Overview
Some Division of Insurance (DOI) webpages do not comply with state information technology (IT) accessibility standards for navigation accessibility and language attributes. During our audit, we determined that 3 out of the 60 DOI webpages tested contained hyperlinks that did not allow users to navigate to related pages (i.e., broken and faulty hyperlinks). For language testing, we determined that 1 out of the 60 DOI webpages contained an inaccurate language attribute, which means that words on the webpage did not match the language to which the webpage was set.
Navigation Accessibility: Broken Hyperlinks
Broken or faulty hyperlinks negatively impact the user experience and make it difficult to locate additional relevant information. (See example below.) They can also limit some users from having equitable access to critical information and key online services offered by DOI (e.g., insurance-related complaint submission). Also, broken or faulty hyperlinks could increase the likelihood that users access outdated or incorrect information or are directed to webpages that no longer exist.
Language: Inaccurate Language Attributes
A language attribute specifies the language of a webpage or an element of a webpage. (See example below.) Inaccurate language attributes can pose a number of challenges for accessibility. Specifically, if DOI does not correctly identify language attributes, people using translation software or a screen reader could lose the ability to interact with or understand critical content on DOI’s website. For example, language attributes allow screen readers that support multiple languages to adapt to the specific pronunciation of the language on the page. This allows a screen reader to speak the text in the appropriate accent with proper pronunciation.
Authoritative Guidance
The IT Accessibility Standards section of the Executive Office of Technology Services and Security’s (EOTSS’s) Enterprise Information Technology Accessibility Policy states,
- a. Accessibility of electronic content, applications, or services must be measured with one or more of the applicable following technical standards.
i. Web and desktop applications, multimedia content, electronic documents: Web Content Accessibility Guidelines 2.1 (WCAG), level A and AA Guidelines.
The Web Accessibility Initiative’s Web Content Accessibility Guidelines 2.1 states,
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 Web Page is the result of, or a step in, a process. . . .
Success Criterion 3.1.1 Language of Page (Level A)
The default human language of each Web page can be programmatically determined.
Reasons for Issue
DOI management stated that the broken hyperlinks were caused by changes to its website architecture,8 webpage updates that replaced content, and copy and paste errors that allowed for improper formatting of text. DOI management believes the language attribute was caused by a system error.
Recommendations
- DOI should review its webpages to ensure that all hyperlinks lead to related information to provide equitable access to critical information and services offered online by DOI to all Commonwealth residents.
- DOI should review web content that appears in other languages to ensure that the pages have accurate language attributes to facilitate effective translation and provide a user experience that is inclusive to all Commonwealth residents.
Auditee’s Response
In 2018, the Commonwealth transitioned to [a new] operating system for agencies to utilize in updating their own content on agency websites. Prior to 2018, information technology staff were responsible for posting new web content and revisions to existing content, and for the DOI this meant sending web content requests to staff in the Information Technology (“IT”) group for the Executive Office of Housing & Economic Development.
Since 2018, designated staff within each agency, having [operating system] access authority granted by the Executive Office of Technology Services & Security (“EOTSS”), have been responsible for maintaining agency website content. EOTSS staff, however, periodically review web content and inform agencies of any noted issues. The DOI agrees that continuous review of our website is important. DOI personnel attend [operating system] user group meetings, and work regularly with EOTSS staff and others who view the DOI’s website, to address identified issues including broken links. As noted during the audit, DOI believes the website accessibility findings identified by the Auditors were caused by factors not directly in DOI’s control but took immediate action to rectify these issues to the Auditors’ satisfaction. We will continue to work closely with EOTSS and others who view and analyze DOI’s website to ensure its accuracy and accessibility for all consumers.
The DOI is working to develop a language access plan that will apply across all operational areas, in accordance with the Governor’s related Executive Order #615 to improve language access across state government. This will facilitate accurate and effective language translation and provide an inclusive user experience to all who need our services. This effort will include issuing [a request for responses (RFR)] to solicit vendors who can provide immediate translation services when the need for them arises. The DOI also surveyed staff to identify those with fluency in multiple languages, who could assist as needed until we secure a vendor with broader language capabilities through an RFR process.
Auditor’s Reply
While we acknowledge that EOTSS (as the oversight agency) plays a role in ensuring the accessibility of web content for state executive branch agencies, DOI should ensure that IT solutions and content are in compliance with accessibility standards of EOTSS’s Enterprise Information Technology Accessibility Policy. This is pursuant to Section 2 of Chapter 7D of the Massachusetts General Laws, which requires all state executive branch agencies, including DOI, to “adhere to the policies, procedures, and objectives established by the executive office of technology services and security.” Based on its response, DOI has taken measures to address our concerns on this matter.
| Date published: | March 19, 2024 |
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