PDF guidance

PDFs are not allowed on any public-facing Penn Medicine websites.

On May 1, 2024, the Department of Health and Human Services (HHS) Office for Civil Rights (OCR) issued a final rule to advance equity and bolster protections for people with disabilities. This rule adopts the Web Content Accessibility Guidelines (WCAG) 2.1, Level AA as its accessibility standard for websites and mobile apps. It also ensures that web-enabled systems in self-service kiosks at medical providers’ offices are accessible. The rule took effect 60 days after the ruling, on July 1, 2024.

Accessibility standards overview
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PDFs

Standard scope

This standard applies to:

  • pennmedicine.org
  • All patient-facing Penn Medicine websites (public-facing, not employee-only or member-only)
  • Penn Medicine public-facing patient-facing mobile applications
  • All Penn Medicine patient-facing digital products (anything digital - if using a computer to access is needed, even if sent as an email attachment.)

Overview

PDFs should not be used to render content in a web browser or mobile application and are not permitted for use in any public-facing Penn Medicine website. To achieve accessibility compliance:

  • All website content and mobile apps must meet WCAG 2.1 Level AA standards.
  • Websites and mobile apps developed or managed by third parties must also comply.
  • These areas must comply within two years starting 60 days after the ruling, i.e., compliance must be completed by July 1, 2026.
  • Healthcare entities are required to train their staff on how to implement and adhere to these standards.

PDF challenges

In addition to our focus on compliance, we are restricting PDFs at this time for the following reasons:

  • PDFs are not designed for reading on screens. PDFs are used to preserve print formatting across different operating systems for printed materials.
  • PDF are often inaccessible to web users who are visually impaired or blind. Colors and text size are difficult to adjust, tab order is not set up correctly for screen readers, and images lack alt text.
  • PDFs do not support best practices in SEO strategy. PDFs lack structured data, files are often large and load slowly and aren’t optimized for mobile devices which makes them rank poorly.
  • PDFs are not mobile friendly. On mobile devices, PDFs have to be downloaded to be viewed. For mobile phone users who have limited data plans, downloading PDFs may be cost prohibitive.

Satisfying print-friendly needs

When there is a need to provide a printer-friendly version of content, use the print.css style instead of creating a PDF. The print.css style will render a printable version of the webpage. This is much easier to implement and conforms to UX best practices.

Rare exceptions

Requests for exceptions must be reviewed and approved by the Director of UX and require signoff by the executive stakeholder of the content.

PDFs may never be used as the only method to render content presented on the web. For the very limited cases in which PDFs must be used, they can only be used as a link from a standard webpage with the same content displayed in HTML. In addition, the following must apply:

  • The PDF must meet all WCAG 2.1 AA compliance criteria.
  • The link to the PDF should not open in a new browser window or tab.
  • The link to the PDF must include the file name, the file size, and the file type, i.e., PDF. For example, Title of document (pdf) (2 MB)

Just as a link to a PDF file from our web site is only permissible if the same content within the PDF file is available as accessible HTML content in the website itself, a link to a form requesting a PDF or other non-HTML file is only permissible if the PDF being provided meets all WCAG 2.1 AA compliance criteria, or if the printed piece will be sent to the requester.

Related resources

Contact

For assistance, please contact web-standards@pennmedicine.upenn.edu

Last updated

Date
Version
Desciption
06/11/25
1.0.0
Initial Release