University Web Accessibility Policies:
A Bridge Not Quite Far Enough

Introduction

Most university web accessibility policies fall short of achieving their purpose. The web sites of these universities often fail to meet minimum web accessibility standards. Part of the problem lies with the policies themselves. Many of them fail to delineate a specific technical standard, fail to indicate whether compliance with the policy is required, fail to indicate a timeline or deadline for compliance, fail to define a system for evaluating or monitoring compliance, and fail to enumerate any consequences for failure to comply.

The Need for Web Accessibility Policies and Systems in Universities

As more and more university information and educational materials migrate to the web, it becomes increasingly important to ensure that those materials are accessible to people with disabilities. Functions such as course registration, tuition payment, financial aid applications, and so on are central to any student’s experience at a university. When those functions are available on the web, they allow for access any time, from anywhere. For students with disabilities, such online functions can be either liberating or limiting, depending on how the web content is constructed. If the content is constructed with web accessibility in mind, then students with disabilities are afforded a new level of freedom previously inexperienced. For example, blind students can use computer software that reads the web content out loud to them, thus eliminating their previous reliance on other people to read the content to them. On the other hand, if the content is not designed with web accessibility in mind, then students with disabilities will be denied the benefits that should be available to them to the same extent that it should be available to all other students.

Key Elements of Web Accessibility Policies and Systems

The task of creating content that is accessible to students with disabilities is not a difficult one, but it cannot happen automatically, without thought or design. web developers must be aware of the issues, they must know the techniques, and they must employ those techniques. In order for this to happen consistently over time, universities must adopt both a policy and a system that supports web accessibility. Policies are important because they define a standard. They explain such things as:

1. Who is responsible for creating accessible web content,
2. How the responsible individuals will receive training and technical support,
3. What "accessible" means, and how to tell when content is "acceptably accessible,"
4. When or how soon the content must be made accessible (especially if the purpose of the policy is to convert inaccessible content into accessible content),
5. Who verifies that the content passes the minimum standard,
6. How and by whom the standard will be enforced, and
7. What consequences will befall those who violate the standard.

Not all of these components will be delineated in detail in the policy itself necessarily. In some cases it makes more sense to describe these in a separate document which describes the implementation system or process. Regardless of where these considerations are addressed, they should all be seriously considered. The failure to consider any one of these points can lead to the eventual failure of the policy or system.

Inadequate Policies and Systems Produce Inadequate Results

A survey of 20 randomly-selected U.S. universities with web accessibility policies revealed that the policies were inadequate on several levels, the most important of which being the fact that the majority of web pages created at those universities had accessibility errors. In fact, 80% of the university home pages had at least one accessibility error when evaluated by WAVE 3.0, an online web accessibility evaluation tool. Similarly, 77% of the sites had accessibility errors on pages other than the home page, based on a random sample of 6 pages per site. In some cases, the errors were minor, such as forgetting to add null alt text to images that do not contain important content. In other cases, the pages contained more serious errors, such as important images missing alt text or forms missing labels. While it is true that the results of any survey of accessibility are disputable, due to the inherent inadequacies of all automated tools, together with the fact that not every tool interprets the accessibility guidelines in the same way, these statistics should at least serve to alert universities that their policies and systems may not be achieving their desired effect. Aside from the fact that the policies were largely ineffective at achieving their stated goal, the policies themselves lacked key elements that could lead to more successful outcomes. These elements are described in the paragraphs that follow.

No official technical standard. Only 4 of the 20 universities (20%) defined a technical standard. Two of these chose Section 508 as a standard. The other two chose Level 1 of the Web Content Accessibility Guidelines (WCAG). All of the rest made mention of these standards, but only by way of information and not as a requirement to follow. All of these other universities explain the virtues of following these standards, but do not endorse them as binding. Some universities (15%) state that their standard is the Americans with Disabilities Act (ADA), which, in fact, contains no technical standard at all for web accessibility. They use such misleading phrases as "ADA compliance." Others simply state that their policy is to make the content "as accessible as possible" (or similar phrases) to students with disabilities. As noble as these statements sound, they do not provide a measurable goal for web developers to achieve. Developers have no way of knowing whether they have satisfied the university’s policy or not.

No indication whether compliance is required or suggested. Despite the fact that 60% of the policies surveyed use words such as "must" and "required," the documents rarely seem authoritative. They are often difficult to find on the university web site, and are often linked from "resources" sections of web sites, rather than "policy" sections. Only half of them (50%) even use the word "policy" (or similar words) at all. Without this kind of terminology, web developers are likely to dismiss the policies as unofficial, unbinding, and unimportant.

No implementation timeline or deadline. Only 2 of the policies specified when the policy was to take effect. One policy was still listed as a draft, and had been listed as such for nearly two years. Without a timeline or deadline, web developers may not have the initiative to independently make their content accessible. They can postpone the task indefinitely without fear of consequences.

No system for evaluating or monitoring. The majority of sites (75%) mentioned no system for evaluating or monitoring the accessibility of web content. However, two of the universities mentioned that complaints could be submitted by email if accessibility errors were found. Three of the universities specified that it was the duty of the developer to check the content for accessibility. The rest of the policies were mute on the issue. The lack of a system for evaluating or monitoring the accessibility of web content over time means that errors can be introduced and remain undetected by developers for long periods of time.

No consequences for failure to comply. None (0%) of the university policies mentioned any sort of consequence for failure to comply with the university policy or standard, despite the language in a few of them that clearly stated that compliance with the policies was not optional. Without any consequence or enforcement for failure to comply, web developers may feel that they can opt out of these "requirements" without fear of retribution, reprimand, or consequences of any kind. Universities may wish to convey the idea that it is better for developers to make their web content accessible simply because it is "the right thing to do," and this will be sufficient for some developers, but the absence of consequences is a loophole that the more reluctant developers are likely to seek out and exploit.

Conclusion

Though the universities surveyed for this paper are to be applauded for creating web accessibility policies, these policies are only partially achieving their purpose. The web sites of these universities often fail to meet minimum web accessibility standards, and therefore present difficulties to students with disabilities. Part of the problem lies with the policies themselves. Many of them fail to delineate a specific technical standard, fail to indicate whether compliance with the policy is required, fail to indicate a timeline or deadline for compliance, fail to define a system for evaluating or monitoring compliance, and fail to enumerate any consequences for failure to comply. With all of these shortcomings, it should be no surprise that the policies are not as successful as they might otherwise be. These universities should seriously consider rewriting their policies to remedy these inadequacies.