I've noticed that with Photoshop and Illustrator CS4, I can no longer obtain the window title name of a document using the accessibility API under Mac OS X. That's when the mouse is over the document - it still works when the mouse is right over the window title.
The easy way to test is to run the UI Inspector sample code from Apple (make sure Universal Access>Enable access for assistive devices is on under Sys Prefs).
I've found lots of resources on the Adobe site about how to build accessible *content* using Adobe's products but very little information about accessibility support in the Adobe apps themselves.