Fourteen documents published by the Pennsylvania Office of Administration, the Pennsylvania Department of Health, the Pennsylvania State Board of Nursing, and the Erie County Department of Health, downloaded from the agencies' own pages and measured with veraPDF against PDF/UA-1 (ISO 14289-1). Each was repaired, measured again, and compared against the original page by page - by raster where the fix was structural, and word by word where a font had to be embedded. Seven now pass with zero failed rules, including the Board’s own Request Form for Testing Accommodations, the Commonwealth’s own Digital Accessibility Policy, and the Board’s own meeting agenda from September 11, 2026. The other seven are published here with exactly what remains and why, because that gap is the honest part of this work.
These seven carry the PDF/UA-1 identifier because veraPDF independently passed them first, 106 rules out of 106. The identifier is written by hand at sign-off, never by the tool, and never before the file has earned it.
The agenda the Board published four days before the meeting. Eight rules failed: no document title, a silent Department of State logo, a Teams link that announced no destination, and a roster table whose rows did not line up. But the finding that mattered is one no validator reports. The agenda had fifty-five headings, and thirty-four of them were empty — no text, no image, nothing. veraPDF passes a file with thirty-four blank headings; there is no rule against it. A nurse moving through the agenda by heading, which is the normal way to read an agenda, stopped thirty-four times at something that announced “heading” and then said nothing. They are a Word export artifact, so the same defect is in every document built from that template. Twenty more headings sit on address lines; those contain real text, so they were left exactly as published — whether a street address belongs in the outline is the Board’s editorial call, not mine.
This is the policy that sets WCAG 2.1 Level AA as the standard for every Commonwealth agency, and it was six rules short of PDF/UA-1 itself. In fairness it was the closest file on this page: tagged, marked, titled, declared as English, with real alternative text already written for the Office’s logo. Somebody did that work. What remained was small — six links with no accessible name, one horizontal rule four points wide tagged as a picture, four empty spaces left unmarked, and one font carrying a stale character set. Nothing about what the document says changed, and all four pages render identically.
Fourteen horizontal rules were tagged as figures, so a screen reader stopped at each one expecting a description. They are decoration, so they are now artifacts. Two headings skipped levels. Five fonts were named but not carried, which is why it is the one file here whose pages are not pixel-identical — see the note below.
Sixteen pages, tagged but with no document title and two table headers with no scope. Both fixed; the file now validates clean.
A one-page letter sent home to parents after a school screening. It had no title, so a screen reader announced the filename instead.
Twenty-six pages of the statute that governs every nurse in the state, published with no tag structure at all, no title, and no language. A screen reader had nothing to work with. Now tagged, titled, and conforming, with every page unchanged.
Untagged and unmarked on arrival, with three fonts named but not carried. Tagged, then the same three typefaces embedded from the names the file already used.
| Document | Pages | Before | After | What is still failing, and why |
|---|---|---|---|---|
| Pennsylvania Office of Administration | ||||
| Digital Accessibility Policy (eff. 11/12/2025) | 4 | 6 | 0 | Nothing. Conforming, signed off. |
| Pennsylvania Department of Health — school health forms | ||||
| Parent / Guardian Scoliosis Notification | 1 | 2 | 0 | Nothing. Conforming, signed off. |
| Certificate of Immunizations | 1 | 2 | 2 | Two rows of the vaccine grid span a different number of columns than the rest, because the serology boxes are merged cells with no span declared. Which cell was merged is readable off the page by eye and not off the file, so it stays a human decision. |
| Medical Certificate | 2 | 5 | 0 | Nothing. Conforming, signed off. |
| School Dental Form | 2 | 5 | 2 | All four fonts now embedded and all 59 table headers given scope. Three rows still disagree on column count — same merged-cell judgment as the immunization card. |
| Parent / Guardian Hearing Screening Notification | 1 | 8 | 5 | It is a scan. The only machine-readable text on the page is the footer “Reviewed 10/2025”. A deterministic pass cannot OCR a page; that is human work. |
| School Health Record | 4 | 8 | 7 | 99 table rows contain non-cell content and 6 rows disagree on column count (7.2). Four pages of clinical grid; the correct structure is a judgment call. |
| Pennsylvania State Board of Nursing | ||||
| Nurse Licensure Compact Act | 16 | 2 | 0 | Nothing. Conforming, signed off. |
| Professional Nursing Law (Feb 2023) | 26 | 8 | 0 | Nothing. Conforming, signed off. |
| Request Form for Testing Accommodations (rev 06/2025) | 2 | 9 | 0 | Conforming, signed off. It still has zero form fields, so it must be printed to be completed — that is a design decision for the Board, not a validator failure. |
| Erie County Department of Health | ||||
| Tuberculosis (TB) Referral | 1 | 7 | 3 | 47 form fields with no accessible name (7.18.4) and 64 pieces of content neither tagged nor marked as artifact. |
| Animal Bite Report Form | 1 | 7 | 5 | 71 unnamed form fields, 56 untagged content items, one unembedded font. |
| Communicable Disease Referral | 1 | 8 | 6 | 52 unnamed form fields, 64 untagged content items, one link with no description. |
See the translated-document proofs — four state files where translation broke the tagging.