Services - Substantial Website Determination

The Problem We Address

A website of over a thousand pages is no longer unusual. A project to make so much content accessible to the disabled is illogical. In all the website audits we've conducted in response to a complaint from the DoJ or Office of Civil Rights (OCR), the accessibility of an entire website was not demanded. In the case of a large website, they first require a determination of the substantial portion of a website to be made accessible.

The problem of course is to determine the meaning of "substantial", the age-old problem of finding the needle in the haystack, in this case, a huge, complex, interrelated haystack.

The same folks who brought us the website auditing standard WCAG-EM 1.0 have also brought us the Web Consortium Accessibility Guidlines Evaluation Methodology (WCAG-EM 1.0) with some guidance on determining the substantial part of a website for accessibility auditing and remediation. A review of that document reveals a great baseline, but one that requires experience to interpret and apply.

More importantly, the enforcement folks like DoJ and OCR are not bound by that document. They have some important additional considerations to define "substantial".

Yet defining the substantial part of a website is the foundation for everything to follow in terms of a website becoming accessible.

Do This Before an RFP

Many accessibility RFPs include determining the substantial part of a website as part of the auditing project. The problem is that you are then asking for a fixed-price proposal of an unbounded project.

Bidders will inflate their bids to cover this uncertainty. Worse, they will seek to define substantial as small as possible during the course of the project, after all, we are talking fixed price.

Better is to define substantial first, get buy-in from any enforcement folks involved, and scope the RFP to address the accessibility of that part of your website.

Access2online coordinator Peter Shikli and three inmates working on a task

Our Solution

We begin with WCAG-EM as our baseline, but we add to the methodology a few critical steps needed both by the enforcement folks and to improve the website visitation experience of the disabled, for example:

  • Templates whether internal or vendor supplied, as in a Content Management System (CMS), need to be addressed first and foremost because of the difficulty remediating them.
  • Gateway pages, that is, application forms, switchboard pages, directories, logins, and other destinations required to access other parts of the website even though they don't place high on visitation logs.
  • External resources on their own independent visitation paths such as job application portals, videos on YouTube, and social media -- as long as they form an integral part of interacting with your organization.

Though we are on the lookout for pages not to include in the definition of substantial, the net effect may be more pages to remediate, perhaps on the order of 10% above a minimalist WCAG-EM approach. However, the likelihood of acceptance by the enforcement folks and the quality of a disabled person's experience on your website is far greater.

After we conclude our analysis, you will receive a spreadsheet itemizing the workflow of the analyst, the web page selection conditions tested, reference to the section of the applicable standard, such as WCAG-EM, and the web pages determined to be part of the substantial website.

Besides the workflow spreadsheet, you will receive a Substantial Website File List document collecting the pages determined in the spreadsheet to be substantial, listed alphabetically. Files determined to be substantial by more than one section of the standard are listed once. This is a simple filelist to indicate the scope of an audit and remediation to follow.

To provide an idea of what to expect, here is a sample of the spreadsheet and its matching sample Substantial Website File List document from a fictitious client.

How to Get Started

Use any of our contact options to tell us about your website, including whether you are answering a complaint. We will respond with a fixed-price proposal to determine the substantial part of your website from an accessibility standpoint.

Frequently Asked Questions (FAQs)

  • Must we accept your determination of the substantial part of our website?
    No, but you will find our determination will go far with DoJ and OCR given that we are Trusted Testers certified by the Office of Accessible Systems & Technology. Without our determination, you may find them defining substantial to include more pages than we would, just to be safe.
  • Why should we believe that you can define the substantial part of a website better than we who built it and run it?
    Because we're specialists who look at just one aspect of your website, its accessibility to the disabled. Even then, we've had to develop a structured methodology to encourage a consistent, objective result. We would be happy to show you the details of that methodology.