The answer is probably what you’d guess – Yes, we should all should care. Everyone would say that. But when we look at the design, content, and structure of websites, does it seem like people care? Or think of your own organizational budgets. How much is dedicated specifically to addressing universal access and support? In most places, it’s literally zero dollars. Part of that is that most people don’t use assistive technology, so it doesn’t rise to the level of organizational awareness that is needed for investment to occur. And, some of us have been a little scammed into thinking the issue has already been solved. Let’s look at that first.
The little bug that looks like it does something.
The Bug
Pay attention as you look at sites on a daily basis – you’ll see that little accessibility bug in the lower corner of websites more and more. It allows you to add an overlay to the site to fix the things that most sites do poorly. But, predictably, they don’t really work. There are some very successful companies that have sold us all a bill of goods, with the promise that if you just install this tool and pay a small yearly fee, your accessibility issues are solved and there’s one less thing to worry about. But no.
That little bug does do… something. It takes the page, once loaded, and adds a few labels, fills in alt text, and allows you to change colors, fonts, etc. So if you want to delegate site design to your visitors, it does that. But they do not work for assistive technology – screen readers, or keyboard commands. This is because those problems are in the source code, and those technologies read the code, not the overlay the little tool uses to mask the page’s problems.
So adding a little bug is not a solution. Plus there are firms that scan for the overlay code as a way to target companies for lawsuits. Most of those fail, but lawfare doesn’t require a win at trial to extract some money from you.
Why this matters more than ever: Government Regulation
Up until this point, the enforcement of the Americans with Disabilities Act in digital properties has been very low. It’s been more about ‘reasonable accomodation’ rather that specific standards. But that’s starting to change.
The stakes are currently highest in the healthcare sector. Federally Funded Health Centers (FQHCs) and other HHS-funded entities are facing a critical deadline this May 2026 to align with WCAG 2.1 AA standards.
This mandate is a localized reflection of a global shift. Whether your industry is currently under the microscope or not, the “barrier-free” web is becoming the standard. The choice for brands today is whether they will be dragged toward compliance by regulation or lead the way through superior design.
Healthcare Website Remediation
XO is fortunate to focus in the healthcare industry, and we’re helping organizations audit and remediate their digital properties to conform with the new guidance.
This is specific to FQHC’s for now, but that won’t last. Any organization that is open to the public will likely face similar regulations in the near future, and even private organizations will feel the pressure to hit conformance as the rest of the world gets better at this.
You can see one of our clients going through this process, Virginia Garcia Memorial Health Center. We build all our sites with the foundations of AA Accessiblity, so getting across the line to full conformance is a reasonable path.
Virginia Garcia Health
Website Refresh Design & Build
Yes we care. But do we act?
I assume you care, that’s why you’re reading this. But I bet you’re like many of our clients, and like us before we started going down this path, where you just don’t know what to do about it or how to think about it. So let’s start that learning here.
The Government Standard: The VPAT
The term VPAT (Voluntary Product Accessibility Template) sounds like a piece of dense, bureaucratic jargon—and to be fair, the document itself can be quite dry. But for any organization aiming for a “barrier-free” digital presence, the VPAT is the most important map you’ll ever use.
Think of it as the “Nutrition Facts” label for your website’s accessibility. It tells the world exactly what’s inside, what’s missing, and how healthy the experience is for users with disabilities.
What is a VPAT, Exactly?
A VPAT (Voluntary Product Accessibility Template) is a standardized form used to document how a digital product (like a website, app, or software) meets specific accessibility standards—most commonly the WCAG 2.1 or 2.2 (Web Content Accessibility Guidelines).
Once an agency like XO completes a VPAT by auditing a site, the resulting document is called an ACR (Accessibility Conformance Report).
- The “V” is for Voluntary: While no one forces you to fill out the template, most government agencies, healthcare systems (like FQHCs), and large enterprises won’t buy your services or partner with you unless you have one.
- The Goal: It provides a transparent, point-by-point breakdown of how your site handles things like screen readers, keyboard-only navigation, and color contrast.
How to Read a VPAT (The Three Pillars)
When you look at an Accessibility Conformance Report, you’ll see a long list of “Success Criteria.” For each one, the report will assign a status:
- Supports: The site fully meets the requirement (e.g., all images have descriptive alt-text).
- Partially Supports: Some parts of the site work, but others fail (e.g., the homepage is accessible, but the checkout portal is not).
- Does Not Support: The feature is completely inaccessible to certain users.
The XO Point of View
A VPAT is often treated as a “pass/fail” test. We prefer to think of it as a usability roadmap. A site that “Supports” every criterion on paper but is frustrating to navigate isn’t truly accessible. We use the VPAT as a key part of a roadmap, not a final certificate. Even XO is working on our roadmap, it’s something we all need to do.
Why Your Clients (and Legal Team) Care
If you are a service provider, especially in the public sector or healthcare, the VPAT is your “license to operate.”
- Procurement: Many organizations are legally required to only purchase “accessible” software. If you make software and can’t provide an ACR, you might be disqualified from the RFP before the conversation even begins.
- Liability Shield: While a VPAT isn’t a “get out of jail free” card for ADA lawsuits, it demonstrates a “good faith effort.” It shows that you are aware of your site’s status and have a plan to address gaps.
- The FQHC Deadline: For entities under the new HHS rulings, the VPAT is the primary way to prove to regulators that you are meeting the May 2026 compliance milestones.
How to Think About It: A Living Document
The biggest mistake a brand can make is treating a VPAT as a “one-and-done” task.
Websites are organic. You add new blog posts, change button colors, and update plugins. Every time you change the site, your accessibility status shifts. We encourage our clients to think of the VPAT not as a static certificate, but as a baseline for continuous improvement.
Summary: The VPAT Checklist
If you’re starting from zero, here is the sequence:
- The Audit: A professional team (like XO) tests your site against WCAG standards.
- The Template: We fill out the VPAT based on the audit findings.
- The ACR: The completed document is published, showing your current level of compliance.
- Remediation: We use the “Does Not Support” sections of the report as a punch-list for design and development fixes. We help you put a roadmap together to remediate issues, according to your timing and budgets
Ready to start?
Brand
Accessibility is simply great design made achievable. Connect with the XO team to see how we can help you support your entire audience through a thoughtful, craft-led approach to inclusion.
