Accessibility for Business and Pleasure

By Sarah Horton and David Sloan

Note: This is the manuscript version of the article that appeared in the January/February 2016 issue of ACM Interactions, posted here with permission.

With digital accessibility, standards compliance is a fleeting illusion, like a rainbow.

We are accessibility consultants who engage with clients from all sectors, many of whom are focused on compliance audits and remediation of accessibility issues. We recognize the value of evaluation and repair of digital resources. We also know that an accessibility strategy defined by chasing compliance with technical standards is shortsighted and will likely end in failure.

Standards compliance is rare, whether with Section 508, the Web Content Accessibility Guidelines, or with any other standard. Thorough evaluation of a website containing hundreds or thousands of pages is practically impossible. Many standards require subjective evaluation—are a thousand words really needed to describe a picture?

Even when there is some semblance of compliance, it’s at a fixed moment in time. What happens when a visitor uploads an image and does not provide a text alternative? With one unconsidered action, the theoretical “accessibility” toggle can switch from on to off in an instant.

Toggle user interface element with "Accessibility" label

Can we rethink accessibility in more effective and sustainable terms—ones that generate a positive return on investment for providers and a pleasurable user experience for everyone?

The Return on Investment for Accessibility

In the Wu-Tang Clan song “C.R.E.A.M.,” Method Man reminds us how money defines success: “Cash rules everything around me, C.R.E.A.M. / Get the money; dollar, dollar bill, y’all.” There’s no denying that organizations must make resource commitments largely based on money. Sometimes these resource decisions are about becoming more profitable, but often the driver is less about profit and more about delivering on promises—paying employees, providing good health coverage, covering overhead.

The practice of making resource decisions based on potential return on investment (ROI) applies particularly to activities with an uncertain outcome. At minimum, a business case for a new activity will show how financial gains will at least cover the costs of engagement. A strong business case will show an ROI that both covers costs and brings in profit.

Making a case for accessibility can take many forms that are not focused on the bottom line: protecting human and civil rights, meeting legal obligations, or creating better designs for everyone. However, these discussions usually come around to the same question: How many people are affected and how much revenue can be gained? No matter how the numbers line up, a business case for accessibility based on how many and how much cannot add up to something that offsets the perceived costs—not enough people are affected and the costs of accessibility are not readily quantifiable. Lainey Feingold, a lawyer specializing in the field of disability rights law applied to technology, explains how in the mid-1990s a Bank of America executive stood up at a national convention and shifted the conversation, saying, “We have to stop counting—this is a civil rights issue.”

How do we reconcile the need to stay solvent and make a profit with the costs of accessibility?

One method is to focus instead on delivering quality experiences. Forbes’ Steve Denning quotes Apple’s Tim Cook, saying, “When we work on making our devices accessible by the blind, I don’t consider the bloody ROI.” Apple is profitable and can afford to ignore ROI in some areas. The article goes on to explain that Apple has many activities that “make little or no money” but are part of a larger business strategy of building a base of happy customers. “Apple makes a lot of money not only because it has a very efficient supply chain but also because it has created a customer ecosystem that, as a whole, delights customers and makes them want to stay as an Apple customer” [1]. While we all may aspire to be customer-focused, with delight as a success indicator, most of us can’t afford to invest resources without considering ROI.

There is a return on investment for accessibility, but it’s not in the profits—it’s in the margins. It’s in the money not spent, or spent more wisely.

Organizations that treat accessibility as a compliance activity wind up throwing resources at it ad hoc, for example:

  • monitoring software to flag technology issues rather than developer training for how to write accessible code
  • add-on overlays that purport to resolve issues rather than user research to learn how to design accessible interfaces
  • one-off express turnaround captioning services rather than program development to establish processes and negotiate favorable terms with a vendor
  • time and effort recruiting a “specialist” who has responsibility for accessibility rather than a coordinated effort to up-skill staff and share responsibility across teams.

Redirecting accessibility resources toward smart and lasting investments saves money, and for the long term.

Accessibility can also generate returns that come from designing in the “margins” of use cases. Focusing design research on the needs and preferences of people with disabilities can drive discovery and innovation.

In Change by Design, Tim Brown cautions against too narrow a view: “By concentrating solely on the bulge at the center of the bell curve we are more likely to confirm what we already know than learn something new and surprising.” With accessibility, insights gained by addressing “the exaggerated concerns of people at the margins” can result in products that are more delightful for everyone [2]. Apple’s VoiceOver and Siri are examples—screen reader and speech recognition software that make mobile devices easy to use for people who can’t see, and help people get from here to there, listen to and send emails and text messages, or switch songs while driving.

Accessibility is something we must address in order to meet obligations. Accessibility done right is a way to cut costs, build capacity, and establish partnerships. Accessibility as a driver for innovation is an opportunity to learn what’s needed to design delightful products.

Accessibility Maturity Continuum, progressing through identifying, prioritizing, injecting, and integrating

Accessibility strategy and activity fit neatly on a maturity continuum. Progress along the continuum means moving away from accessibility as a retroactive, responsive activity of doing “just enough to comply” toward one where accessibility is part of culture and practice. The continuum begins with identifying and endeavoring to address existing barriers. The second phase prioritizes the repair of issues based on real-world impact on target user groups’ ability to complete tasks, rather than technical conformance levels.

However, both these phases focus on retrofitting existing products. Moving along the continuum we inject accessibility activities into the development process, addressing issues before they are embedded into design and code. Accessibility activities are still responsive, looking at designs and course-correcting to avoid creating barriers.

In its most mature form, accessibility is integrated into all aspects of organizational planning and thinking, where it helps to frame a problem space, identify opportunities, and influence the design of solutions. A mature approach to accessibility has broad benefits. As Feingold notes, commitment to accessibility helps anticipate and deal with the unknown future: “Companies have to bake accessibility in because who knows what they’re going to be developing tomorrow?”

Moving accessibility from a peripheral activity to one as central to practice as safety, ethics, and good grammar requires shared responsibility and a commitment to accommodating user diversity across all areas of organizational activity. User experience must be valued as a critical business strategy, and accessibility prioritized as a quality attribute. With a mature accessibility program in place, organizations can reap the benefits of improved business processes and better products, and enjoy the resulting return on investment.

Progress Toward Accessibility Maturity

Many organizations embark on strategic accessibility activities in response to some form of complaint. It’s not that organizations have expressly ignored the concerns of people with disabilities. In most cases, the complaint comes because they have not paid enough attention, or because other issues took priority. But complaints can galvanize organizations to make fundamental changes in how they provide digital resources, beyond addressing the specific product at issue and then closing the accessibility project.

Feingold describes how Bank of America first engaged in addressing accessibility and technology issues in the mid-1990s, when they received complaints about the inaccessibility of their ATMs to blind customers. Bank of America worked to address issues specifically related to ATM accessibility, but their focus soon had to extend beyond ATMs, as banking activities moved to the Web:

What makes it work? When companies get to know the user at the start. That’s really the key. What makes it work less well? When the process is in the hands of the lawyers only. There’s good agreement, we get improved accessibility, but it doesn’t always stick in the same way.

An accessibility program fueled by addressing a complaint can only be sustained a limited time before it runs out of steam. A mature program grounded on a commitment to ensure people with disabilities can participate helps embed accessibility as a core value and lasting concern.

In our work, we help organizations move from a reactive, compliance-driven approach of audit-and-repair to one that positions accessibility as a strategic long-term activity. Here we share case studies from three organizations, each diverse in its business activity and distinct in its position and progress in the journey. These stories illustrate approaches that can lead to success, and where organizational challenges can lead to a need to a change in approach.

Healthwise: Sharing responsibility for accessibility in product development

For Healthwise, a nonprofit provider of health information and products, the push to take a strategic approach to accessibility came from clients. Healthwise had been considering accessibility but did not have a formal program in place. Organizations that use their products, such as health systems and other healthcare providers, have obligations in meeting the needs of all patients, and those customers taking active interest in the technical accessibility of Healthwise products to their patients provided the push Healthwise needed to prioritize a more structured approach.

Healthwise’s mission is to help people make better health decisions. To be successful they must design products that speak to a diverse audience. Healthwise’s vice president of user experience, Becky Reed, observes that within healthcare in general, “accessibility is tied to a broader health compliance sphere that cares about usability and engagement and a whole myriad of other things.”

Even with lots of commitment to meeting user needs, accessibility was seen primarily as an engineering concern—something addressed under the hood, in code. The UX team knew accessibility was important but wasn’t well versed in how to integrate it into visual and interaction design. The content team was expert at creating health resources using plain language but didn’t have insights into how content affected the experience of people with disabilities. The engineering team felt on the hook, implementing designs that were sometimes difficult to make accessible, and viewed coding for accessibility as somewhat mysterious.

In the end, Healthwise found success in getting people in every team passionate about accessibility, supporting interested staff in what they needed to build their expertise and their organizational advocacy. This was a shift from having a single strong voice, which might have been more of a blocker than a benefit, as Reed notes: “We needed to move away from the mindset of, ‘We need to talk about this with Becky.’ ” Within six months of this new approach, team-level accountability and responsibility emerged, alongside a sense of pride and ownership among team members in work that was important to them.

As it increased focus on accessibility, Healthwise found success in dealing with accessibility problems as technical debt: “We can either continue to create technical debt, or we can just tackle this now.” One developer analyzed audits that were done on the software and found that 98 percent of all the changes made to repair accessibility issues were about implementing semantic coding practices that are not unique to accessibility. The ROI found in this technical analysis got the attention of the chief technology officer, who saw the data and laid out a more efficient path.

The result was a partnership between UX and engineering teams to share energy and budget dollars. All team leadership set expectations with staff and supported their teams in the training, time, and priority they needed. Team leadership also talked about the strategic approach to accessibility with passion because they were just as invested in it as the historical champions were. It also resulted in an organizational mandate that UX won’t hand anything to engineering that could not be made accessible, and that accessibility is a much larger part of the product release process.

With engineering, QA, UX, and content teams engaging meaningfully with accessibility, product management created a new product manager position focused on accessibility. Reed recalls how it came about:

It wasn’t “Becky wants another resource.” It was, “Seventeen people are talking about this. This is an organizational commitment.” Once we had enough folks in the organization seeing accessibility as an imperative in healthcare, that was where the switch really flipped for product management. They said, “Whoa, we’re going to take one of our FTEs and make it more about accessibility.”

Pearson: Building accessibility knowledge and skills across the board

Pearson PLC is a large multinational company with many products and services, from brick-and-mortar schools to standardized tests to digital books to learning management systems. With such a diverse and global portfolio, Pearson is accustomed to receiving and responding to complaints of many different flavors. The one that kicked off their strategic accessibility program was when they were called out by the National Federation of the Blind (NFB), who in their 2012 Resolutions “condemned and deplored” Pearson for their inattention to the needs of people who are blind [3]. Pearson understandably felt it needed to respond positively.

The company recognized that the solution was not to quickly apply Band-Aids to staunch the bleeding until the negative attention has passed. “For me there was a realization that it’s going to be impossible for people to function in life without being able to manage digital resources,” says Rick Ferrie, Pearson’s director of global policy.

Pearson initially made good progress addressing the concerns raised by the NFB, but when the heat eased up, attention to accessibility began to wane. When it came time to define the work order for the next release of one product, the product team asked whether they needed to include accessibility in the new release. “As long as someone still thinks it’s something they have to do as opposed to something they want to do, then we haven’t moved the needle where it needs to go,” says Ferrie.

Ferrie’s greatest challenge has been engaging the design and development teams. “When your chief engineer making a product says, ‘We don’t want to do this,’ that’s a hard thing to get past. We have to somehow convince the development community that this isn’t going to make bad products, that it isn’t hard, and that it isn’t some kludge add-on thing.”

So far Pearson’s efforts have been focused on developing individual accessibility specialists at a junior level, but there is ambition to ensure accountability for accessibility moves up the organization chart. Ferrie knows that long term, responsibility must be owned by managers and shared by everyone on the team: “Having lots of accessibility worker bees is not the same as having the lead architect on a product owning accessibility and manifesting it in designs.”

Knowledge building at Pearson has been a combination of building awareness among leaders and developing skills on the ground. These efforts have been successful at building accessibility specialists, but the company knows a strong infusion of high-level expertise is needed:

We want to find big-time developers, designers, academic technologists, that get it and embed them into core platform teams, as peers of the mainstream architects and engineers. We can’t train 10,000 developers in enough time to get where we need to be.

University of Colorado at Boulder: Establishing an accessibility program

For the University of Colorado at Boulder, the trigger for rethinking accessibility was a formal investigation by the Department of Justice, representing several students with vision impairments who submitted a complaint that their rights under the Americans with Disabilities Act (ADA) had been violated by the university. CU-Boulder has a strong program supporting students with disabilities, but the relationship between accommodating students with disabilities and providing an accessible digital environment—one composed mainly of third-party tools—had not been solidified [4]. Accessibility barriers were present in a range of tools that students were expected to use.

CU-Boulder’s response has been grounded in a commitment to address the issues at the foundational layer. “The way we are building our digital accessibility program is definitely for the long haul as opposed to a short sprint,” says Marin Stanek, director of academic and campus technology communications and support.

Historically, CU-Boulder has followed the model of accommodating students, staff, and visitors with disabilities through the Student Disability Services (SDS) and Human Resources’ Office of Equal Opportunity (OEO), with the Office of Information Technology (OIT) playing a supporting role, helping SDS or OEO where needed with assistance with accommodations.

With the digital accessibility program, OIT made accessibility among its “chief” concerns by establishing a new role: chief digital accessibility officer. Like security and privacy, CU-Boulder recognizes that everyone at the university has a role to play in ensuring an accessible IT environment. Including accessibility in the larger context provides the opportunity to layer accessibility on top of prior experience and existing frameworks.

For CU-Boulder, a public university with a large and complex digital estate, the challenge is one of scope and control. “We have hundreds of IT services; we have over 1,000 different websites,” says chief security officer/chief digital accessibility officer Dan Jones. For success, many individuals and organizations must see the value of accessibility and engage with it in their work. Faculty must understand what’s needed to produce accessible course materials, and make the effort to follow best practices. “I think at the end of the day the concerns that people will have will be, what are you requiring for websites, or why are you telling me to have language in the syllabus?” says Jones. To reduce the learning curve, training is focused on giving people the skills to apply relevant accessibility knowledge in the context of doing their job. “Rather than saying, you must have accessibility training, we talk about role-based training. You are a faculty member; here are the things you need to know as part of being a faculty member.”

In the course of writing this article, the Department of Justice closed their inquiry with CU-Boulder. And while they are relieved, Jones relates, “The best part is that it really reflects on all of the hard work the project team has been doing and reinforces the direction we are taking.” In particular, it solidifies the connections and partnerships established in the course of responding to the inquiry. The CU-Boulder team is on a journey, and they know their work isn’t done. But they’re building an accessibility program that allows them to strategically deal with legacy accessibility issues while minimizing the chances of barriers emerging as they grow and develop their digital estate.

Pleasure in the Margins

Anyone involved with book design understands that margins are where the magic happens. In his Medium article “Let’s Talk About the Margins,” Craig Mod walks us through a love story, with protagonists from a dictionary publisher who unite around close attention to details that normally go unnoticed—the quality of paper that makes it adhere to fingers at just the right amount to make turning pages effortless, even sensual [5]. Examining this and other subtle pleasures, he says, “Thoughtful decisions concerned with details marginal or marginalized conspire to affect greatness.”

Accessibility provides us with an opportunity to affect greatness in design. By approaching accessibility as a creative challenge, we can see clearly the nuances that make or break user experience—and avoid the issues that over time make interaction so difficult, so inefficient, and so physically tiring as to be practically impossible for someone with a disability.

Usability studies and user research with people with disabilities can bring into sharp focus issues that everyone faces. In a recent usability study, we evaluated a Web application with people with a range of disabilities, including no vision, low vision, and limited dexterity. The uncertainty when activating a button that does not provide visual or audible feedback is felt keenly by users with limited dexterity, who have difficulty clicking or tapping a button. The difficulty and strain of tracking along the row of a bus timetable to find the right departure time are magnified when using zoom. Inconsistency in design patterns is even more disorienting when navigating a site by ear—is this supplementary information a tooltip, a dialog, or a new page, and how do I resume where I left off? Difficulty interpreting interaction feedback, data tables, and inconsistent design are familiar issues for all of us.

The recently published “Manifesto for Accessible User Experience” [6] includes a statement from our colleague Léonie Watson. She powerfully described accessibility as “a creative challenge, not a challenge to creativity.”

We have no doubt there is a business case for accessibility that involves both cost savings that arise from smart resource allocation as well as newfound general innovations for the broader market. Better to invest in making desirable products than cleaning up a mess. What really gets our juices flowing is the business case for designing pleasure that can be experienced by everyone. With accessibility as an attribute, user experience moves from “nice to have” to “blocker” due to the imperatives of legal obligations and the clarity that comes from focusing on the margins. Accessibility spotlights essential attributes of quality and focuses attention on what matters: whether or not people can participate.

Ferrie says, “If I could call it something other than accessibility I would. I would call it design that works for everyone, or good design.”

We are sympathetic to the desire to move away from talking about accessibility, with its attendant misperceptions of limited return on investment and crushing influence on innovative and appealing design. But we’re also mindful of our responsibility to people with disabilities, to the human rights issue that underpins our work, and our creative powers to reduce or remove barriers to social interaction, not construct new ones. When we talk about the benefits of accessibility, we must make sure we don’t inadvertently downplay the focus on people with disabilities. At the same time, we can’t help but spill over with enthusiasm for exploring the opportunities we collectively stand to gain by careful attention to people who are not in the mainstream. While we acknowledge the pragmatism of Method Man, we join our voices with Craig Mod’s Paper Man in saying, “WE WILL TRY HARDER.” Creativity and innovation arise from understanding the nuances that are experienced keenly in the margins. There lie the insights that will lead us to discover more pleasurable experiences for everyone.


    1. Denning, S., Why Tim Cook doesn’t care about ‘the bloody ROI’Forbes, Mar. 7, 2014
    2. Brown, T., Change By Design, HarperBusiness, New York, 2009
    3. National Federation for the Blind, 2012 Resolutions
    4. University of Colorado Boulder Accessibility Initiative
    5. Mod, C., Let’s talk about the margins
    6., Manifesto for Accessible User Experience


Sarah Horton and David Sloan lead the user experience strategy and research activities at TPGi. Sarah is co-author of Web Style Guide and A Web for Everyone. David’s Ph.D. focused on innovative ways to enhance user experience for older and disabled people.

Categories: Accessibility Strategy, Technical