Organizations should ensure that forms designed to be printed and then filled out are also made electronically fillable. These types of forms typically appear in Adobe Acrobat’s PDF format and contain dashes, underlining, or boxes where information should be entered after printing. These “print forms” do not contain form fields that can electronically be completed using a computer. When forms are designed to be printed and filled out, users with disabilities such as those who are visually impaired, those with mobility impairments, and those or who cannot write may not be able to complete the forms by themselves. Providing forms in an electronically fillable format will allow users in these groups to complete the form electronically in private. The user can then print the form if a paper copy if required. Additionally, having the form completed electronically allows users with disabilities to electronically submit the form where applicable. Submitting paper forms can be difficult for users with disabilities as this often requires mailing, faxing, or delivering the form – all of which require some actions that are inaccessible to some disability groups. Using electronically fillable forms has additional benefits including an increase in form processing time, error prevention, and receipt notification using automation.
Related Disability Legislation
There are a number of disability related laws, regulations, and rulings that may require forms to be electronically fillable. The applicable provisions may depend on the jurisdiction, whether Federal funding is involved, public/private status of the organization, the purpose of the form (medical, employment related, job application), whether alternatives exist, and when the form was last updated. Current accessiblity legislation however does not specifically address making forms electronically fillable. Recent rulings and settlements indicate however that while the accessiblity of content such as this was not specifically covered when accessiblity laws were created, it may be covered by the legislation. This premise is strengthened by the recent use of California’s disability discrimination legislation and the Americans with Disabilities Act (ADA) being used to challenge the accessibility of public websites and electronic content.
The U.S. Rehabilitation Act’s Section 508 technical provisions apply to electronic and information technology used, procured, or maintained by the Federal government. Many states and local governments have adopted accessiblity legislation based on Section 508 and may require certain organizations to conform to these requirements. The technical requirements state that when forms are designed to be completed electronically they are created in an accessible manner. The standards also address the accessibility of the non-electronically fillable content – for example, can the text of the form be access by users of assistive technology and does it appear in the correct reading order. The technical provisions do not specifically address making forms electronically fillable that are designed to printed and filled out. However, Section 508 contains several other sections including Subpart C – Section 1194.31 Functional Performance Criteria. The functional performance criteria address the functional accessiblity of electronic and information technology including when a technical provision does not exist. Under Section 508 Federal agencies are required to afford employees and individuals of the public the same access to and use of information and data that is comparable to that provided to the public who are not individuals with disabilities.
Similarly, the Web Content Accessiblity Guidelines (WCAG) 1 and 2 technical standards do not specifically address making forms electronically fillable. Like the Section 508 requirements, WCAG only specifically addresses the accessibility of forms that are electronically fillable and the accessibility of the non-fillable content. In addition to the WCAG 2 technical guidelines, there are five (5) conformance requirements that must exist for web based content to conform to WCAG 2. These five conformance requirements however do not specifically address this issue. Requirement 4, “Only Accessibility-Supported Ways of Using Technologies:” does specifically address this issues as it relates to ensuring accessibility-supported ways of using technologies are used to meet the technical guidelines’ success criteria. There is not a success criteria non electronically fillable forms.
Methods to Make Forms Electronically Fillable
There are numerous methods to convert paper forms into electronically fillable forms. These methods exist for many document formats including Adobe Acrobat (PDF format). The PDF format sufficiently supports accessiblity that would allow electronically fillable forms to be compliant with the relevant accessibility standards including Section 508 and WCAG 1 and 2.
To allow PDF forms to be filled out electronically, Adobe Acrobat Professional’s “Form Wizard” under the Forms Menu > Start Form Wizard should be used by the organization creating the form. The organization must then ensure that the form is accessible by following all relevant best practices making electronic forms accessible. For example, organizations must ensure that form fields provide explicit accessible labels, ensure error messages are accessible, ensure keyboard access to all form controls, and ensure that instructions and cues are provided in an accessible manner.
Areas of Consideration
Organizations must consider that when information is submitted electronically, it must safe guard the content for individual’s privacy. For this reason, organizations may choose to allow the forms to be filled out electronically on an individual’s computer but require the user to print the form and submit it using non-electronic methods. This approach still provides the bulk of the benefit of electronic forms to users with disabilities.
While the technical accessibility standards defined by current legislation and guidelines do not specifically address the issue of making forms that are designed to be printed and filled out electronically fillable, SSB perceives there is sufficient momentum in court rulings and settlements to indicate that organizations should provide paper forms in electronically fillable format to reduce the legal and associated financial risk associated with inaccessible forms. The current ease at which forms can be made electronically fillable coupled with the benefits of access by users with disabilities, accessibility to the general population, and automation of electronic form processing provide excellent grounds to convert paper fillable forms to electronically fillable forms.