Overview
The Massachusetts Teachers’ Retirement System’s (MTRS’s) website was not fully accessible to all website users. We reviewed a sample of 50 webpages and found that none of these webpages were compliant with Web Content Accessibility Guidelines (WCAG) 2.1. We determined the following issues within our sample:
- Of these 50 webpages, all 50 had content that could not be navigated to via a keyboard;
- Of these 50 webpages, all 50 did not have the first focusable control be a hyperlink that skips to the main content of the webpage;
- Of these 50 webpages, all 50 had hyperlinks that did not have any secondary identifiable component to distinguish themselves;
- Of these 50 webpages, 24 contained content that was illegible when zoomed in to 400%;
- Of these 50 webpages, 5 had broken hyperlinks;
- Of these 50 webpages, 5 misused headers;
- Of these 50 webpages, 1 did not provide users with warnings when they left entry fields blank; and
- Of these 50 webpages, 1 did not properly label input fields.
Noncompliance with WCAG 2.1 reduces accessibility for individuals with disabilities and limits equitable access to MTRS information and services. Specific risks include the following:
- A lack of keyboard navigability means that users with mobility impairments cannot access certain content.
- Because MTRS’s website does not make the first focusable control on a webpage a hyperlink that skips to the main content of the webpage, users who navigate sequentially through webpages are forced to navigate through repeated content every time a webpage loads. This increases the time needed to reach the desired information on a webpage and may, for users who have motor impairments, make navigating content cumbersome or difficult.
- Hyperlinks that do not have a 3:1 contrast ratio or a secondary identifiable component may be imperceptible to users and will prevent them from interacting with MTRS content.
- If MTRS’s website cannot reflow13 at 400%, some users will not be able to read content if they zoom in to alleviate a visual impairment.
- Broken or faulty hyperlinks limit users from having access to critical information and key online services offered by MTRS. Broken or faulty hyperlinks also increase the likelihood that users may either access outdated or incorrect information or be directed to webpages that no longer exist.
- Improper use of headings and labels makes it difficult for users to navigate and read the website. Additionally, improper use of headers and labels negatively impacts users who rely on screen readers to navigate the website.
- Entry fields that are improperly labeled or that do not provide users with warnings about input errors or omissions prevent users from accessing MTRS content.
Authoritative Guidance
The World Wide Web Consortium’s WCAG 2.1 states,
Success Criterion 1.4.1 Use of Color
(Level A)
Color is not used as the only visual means of conveying information, indicating an action, prompting a response, or distinguishing a visual element. . . .
Success Criterion 1.4.10 Reflow
(Level AA)
Content can be presented without loss of information or functionality, and without requiring scrolling in two dimensions for:
- Vertical scrolling content at a width equivalent to 320 [cascading style sheet (CSS)] pixels;
- Horizontal scrolling content at a height equivalent to 256 CSS pixels.
Except for parts of the content which require two-dimensional layout for usage or meaning. . . .
Success Criterion 2.1.1 Keyboard
(Level A)
All functionality of the content is operable through a keyboard interface without requiring specific timings for individual keystrokes, except where the underlying function requires input that depends on the path of the user’s movement and not just the endpoints. . . .
Success Criterion 2.4.1 Bypass Blocks
(Level A)
A mechanism is available to bypass blocks of content that are repeated on multiple web pages. . . .
Success Criterion 2.4.5 Multiple Ways
(Level AA)
More than one way is available to locate a web page within a set of web pages except where the Webpage is the result of, or a step in, a process.
Success Criterion 2.4.6 Headings and Labels
(Level AA)
Headings and labels describe topic or purpose. . . .
Success Criterion 3.3.1 Error Identification
(Level A)
If an input error is automatically detected, the item that is in error is identified and the error is described to the user in text.
Success Criterion 3.3.2 Labels or Instructions
(Level A)
Labels or instructions are provided when content requires user input.
Reasons for Issue
MTRS management provided us with the following reasons for the findings identified in this audit:
- MTRS management stated that they chose a theme14 for their website that created accessibility challenges. MTRS was unable to alter website characteristics like text and hyperlink color and continued to create webpages using this problematic theme.
- MTRS management stated that, in 2017, MTRS made the decision to host its own website and contract with a third-party vendor to create it. MTRS management stated that the original third-party vendor contracted to create its website did not have the required expertise to create an accessible website. Additionally, MTRS stated that subsequent contracts for website hosting and maintenance services did not include provisions for assessing or improving website accessibility.
- MTRS management stated that they did not provide website accessibility training to MTRS staff members, and that those staff members were unable to identify accessibility shortcomings on the website.
- MTRS management stated that their content management system15 does not have preventative controls in place to ensure that content is posted in a WCAG-compliant fashion and that they do not perform periodic accessibility reviews.
Recommendations
- MTRS should work with its vendor to resolve the issues directly identified in this report.
- MTRS should select a new theme for its website with more accessible design elements.
- MTRS should train staff members on website accessibility requirements and provide staff members with third-party website accessibility tools to monitor WCAG compliance.
- MTRS should implement preventative controls to ensure that content on its website is posted in a WCAG-compliant manner.
- MTRS should ensure that its third-party vendor monitors the website for instances of WCAG noncompliance, or MTRS should acquire tools to monitor WCAG compliance on its own.
Auditee’s Response
The MTRS acknowledges the audit findings and agrees that our website was not fully compliant with the Web Content Accessibility Guidelines (WCAG) 2.1 at the time of review.
We recognize the importance of ensuring equitable access for all website visitors, including individuals with disabilities, and we take these findings very seriously. Corrective actions are already underway. These include immediately addressing critical issues such as broken links and mislabeled input fields, improving keyboard navigability, and correcting header structures.
Most significantly, we plan to work with our website hosting vendor to implement a modern, fully accessible WordPress theme. WordPress themes determine much of the website’s underlying code, including accessibility functions. Selecting an “accessibility-ready” theme will provide a strong foundation for achieving full compliance. This initiative, combined with staff training and regular scheduled third-party accessibility scans, will help ensure ongoing compliance and equitable access for all users.
Auditor’s Reply
Based on its response, MTRS has taken measures to address our concerns regarding this matter. As part of our post-audit review process, we will follow up on this matter in approximately six months.
| Date published: | October 16, 2025 |
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