Scope
As of September 2018, accessibility legislation states that public sector websites must adhere to the Website Content Accessibility Guidelines (WCAG) 2.2 AA.
This document outlines the reasons why achieving full compliance with the Web Content Accessibility Guidelines (WCAG) 2.2 AA standards on the website www.kentandmedway.icb.nhs.uk would place a disproportionate burden on NHS Kent and Medway.
Organisational context
NHS Kent and Medway are the NHS organisation that plans and buys healthcare services to meet the needs of the 2 million people living in Kent and Medway. We have an annual budget of around £4.2 billion in 2023/24 to provide the best possible care for the whole county.
NHS Kent and Medway exists to improve health and healthcare for the people of Kent and Medway.
We do this using influence and partnership to lead the NHS to find ambitious, collaborative solutions to long-standing issues and inequalities, driving innovation and transformation.
We represent the NHS in Kent and Medway in the national NHS.
Disproportionate burden assessment
Financial burden
Currently, we are in the process of procuring a new website, which is expected to be completed by August 2025. Upgrading the existing website to meet WCAG 2.2 AA standards would incur significant costs that are not financially viable. The current website is outdated and near the end of its lifecycle, and investment in major updates to ensure accessibility would not represent an effective use of resources, given the upcoming procurement.
The cost to bring the current website into compliance would divert funds away from the procurement of the new website, which will be designed and developed to fully meet accessibility standards.
Time and resource constraints
Updating the existing website to meet WCAG 2.2 AA standards would require extensive time and resources. This includes auditing the site, implementing fixes, testing accessibility, and training staff. Given that the current focus is on the procurement and development of the new website, devoting significant resources to updating a temporary platform would hinder our ability to deliver the new site on schedule.
The time required to make changes would also delay other critical projects that support the needs of our users. The procurement process has been prioritised to ensure that we can deliver a long-term accessible solution as soon as possible.
Proportionality
Given that the current website will be replaced in less than eight months, the cost and time required to achieve full compliance would not be proportionate to the short-term benefit. Instead, our resources are being directed towards ensuring the new website fully adheres to accessibility regulations.
Steps taken to minimise the impact
Although we have determined that full compliance would be a disproportionate burden, we are committed to taking reasonable steps to minimise the impact on users with disabilities. We do this by:
- Providing alternative ways to access information, such as by phone, email, or in-person services.
- Addressing specific accessibility issues brought to our attention where feasible.
- Ensuring that the new website is developed in full compliance with WCAG 2.2 AA standards.
Timeline for compliance
We anticipate that the new website will be launched by August 2025. This website will be fully compliant with WCAG 2.1 AA standards, ensuring accessibility for all users.
Roadmap 2025
Phase 1 – Planning January - February |
Phase 2 – Discovery March - April |
Phase 3 - Build and content May - July |
Phase 4 Testing and launch August |
Develop website specification |
User feedback and engagement |
Design and build |
Final testing |
Issue Invitation to Tender notice |
Sitemap |
Content development |
Final user testing |
Supplier interviews |
Wireframes |
Feedback and engagement |
Launch |
Review of this assessment
This disproportionate burden assessment will be reviewed regularly and updated as necessary. We are committed to ensuring compliance with accessibility regulations as soon as reasonably possible. Date of last assessment: 10 January 2025.
Contact information
If you experience any difficulty accessing our content or services, please contact us at kmicb.engagecomms@nhs.net