Disproportionate burden assessment
Find out how we’re checking our website for accessibility issues, and what we consider to be a disproportionate burden.
Walsall Healthcare NHS Trust is committed to meeting its legal obligations set out in The Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018 (“No. 2 Regulations”). However, we have a complex collection of online service information and limited resources to check them all for accessibility issues. You can read our approach to checking our website, and how we’ve assessed what we consider a disproportionate burden.
Our approach to carrying out accessibility checks
We’re doing a detailed accessibility check for the Walsall Healthcare NHS Trust website (www.walsallhealthcare.nhs.uk) in compliance with the No. 2 Regulations. The process for doing this check will include a combination of manual testing and automated-testing using accessibility monitoring tools (AXE). Our accessibility statement for walsallhealthcare.nhs.uk will cover problems any we found, and our plans to fix them.
Walsall Healthcare NHS Trust’s website covers a variety of purposes, and content types. It is hosted by our appointed hosting provider; other elements are 3rd party hosted and maintained by external suppliers, managed and paid for by an individual Trust service or directorate.
Some link names may not be accessible to a screen reader. This occurs in very limited circumstances such as within 3rd party plugins e.g our homepage carousel. To resolve this would be a disproportionate burden within the meaning of the accessibility regulations as it would require a complete replacement of the system and the templates we use to run our website, at significant cost. We are committed to resolving this issue at the next major redesign of our website when the contract is due for renewal, and we will review this decision again in June 2021.
Some content may not reflow when viewed on mobile at 320 x 256 screen size and zoomed in at 400%. To resolve this would be a disproportionate burden within the meaning of the accessibility regulations as it would require a complete replacement of the system and the templates we use to run our website, at significant cost. We are committed to resolving this issue at the next major redesign of our website when the contract is due for renewal, and we will review this decision again in June 2021.
Drop-down menus on the side navigation may not be viewable when using keyboard. This is not an available feature of our website and we feel it would be a disproportionate burden to resolve this within the meaning of the accessibility regulations as it would require a complete replacement of the system and the templates we use to run our website, at significant cost. We are committed to resolving this issue at the next major redesign of our website when the contract is due for renewal, and we will review this decision again in June 2021.
Cost of fixing links and text reflow
Our assessment of the issues identified is that our website is inherently not designed, and does not permit the Trust to fully resolve these issues in an immediate timeframe. We have conducted a cost and benefit analysis to guide our approach.
Assessment of costs and benefits
We believe that:
- The human and financial cost of carrying out detailed checks for all our website content, technical site files, and fixing all website themes on walsallhealthcare.nhs.uk would be a disproportionate burden on our organisation. The Trust does not currently benefit from developer resource or a support cotract.
- The benefit to users of carrying out these detailed checks and fixes on the website and obtaining technical resource to fix these issues on walsallhealthcare.nhs.uk would not be justified and would impose a disproportionate burden on Walsall Healthcare NHS Trust.
In reaching this decision, we have considered the following:
Our organisation’s size and resources
Walsall Healthcare NHS Trust is an acute and community healthcare trust managing unprecedented front-line service demands but with annual budgets under continual pressure.
Past and current investment in our digital channels and particularly our website is negligible due to these financial constraints, and Walsall Healthcare NHS Trust does not currently benefit from any allocated budget or resource that supports website technical development, technical support, coding, or any enhancement other than basic hosting services. Maintenance of the website is carried out in-house within the communication team at the current time. It is maintained on an open-source platform.
During 2020/2021 we have been forced to re-prioritise resources owing to the coronavirus (COVID-19) pandemic, ensuring business continuity of essential services.
We also currently have a long-term project to replace our internal intranet and central to this service will be ensuring accessibility and a fully inclusive user experience. Redirecting resources away from this project, to complete detailed accessibility checks and fixes will delay the delivery of this key, digitally transformational, user-centric service.
It should also be taken into account that the Trust has plans to review and replace its website in its entirety in the next financial year at which time it is committed to addressing any remaining issues and become fully accessibility compliant. We feel it is the most appropriate decision to direct any available resources to that project as a long-term permanent resolution.
The nature of our organisation
We do provide services aimed at people with a disability, and these are generally very well supported through both our patient relations and patient experience teams who have access to specialist services and support (e.g. BSL sign language and interpreters).
The estimated costs and benefits for our organisation: in relation to the estimated benefits for persons with disabilities, taking into account the frequency and duration of use of the independent websites
We believe the potential of paying several thousands of pounds just on audits (before we’ve actually fixed anything and appointed developers) is unreasonable.
We believe that:
- maintaining essential front-line clinical services, particularly during a pandemic, should be prioritised over paying for independent website audits
- it would be reasonable within the meaning of the No. 2 Regulations for our services to carry out basic checks of their content, and use any available budget to fix the main issues found
Our services will be assisted in their basic checks by:
- using automated accessibility monitoring tools
- internal guidance and support from the communications team
The Walsall Healthcare communications team is a very small team, and the scale of co-ordinating the auditing and fixing of our main website – in addition to their other essential functions – means they lack the capacity to carry out a detailed audit.
How much users with a disability would benefit from making things accessible
All of our users will benefit from us making our website and online information accessible.
However, we do not believe that for the majority of our online content, that the extra improvements that could be gained from paying for detailed checks and fixes would be justified, given the fact that the Trust has not encountered any previous cases or request for support in these areas from users.
We also believe that users will benefit most from us focusing our limited resource on maintaining the most used accessible content on walsallhealthcare.nhs.uk, and ensuring that new documents are accessible where they are required for essential services or used by people with disabilities.
Please note: While this assessment explains our corporate position on disproportionate burden, some services may still choose to carry out a detailed check themselves, or pay for one if they are able to budget for it.
Paying for detailed audits
On the basis of these assumptions, we estimate the cost to our organisation overall for detailed audits for our website would be between £6,500 and £13,000.
These costs are based on estimates from GOV.UK’s guidance on deciding how to check your website and getting an accessibility audit. These include:
- a third-party day rate of £1,300
- about 1 to 3 days to audit a small website
- about 5 to 20 days to audit a large website
A basic accessibility audit has previously been commissioned by the trust at a cost of £1512 .
This assessment was last updated on 25 February 2021.