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California State Auditor Report Number : 2014-131 (June 2, 2015)

California State Government Websites—Departments Must Improve Website Accessibility So That Persons With Disabilities Have Comparable Access to State Services Online



Our review of the accessibility of key online services offered by four departments—California Community Colleges (Community Colleges), California Department of Human Resources (CalHR), Covered California, and State of California Franchise Tax Board (Franchise Tax Board)—highlighted the following issues:

Results in Brief

A significant number of Californians use the Internet to obtain information about and avail themselves of government services. According to a 2013 report by the Public Policy Institute of California, 47 percent of Californians report they use the Internet to access government services, an increase of 4 percentage points from 2008. Also, data featured on the California state government home page showed that in January 2015 there were millions of unique visits to California government websites such as the California Department of Motor Vehicles and Employment Development Department sites.

To ensure access to online government services for persons with disabilities, California has adopted standards that address the needs of users who may have one or more of a range of disabilities, including those with visual impairments, hearing impairments, and impairments to mobility. Since January 2003 state law has required California websites to meet requirements stemming from Section 508 of the federal Rehabilitation Act of 1973, as amended (Section 508). Subsequently, in July 2006, California added the World Wide Web Consortium’s (W3C) Web Content Accessibility Guidelines (WCAG) version 1.0 as additional state web accessibility standards for departments that report to the governor and the state chief information officer.

Despite the growing use of government services online and the State’s accessibility requirements, the California government websites we reviewed during this audit are not fully accessible. We reviewed one key online service offered by each of four departments—California Community Colleges (Community Colleges), California Department of Human Resources (CalHR), Covered California, and State of California Franchise Tax Board (Franchise Tax Board)—to determine whether their online services and the associated portions of their websites complied with the State’s accessibility requirements.1 We found violations of applicable accessibility standards on each department’s website.2 Among the four departments we reviewed, Covered California’s website has the largest number of violations of web accessibility standards. Although the violations we found ranged in severity, many of them are critical, meaning that they are severe enough to make elements of the websites inaccessible to persons with disabilities. For example, one such critical violation was on a CalHR online job exam. Users who employ screen reader software—software that reads web pages aloud to those who cannot read text—should be able to have exam questions read to them as they navigate through the exam. However, because CalHR did not appropriately label the exam questions, persons using screen readers would have had to leave the exam question response area and use other methods, such as browsing the surrounding text on the web page line by line with the keyboard’s arrow keys, to try to determine what information they should enter.

Some of the critical accessibility violations we identified are so severe that, under certain circumstances, they may prevent persons with disabilities from completing the core tasks necessary to access online services. These violations occurred at three departments and would affect users with a variety of disabilities, including motor disabilities and vision loss. A violation on Franchise Tax Board’s website prevents users who cannot use a computer mouse from registering an online account—a required step in submitting tax returns online through the department’s CalFile service. In addition, a violation on Community Colleges’ online application for college prevented screen reader users who were applying to college online from registering for an account if they took too long to complete individual registration pages. This occurred because the notification that alerted users that their time to complete the page was almost expired was not programmed correctly, meaning that the screen reader software did not identify the notification when it appeared. Because these users were not made aware of this notification box, they were unable to request additional time to complete the page and would be logged off without warning at the expiration of the allotted time. The user would then need to start the account creation process over again from the beginning. Community Colleges was made aware of this issue through a complaint from a user in February 2015 and has now resolved the problem. Finally, at Covered California, users who cannot use a computer mouse could not start an application for health insurance because the button on the Covered California website that begins the application process could not be accessed using only the keyboard.

Further, updated standards are available that could help California make its websites more accessible. In 2008, shortly after California adopted the first version of the WCAG standards, WCAG 1.0, the W3C issued WCAG 2.0. When it did so, the W3C stated that the WCAG 2.0 standards apply more broadly to different types of web technologies and allow for more effective testing of websites’ accessibility. However, California has not adopted these updated standards. In light of these improvements, it is important that the Legislature amend state law to require departments to meet the WCAG 2.0 standards. Further, it is important for the California Department of Technology (CalTech) to monitor commonly accepted accessibility standards going forward to help ensure that California’s standards do not again become outdated in the future.

Most of the departments we reviewed could improve the type and frequency of accessibility testing that they perform on updates to their online services. Three of the four departments we reviewed—Community Colleges, Covered California, and CalHR—conducted some accessibility testing on their websites before initially releasing the sites to the public. However, best practice guidance suggests that departments test updates to their websites as well, using both automated and manual techniques. Only Franchise Tax Board performed update tests on its website updates in this manner.

At the start of our audit, most of the departments we reviewed did not provide important information on their websites to the public about how to complain about website accessibility problems. State policy requires departments to provide users who may want to complain about website accessibility with multiple forms of contact information, such as an email address, phone number, and mailing address. However, at the start of our audit Franchise Tax Board had failed to publish an email address on its website. Since then, it has added the required information. Although Covered California is not required to comply with policies issued by the state chief information officer, who is the director of CalTech, and it is unclear whether Community Colleges must comply with those policies, we assessed the complaint contact information on both departments’ websites against the requirements that other departments must follow. At the time of our review, neither department provided on its website all of the complaint contact information that state policy requires other departments to provide. When departments do not provide multiple forms of contact information, the risk increases that users will be unable to complain about web accessibility problems they may encounter so that departments can fix those issues.

Similar to the reported level of complaints received by federal departments, the departments we reviewed appear to receive very few complaints about the accessibility of their websites. In 2010 and 2011 the U.S. Department of Justice surveyed 89 federal agencies about their compliance with Section 508. In their responses to the survey, those agencies reported that, from June 2001 through 2010, they had received a total of 140 administrative complaints about their web accessibility, or only about 15 complaints per year among all of the agencies. Similarly, we identified no web accessibility complaints received at Covered California since June 2013, no complaints at Franchise Tax Board since 2010, and only five complaints Community Colleges received since November 2012. Most of the complaints we reviewed at Community Colleges related to problems that screen reader users had with the online application to college. However, it is possible that the low level of complaints we observed is partly related to the lack of complaint contact information provided by some departments.

CalHR did not keep adequate records of its accessibility testing or the web accessibility complaints it received. The department’s web manager and the supervisor over development for the Careers in California Government website (jobs site) acknowledged that CalHR does not currently have a level of information about accessibility testing that would allow it to know what portions of the site had been tested, what issues were found, and whether and when those issues were resolved. Additionally, the department lacks a tracking method for the web accessibility complaints it received. CalHR’s web manager stated that only a few accessibility complaints have been made and that he generally tries to assist users in navigating the site if they are experiencing problems. However, there is no procedure in place to ensure that if he discovers a problem with the website while assisting a user, the error will be documented and resolved.

Although best practice guidance suggests that departments provide specific training on web accessibility to staff involved in the procurement or development of websites and web-based services, there is no statewide requirement for web accessibility training. At the four departments we reviewed, staff had inconsistent levels of training. We believe that statewide training on web accessibility would benefit all California departments. As the lead agency in California for matters related to information technology, CalTech could provide this training in consultation with other departments, such as the California Department of Rehabilitation. Further, because the departments we reviewed were not consistent in their approach to web accessibility testing, we believe it is important for the Legislature to direct all state government entities to report to CalTech about their web accessibility testing approach. CalTech would then assess each entity’s approach, determine whether it is adequate, and publish the results of that assessment online.



The Legislature should amend state law to do the following:

The Legislature should direct all state government entities to report biennially to CalTech regarding the frequency and method of their web accessibility testing. Further, the Legislature should direct CalTech to assess the sufficiency of each government entity’s testing approach and publicize the results of its review online.


Each of the four departments should correct the accessibility violations we found during our review.

Covered California, CalHR, and Community Colleges should develop and follow written accessibility test approaches that include both manual and automated testing of updates to their websites.

Community Colleges and Covered California should update their websites to include all methods of communication described in state policy for someone wishing to report a problem about website accessibility.

CalHR should develop tracking tools that will allow it to document its accessibility testing efforts. At a minimum, these tools should track what portions of its jobs site were tested, what errors were found, and whether and when those errors were addressed.

CalHR should develop procedures for addressing complaints about the accessibility of its website and methods for tracking the complaints it receives and their resolution.

Agency Comments

The four departments at which we performed detailed audit work—Community Colleges, CalHR, Covered California, and Franchise Tax Board—all generally agreed with our recommendations to address the problems we found. However, Franchise Tax Board disagreed with the portrayal of our audit results. Further, CalTech outlined actions it plans to take in resposne to the recommendations we directed to it.


1 Throughout this report, we refer to each of these state government entities as departments. Go back to text

2 For the purposes of this report, we use the term violation to mean noncompliance with an accessibility standard a department’s website was expected to conform to because of state law or a grant or contract agreement. Go back to text

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