Readability for Government and Plain-Language Compliance: Meeting Federal and Accessibility Standards

Readability for government audiences isn't optional. The Plain Writing Act of 2010 requires federal agencies to write covered documents in plain language, and Section 508 requires their web content to meet WCAG accessibility standards. Neither one defines plain language as a score. The Act names no readability formula and no grade level, so most government writers work from scattered guidance: an outdated training module here, an agency memo there.

This guide separates what the law requires from what is good practice, shows how readability formulas fit in, and gives you a checklist for reviewing a document before it goes out.

The Plain Writing Act: What Government Agencies Are Actually Required to Do

The Plain Writing Act (PWA), signed in 2010, requires federal agencies to use writing that is "clear, concise, well-organized," and follows best practices suited to the subject and the intended audience. But what does that mean in practice?

The law requires each agency to:

• Use plain writing in every covered document it issues or substantially revises
• Designate a senior official to oversee the agency's implementation
• Train employees in plain writing
• Keep a plain writing section on its website that tells the public how the agency is complying and takes public feedback
• Report on its compliance publicly

The Act does not name a readability formula, set a grade level, or require agencies to score documents. Readability formulas are a tool writers use to check their work, not a legal test. What plain language means in practice comes from the Federal Plain Language Guidelines: write for your audience, organize for the reader, and prefer short sentences and common words.

A "covered document" is one the public needs to obtain a federal benefit or service or to file taxes, one that provides information about a benefit or service, or one that explains how to comply with a requirement the government administers. That includes letters, forms, notices, and instructions. Regulations are excluded.

Compliance is enforced through reporting and public scrutiny, not audits against a score. Agencies publish their own compliance reports, and the nonprofit Center for Plain Language has published report cards grading agencies' plain writing.

Which Readability Formula Do Federal Agencies Use? (And Why Flesch-Kincaid Dominates)

Not all readability formulas are equal in government contexts. No formula is required. Flesch-Kincaid Grade Level is a common choice, because:

1. It's built into Microsoft Word, which many offices already use
2. It reports a school grade, which is easy to explain to reviewers and managers
3. It was developed for the US Navy in 1975, so it has a long history in government writing
4. It tracks sentence length and word length, the two things plain-language rewrites change most

The Flesch-Kincaid Grade Level formula weights sentence length and syllable count:

Grade = 0.39 × (words/sentences) + 11.8 × (syllables/words) − 15.59

In plain terms: longer sentences and longer words raise the grade level. A 9th-grade text requires roughly 15–17 words per sentence and single-syllable or two-syllable words.

Other formulas—Flesch Reading Ease, SMOG, Gunning Fog, Dale-Chall—are common in healthcare and accessibility work. Flesch-Kincaid is simply the one that anyone with Word can check.

Why not just use the simpler Flesch Reading Ease score (0–100 scale, higher = easier)? Because the grade-level output is more intuitive for compliance reporting. Saying "this document meets 7th-grade readability" means more to a government writer than "this document scored 75 on Reading Ease."

Target Grade Levels by Audience

Federal agencies don't have one universal readability target, and the Plain Writing Act doesn't set one. Grade-level targets come from agency style guides, program offices, and individual editors, and they are rarely published. So rather than list agency numbers we cannot source, here is how to set a target by audience. These are this site's recommendations, not federal requirements.

• Benefits notices, eligibility letters, and health alerts: aim for grade 6 to 8. These readers are often under stress, and many are older, disabled, or reading in a second language.
• Tax instructions and public forms: aim for grade 8 or below. The audience is everyone who files.
• Guidance for businesses and grantees: grade 9 to 10 is realistic when the subject is technical, as long as terms are defined.
• Internal procedures for federal staff: grade 10 to 12 is acceptable. The Act covers documents the public uses to get a benefit, learn about one, or follow a rule, so staff-only procedures usually fall outside it. Plain writing still saves time.

The pattern: the more vulnerable the audience, the lower the target. If readers include older adults, people with disabilities, non-native English speakers, or people in a crisis, write for grade 6 to 7.

Flesch Reading Ease Bands for Government Writing

Flesch-Kincaid Grade Level is the number most federal writers report, but the Flesch Reading Ease score (0–100, higher = easier) is a useful second check. The first three columns below are Rudolf Flesch's own bands. The last column is this site's guidance, since no federal rule sets a Reading Ease score.

Score Range	Flesch's Label	Approximate School Level	Good Fit For
90–100	Very easy	5th grade	Children's health materials, simplified forms
80–89	Easy	6th grade	Veteran benefits, public health alerts, Medicare info
70–79	Fairly easy	7th grade	Tax forms, federal benefits, most public notices
60–69	Standard	8th–9th grade	General public guidance
50–59	Fairly difficult	10th–12th grade	Technical guidance, internal procedures
Below 50	Difficult	College and above	Rewrite before it goes to the public

A Flesch Reading Ease score of 65–75 usually lands at a Flesch-Kincaid grade of roughly 7–9. The two formulas are correlated but not identical; use both to validate.

In practice: a Flesch-Kincaid score of 8.5 with a Reading Ease of 72 suits most public-facing writing, but flag it for another edit if your audience includes non-native English speakers.

WCAG and Readability: Beyond Grade Level to Accessibility

The Plain Writing Act is about clear writing, but WCAG (Web Content Accessibility Guidelines) and Section 508 add a second layer: structural readability for screen readers and cognitive accessibility. Section 508 adopts WCAG 2.0 Level A and AA for federal web content.

WCAG's only reading-level rule, Success Criterion 3.1.5 (Reading Level), is Level AAA, so Section 508 does not require it. It asks for a simpler version or supplemental content when text needs more reading ability than the lower secondary education level, about nine years of school. For a 508 review, structure matters more.

Practical implications for government writers. The first item is a WCAG Level A requirement; the rest are good practice that WCAG encourages but does not require at Level AA:

1. Headings must be semantic and scannable, not just bold text

   • Don't: Important note: Your form expires after 30 days.
   • Do: Use a proper H3, and lead with the deadline: "Your form expires after 30 days."

2. Lists break up dense text and lower cognitive load

   • Dense: "You must provide your Social Security number, date of birth, and state of residence in order to verify your identity."
   • Accessible: "To verify your identity, provide: Your Social Security number; Your date of birth; Your state of residence."

3. Acronyms must be expanded on first use

   • Don't: "File your 1040-NR form with the IRS by April 15."
   • Do: "File your 1040-NR form with the Internal Revenue Service (IRS) by April 15."

4. Avoid abbreviations for months and states

   • Don't: "Your benefit started 03/15/2024 in NY."
   • Do: "Your benefit started March 15, 2024 in New York."

These changes don't directly lower a grade-level score, but they dramatically improve comprehension for screen readers, dyslexic readers, and non-native speakers. A document can score 7th-grade Flesch-Kincaid and still fail a 508 review if its headings are just bold text.

Example: Rewriting Tax Instructions in Plain Language

Here's an illustrative rewrite of tax-instruction language about the child and dependent care credit. The original is written in the style of statutory text; it is not quoted from an IRS publication.

Original

"In the event that a taxpayer has received or is entitled to receive dependent-care benefits through a cafeteria plan maintained by an employer, the taxpayer shall exclude from the definition of 'qualifying person' any child for whom such benefits were provided if the child's age exceeded 12 years at the close of the relevant taxable year, and furthermore shall not take into account such benefits in the computation of employment-related dependent care expenses for the purposes of this section."

• Flesch-Kincaid: 36.3 (one 79-word sentence)
• Flesch Reading Ease: below zero (displayed as 0)
• Against an 8th-grade target: far above

Revised

"If your employer gave you dependent-care benefits for your child, don't claim the child and dependent care credit if your child was older than 12 at the end of the year. Also, don't include those benefits when you calculate dependent-care expenses."

• Flesch-Kincaid: 10.8 (10th–11th grade)
• Flesch Reading Ease: 54 (fairly difficult)
• Against an 8th-grade target: still above. Splitting the 31-word first sentence would bring it closer.

Changes made:

1. Removed "shall," "in the event that," "entitled to receive"—replaced with direct address ("your")
2. Broke one 79-word sentence into two sentences of 31 and 10 words
3. Cut passive voice; converted to active ("don't claim" vs. "shall not take into account")
4. Removed subordinate clauses; made relationships explicit with "Also" and "don't"
5. Replaced "qualifying person" and "relevant taxable year" with "your child" and "the end of the year"

The revision keeps every condition in the original. It just makes them readable.

You can test this yourself using a Flesch-Kincaid calculator for compliance testing, which will show you grade level and Reading Ease simultaneously.

Conducting a Readability Audit: Compliance Checklist for Government Writers

Use this checklist to review a government document for plain language and accessibility before it goes out:

Grade-Level Validation

• Run the document through Word's readability stats or an external tool
• Record the Flesch-Kincaid Grade Level and Flesch Reading Ease
• Verify the grade level matches your target audience (we suggest 6th to 9th grade for most public-facing content; no rule sets one)
• Flag any paragraph above 9th grade for rewrite
• Spot-check individual sections; don't rely on whole-document averages alone

Sentence and Word Checks

• Average sentence length: aim for 15–17 words
• Flag sentences over 25 words; break them into two
• Scan for Latinate or technical terms; replace with common synonyms where possible
• Replace "utilize" with "use," "subsequent" with "next," "terminate" with "end"
• Check what is a good readability score for your specific agency or audience type

Accessibility and Structure

• All headings are semantic (HTML H2, H3, etc., not just bold text)
• Lists are used instead of dense paragraphs
• Acronyms are expanded on first mention
• No abbreviations for months or states
• Active voice dominates (spot-check at least 10 sentences)
• Conditional phrases ("if…then") are broken into separate short sentences

Record-Keeping (Good Practice)

• Document is dated with readability score at sign-off
• Grade-level target and achieved score are noted in the document's review record
• Any exceptions (technical terms that can't be simplified) are justified in writing
• Multiple readers (including non-experts) have reviewed for clarity

Red Flags in Review

• Document tests above 10th grade on any section
• Sentences average over 20 words
• Passive voice appears in more than 10% of sentences
• Acronyms are used without expansion
• Tables or forms lack clear labeling

Tools and Training: Microsoft Word, Grammarly, and Plain Language Validation

Microsoft Word (Built-In)

• Enable readability stats: File > Options > Proofing > Show readability statistics
• Pros: Already installed in most offices, and it reports a score many reviewers recognise
• Cons: Accuracy varies; can miss structural accessibility issues
• Government use: An easy first check, because most staff already have Word
• Limitation: Microsoft Word readability score accuracy can drift on documents with heavy formatting or embedded tables

Grammarly (Subscription, ~$10–15/month)

• Flags long sentences, passive voice, and readability in real-time
• Pros: Catches more patterns than Word; integrates with browsers and Office
• Cons: It is an online service, so check your agency's rules before pasting in draft text
• Government use: Check your agency's cloud-security policy first
• Note: Grammarly's readability scores correlate with Flesch-Kincaid but don't always match Word exactly

Flesch-Kincaid Specialist Tools

• Readability Check and ProWritingAid report a Flesch-Kincaid grade. Hemingway Editor shows one grade level
• Pros: Several formulas side by side
• Cons: Check where each tool processes your text before using it on sensitive drafts. Readability Check scores text in your browser
• Government use: Useful as a second opinion on Word's score

Plain Language Training

• The Plain Language Action and Information Network (PLAIN) wrote the Federal Plain Language Guidelines
• plainlanguage.gov now redirects to GSA's Digital.gov, which carries selected plain language guides. Ask your agency's plain writing office about training
• Many agencies (VA, HHS, IRS, SSA) run internal plain language workshops; check your agency's learning portal
• Consider improving readability scores with concrete editing tactics specific to your document type

Validation Without Tools

• Read-aloud test: Read the text aloud to a peer. If you pause for breath more than once per sentence, it's too long.
• Audience proxy: Have someone outside your field read a section silently and summarize it back to you. If they misunderstand, revise.
• Grade-level estimation: Compare your writing to 7th-grade newspaper articles (local news, not opinion). If yours is more complex, it's above your target.

Conclusion

Plain writing is a legal requirement for federal agencies, but a readability score is not. The Plain Writing Act requires clear, well-organized writing in covered documents and leaves the measuring to agencies. Flesch-Kincaid is the most practical check: aim for grade 6 to 8 for benefits and health content, and grade 8 or below for most other public-facing documents.

Beyond grade level, Section 508 requires the structural accessibility in WCAG Level A and AA, such as real headings, text alternatives, and instructions that don't rely on color alone. A document that scores 8th-grade Flesch-Kincaid can still fail a 508 review without them.

Use the checklist above before sign-off. Record your baseline readability score and validate it with a second tool (Word plus an external calculator). Keeping the score with the document gives your team a record of the review if a reader later challenges its clarity.

Your writing doesn't need to be simplified or dumbed down. It needs to be clear and direct—which is harder than it sounds, because clarity requires work. But that work is the job. Plain language compliance isn't a box to check; it's the standard.