Web Accessibility Testing of ABLE Program Websites for Persons with Disabilities – Center for Retirement Research

Abstract

This study investigates the accessibility of the Achieving a Better Life Experience (ABLE) account program websites for people with disabilities, which is important to ensure that people can take full advantage of ABLE accounts. Using the Wave Test Tool, Adobe Pro DC Accessibility Checker, and the Flesch-Kincaid (FK) readability formula, this study comprehensively analyzes 44 ABLE websites, and their program disclosure documents, for compliance with the Web Content Accessibility Guidelines ( WCAG), for clarity in transferring funds and risks, and readability for people with disabilities.

Key findings include:

The prevalence of low web accessibility

• Notably, 94 percent of ABLE program websites tested did not fully comply with WCAG standards.
• The most common violation (75.2 percent of websites) involves insufficient contrast between the text and the background, which prevents the suitability of people with visual impairments.
• About 9.5 percent of sites failed to use alternative text in hyperlinks, and 8.5 percent ignored descriptive link text, hindering navigation for users who rely on screen readers.
• The breach also included missing some text and non-text content on 7.5 percent of sites, affecting accessibility for blind or visually impaired users.
• Additional concerns have been noted for less common issues, such as content dependency on visual or auditory cues, keyboard navigation, and descriptive topics.

Non-Compliance with Disclosure Documents

• An analysis of the program’s disclosure documents revealed an average of 12 accessibility violations per form, ranging from 1 to 19 violations.
• Differences in accessibility adherence among ABLE programs reflect a broader issue of noncompliance, which may limit people with disabilities from accessing important financial information.
• A significant correlation was found between the number of WCAG violations on websites and accessibility problems in their financial disclosure PDFs, suggesting a relationship between web and document accessibility within ABLE programs.

Low Reading Levels Among ABLE Exposures

• The average Flesch-Kincaid readability disclosure score was 33.1, indicating the complexity of the college to complete school level and graded material as “difficult to very difficult” to understand (note: the Flesch-Kincaid reading score assesses the comfort of the text. can be read, scored lower scores indicate more difficult texts that require higher levels of education to understand, and higher scores represent simpler, more accessible texts).
• This complexity presents a significant barrier, especially for people with intellectual or learning disabilities, as the average American adult reads at a 7th grade level (which is about 80 on the Flesch-Kincaid reading scale).

Discussion and Results

• The study underscores the critical need for comprehensive reform to address issues of web accessibility and documentation in ABLE programs and to ensure financial empowerment and inclusion for people with disabilities.
• It also highlights the digital divide that affects people with disabilities, emphasizing the need for accessible web design and document creation to allow full participation in digital and financial services.
• Communication of digital accessibility across platforms and documents within ABLE programs requires a comprehensive approach to ensure that all eligible individuals can access these financial tools effectively.

Federal- and State-level policy recommendations based on these findings:

Government level policy proposals:

1. Strict Compliance Standards: The law may require strict compliance with the Web Content Accessibility Guidelines (WCAG) for all ABLE account program websites and related digital documents. This may include specific access benchmarks and hardware times available to meet these standards.
2. Federal Oversight Body: A federal oversight body could be established to oversee and enforce accessibility standards for ABLE programs. This body may be responsible for conducting routine audits of ABLE websites and documents, providing technical assistance, and imposing penalties for non-compliance.
3. Measures to Improve Accessibility: Federal funds may be allocated specifically for the purpose of improving digital accessibility of ABLE account websites. This may include grants for districts to redesign websites, make PDFs accessible, and other modifications necessary to meet or exceed WCAG standards.

State-level policy recommendations based on these findings include:

1. Regular Training and Resources: States can provide regular training for ABLE program managers and technical staff on the importance of digital accessibility, how to achieve it, and how to maintain compliance with changing standards. Additionally, districts can develop and share resources on best practices for digital accessibility in ABLE programs.
2. ABLE Disclosure Reading Standards: Consider mandating that all ABLE program disclosures and related documents conform to some easily readable level that is accessible to the general public, such as the Flesch-Kincaid Grade Level 8.^th– to a 9th grade reading level. This will help ensure that information is accessible to a wider audience, including those with intellectual disabilities.
3. State-Level Monitoring and Accountability Mechanisms: Consider developing state-level mechanisms for monitoring ABLE website and document accessibility, including regular testing and feedback logging with users with disabilities. States can also establish clear penalties for non-compliance and procedures for dealing with complaints related to accessibility.