the issue and verify their ability to access the electronic content.

If HealthPals Compliance, in consultation with the greater HealthPals organization responsible for the electronic content, determines that the electronic content cannot be made accessible, or that doing so would constitute a fundamental alteration of the nature of the services provided through the electronic content, HealthPals Compliance will engage in an interactive process with the User about alternative methods for providing the information or service in an equally effective alternative manner.

In the event that an equally effective alternative manner cannot be provided or the User is not satisfied with the results, they may contact the Compliance Officer by email at for assistance in resolving the issue.

5.0 Record Keeping

Effective Implementation of Corrective Action and subsequent record keeping will be maintained by the HealthPals Compliance team.

6.0 Enforcement

This policy will be enforced by the Office of the CIO and/or Senior Leadership Team. Violations may result in disciplinary action, which may include suspension, restriction of access, or more severe penalties up to and including termination of employment. Where illegal activities or theft of Company property (physical or intellectual) are suspected, the Company may report such activities to the applicable authorities.

7.0 HIPAA (“Health Insurance Portability and Accountability Act”) Factors

The following sections support are material to and support HIPAA Compliance:

  • All sections of this document are unrelated to HIPAA compliance.

8.0 Definitions


When an individual with a disability is afforded the opportunity to acquire the same information, engage in the same interactions, and enjoy the same services as a person without a disability in an equally effective and equally integrated manner, with substantially equivalent ease of use.

Equally Effective

Alternative access to electronic content that, while not required to produce the identical result or level of achievement, affords an individual with a disability equal opportunity to obtain the same result, to gain the same benefit, or to reach the same level of achievement in the most integrated setting appropriate to the individual’s needs.

Individual with a disability

An individual who has one or more physical or mental impairments that substantially limits one or more major life activities.

Electronic Content

Electronic information and data, as well as the encoding that defines its structure, presentation, and interactions, that accesses, displays, or transmits HealthPals or HealthPals Customer information within the HealthPals domain. Examples include but are not limited to: websites; web- and mobile-based applications; audio and video media; and electronic documents.


As it relates to equally effective alternative access to electronic content, timely means that the individual with a disability receives access to electronic content in reasonable time frame that meets the needs of the individual based on the circumstances.


Defined as current and prospective HealthPals customers, staff, and other relationships with HealthPals.

WCAG 2.0 Level A and Level AA

The Web Content Accessibility Guidelines version 2.0, Level A and Level AA (“WCAG 2.0 A/AA”) are technical standards for web content accessibility developed by the World Wide Web Consortium.