COMPLIANCE AUDIT LEDGER · TITLE II / 28 CFR Part 35, Subpart H
A live, machine-verified record of how this website conforms to the federal accessibility standard adopted under Title II of the Americans with Disabilities Act, organized by the six subsections of the rule that established the obligation.
Conformant
Every interactive page on this website is currently passing all four automated test suites. The metadata below records when, against what standard, and with what scope.
187 / 187 automated checks passing · snapshot April 8, 2026
§ 35.200 — General Requirement
Subpart H requires public entities to make web content readily accessible to and usable by people with disabilities. The technical standard is WCAG 2.1 Level AA, incorporated by reference. Below: every Level A and AA success criterion that applies to the public site, with the verification mode for each. WCAG conformance is cumulative — Level AA conformance requires satisfying every Level A criterion as well as every Level AA criterion, so the A and AA rows in the table below are not separate categories but a single set of obligations the site must meet in full.
Every Level A and AA criterion that applies to the public site is satisfied by one of three verification modes. The Status column on each row tells the reader which:
<Header /> and <Footer /> components guarantee consistent navigation; manual zoom test verifies reflow at 200%). The MAN column carries a green dot for these rows (7 criteria).| SC | Success Criterion | Status | Lvl | axe | LH | KB | SR | MAN |
|---|---|---|---|---|---|---|---|---|
Principle 1Perceivable | ||||||||
| 1.1.1 | Non-text Content | AUTO | A | ● | ● | — | ● | — |
| 1.2.1 | Audio-only and Video-only (Prerecorded)Not applicable — the public site contains no prerecorded audio-only or video-only content. | N/A | A | — | — | — | — | ● |
| 1.2.2 | Captions (Prerecorded)Not applicable — the public site contains no prerecorded video with audio. Board meetings are held on Zoom (an external service) and are not embedded. | N/A | A | — | — | — | — | ● |
| 1.2.3 | Audio Description or Media Alternative (Prerecorded)Not applicable — the public site contains no prerecorded video. | N/A | A | — | — | — | — | ● |
| 1.2.4 | Captions (Live)Not applicable — the public site does not stream live audio or video. | N/A | AA | — | — | — | — | ● |
| 1.2.5 | Audio Description (Prerecorded)Not applicable — the public site contains no prerecorded video. | N/A | AA | — | — | — | — | ● |
| 1.3.1 | Info and Relationships | AUTO | A | ● | ● | — | ● | — |
| 1.3.2 | Meaningful Sequence | AUTO | A | ◐ | — | — | ● | — |
| 1.3.3 | Sensory CharacteristicsVerified by manual content review — the public site has no instructions that rely on shape, size, sound, or visual location alone (e.g. "click the round button on the right"). | MANUAL | A | — | — | — | — | ● |
| 1.3.4 | Orientation | AUTO | AA | ● | — | — | — | — |
| 1.3.5 | Identify Input Purpose | AUTO | AA | ● | ● | — | — | — |
| 1.4.1 | Use of ColorColor-only state information is also covered by manual review. | AUTO | A | ◐ | — | — | — | ◐ |
| 1.4.2 | Audio ControlNot applicable — the public site has no audio that plays automatically. | N/A | A | — | — | — | — | ● |
| 1.4.3 | Contrast (Minimum) | AUTO | AA | ● | ● | — | — | — |
| 1.4.4 | Resize Text | AUTO | AA | ◐ | — | — | — | — |
| 1.4.5 | Images of TextVerified by manual review of the public-site image inventory; all text is rendered as HTML, not images. | MANUAL | AA | — | — | — | — | ● |
| 1.4.10 | ReflowVerified by responsive viewport testing in Playwright at 320px and a manual 200% browser zoom check. | MANUAL | AA | — | — | — | — | ● |
| 1.4.11 | Non-text Contrast | AUTO | AA | ● | ◐ | — | — | — |
| 1.4.12 | Text SpacingVerified by manual stylesheet-override test (line-height 1.5×, paragraph spacing 2×, letter spacing 0.12×, word spacing 0.16×). | MANUAL | AA | — | — | — | — | ● |
| 1.4.13 | Content on Hover or Focus | AUTO | AA | — | — | ◐ | — | — |
Principle 2Operable | ||||||||
| 2.1.1 | Keyboard | AUTO | A | ◐ | — | ● | — | — |
| 2.1.2 | No Keyboard Trap | AUTO | A | — | — | ● | — | — |
| 2.1.4 | Character Key ShortcutsNot applicable — the site implements no single-character key shortcuts. (Cmd+K for site search uses a modifier key and is exempt from this criterion.) | N/A | A | — | — | — | — | ● |
| 2.2.1 | Timing AdjustableNot applicable — the public site enforces no time limits on user actions. | N/A | A | — | — | — | — | ● |
| 2.2.2 | Pause, Stop, HideDecorative animations honor prefers-reduced-motion via the global @media rule in globals.css. | AUTO | A | ◐ | — | — | — | ◐ |
| 2.3.1 | Three Flashes or BelowNot applicable — the public site has no flashing content. Verified by manual review of every animation. | N/A | A | — | — | — | — | ● |
| 2.4.1 | Bypass Blocks | AUTO | A | ● | ● | ● | ● | — |
| 2.4.2 | Page Titled | AUTO | A | ● | ● | — | — | — |
| 2.4.3 | Focus Order | AUTO | A | ◐ | — | ● | — | — |
| 2.4.4 | Link Purpose (In Context) | AUTO | A | ● | ● | — | ● | — |
| 2.4.5 | Multiple WaysVerified architecturally — the site provides three independent ways to find content: site-wide command palette (Cmd+K), the /site-map index page, and linear top-navigation menus. | MANUAL | AA | — | — | — | — | ● |
| 2.4.6 | Headings and Labels | AUTO | AA | ● | ● | — | ● | — |
| 2.4.7 | Focus Visible | AUTO | AA | — | — | ● | — | — |
| 2.5.1 | Pointer GesturesNot applicable — no path-based or multipoint pointer gestures are used on the public site. | N/A | A | — | — | — | — | ● |
| 2.5.2 | Pointer CancellationVerified architecturally — all interactive elements use standard browser click semantics, which fire on pointer-up and are cancelable by dragging away before release. | MANUAL | A | — | — | — | — | ● |
| 2.5.3 | Label in Name | AUTO | A | ● | ● | — | ● | — |
| 2.5.4 | Motion ActuationNot applicable — the public site has no motion-actuated functionality (no shake-to-undo, no tilt controls). | N/A | A | — | — | — | — | ● |
Principle 3Understandable | ||||||||
| 3.1.1 | Language of Page | AUTO | A | ● | ● | — | — | — |
| 3.1.2 | Language of Parts | AUTO | AA | ● | — | — | — | — |
| 3.2.1 | On Focus | AUTO | A | — | — | ◐ | — | — |
| 3.2.2 | On Input | AUTO | A | — | — | ◐ | — | — |
| 3.2.3 | Consistent NavigationVerified architecturally — every public page renders the same shared <Header /> and <Footer /> components from src/app/(logged-out)/_components2, so navigation order is necessarily consistent. | MANUAL | AA | — | — | — | — | ● |
| 3.2.4 | Consistent Identification | AUTO | AA | — | — | — | ◐ | — |
| 3.3.1 | Error Identification | AUTO | A | ◐ | — | — | ● | — |
| 3.3.2 | Labels or Instructions | AUTO | A | ● | ● | — | ● | — |
| 3.3.3 | Error Suggestion | AUTO | AA | — | — | — | ◐ | — |
| 3.3.4 | Error Prevention (Legal / Financial / Data)Not applicable — the public site contains no legal, financial, or data-modification submission forms. (Renewals and applications live behind authentication and are scoped separately.) | N/A | AA | — | — | — | — | ● |
Principle 4Robust | ||||||||
| 4.1.1 | Parsing | AUTO | A | ● | ● | — | — | — |
| 4.1.2 | Name, Role, Value | AUTO | A | ● | ● | — | ● | — |
| 4.1.3 | Status Messages | AUTO | AA | — | — | — | ● | — |
§ 35.201 — Exceptions
Subpart H lists five categories of content that are exempted from the WCAG conformance requirement. NDSBO invokes two of them, and explicitly does not rely on the other three.
§35.201(b)
Invoked
PDF, Word, PowerPoint, and Excel documents posted before the compliance date, unless currently used to apply for, access, or participate in a public entity’s services, programs, or activities.
NDSBO ScopeBoard meeting minutes, statute reprints, and application form PDFs posted before April 24, 2026. Each is being remediated or replaced with HTML alternatives on a rolling basis.
Tracked at docs/pdf-accessibility-backlog.md
§35.201(c)
Invoked
Content posted by a third party where the third party is not posting due to a contractual, licensing, or other arrangement with the public entity.
NDSBO ScopeExternal Zoom meeting links, the ARBO OE Tracker continuing-education portal, and outbound links to the National Board of Examiners in Optometry. NDSBO has no contractual control over the accessibility of these third-party destinations.
Exceptions NOT invoked
§35.201(a)
Archived web content
§35.201(d)
Individualized password-protected documents
§35.201(e)
Pre-existing social media posts
§ 35.202 — Conforming Alternate Versions
NDSBO does not generally rely on conforming alternate versions in lieu of direct accessibility. The one exception is the optometrist directory map: visual map interactions are supplemented with a fully accessible card-based list view of the same data, reachable from the same page without additional navigation.
§ 35.203 — Equivalent Facilitation
Not currently invoked. NDSBO meets WCAG 2.1 AA directly on every public page; no substitute methods are claimed in place of the standard.
§ 35.204 — Duties Beyond Subpart H
Subpart H does not displace NDSBO's broader Title II obligations. The Board remains responsible for effective communication, reasonable modification of policies, and program access under the underlying ADA regulations. Requests for an alternative format, an interpreter, or any other accommodation may be directed to the Board's ADA Coordinator using the contact information in the Feedback section below.
§ 35.205 — Minimal-Impact Noncompliance
Subpart H provides a narrow safe harbor for noncompliance whose impact on access is so minimal that it would not affect a person with a disability's ability to use the content. NDSBO does not invoke this provision. Any barrier reported through the feedback channel below is treated as a remediation item, not a safe-harbor case.
Methodology
Each suite is reproducible from the source repository. The commands below run against either the dev server or a production build (Lighthouse). All four are executed on every code change as part of the normal development workflow.
Suite I
Static DOM and ARIA audit
axe-core 4.11 via Playwright (Deque Systems)
Walks every public route and asserts zero serious or critical violations against the WCAG 2.1 A and AA rule sets. Catches missing labels, contrast failures, malformed ARIA, parsing errors, broken landmark structure, and most static-DOM correctness issues.
$ pnpm test:e2e accessibility.spec.ts
Suite II
Composite accessibility score
Lighthouse 12 via Lighthouse CI (@lhci/cli)
Independent corroboration of axe-core's findings using Google's accessibility audit. Run against a production build (not the dev server) to catch issues that only manifest after Next.js optimization. CI fails any route below 95.
$ pnpm dlx @lhci/cli autorun
Suite III
Real Tab / Enter / Space / Escape interaction
Playwright keyboard spec (Chromium)
Verifies what static-DOM tools cannot: that the skip link is the first tab stop on every page, that 20 sequential tab stops on every page show a visible focus indicator, that no element traps focus, and that page-specific flows (mobile drawer, command palette, directory filters, FAQ accordion) activate correctly via keyboard.
$ pnpm test:e2e keyboard.spec.ts
Suite IV
Spoken-output assertions for every interactive element
@guidepup/virtual-screen-reader via Playwright (Chromium)
Walks the same accessibility tree that VoiceOver, NVDA, and JAWS consume and asserts the actual phrases each interactive element produces — landmark announcements, heading hierarchy, label / role / state on form controls, live-region updates, dialog announcements, and external-link affordances.
$ pnpm test:e2e screen-reader.spec.ts
Audit Ledger
Issues identified during the initial WCAG audit and the work required to resolve each one. Every category is now fully remediated; the test suites above are the regression guards.
Category
A
WCAG 1.3.1, 3.3.2, 4.1.2
Every directory search input, sort dropdown, and license-status select was given a visible, programmatically-associated <Label>. Advanced filter toggles expose aria-expanded / aria-controls.
Category
B
WCAG 2.1.1, 4.1.2
Replaced non-semantic clickable elements with real <button>s. Added accessible names to the mobile drawer trigger and search-trigger button, and added required Radix DialogTitle / DialogDescription.
Category
C
WCAG 1.3.1, 4.1.3
Directory result-count badge wrapped in role="status" + aria-live="polite" so search counts are announced as the user types.
Category
D
WCAG 1.1.1
All decorative Lucide icons across header, footer, meetings, directory, and site search marked aria-hidden so screen readers don’t read out icon names redundantly.
Category
E
WCAG 2.4.4, 3.2.4
Every link that opens in a new tab announces "(opens in new tab)" via a screen-reader-only span and uses rel="noopener noreferrer". A reusable <ExternalLink> wrapper exists for new code.
Category
F
WCAG 1.4.3
Brand --primary, --primary-foreground, and --muted-foreground tuned in globals.css to clear 4.5:1 against their backgrounds. Status badges and the "Unlimited" badge bumped one shade darker. Hero accent retuned for navy backgrounds.
Category
G
WCAG 2.3.3
Global @media (prefers-reduced-motion: reduce) rule neutralizes all CSS animations and transitions. Framer Motion page transitions wrapped with useReducedMotion().
Category
G2
WCAG 1.3.1
FAQ section titles (previously rendered with shadcn <CardTitle> as <h3>) replaced with <h2> so the page reads h1 → h2 → h3 instead of skipping a level.
Category
G3
WCAG 1.3.1
Home page restructured so <Header /> and <Footer /> are siblings of <main> rather than children. Nesting them inside <main> stripped their implicit banner / contentinfo ARIA roles. Caught by the screen reader spec, not by axe or Lighthouse.
Category
H
WCAG 2.4.5
Site-wide command palette (Cmd+K) enabled in production, satisfying the "Multiple Ways" criterion. /accessibility added to the unauthenticated routes allowlist.
Category
I
WCAG 28 CFR §35.200
Public accessibility statement added at /accessibility, plus this auditor compliance ledger at /accessibility/monitor, both linked from the footer of every public page.
Pre-existing Conformance
Items that required no remediation. Verified during the initial exploration and confirmed by the test suites.
| SC | Criterion | What was already in place |
|---|---|---|
| 3.1.1 | Language of Page | <html lang="en"> set on the root layout |
| 2.4.1 | Bypass Blocks | "Skip to main content" link as the first focusable element on every public page |
| 1.3.1 | Info and Relationships | Heading hierarchy is sequential on every public page (post Category G2 fix) |
| 2.4.4 | Link Purpose | No "click here" / "read more" anti-patterns anywhere in the public site |
| 4.1.2 | Name, Role, Value | All Radix UI primitives (Accordion, Dialog, Select, ToggleGroup, NavigationMenu) ship with correct ARIA out of the box |
Feedback & Escalation
If you encounter an accessibility barrier, need information in an alternative format, or have questions about anything on this page, contact the Board's ADA Coordinator. We aim to respond within five business days.
ADA Coordinator
North Dakota State Board of Optometry
2222 E. Broadway Ave, Bismarck, ND 58501
Phone(701) 471-0289
Emailndoptometryboard@gmail.com
Other paths
ACCESSIBILITY_CHANGES.md in the source repository.Colophon — this ledger was last reviewed April 8, 2026 and is regenerated from the source repository on every code change.