Assessing the Web Accessibility of ABLE Program Websites for Persons With Disabilities – Center for Retirement Research

Abstract

This study investigates the accessibility of websites for the Achieving a Better Life Experience (ABLE) account program for people with disabilities, which is critical for ensuring individuals can fully benefit from ABLE accounts.  Utilizing the Wave Evaluation Tool, Adobe Pro DC’s 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 communicating fees and risks, and for readability for individuals with disabilities.

Key findings include:

Prevalence of Low Web Accessibility

• Significantly, 94 percent of ABLE program websites evaluated did not fully comply with WCAG standards.
• The most common violation (75.2 percent of websites) involved insufficient contrast between text and background, hindering legibility for individuals with vision impairments.
• Around 9.5 percent of sites failed to use alternative text for hyperlinks, and 8.5 percent neglected descriptive link text, impairing navigation for users relying on screen readers.
• Violations also included a lack of alternative text for non-text content on 7.5 percent of sites, affecting accessibility for blind or visually impaired users.
• Additional concerns were noted for less prevalent issues, such as content reliance on visual or auditory cues, keyboard navigation, and descriptive headings.

Non-compliance in Disclosure Documents

• Analysis of program disclosure documents revealed an average of 12 accessibility violations per form, ranging from 1 to 19 violations.
• The disparity in accessibility adherence among ABLE programs indicates a broad non-compliance issue, potentially limiting individuals with disabilities from accessing crucial financial information.
• A significant association was found between the number of WCAG violations on websites and the accessibility issues in their financial disclosure PDFs, suggesting a relationship between web and document accessibility within ABLE programs.

Low Levels of Readability among ABLE Disclosures

• The average Flesch-Kincaid readability score of disclosure documents was 33.1, indicating complexity at the college to graduate school level and classifying the material as “difficult to extremely difficult” to comprehend (note: the Flesch-Kincaid readability score evaluates the ease with which text can be read, with lower scores indicating more complex texts requiring higher education levels for understanding, and higher scores representing simpler, more accessible texts).
• This complexity presents a significant barrier, especially for individuals with cognitive or learning disabilities, as the average American adult reads at a 7th-grade level (which is around an 80 on the Flesch-Kincaid readability scale).

Discussion and Implications

• The study underscores the critical need for comprehensive reform to address web and document accessibility issues in ABLE programs and to ensure financial empowerment and inclusion for individuals with disabilities.
• It also highlights the digital divide affecting individuals with disabilities, emphasizing the necessity of accessible web design and document creation to enable full participation in digital and financial resources.
• The interconnectedness of digital accessibility across platforms and documents within ABLE programs calls for a broad approach to ensure that all eligible individuals can access these financial tools effectively.

Federal- and State-level Policy Suggestions based on these findings:

Federal-level policy suggestions:

1. Stricter Compliance Standards: Legislation could require strict compliance with Web Content Accessibility Guidelines (WCAG) for all ABLE account program websites and associated digital documents.  This could include specific benchmarks for accessibility and timelines for existing platforms to meet these standards.
2. Federal Oversight Body: A federal oversight body could be established to monitor and enforce accessibility standards for ABLE programs.  This body could be responsible for conducting regular audits of ABLE websites and documents, providing technical assistance, and imposing penalties for non-compliance.
3. Accessibility Improvement Initiatives: Federal funds could be allocated specifically for the purpose of improving digital accessibility on ABLE account websites.  This could include grants for states to redesign websites, create accessible PDFs, and other necessary modifications to meet or exceed WCAG standards.

The state-level policy suggestions based on these findings include:

1. Regular Training and Resources: States could provide regular training for ABLE program administrators and technical staff on the importance of digital accessibility, how to achieve it, and how to maintain compliance with evolving standards.  Additionally, states could develop and share resources on best practices for digital accessibility in ABLE programs.
2. Readability Standards for ABLE Disclosures: Consider a mandate that all ABLE plan disclosures and related documents adhere to a specific readability standard that is accessible to the general population, such as the Flesch-Kincaid Grade Level suitable for an 8^th– to 9th-grade reading level.  This will help ensure that information is accessible to a broader audience, including those with cognitive disabilities.
3. State-Level Monitoring and Accountability Mechanisms: Consider developing state-level mechanisms for monitoring ABLE website and document accessibility, including regular audits and feedback loops with users with disabilities.  States could also establish clear penalties for non-compliance and procedures for addressing grievances related to accessibility.