Creating a Better ADA Self-Evaluation (Part 3)Treat Web and Digital Accessibility as a Part of Program Access

This is Part Three of our Four-Part Blog Series describing how state and local governments (as well as Federal grantees) can conduct better self-evaluations under Title II of the Americans with Disabilities Act and Section 504 of the Rehabilitation Act. We developed our approach from working for over twelve years with organizations like the National Aeronautics and Space Administration (NASA), the California State University (CSU), and King County in Washington state.

In our first installment, we discussed why Title II of the Americans with Disabilities Act and Section 504 of the Rehabilitation Act require state and local government agencies and federal fund recipients, respectively, to evaluate how their programs impact their customers and users with disabilities. We also introduced the importance of seeking feedback from the local community of people with disabilities early and often in the self-evaluation process because it helps set priorities and uncovers hidden problems. Last week, we described how our survey tool avoids the time-consuming process of conducting traditional self-evaluations and how our two-part survey process quickly identifies gaps in existing policies and training, provides a library of template policies, and quickly identifies policies and practices need to be implemented first.

In this week’s installment, we will talk about another ingredient that is all but missing from traditional self-evaluations—web and digital accessibility. This is unfortunate because almost all government programs, services, and activities are provided through websites and digital apps. This means that organizations need to approach web and digital accessibility as an integral part of program access. This requires an expert-level understanding of both traditional and digital accessibility.

Traditional Accessibility Consultants Don’t Understand Web and Digital Accessibility

Title II and Section 504 are almost always conducted by consultants who come from the world of traditional built environment accessibility. Often, these are architecture firms, construction engineering companies, and traditional ADA consultants. Almost without exception, one thing that these groups don’t understand is web and digital accessibility.

This lack of knowledge around the technical aspects of web and digital accessibility means that these consultants lack an appreciation of testing to the W3C’s Web Content Accessibility Guidelines (WCAG) 2.1 A/AA—the worldwide de facto standard for electronic accessibility—or even what to test. For instance, do third-party web applications (e.g. a records management system) need to be tested separately from the Content Management System (CMS) used by the agency? Or when user access agency resources over their mobile devices, are they using a mobile-optimized website or a mobile application—and how does that affect testing?

Websites, Websites Everywhere and No Idea What to Test

Savvy organizations or consultants conducting a Section 504 or Title II Self-Evaluation always bring in a specialist firm for web and digital accessibility reviews. Unless those specialists are intimately involved in the rest of the program access review, however, the resulting self-evaluation will only provide a partial snapshot of the overall accessibility of the organization’s website and digital technologies. This is because most medium or large state or local governments own several hundred domains to support their public-facing programs, services, and activities. They also use several different Content Management Systems (CMS) and third-party applications. It is simply impossible to completely survey all of these systems in a cost-effective manner. Prioritizing systems to test means understanding both technology and what program access means under Section 504 and Title II.

To quickly address the sheer volume of unorganized digital content that most state and local government control, web accessibility specialists often recommend that state and local organizations use automated testing solutions. As any web accessibility expert knows, however, automated testing solutions can only test one-quarter to one-third of WCAG success criteria and they do a particularly lousy job at testing the basic infrastructure of sophisticated CMS systems and third-party applications because these portions often rely on specialized JavaScript and CSS. The better approach is to initially conduct manual testing of the infrastructure of each system and to save automated testing for day-to-day content updates.

Your Web Consultant and Your ADA/504 Consultant Should be the Same Person

Identifying which systems and technologies need to be tested first means that your web accessibility consultant needs to understand how each system fits in to the overall means in which a program, service, or activity is delivered. For instance, is an online application form also available at an agency’s public offices—and, if so, do agency staff help people with vision impairments complete the form? Or do people with disabilities rarely access the program supported by this form but they frequently encounter barriers with a different online program. In short, your web accessibility consultant should be the same person as your ADA/Section 504 consultant.

Remember Those Upcoming ADA Title II Web Accessibility Regulations

In July, I blogged about the new draft regulations that the Department of Justice expects to issue for state and local government website accessibility. These regulations will put renewed pressure on state and local governments to make their websites accessible as they will likely be subject to more litigation. The easiest way to reduce this risk is to include web accessibility as part of an overall self-evaluation of state and local government Title II compliance.

Interested in Other Ideas for a Better Self-Evaluation?

A smarter self-evaluation needs to include web and digital accessibility as a seamless, integrated part of its review of an organization’s programs, services, and activities. This means that your web consultant should be the same as your ADA/504 consultant. Only Converge Accessibility brings together this kind of combined expertise.

If you’d like to learn more about how to conduct a better self-evaluation, download our white paper using the form below. Or if you’d like to talk to us about how we can help, contact us today at

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