Digital accessibility standards

Version 1.2 28 June 2023

This guidance is part of the Working in a digitally transformed NHS section of the Good practice guidelines for GP electronic patient records.

Standards

Primary care organisations must ensure that their digital information systems meet the highest standards of accessibility.  In turn, this will enable staff and patients to access information regardless of any disability, impairment, or sensory loss. 

All digital services produced by or for public sector bodies in the UK must meet the internationally recognised ‘AA’ standard of accessibility, the Web content accessibility guidelines (WCAG) 2.1

The standard sets out how to make digital services, websites, and apps accessible to everyone.  Briefly, these standards cover:

  • websites and all their content
  • all software which uses the web browser as the interface
  • intranets
  • extranets
  • applications for mobile devices, such as phones or tablets

Key point | Digital accessibility refers primarily to the technical aspects of the services listed above, and the way they present information and enable users to interact. 

Importantly, digital accessibility standards do not replace other requirements or best practice, such as creating information in plain English and providing translated materials where possible. 

The standards for digital accessibility are particularly relevant when IT suppliers are developing systems.  It is also important, however, for NHS commissioners and providers to factor these in when making purchasing decisions.

The NHS also has an accessible information standard which applies to all NHS- funded organisations.

Actions for practices

Practice website design

Practices are legally responsible for ensuring their website meets accessibility requirements, even if it has been outsourced to an external supplier.

NHS Digital has produced a simple guide to undertaking a rapid accessibility audit which can be performed by staff in the practice.

This can help identify major lapses in accessibility which will need fixing.  Examples include the legibility of fonts and ensuring the use of ‘alternative text’ for images, which allows text readers to read details of web pages more thoroughly.

Guidance is also available on undertaking a more detailed technical audit.  This usually requires input from technical experts rather than practice staff and is most relevant when a new, or significantly updated, system is installed.

The technical audit can also pick up potential issues that users with certain impairments may face when navigating and interacting with the website.

NHS England has published a key resource, Creating a highly usable and accessible GP website for patients, which is designed to help staff that are involved in planning, developing or maintaining a general practice website in order to ensure it meets patients’ accessibility needs. It covers user testing, design and patients’ key information needs, and provides recommended copy for an  ‘appointment’ page,  ‘prescription’ page and ‘contact us’ page.

Staff training

Where practice staff are involved in setting up digital systems or creating content, it is important that they are fully aware of the required standards.  Free eLearning is available for NHS staff on how to apply and follow the accessible information standard.

Practices may wish to consider including this as mandatory training for all staff working in this domain.

Empowering patients

The Patient Information Forum has published a Health And Digital Literacy Charter to encourage healthcare providers to create digital content that is accessible for the widest range of users possible.

The charter prompts organisations to aspire to make digital content that is easy for people to navigate, understand, and use to optimise their health and wellbeing.

Key points:

  • Involve users in the development of information and invite feedback whenever new information is produced.
  • Practices can liaise with their patient participation group (PPG) to obtain this feedback and may also consider using social media platforms where appropriate.
  • Check the readability of written and verbal information created for patients. One of the simplest ways to do this is using the tools included in Microsoft Word to provide a document’s readability and reading age statistics.
  • The NHS Digital Service Manual provides a useful overview on how to write content and includes guidance on writing style, tone, clarity and reading age.
  • It is important to note that the recommended reading age for patient accessible resources is of 9 -11 years old.
  • The Plain English Campaign provides guides and a free tool that can be used to check the readability of a practice website.
  • There are several other online tools that provide recommendations for improving the readability of any text. One free example of this is the Hemingway
  • Train staff in health literacy. Health literacy training could be linked with equality and diversity training, such as that included in the NHS core skills training framework.  E-learning for healthcare also provides a health literacy course for NHS staff.

Exemptions

Some content is exempt from these accessibility regulations.  In general practice, this usually relates to older content which is not feasible to update.  

The exemptions are: 

  • pre-recorded audio and video published before 23 September 2020
  • live audio and video
  • heritage collections like scanned manuscripts
  • PDFs or other documents published before 23 September 2018 can stay as a PDF or office document but only if they are not in current use. If it relates to a current active process, then it must be updated and made accessible
  • maps – but you will need to provide essential information in an accessible format, like an address
  • third party content that is under someone else’s control if you did not pay for it or develop it yourself – for example, social media ‘like’ buttons
  • content on intranets or extranets published before 23 September 2019 (unless you make a major revision after that date)
  • archived websites if they’re not needed for services your organisation provides and they are not updated

Disproportionate burden

The law also includes a provision that releases organisations from complying fully with accessibility regulations if to do so would place a ‘disproportionate burden‘ on them.  The threshold for meeting this exemption is, however, high for organisations who serve people with disabilities or provide essential services.

Other helpful resources