that the textbooks used in higher education remain bound by copyright restrictions, which is a major obstacle for students with visual impairments. Although the MOE has established formulated regulations of collection, transfer, and provision of special format materials in accordance with Article 9 of the Library Act and designated the National Taiwan Library as the library for persons with disabilities, 2019 statistics show that materials designed for persons with visual impairments (157,526 items) accounted for only 9.7% of the overall materials in the library (1,620,277 items). The NHRC recommends that the MOE request government publications to donate to the National Taiwan Library in priority to reprint into editions suitable for persons with visual impairments. 134. The NHRC found that the pass rate for audits of green spaces and playground facilities for children declined between 2016 and 2019 from 82.7% to 24.7% and that the number of audits themselves declined significantly, from 3,171 to 1,172. The MOI attributed the decline in the pass rate to MOHW-amended safety management regulations. The MOHW responded that it is the MOI’s responsibilities to analyze the reason for the decline of the pass rate. The reasons could be that playgrounds have failed to meet national regulations, complete professional testing, or employ qualified managers. The MOHW asserts that the MOI shall identify the reasons for the decline and formulate clear objectives and schedules to help the MOI-affiliated units create budgets for improving their playgrounds. Regarding the number and proportion of unaudited city/county green spaces and playgrounds, the MOI stated that those were based on a checklist created by the MOHW. Therefore, the relevant statistics were not collected. The MOHW responded that the MOI is the competent authority responsible for overseeing park playgrounds. Therefore, the MOI should provide the relevant statistics. These inconsistent responses show the shifting of responsibility between the two agencies at the expense of disabled children's equal opportunity to play. Article 33: National implementation and monitoring 135. The Executive Yuan announced the establishment of the Human Rights Division in December 2020. The division will coordinate human rights matters across 92