Disproportionate burden statement

Find out how we’re checking our website for accessibility issues and what we consider to be a disproportionate burden


This website is run by South Central Ambulance Service NHS Foundation Trust (SCAS). We are committed to meeting our legal obligations set out in The Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018 (“No. 2 Regulations”). However, we have a complex collection of online service information and limited resources to check them all for accessibility issues. You can read our approach to checking our website, and how we’ve assessed what we consider a disproportionate burden.


Reporting accessibility problems with this website


We’re always looking to improve the accessibility of this website. If you find any problems not listed on this page or think we’re not meeting accessibility requirements, please contact: PatientExperience@scas.nhs.uk


What we’re doing to improve accessibility


We are working to improve accessibility on this website. Internally we have created an ‘Accessibility Hub’ training site on our intranet with templates, instructions and video guides. This has been communicated to all staff who are expected to produce accessible material going forward. We have also carried out extensive staff training to our small team of web editors and implemented processes to ensure that documents we produce are easier to navigate. We are also working closely with our Network Accessibility Lead to further improve our site in the future. We have trained our staff to add alternative text to all images on our website.


Our approach to carrying out accessibility checks


SCAS does not have the resources in-house to carry out accessibility checks, so the role of analysing and fixing technical issues is outsourced to our third party web hosting company. The process for doing these checks includes a combination of manual testing and automated-testing using accessibility monitoring tools. Our accessibility statement will cover problems any we find, and our plans to fix them.


Website: Navigation and accessing information


The SCAS website covers a variety of purposes and content types. It is hosted by our appointed hosting provider; other elements are third party hosted and maintained by external suppliers, managed and paid for by an individual Trust service or directorate.

We recently commissioned an external web design agency to help improve the html code for this website so that it is more accessible, however, our website code is not fully accessible at the moment for the following reasons:

Keyboard (WCAG 2.1.1)

– Some links under ‘Latest News’ cannot be accessed using the keyboard.
– The back to the top button is not accessible using the keyboard.
– The search magnifying glass icon is now not accessible using the keyboard. It does not open the same way as the mouse.
– At 200% zoom, links within the hamburger menu are not accessible using the keyboard.

This is a problem with the plugin used by the website developer and, unfortunately, our web hosting company is unable to resolve this.

Parsing (WCAG 4.1.1)

This ID appears twice in the website code: =”wpa_label_s” (once in the mobile navigation and once in the desktop navigation due to the way the website developer has added it).

Info on parsing: In content implemented using markup languages, elements have complete start and end tags, elements are nested according to their specifications, elements do not contain duplicate attributes, and any IDs are unique, except where the specifications allow these features. (Level A).

Every site currently must conform as much as possible to WCAG 2.1 standards and there is a process in place for WCAG 2.2 to be released in August 2023. Information about how parsing is being removed as an issue: www.w3.org/WAI/WCAG22/Understanding/parsing.html.



Estimated costs to resolve


In order to reach a complete for these existing issues we would have to redesign our website using a different operating system and costs could be as high as £30,000. The financial cost of correcting these outstanding issues on scas.nhs.uk would be a disproportionate burden on our organisation at a time when there are significant financial challenges.

We have therefore noted these issues so that when we replace our current website in 2026 we will make sure that these are addressed and overcome at the planning stage.

We have also made a formal request to the developers for the plugin which is responsible for the inaccessible error. We are hopeful that they will update their software to conform to AA regulations at some point.

With regards to parsing specifically, we have thoroughly considered the upcoming changes in the Web Content Accessibility Guidelines (WCAG) 2.2 that may lead to the removal of parsing requirements. After careful evaluation, we have decided not to prioritise immediate changes to parsing implementation due to its potential upcoming changes.

The decision to retain parsing in our accessibility initiatives has been made based on several factors. As WCAG 2.2 may no longer mandate parsing, we recognise that dedicating resources to its immediate resolution may not yield significant long-term benefits. Moreover, modern web technologies and evolving assistive technologies have advanced considerably, reducing the dependency on parsing as a critical accessibility mechanism.

It is essential to clarify that while we are not actively addressing parsing in our current accessibility efforts, our commitment to creating an inclusive user experience remains unwavering. Our focus has shifted towards implementing other accessibility best practices and ensuring our digital content is accessible to all users, regardless of their abilities.

We acknowledge that technology and accessibility guidelines are continuously evolving, and we will remain vigilant in adapting our practices to align with emerging standards and user needs. As we move forward, we will keep a close eye on industry developments, and if the importance of parsing is reaffirmed or new compelling use cases arise, we will reassess our approach accordingly.

Cost breakdown:

  • Cost to redevelop the site and make it 100% accessible: Between £20k and £30k.
  • Cost to run full accessibility check on current site annually: Between £4k and £6k.




SCAS has completed a major web accessibility project which looked at all of our online PDF documents in order to bring all our polices, procedures, strategies and research documents in line with the accessibility regulations. This involved the creation of templates that our internal departments now use for their future documents.

However, we remain unable to comply with our board papers. These PDF documents regularly contain hundreds of pages which contain scanned images and large reports that have been sourced from multiple departments and agencies. They are also complied and uploaded only hours before they are legally required to be available to the public, so a delay would risk a fine or a cancelled public meeting.

The cost of converting these documents would be significant and is not financially justifiable. Instead, we advice all interested parties to contact company.secretary@scas.nhs.uk to talk through any information that might be required as an alternative.


Estimated costs to resolve


The resource and financial cost of making our Board Papers accessible on scas.nhs.uk would be a disproportionate burden on our organisation.

SCAS is managing unprecedented frontline service demands with annual budgets under continual pressure. The content for the website is carried out in-house within the communication team at the current time with limited web resource. The scale of co-ordinating the auditing and fixing the main website fully would be difficult to achieve in addition to their other essential functions and would therefore come at an additional cost.

SCAS does not currently benefit from any allocated budget or resource that supports website technical development, coding or any enhancement other than basic hosting services.

A regular 350 page Board Paper would cost £5,705 to be adapted but receives only around seven views per report on average. The annual cost would be in excess of £30k.

The organisation, however, does provide services aimed at people with a disability, and these are generally very well supported through our patient experience teams who have access to specialist services and support (e.g. BSL sign language and interpreters).

Under current financial constraints, payment to an external agency to make board papers accessible is not justifiable over other essential service requirements.

All of our users will benefit from us making our website and online information accessible, so focusing our limited resource on maintaining the most-used accessible content on scas.nhs.uk and ensuring that new documents are accessible where they are required for essential services or used by people with disabilities is our priority in the interim period.

Updated 31 July 2023