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The parties agree to fully, fairly, and finally settle all claims regarding the accessibility of PSI’s Online Testing Technology. Key provisions require CDI to end medical-documentation prerequisites for blind or visually impaired users relying on screen access software, subject to individualized accommodations, self-certification, and updated procurement and testing obligations under EIT Standards.",{"@graph":69,"@context":122},[70,84,105],{"@type":71,"itemListElement":72},"BreadcrumbList",[73,77,79,82],{"item":74,"name":75,"@type":76,"position":8},"https://docshare.wps.com","Home","ListItem",{"item":78,"name":9,"@type":76,"position":14},"https://docshare.wps.com/document/",{"item":80,"name":35,"@type":76,"position":81},"https://docshare.wps.com/document/healthcare/",3,{"item":83,"name":65,"@type":76,"position":19},"https://docshare.wps.com/document/settlement-agreement-and-release-fully-executed-accessibility-of-online-testing-technology/319852/",{"url":83,"name":65,"@type":85,"image":86,"author":91,"headline":65,"publisher":94,"fileFormat":97,"inLanguage":63,"description":67,"dateModified":98,"datePublished":99,"encodingFormat":97,"isAccessibleForFree":100,"interactionStatistic":101},"DigitalDocument",{"url":87,"@type":88,"width":89,"height":90},"https://docshare.wps.com/thumbnails/settlement-agreement-and-release-fully-executed-accessibility-of-online-testing-technology/319852.png","ImageObject",300,407,{"name":92,"@type":93},"Violet","Person",{"url":74,"name":95,"@type":96},"DocShare","Organization","application/pdf","2026-10-17","2026-09-20",true,{"@type":102,"interactionType":103,"userInteractionCount":19},"InteractionCounter",{"@type":104},"ViewAction",{"@type":106,"mainEntity":107},"FAQPage",[108,114,118],{"name":109,"@type":110,"acceptedAnswer":111},"Who are the parties to the Settlement Agreement and Release?","Question",{"text":112,"@type":113},"The Agreement is entered into by Angela Fowler, Miguel Mendez, Hy Cohen, and the National Federation of the Blind (“Plaintiffs”), and by PSI Services, LLC (“PSI”) and the California Department of Insurance (“CDI”) (“Defendants”).","Answer",{"name":115,"@type":110,"acceptedAnswer":116},"What change does the Agreement require CDI to make regarding medical documentation?",{"text":117,"@type":113},"Within the specified timeline, CDI will no longer require blind or visually impaired individuals who use screen access software to provide medical documentation, unless the individual requests other individualized accommodations.",{"name":119,"@type":110,"acceptedAnswer":120},"How must PSI ensure accessibility of its Online Testing Technology?",{"text":121,"@type":113},"Within 180 days of the Effective Date, PSI must ensure its online testing technology complies with EIT Standards and is independently usable by blind and visually impaired users, and PSI must develop and train proctors on policies permitting use of screen access software without medical certification.","https://schema.org",{"og:url":83,"og:type":124,"og:title":65,"og:site_name":95,"og:description":67},"article",{"robots":126,"canonical":83},"index,follow",{"doc_id":128,"site_id":62},319852,1790259543,{"code":4,"msg":5,"data":131},{"doc_id":128,"user_id":132,"nickname":92,"user_avatar":133,"doc_module":4,"category_id":34,"category_name":35,"doc_title":65,"doc_description":67,"doc_content":134,"file_id":135,"file_url":136,"file_type":137,"file_size":138,"view_count":19,"is_deleted":4,"is_public":8,"is_downloadable":8,"audit_status":8,"page_count":52,"language":139,"language_code":63,"site_id":62,"html_lang":63,"table_of_contents":140,"faqs":141,"seo_title":142,"seo_description":67,"update_tm":143,"read_time":144},4398048950312,"https://ap-avatar.wpscdn.com/avatar/400002538284de19e3c?_k=1778320343897328908","This Settlement Agreement and Release (“Agreement”), deemed in effect as of the Effective Date, is entered into by Angela Fowler, Miguel Mendez, Hy Cohen, and the National Federation of the Blind (“NFB”) (collectively,“Plaintiffs”) and by and between PSI Services, LLC (“PSI”) and California Department of Insurance (“CDI”) (collectively,“Defendants”) . Each of the foregoing are also referred to as a“Party” and collectively referred to as the “Parties.”  \n1. RECITALS  \n1.1 WHEREAS, on October 12, 2021, Plaintiffs, through counsel, filed a Complaint in the Superior Court for the County of Alameda entitled Angela Fowler, et al., v. PSI Services, LLC, et al., Case No. 21CV000126 (“Complaint”) and which alleged disability discrimination in relation to the electronic testing services provided by PSI on behalf of CDI using PSI’s Online Testing Technology and accommodations request and medical documentation procedures;  \n1.2 WHEREAS Defendants deny any wrongdoing or violation of law arising out of the allegations in the Complaint;  \n1.3 WHEREAS the Parties wish to avoid the expense of further proceedings and desire to resolve all claims alleged or that could be alleged in the Complaint;  \n1.4 WHEREAS the Parties hereby fully, fairly, and finally settle all claims Plaintiffs have or may have against Defendants with respect to the accessibility of PSI’s Online Testing Technology for valuable consideration, the receipt and sufficiency of which are hereby acknowledged.  \n2. DEFINITIONS  \nThe following terms shall have the following meanings with respect to this Agreement. All other terms shall be interpreted according to their plain and ordinary meaning.  \n2.1 Electronic and Information Technology Standards (EIT Standards) shall have the same meaning as is set forth in Section 508 of the Rehabilitation Act (29  \nU. S. C. § 794d., subdivision (a)(2)) and its implementing regulations at 36  \nC.F.R. § 1194 app. D.  \n2.2 “Screen Access Software” means software and/or technology that blind or vision impaired individuals use to access electronic content that complies with the EIT Standards defined in section 2.1. For purpose of this Agreement, the Parties agree that Screen Access Software consists of the following:  \nx JAWS (v8 and above)  \nx WindowEyes (v6 . 1)  \nx ZoomText (v8 and above)  \nx MAGic  \nx Dragon NaturallySpeaking (DNS)  \n2.3 “Effective Date” refers to the date by which this Agreement is fully executed by the Parties.  \n2.4 “Online Testing Technology” refers to all electronic information that potential applicants and examinees might use to register for and take online examinations administered by PSI to obtain a license from the CDI.  \n2.5 “Plaintiffs’ Counsel” refers to TRE Legal Practice and Disability Rights Advocates.  \n3. REMEDIATION  \n3.1 CDI’s Testing Accommodations and Procurement. Within the same timeline required of PSI in section 3.2, including any extensions granted after the Effective Date, CDI shall no longer require any blind or visually impaired individual who requires the use of Screen Access Software to access PSI’s Online Testing Technology to first provide medical documentation, unless the individual has requested other individualized accommodations (such as, but not limited to, extended testing times or similar reasonable modifications) . Except for those individuals who request other individualized accommodations, any blind or visually impaired individual who requires the use of Screen Access Software to access PSI’s Online Testing Technology can use such Screen Access Software after a self-certification of the need based on blindness or visual impairment, and without the requirement to submit medical documentation or delay exam scheduling.  \n3.1.1 Unless prohibited by CDI’s delegated authority from the Department of General Services and/or the California Department of Technology, any IT project which is solicited by CDI after the Effective Date and seeks to procure computer-based examination software and on-l","cbCaim9kPYmqTa4p","https://ap.wps.com/l/cbCaim9kPYmqTa4p","pdf",536160,"English","# Recitals\n## Definitions\n# Remediation\n## CDI’s Testing Accommodations and Procurement\n## PSI’s Online Testing Technology and Policies","[{\"question\":\"Who are the parties to the Settlement Agreement and Release?\",\"answer\":\"The Agreement is entered into by Angela Fowler, Miguel Mendez, Hy Cohen, and the National Federation of the Blind (“Plaintiffs”), and by PSI Services, LLC (“PSI”) and the California Department of Insurance (“CDI”) (“Defendants”).\"},{\"question\":\"What change does the Agreement require CDI to make regarding medical documentation?\",\"answer\":\"Within the specified timeline, CDI will no longer require blind or visually impaired individuals who use screen access software to provide medical documentation, unless the individual requests other individualized accommodations.\"},{\"question\":\"How must PSI ensure accessibility of its Online Testing Technology?\",\"answer\":\"Within 180 days of the Effective Date, PSI must ensure its online testing technology complies with EIT Standards and is independently usable by blind and visually impaired users, and PSI must develop and train proctors on policies permitting use of screen access software without medical certification.\"}]","Settlement Agreement and Release - Fully Executed - Accessibility of Online Testing Technology | PDF",1789947530,25]