In Black & White

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The ADA & US Government: What you need to know in 6 minutes

The ADA & US Government: What you need to know in 6 minutes

  • Jamie Black
  • Financial Reporting
  • minute(s)While many have heard of the Americans with Disability Act (ADA), few truly understand its importance: Why should a finance or budget professional care about it? What do the laws (there are three) specifically require? How must I comply with the laws? This article answers these questions. 1) Finance & Budget Departments Should Care Designing documents that are easily understood by your audience is challenging. When some of your audience have visual impairments, there is an additional set of considerations. There are three primary reasons you should care about this topic: As a public sector organization, you want your message available to everyone. Approximately 5.5 million people have visual impairment in North America today. This is expected to double by 2050.  To “read” your CAFR or Budget Book, visually impaired individuals must use assistive technology. These tools read the PDF to them electronically. Unless specifically designed for accessibility however, your PDFs will not be readable by assistive technology. Your organization is legally required to ensure all public documents are accessible (readable by assistive technology). Accessibility for your documents is legally mandated if: you work in a local government, a federal agency, or, a place of "public accommodation" (privately-owned, leased or operated facilities like hotels, restaurants, retail merchants, doctor’s offices, golf courses, private schools, daycare centers, health clubs, sports stadiums, movie theaters, and so on), and you are located in the United States, and you publish content to a publicly accessible website. Numerous lawsuits have been launched for failure to ensure accessibility both for businesses and local governments. As identified by Seyfarth Shaw LLP, these lawsuits are becoming more and more prevalent.   2) The Laws Mandate Accessibility Section 508 of the Rehabilitation Act of 1973 In 1998, Congress amended the Rehabilitation Act of 1973 to require Federal agencies to make their Electronic and Information Technology (EIT) accessible to people with disabilities. The law (29 U.S.C § 794 (d)) applies to all Federal agencies when they develop, procure, maintain, or use electronic and information technology. Under Section 508, agencies must give disabled employees and members of the public access to information comparable to the access available to others. On January 18, 2017, the U.S. Access Board published a final rule updating accessibility requirements for Information and Communication Technology (ICT) covered by Section 508 of the Rehabilitation Act and Section 255 of the Communications Act. E205.4 of this final rule stipulates the accessibility standard mandated by Section 508: Electronic content shall conform to Level A and Level AA Success Criteria and Conformance Requirements in Web Content Accessibility Guidelines ( WCAG 2.0) (incorporated by reference, see 702.10.1). Americans with Disabilities Act (ADA) It was signed into law on July 26, 1990, by President George H.W. Bush. The ADA is one of America's most comprehensive pieces of civil rights legislation that prohibits discrimination and guarantees that people with disabilities have the same opportunities as everyone else. The ADA has three "Titles" (think sections), and it is Title II that applies to the programs and activities of state and local government (title I is employment practices and title III covers private entities that are considered public accommodations).  While the ADA does not explicitly reference requirements for web content, the Department of Justice (DOJ) Civil Rights division has confirmed their opinion that the ADA does in fact cover content on web sites. Unfortunately, there is no technical definition for ensuring your web content complies with the ADA. Congress sought clarification from the DOJ in 2018, but their response was noncommittal as to the standard required: Absent the adoption of specific technical requirements for websites through rulemaking, public accommodations have flexibility in how to comply with the ADA's general requirements of nondiscrimination and effective communication. In late July 2019, a series of questions were again raised to the DOJ from several senators looking for clarification. In particular, the senators attempted to learn if the DOJ "consider WCAG 2.0 an acceptable compliance standard". No response from the DOJ has been received as of this writing. California Assembly Bill No. 434 This legislation states that by July 1, 2019 all web content of the state agency or entity must meet... the Web Content Accessibility Guidelines 2.0, or a subsequent version, published by the Web Accessibility Initiative of the World Wide Web Consortium at a minimum Level AA success criteria. 3) Standards Determine Compliance Web Content Accessibility Guidelines (WCAG) Two of the three pieces of legislation above specifically reference Web Content Accessibility Guidelines 2.0 as the relevant standard that our documents must conform to. These guidelines were developed by the World Wide Web Consortium (W3C),  an international community that develops open standards for the Web. WCAG 2.0 contains 12 guidelines designed to make content published on the web more accessible for those with impairment. Testable criteria are also provided to allow for the assessment of your content. Any piece of content can be assessed into one of three levels of conformance : A (lowest), AA, and AAA (highest). Note that the legislation mentioned above specify the level that your content must achieve. PDF/Universal Accessibility (PDF U/A) We mention this standard here as you may hear it and be confused by it. PDF/UA is the informal name for ISO 14289, the International Standard for accessible PDF technology. A technical specification intended for developers implementing PDF writing and processing software, PDF/UA provides definitive terms and requirements for accessibility in PDF documents and applications. PDF/UA defines the technical specifications to enable PDF documents to meet WCAG 2.0, but WCAG 2.0 has additional requirements that call for an author’s attention. For these and other additional requirements, the W3C’s technique documents (both general and PDF-specific techniques) guide authors interested in complying with WCAG 2.0. In short, if you are a state or local government in the United States and want to be confident that you comply with the various pieces of legislation, all content you publish to the web must conform to WCAG 2.0 level AA standard. Watch this space for our next article on the technical requirements of WCAG 2.0 and a methodology to employ to make your published documents fully compliant with the standards mandated by the ADA, Section 508, and California Bill 434.   
Accessibility - Why should finance & budget professionals care? What do the laws (3!) require? How can you comply? This article provides the answers.
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What do you mean? How to be sure your readers understand you

What do you mean? How to be sure your readers understand you

  • Jamie Black
  • Financial Reporting
  • minute(s)Communicating is difficult at the best of times. When our topic is complex and, let's be honest, boring, the job is even harder. In this article, we will tackle one very useful technique for ensuring the readers of your financial reports and budget books understand what you are attempting to convey. The single biggest problem in communication is the illusion that it has taken place. George Bernard Shaw As we have discussed in previous posts, text is one of the three essential tools at your disposal when trying to communicate non-verbally. Recall, the purpose of text is to: introduce a topic, a problem, a business process, or other item that the reader might not be fully conversant in, explain a graph or the table so the reader does not miss any nuances, highlight or call out a particular point in a table or graph, label a specific data point in a graph or columns or rows in a table, recommend appropriate next steps or actions. When using text, however, not all words or the sentences they create are equal. Readability Readability is the degree that the prose you write can be understood. Readability is influenced by: word length, use of conventional or unique words, sentence length, number of clauses in each sentence, number of syllables in each sentence, A common but bad habit for writers is to prefer longer, wordier, and more complex text. In almost all cases, this is a mistake. When trying to communicate complex information, as is often the case for finance and budget officers, focus on simplicity. Simplicity makes understanding easier and faster for your reader. After all, who has not abandoned reading an article because it was too long or too hard to follow? Some tips to consider to improve the readability of your text: avoid jargon and acronyms, omit unnecessary words, use shorter sentences, consider the reading level of your audience. Testing Readability If you want to improve readability, test your text. There are numerous readability-formulas & tools you can use. One popular formula is the Flesch-Kincaid Grade Level. It attempts to measure the approximate grade level required to understand the text. There are numerous tools that will use this and other formulas on your text. From tools that only test the Flesch-Kincaid Grade Level (ReadabilityFormulas.com) to broader tools that also asses grammar more generally (Grammarly  & Readable) there are many options to choose from. The results of testing your text can be surprising.  An Example Imagine you are drafting an introduction to your budget book. Your goal is to explain to the reader some of the high-level goals of the organization. You want them to understand the principals that lead to designing the budget council adopted. Here is the first paragraph you initially write: The City's annual budget is created to reflect the Mayor's priorities and address community needs each year. The budget process takes place over a five-month period, during which agencies propose new or expanded programs and investments to better serve the public and meet the goals set out by the City. The Budget & Management Office staff assess proposals for their merits across a collection of considerations, with the first among them being the Mayor's Strategic Framework. This framework, shown in the graphic below, illustrates Mayor Smyth's dynamic priorities as it relates to creating a world class city where everyone has access to a home, a job, and a content future. The following pages outline key strategies and investments for priority areas and the metrics used to calibrate success. The score of this text: 128 words Average word length is 5.2 characters 5 sentences Average sentence length is 25.6 words Reading time: 30 seconds Flesch-Kincaid Grade Level: 14 (college level) This scoring may not immediately cause you concern. If you consider the average level of education in your community, however, you will see the problem. First, only 61.8% of Canadians and 49.8% of Americans aged 25 to 34 had either college or university qualifications. Secondly, most people prefer to read a few levels below their absolute maximum comprehension level. A second draft of the paragraph revised to improve readability: The City's annual budget reflects the Mayor's priorities and addresses community needs. First, agencies propose new/expanded programs. Budget & Management Office staff then assess these proposals for their merits. This process takes five months. The graphic below illustrates Mayor Smyth's priorities to create a world-class city where everyone has access to a home, a job, and a future. The following pages outline strategies for priority areas. They also provide the measures used to determine success. The score of the revised text: 75 words (decreased 53 words) Average word length of 5.6 characters (increased slightly) 7 sentences (increased by 2) Average sentence length is 10.7 words (decreased by approximately 15) Reading time: 18 seconds (decreased by 12 seconds) Flesch-Kincaid Grade Level: 9 This second version of the text reduced reading time by 40% and made the content understandable to more of our potential audience. Evaluate the readability of your text and make it as easily comprehensible as possible. Improving readability is one essential and easy step to improving your communication.  
Communicating complex information is a challenge faced everyday by finance & budget departments. This article explores one key to success - readability.
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3 questions to answer before report design

3 questions to answer before report design

  • Jamie Black
  • Style & Substance
  • minute(s)When finance is asked to prepare a new report or redesign an existing report (financial statements, budget book, quarterly forecast, MD&A, etc) the decisions made can dramatically impact understanding.   In our experience, formally dealing with these decisions (the design stage) is rare. As we have discussed in Style & Substance before, there seems to be little formal direction on how to design reports. Combine this lack of direction with an abbreviated, overlooked design process, and you run the risk of having some fundamentally flawed reports; reports that confuse, distract and obfuscate the data.  When tackling a new report or re-developing an old one, these three questions need to be asked during the design phase: Who will use the report, What must be reported, and How should it be presented This article examines the best practice for communicating financial information and why adhering to it is essential to improve your financial reporting.  Question 1 - "Who" Knowing who the likely user of the report is, should make a critical difference in report design decisions. For example, if the likely user is the senior management team, perhaps very general introductions and explanations are unnecessary as you can be certain they have great knowledge about the organization.   On the other hand, if the users are likely to be non-finance experts, new to the organization (newly elected council members for example), or external to the organization, then the use of jargon or omitting general introductions or explanations may well be unwise. Are the users technologically adept? If so, providing the report electronically may be the best option. Electronic distribution is especially powerful if the board/council will want to make & share notes, and create action items based on the report.  On the other hand, if the user is not comfortable with technology, a well crafted, printed document is likely a superior choice.  Why does technology matter when designing a new report? If the destination is paper & ink, then you are bound to designing a report to fit on 8.5" x 11" paper, printed in portrait orientation. If the ultimate destination is an iPad or a computer screen, you may be able to abandon these constraints.  Question 2 - "What" The first, most fundamental "What" question is "What answers are readers trying to get with this report?" This is an absolute prerequisite before creating the report.  Consider some examples - If finance is reasonably confident that users of the report are looking to understand profitability, they will tailor the "What" to show the variables that are most explicitly tied to profit. In many cases, this is where finance's expertise comes in. Likely their experience means they have a very clear understanding of the relationships that affect profit. Now is finance's opportunity to leverage the report to communicate their knowledge to the user(s) of the report.  If you are in the automotive sales industry, you might know that region, and product category most directly affects profit. You would then omit or summarize data if it confused the topic. Thus the design must allow the user to see the relationship clearly. Do they need to know how much budget is available for a specific department, fund or program? If so, this information should be displayed with priority. Too often reports are generated without first establishing very clearly what answers the user needs. If this failure occurs, end users of the report are often left to dump a report out to Excel to manipulate the data to find the answers they seek themselves.  The next step in report design is asking, "What data should be included in this report to answer the readers' questions?" In our experience, these sorts of questions are fairly straightforward and easily answered by the finance team. Examples include: What type of data should be presented? Actuals, Budget, Forecast or all three? Revenues, Expenses, Operating, Capital What date range will this report cover? Current Year to Date, Current Period, Prior Year(s) What level of detail must be presented? Individual GL accounts? Or should the accounts be grouped on some basis? Question 3 - "How" For finance professionals, the "How" can be more challenging. This is because formal training on how to present the data and how presentation choices can affect interpretation is not commonplace. Consequently the answer to "How?" is often "Let's throw the data in a table with several columns and rows. That'll satisfy them!" As a means of helping our would-be report creators, here are some guideposts (at a high level) for how best to present our data. There are 3 different devices we might use to communicate our message: Tables: A table encodes quantitative data as text. Table are the right choice when: the exact value is important. For example, budget officers might need to know that Public Works is precisely $101,985 over budget. comparison of exact values is important. there are multiple units of measure to be displayed together. For example, the quantity of 911 calls, dollars of expense for the Policing department and variance against budget as a percentage.  Graphs: A graph encodes quantitative data visually. They are best used when: the message you wish to communicate is best understood in patterns, relationships among and between quantitative values & exceptions.  there is no need for precise numbers or to compare individual values. For example, budget officers only need to know that Public Works is approximately $100k over budget. there is a need to show much more complex relationships. vary large data sets must be presented. Narrative/Text: Complements graphs and tables. Consider using narrative text to: Introduce a topic, a problem, a business process or other item the reader might not be fully conversant on.  Explain the graph or the table so the reader does not miss any nuances. Highlight or calling out a particular point in a table or graph. Label a particular data point in a graph, or columns or rows in a table. Recommend appropriate next steps or actions. In subsequent articles, we will delve deeply into Tables, Graphs, and Text to layout their use and how they fit into the best practices in financial reporting. If you are interested in further reading on these topics we strongly recommend a couple of authors who have fundamentally informed & challenged our opinion over the years. Stephen Few & Edward Tufte are both incredibly insightful and helpful on all topics associated with communicating complicated information. As an added bonus, the hardcover versions of their books are very close to works of art!
When finance is tasked with creating a new report, best practice for financial reporting says there are 3 essential questions to answer before you begin.
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Best practices for communicating financial information

Best practices for communicating financial information

  • Jamie Black
  • Style & Substance
  • minute(s)Our appetite for reporting is insatiable. Every time finance professionals turn around there is some new disclosure required. Non-finance folks often do not appreciate how much work each new request entails. After all - designing the report and obtaining the right data is often a great deal of work and there is no magic shortcut (once the design is done however there are tools that can dramatically accelerate the generation of the reports). When designing some reports, we are constrained by a financial reporting standard (PSAB, GAAP, GASB, IFRS etc.). These standards are very prescriptive; they guide professionals about what data must be presented and how it is to be presented.  What about those other reports you prepare and present that may not have such absolute standards to guide you? Reports like the budget book, management discussion & analysis (MD&A), and quarterly variance reports are often complex documents full of images, graphs, tables and narrative that must combine to tell a comprehensive story to the reader. Where do you get direction on what these reports should look like and what they should include? Very often the What is based on broad guidance from an authority (GFOA perhaps), past experience, custom, what your competitor/neighbor has done and your understanding of reader preference.  Significant weight is often given to recreating the same information which appeared in past iterations, especially when presenting to board/council that are not finance experts. Our experience tells us your recipe starts with "that's what we have always done", and is updated based on the questions your receive from council or board of directors.   And the How? The answer is the same as for the "What", supplemented by the Communication department. In many organizations, there is a Communications department that specifies fonts and spacing guidelines and such. Despite these "guides", there are still a lot of questions left to the finance professional to answer: Should you use tables, graphs or prose to communicate a particular point? Is a pie, bar, line, column, area, scatter, bubble, doughnut or radar chart/graph best in this situation? What colours should we use in our charts/graphs?  Should we put labels in the chart/graph, below in a legend, or both?  Finance & budget professionals who are given the responsibility of making these decisions may not be well-trained in the How, and their choices will affect how the data is read and understood. Consider the graph below: Is the reader now likely to better understand your data as a result of this graph? Unequivocally, "NO" is the answer.  These decisions are far too important to leave to the flip of the coin or a personal sense of style, especially if you are presenting financial data to non-finance experts.  In this series, we will provide finance & budget officers with best practices they should employ when presenting financial data. We will explore many of the Do's and Do Not's and will endeavor to show examples (good and bad) to illustrate the point. For example, not sure why we say the graph above is horrible? Continue reading this series and you will learn this and much more! To make sure you do not miss any of our Style & Substance posts, be sure to sign up for our blog today. 
Finance officers are often unaware of the best practices in communicating complicated information. The result can be confusion, and poor decision making.
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