Importance of the GOALS Cost Case Studies

Linda Goetze

The topic

There are many reasons why institutions are working to improve the accessibility of digital content for faculty, students and staff with disabilities. Those in postsecondary settings have often heard in the past two decades, “it's the right thing to do”, “it's the smart thing to do”, and “it's the law”. There is no doubt that the internet has become central to the modern higher education experience. While it is true that Federal law requires institutions that accept federal funds to provide equal opportunity for persons with disabilities, including digital media, the motivations for digital accessibility are deeper for those making the choice to engage in this work across the enterprise. Some indicate that this work is mission driven and in line with institutional directions. Others express a keen understanding of the importance of accessibility if they are to focus on the academic outcomes of all students. Still others express its importance in keeping a diverse and vibrant campus community with faculty, staff, and students who represent different personal experiences.

Web accessibility advocates have helped top-level administrators understand and commit to web accessibility initiatives, however the field has yet to reach a national saturation so that universal access is present for all who would benefit from it. Partners in Project GOALS1 are working to provide information, resources, and tools to impact motivation and practices of leadership in higher education. One motive on the minds of many in administrative positions is how they can provide these efficiently to their institution.

A significant barrier to increasing web accessibility in higher education is concern about what these efforts cost. The field is replete with logical statements about how web accessibility presents a cost savings and benefits (e.g., increases customer base and income, increases search engine optimization, decreases direct costs of future accommodations, reduces costs of future litigation), yet is devoid of cost or benefit data to support such claims. For those in top administrative positions in higher education, cost is a topic that has not been sufficiently addressed. Many express a fear that the cost of implementation will exceed available resources. They continue to ask questions about the higher education “business case”, the “return on investment”, and in general they want to understand how the cost of making content accessible from the beginning is in their best interest. If we are going to make headway with many postsecondary administrators, the field must address the issues surrounding cost.

Higher education administrators are not the only ones looking for cost information on web accessibility. When the Department of Justice (DOJ) published the Advanced Notice of Proposed Rulemaking (ANPRM)2 they sought feedback on 19 questions, 4 of which were on costs and cost benefit alone.

What we found

In preparation for our work to collect data on costs of web accessibility, GOALS staff conducted a comprehensive review of the literature to identify existing data, economic methods and instruments used. The finding was that there is a significant amount written about the rate of return on investment of web usability and very little on web accessibility across any sector of society, let alone in education. The return on investment literature examines the costs and benefits from increasing usability of web sites and content. The published work related to identifying the actual costs and benefits of web accessibility was very limited. While there are many sources that detail the financial benefits to web accessibility3, few provide data on actual costs or savings.

It is not surprising that so many are looking for documentation on costs of web accessibility. When one looks to the available literature, there is a paucity of data on actual costs or cost-benefit data4. The most detailed work on costs of web accessibility was found in only one source5. In a book chapter, the author described the costs and benefits associated with web accessibility. However what he described was a hypothetical method to estimate the cost of retrofitting web content to be accessible to various standards– such as the W3C's Web Content Accessibility Guidelines6, or to the U.S. Federal Government's Section 508 of the Rehabilitation Act7. The proposed method estimated (1) the number of templates, (2) test and repair hours per template, (3) number of pages, (4) hours per page, and (5) hourly cost to estimate the overall cost to test and repair pages to a specific web accessibility standard. The standards used in the proposed method included standard quality assurance, Section 508, and additional browser compatibility. No actual cost data to achieve those various standards was collected. The estimates in the text are based on simplified assumptions about what the author believed web accessibility changes would cost, based on time spent, salaries and standards achieved based on very simplified assumptions.

There are some examples of common economic comparisons in web accessibility and web usability and they illustrate why understanding what is being compared is so important. "The rule of thumb in many usability-aware organizations is that the cost-benefit ratio for usability is $1:$10-$100. Once a system is in development, correcting a problem costs 10 times as much as fixing the same problem in design. If the system has been released, it costs 100 times as much relative to fixing in design." 8

Keep in mind that this refers to usability not accessibility. The comparison that is being made is one of fixing a problem in the design phase versus waiting until it is deployed. Noted accessibility expert, Karl Groves pointed out “I don't see any difference in terms of development time for something inaccessible vs. something accessible (provided the developer understands accessibility). I generally consider the level of effort to be identical for new development.” 9 He argues that there might even be reduced maintenance time and costs from developing accessibly. However, he goes on to point out that there are a number of things that weaken this central argument; primarily that most development work is not completely new and doesn't fall into this simplified comparison. With that said, data were not provided to illustrate his arguments.

This lack of information extended beyond published literature to responses returned to the Department of Justice (DOJ) as they sought comment on an Advanced Notice of Proposed Rulemaking. The DOJ sought to clarify expectations in regards to cost to provide accessible web content under the proposed rules. GOALS staff reviewed over 300 responses sent into DOJ posted on the Regulations.gov website. The comments mentioned a variety of costs incurred as a result of web accessibility requirements including such things as legal fees (interpreting standards), testing for compliance, licensing, user testing, transcript and captioning for video and audio. However, there were no specific sources of cost data relevant to web accessibility cited in the responses. This lack of evidence validated the findings of the literature review.

While there is demand for information on cost, neither cost methods nor data about cost and efficiency of web accessibility are available to those who would benefit from it. It means that institutional leaders are making decisions in an information vacuum. Key questions for institutions that wish to pursue web accessibility will necessarily include how to get started and where to begin? The need for accessible content is great across the enterprise and exists across classroom, department, college and institution-wide websites. How can we help leaders prioritize limited resources to have the most positive impact when there is no information for them on which to do so?

What we wanted to examine

One of the reasons that this information may be missing in the literature is that it is a complex issue that is not easily obtained. Ultimately we were looking for methods and data on the cost of accessible designs compared to inaccessible designs– so we could use the same vetted methods in higher education. We were unable to secure true cost information to use as we moved forward.

The reader may be interested in hearing that GOALS Project staff initially wanted to conduct a project that could show the total cost of creating a web site when done accessibly from the start versus the total cost of creating an inaccessible web site plus the cost of retrofitting that site for accessibility later; since this is typically what is done in higher education. But because there were no existing research models to use, we had to shift to another plan. While we discussed creating such a design, there were a number of barriers to executing it in the short timeframe we had for the work.

It is difficult to hold everything constant and only vary the one thing we wish measured– costs for accessible and inaccessible design. Yet, that is what would have to be done to get to an honest comparison. In order to quantify a true comparison we would need comparable web site requests for development (e.g., in terms of complexity, number of pages, and all other components). We would also have to have access to web developers who were “equivalent” in terms of their professional skill. The human capital of the developer(s) would need to be the same for the comparison to give us the true cost of the different methods, yet this is difficult. You cannot ask someone to build a website accessibly unless they are trained to do it accessibly. Nor can you ask someone who is trained to build content accessibly to build it as if they didn't know accessibility. The design would require both conditions of the comparisons to be made by those who have knowledge and skill in accessible design. In one condition you would ask them to create an accessible page or site. In another condition you would ask the same person to create an inaccessible one, matched for complexity and features. However, the question remains if a web developer trained in creating accessible content could ignore the techniques that they have used in the past to create an inaccessible website since this would be contrary to their training and professional experience. It is possible that it could take more time for developers trained in accessibility practices to create a web page that is not accessible, as it may be a conscience effort on their part to do so. Also since much of the developers' work on accessibility is also good practice for usability, is it possible for the developer to create an inaccessible website with good usability but not accessibility?

Because of such challenges, conducting a rigorous comparison of accessible and inaccessible web content is yet to be done. There are many important economic questions that we realized we could not address. In our GOALS Cost Case Studies, we were unable to get the empirical evidence needed to state if it is more or less cost effective and efficient to build web content accessibly from the beginning than it is to retrofit it after it is built. This answer is the Holy Grail in web accessibility today.

However, what we did accomplish is important in the field. We identified existing practices in higher education, described them, and collected costs for them. It is hoped that this will be the beginning of a serious exploration of costs of web accessibility in higher education. Readers may acknowledge some tradeoffs in regards to costs, benefits and outcomes as they read each case study. It should be noted that this collection of institutional experiences is merely a description of their experience, and not an attempt to compare across institutions or practices. The web accessibility strategies that are described were the result of internal comparisons at each institution but not external ones. Everyone faces limited resources and so staff considers alternative web accessibility activities to undertake with competing resources and make an internal determination about where those resources are best applied. We hope this information is helpful to postsecondary leadership as they make choices about web accessibility practices in a way that will save them money and improve outcomes for students, faculties, staffs, and community members with disabilities.

As the field moves forward to achieve web accessibility in postsecondary education, one thing is clear, we must speak to the motivations of top administrators. Until Presidents, Chancellors, and Provosts fully support web accessibility initiatives, the resources necessary for success will be used to support competing institutional priorities. Costs and efficiencies are motivators for our leadership in postsecondary settings.


1.   Partners in Gaining Online Accessibility through Self-Study (GOALS) include

2.   Department of Justice. (2010). Nondiscrimination on the Basis of Disability; Accessibility of Web Information and Services of State and Local Government Entities and Public Accommodations

Retrieved from http://www.ada.gov/anprm2010/web anprm_2010.htm

3.   See the following examples:

4.   Rowland, C., Whiting, J., Mariger, H., & Goetze, L. (2010). Year One Report to the U.S. Department of Education (FIPSE P116B100152). National Consortium to Broaden Access of Electronically-Mediated Education through Institutional Self-Study: Project GOALS. Washington: DC

5.   Bias, R.G., & Mayhew, D.J. [2005], Cost-Justifying Usability: An Update for the Internet Age; Second Ed., Morgan Kaufmann Publishers

6.   See http://www.w3.org/TR/WCAG20/

7.   See http://www.access-board.gov/sec508/guide/1194.22.htm

8.   (Gilb, 1988)– *Gilb, T. (1988). Principles of software engineering management. In Usability is good business. Cited in Return on Investment for Usable User-Interface Design: Examples and Statistics, Version 28, February 2002; Aaron Marcus.

9.   Karl Groves Blog post Oct 7, 2011
http://www.karlgroves.com/2011/10/07/accessibility-and-reduced-design-development-production-maintenance-costs/; Website Accessibility and Reduced Design, Development, Production, Maintenance Costs, October 7, 2011, Karl Groves.