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Manual WCAG Testing: Key For ADA Website Compliance Auditing

David Gibson

When it comes to WCAG website auditing for Section 508 or ADA compliance there are different approaches. Automated plus manual WCAG testing is the best practice, but there is a significant cost to consider. Essentially the best approach for you comes down to the right balance between risk tolerance and budget for your organization.

Manual WCAG Website Auditing Overview for ADA Compliance

For a complete WCAG website audit, manual testing of each and every web page is luckily not necessary. Websites are built using templates. Global elements such as headers and footers are shared. Widgets for specific functions such as calendars, photo galleries, and lead capture are shared throughout the content areas of websites. Therefore, each page and each instance of shared elements do not need to be manually audited. Just the unique pages and each individual element once. So the first step is to identify those. Your accessibility partner along with your development team can do that together. Inventory the site and identify all of the templates and unique pages, and then weed those that are essentially the same. Make sure your list includes instances of all elements, and widgets. The manual auditor then reviews the code and tests use-cases using actual assistive technologies such as screen readers and keyboard-only for those who cannot use a mouse. 


The Limits of Automated WCAG Auditing Solutions Cannot Replace Manual Testing

Automated website testing using software is very limited. The WCAG - the de facto standard for ADA and Section 508 compliance - is nuanced and interpretive to begin with. And software is only good for binary testing. In addition, automated testing tools cannot even detect many issues. And there is quite a wide range in the quality and depth of such tools. Even the best cannot detect more than ~30% of WCAG issues. Therefore, manual testing is required to address the balance.


Best Practices for WCAG Website Auditing

To ensure you get a complete view of your website’s level of accessibility, you first start with automated testing. This captures most of the low-hanging fruit, such as missing labels/tags, and serves as the base of the audit report. Then, your accessibility consultant will layer in his/her findings using manual and assistive technology testing. Findings are presented in an audit report that documents all WCAG violations to then address, and ideally provides guidance for remediation.

What’s really important is that your web accessibility partner has a strong understanding of the front-side code of the website. That’s the “presentation layer” of what you see on your screen - the html, css, and javascript. With a strong understanding of the code, your partner will be qualified to not only show where and what each issue is, but also how to fix each. That’s where our team really shines.


Automated Tools for WCAG Website Audits

Here you get what you pay for. There is a very wide range - from free to more than $10K per year. You can find a few that we have used and can recommend on our resources page. We suggeste avoiding website "monitoring" tools that have bolted on WCAG scanning along with SEO, 404 error, and other error monitoring tools. It's important is to use tools that are purpose built for accessibility auditing. It’s also important to be aware of the difference between page testing tools and full site auditing tools. Page testers such as WebAIM's WAVE are good for testing a specific page. This tool, in particular, is nice because it adds a visual layer over a page with flags for each issue, so you can quickly visually see the issues, but it’s not an auditor. What you want in a WCAG website auditor, is one that indexes the entire site and provides a single report that catalogs all issues and for each issue indicates where it is, what it is, severity for the end-user, and then provides remediation guidance for each item. 


How Much Does A Proper Manual WCAG Audit Cost?

The cost for a full audit that includes automated and manual testing that includes assistive technology testing is expensive. It’s very time consuming to examine each page, test using various AT devices, and then to document findings and add remediation guidance. The way we price such an audit is by the number of unique pages we need to manually test. Typically, these average in the $10K-$30K range. 


Pragmatism: Taking a Phased Approach to WCAG Website Testing

In most cases this is a cost that was not budgeted for. You may not have $10K or more in the current budget cycle. In such a case, you can take a phased approach and begin with just an automated audit. Remediate those items, and then in the next budget cycle, go back and do the manual audit.


508 & ADA Testing & Remediation: What to Avoid

There is a growing breed of too-good-to-be-true “overlay” solution providers who claim that by adding a plugin or javascript snippet they can automagically make any website WCAG compliant. Without naming names, these rely on automated tools which we know can only detect ~30% of issues in the first place. As the term “overlay” suggests, these methods fail to fix the underlying code. They also need to be manually turned on by the end-user. Attorney Richard Hunt of Hunt Huey PLLC was one of the first attorneys to specialize in digital ADA cases. He recently wrote Is there a silver bullet for ADA website accessibility? Sorry, but the answer is no. on March 31, 2020: "If your business wants to avoid getting sued under the ADA because of an inaccessible website an accessibility overlay or widget isn’t going to help you. I can say this with some certainty because in the last two weeks alone five lawsuits have been filed against businesses that use an accessibility widget or overlay on their websites."

Also be sure to avoid alternate “accessible website tactics. This approach fails the separate but equal mandate of the ADA, as such sites are never equal in practice. 

Here is an entire article about these and other things to avoid.


Final Thought

If you only remember one thing from this post…  automated solutions can only detect 30% of WCAG issues. To protect yourself from endless legal actions and to ensure all can use your website, you must also have an expert in WCAG and font-side code conduct a manual audit as well.