Audit of the Massachusetts Health Policy Commission Overview of Audited Entity

This section describes the makeup and responsibilities of the Massachusetts Health Policy Commission.

Overview

The Massachusetts Health Policy Commission (HPC) was established in 2012 through the Commonwealth’s landmark health care cost containment law, Chapter 224 of the Acts of 2012.

According to HPC’s website,

The Massachusetts Health Policy Commission (HPC) is an independent state agency working to improve the affordability of health care for all residents of the Commonwealth. Through data-driven analysis, actionable policy insights, public accountability, and innovative investments, the HPC seeks to improve health care delivery, lower costs, and reduce health disparities.

HPC is overseen by an 11-member board of commissioners. HPC staff members and commissioners collaborate to monitor and enhance the effectiveness of the Massachusetts healthcare system. HPC is led by an executive director and a deputy executive director, and it comprises six departments: the Office of the Chief of Staff, Office of the General Counsel, Health Care Transformation and Innovation, Market Oversight and Transparency, Office of Patient Protection, and Research and Cost Trends. Each department focuses on specific areas, while also collaborating on cross-agency initiatives to ensure that HPC’s responsibilities are met efficiently, transparently, and on time. The oversight and administrative duties are handled by two departments, while the remaining four concentrate on policy, research, and program operations.

According to Section 9 of Chapter 6D of the Massachusetts General Laws, “Not later than April 15 of every year, the board shall establish a health care cost growth benchmark for the average growth in total health care expenditures in the commonwealth for the next calendar year.”

HPC received appropriations of $11,436,606 and $12,028,078 for fiscal years 2024 and 2025, respectively. HPC’s office is located at 50 Milk Street, 8th Floor, in Boston.

HPC launched masshpc.gov in July 2024. HPC’s website provides reports, policy tools, and updates on healthcare systems within Massachusetts.

Massachusetts Requirements for Accessible Websites

In 1999, the World Wide Web Consortium (W3C), an international nongovernmental organization responsible for internet standards, published the Web Content Accessibility Guidelines (WCAG) 1.0 to provide guidance on how to make web content more accessible to people with disabilities.

In 2005, the Massachusetts Office of Information Technology,¹ with the participation of state government webpage developers, including developers with disabilities, created the Enterprise Web Accessibility Standards. These standards required all executive branch state agencies to follow the guidelines in Section 508 of the Rehabilitation Act amendments of 1998. These amendments went into effect in 2001 and established precise technical requirements to which electronic and information technology (IT) products must adhere. This technology includes, but is not limited to, products such as software, websites, multimedia products, and certain physical products, such as standalone terminals.

In 2008, W3C published WCAG 2.0. In 2014, the Massachusetts Office of Information Technology added a reference to WCAG 2.0 in its Enterprise Information Technology Accessibility Standards.

In 2017, the Executive Office of Technology Services and Security (EOTSS) was designated as the Commonwealth’s lead IT organization for executive branch state agencies. EOTSS is responsible for the development and maintenance of the Enterprise Information Technology Accessibility Standards² and the implementation of state and federal laws and regulations relating to accessibility. As the principal executive agency responsible for coordinating the Commonwealth’s IT accessibility compliance efforts, EOTSS supervises executive branch state agencies in their efforts to meet the Commonwealth’s accessibility requirements.

In 2018, W3C published WCAG 2.1, which built on WCAG 2.0 to improve web accessibility on mobile devices and to further improve web accessibility for people with visual impairments and cognitive disabilities. EOTSS published the Enterprise Information Technology Accessibility Policy in 2021 to meet Levels A and AA of WCAG 2.1.

Timeline of the Adoption of Website Accessibility Standards by the Federal Government and Massachusetts

This object states the following: 1998: The federal Rehabilitation Act is amended. Section 508 of the act mandates that standards establish functional criteria to make information accessible to people with disabilities. 1999: W3C publishes the first version of WCAG. 2001: Section 508 of the federal Rehabilitation Act is in effect. 2005: Massachusetts publishes new standards for accessible websites, called the Enterprise Web Accessibility Standards. 2008: W3C publishes WCAG 2.0. 2014: Massachusetts publishes the Enterprise Information Technology Accessibility Standards to address WCAG 2.0 requirements. 2017: EOTSS is established as the lead information technology organization. 2018: W3C publishes WCAG 2.1. 2020: EOTSS’s Web Design Guidelines are published. They are based on the federal 21st Century Integrated Digital Experience Act. 2021: EOTSS replaces the previous accessibility policies with its new Enterprise Information Technology Accessibility Policy, enforcing the WCAG 2.1 guidelines.

Executive branch state agencies must comply with EOTSS’s policies and standards. However, non-executive branch state agencies, such as HPC, must also comply with EOTSS’s accessibility policies and standards when using an EOTSS web domain,³ as established by EOTSS’s Website Domain Policy. Part of this policy states that any government organization using an EOTSS web domain must comply with EOTSS’s Web Design Guidelines, which were published in 2020 and were based on the federal 21st Century Integrated Digital Experience Act. This law helps state government agencies evaluate their website design and implementation decisions to meet state accessibility requirements.

Web Accessibility

Government websites are an important way for the general public to access government information and services. Deloitte’s⁴ 2023 Digital Citizen Survey found that 55% of respondents preferred to interact with their state government services through a website instead of face-to-face interaction or a call center. Commonwealth of Massachusetts websites have millions of webpage views each month.

However, people do not interact with the internet uniformly. The federal government and nongovernmental organizations have established web accessibility standards intended to make websites more accessible to people with disabilities, such as visual impairments, hearing impairments, and others. The impact of these standards can be significant, as the federal Centers for Disease Control and Prevention estimates that 1,488,012 adults (26% of the adult population) in Massachusetts have a disability, as of 2022.⁵ Among the estimated 26% of the adult population, 14% reported having serious difficulty with cognition, 10% reported having serious difficulty with mobility, 6% reported having deafness or serious difficulty hearing, and 5% reported having blindness or serious difficulty seeing (even when wearing glasses).⁶ Examples of web accessibility measures include, but are not limited to, having captioning on videos to help people with difficulty hearing understand the contents of the video, having form fields describe what data needs to be input into them to help people who have cognitive difficulties, and ensuring that people can interact with a webpage using keyboard commands alone to help people who have difficulty with mobility.

How People with Disabilities Use the Web

According to W3C, people with disabilities use assistive technologies and adaptive strategies specific to their needs to navigate web content. Examples of assistive technologies include screen readers, which read webpages aloud for people who cannot read text; screen magnifiers for individuals with low vision; and voice recognition software for people who cannot (or do not) use a keyboard or mouse. Adaptive strategies refer to techniques that people with disabilities employ to enhance their web interactions.⁷ These strategies might involve increasing text size, adjusting mouse speed, or enabling captions.

To make web content accessible to people with disabilities, developers must ensure that various components of web development and interaction work together. This includes text, images, and structural code, users’ browsers and media players, and various assistive technologies.

Accessibility Features of a Website⁸

This object states the following: A website’s header should appear throughout an entire website and contain hyperlinks to main content areas. Properly labeled fields where a user can enter text allow screen readers to read aloud the types of information that the user should enter. Screen reader users and people with motor disabilities rely in part on the Tab key to navigate between major portions of a website’s content. Headings organize web content in a logical manner and allow users to navigate that content easily. Alternative text should provide a description of any images present so that screen readers can describe those images.

1.    The Massachusetts Office of Information Technology became the Executive Office of Technology Services and Security in 2017.

2.    EOTSS has since changed the titles and numbers of at least some of its policies and standards between the end of the audit period and the publication of this report. In this report, we reference the titles and numbers of EOTSS’s policies and/or standards as they were during the audit period (unless stated otherwise).

3.    EOTSS web domains, according to its Website Domain Policy, include Mass.gov, Massachusetts.gov, Ma.gov, State.ma.us, related subdomains (e.g., example.mass.gov), and all domains that EOTSS owns and manages.

4.    Deloitte is an international company that provides tax, accounting, and audit services to businesses and government agencies.

5.    This data is collected from surveys conducted using both landline telephones and cellular telephones, and all responses are self-reported.

6.    The percentages do not add up to 26%, as estimated by the federal Centers for Disease Control, because of overlapping data. The self-reported survey allows individuals to report having multiple disabilities.

7.    Web interaction refers to the various actions that users can take while navigating and using the internet. It encompasses a wide range of online activities, including, but not limited to, clicking on hyperlinks, submitting forms, posting comments on webpages, and engaging with web content and services in other forms.

8.    We resized this webpage to fit in this audit report. To see the unaltered webpage, visit https://masshpc.gov/about.

Date published:	November 3, 2025