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Disproportionate burden statement

Find out which of our websites we are checking for accessibility issues and which we are not, and our reasons for this.

Health Education England is committed to meeting the requirement to make websites accessible, set out in The Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018 ("the accessibility regulations"). 

However, our work covers more than 100 programmes from planning and commissioning, to recruiting and developing healthcare staff in a range of healthcare and community settings.  We also have a vast, complex collection of more than 120 websites, many of which we inherited from other organisations, and have limited resources to check them all for accessibility issues.  

Our approach to carrying out accessibility checks

We've decided to use a combination of methods, as set out in the GOV.UK guidance on deciding how to check your websites and in compliance with the accessibility regulations. 

Detailed checks

We're doing a detailed accessibility checks for:

We call these our ‘main websites’.

The process for doing a detailed check will include:

Please note: our manual testing will also include users with disabilities and impairments, who may be using assistive technology such as screen readers. 

We believe it is reasonable to carry out a detailed check for our main websites, as this covers the most important web-based services provided by Health Education England. 

Our accessibility statement for hee.nhs.uk covers problems we found for our main websites, our plans to fix them and any issues it would be a disproportionate burden to fix at this time. 

Basic checks

We will carry out basic accessibility checks on Health Education England websites that are independent of our main websites.

These basic checks will be carried out by the team responsible for the website, based on:

Teams will check samples of content, which may include

  • their homepage
  • content pages that are mostly text based
  • images, video and audio content
  • interactive tools and transactions, like forms
  • pages including login functionality, if the website has them
  • PDFs and other document types they publish
  • dynamic content like pop-up windows
  • navigation pages, including their sitemap and pages with search functionality

Where possible accessibility statements for these websites will be published independently of hee.nhs.uk, on the websites in question.

Disproportionate burden assessment

We believe that our approach to carrying out accessibility checks is reasonable but means that we will not do detailed accessibility checks on all of our websites.  This might mean accessibility issues on some of websites are not fixed.

However, the accessibility regulations say that we do not need to make a website accessible if doing so would impose a disproportionate burden on us.  We believe that carrying out more detailed checks and fixing documents, beyond what is set out above, would be a disproportionate burden.

You can read why we consider this to be a disproportionate burden.

Please note: While this assessment explains our corporate position on disproportionate burden, some services may still choose to carry out a detailed check themselves, or pay for one if they are able to budget for it.

Checking websites

Our most important content and transactions are provided on our main websites. We're doing detailed checks of these. 

However, we do not believe the benefit of paying an auditor for detailed checks of our other websites would justify the impact on us except where those sites are specifically aimed at people with a disability.  

Checking documents 

We've also assessed that it would be a disproportionate burden to fix all documents published on these websites since 23 September 2018. 

The majority of these documents are rarely viewed, therefore they are unlikely to be negatively impacting users with disabilities or impairments. For this reason, we don't believe the cost of time, effort and resource to fix all the documents is justified. 

We will focus on fixing the most-viewed documents on these sites (top 5%), and ensuring that new documents are accessible where they are required for essential services or specifically address the needs of, or are meant for, persons with disabilities. 

Types of website and documents 


Health Education England has more than 120 websites independent of its main websites. 

These websites vary in purpose, size and content. Some are hosted by us; others are hosted and maintained by external suppliers, and managed and paid for by an individual HEE service, programme or directorate. 

Most of our independent sites are relatively small in scale, usage and complexity, and do not provide essential services or specifically address the needs of, or are meant for, persons with disabilities.

Examples of these sites include: 

  • National School of Healthcare Science (500 pages) facilitates and supports the education, training and development of healthcare scientists
  • Genomics Education Programme (600 pages) delivers genomics education, training and experience for the healthcare workforce
  • Step into the NHS (250 pages) provides careers information and advice on the range of career opportunities, including finding work experience and jobs.
  • Mouth Care Matters (200 pages) a hub for resources, training and information relating to educating patients on the health benefits associated with oral health.


As of 2 September 2020, there were 855 documents on our main websites published since 23 September 2018 (within scope of the accessibility regulations), however if you consider our entire web estate there would be many thousands of historic documents created by the organisation.

Focusing on fixing the top 5% most viewed documents on our main websites is equivalent to about 45 documents.

Estimated costs

Paying for detailed audits

We have estimated the costs for an external expert to do a detailed check (and later re-audit) on our full collection of over 120 websites. This is assuming:

  • Our main websites are excluded (as they're getting a detailed check done anyway)
  • 70% of our websites were considered "small" and 30% were considered “large” by an auditor

On the basis of these assumptions, we estimate the cost to our organisation overall for detailed audits for all of our websites would be between £343,200 and £1,263,600

These costs are based on estimates from GOV.UK's guidance on deciding how to check your website and getting an accessibility audit. These include:

  • a third-party day rate of £1,300
  • about 1 to 3 days to audit a small website
  • about 5 to 20 days to audit a large website

Cost of fixing documents

It's difficult to know how long it would take to make every document accessible without first reviewing each one.  

Potentially each document would require several hours of work to be recreated in a fully accessible version. (estimated based on extensive experience of converting documents at between 2 and 30 hours per document, depending on length and complexity, plus any required sign-off, or subject matter expert involvement) 

However, if we use a conservative estimate of two hours to review and fix each document within scope, fixing all 855 would take 228 working days (based on a 7.5-hour working day at Health Education England).  

Assessment of costs and benefits

We believe that:

  • The size, resources and nature of our organisation mean that there are limited public resources available which must be managed appropriately and in the public interest to prioritise the delivery of essential services to the public
  • The costs of paying for detailed checks for all our websites and fixing all of the documents on our main websites would be a substantial burden on us and the public resources we manage
  • The benefit to users would be limited and their needs can be met in other ways
  • Therefore, doing detailed checks on all of our websites and fixing all documents on our main website would impose a disproportionate burden on us.

In reaching this decision, we have considered the following:

Our organisation’s size, resources, and nature

Health Education England (HEE) is a non-departmental public body to the Department of Health and Social Care. HEE exists for one reason only, using education and training to support the delivery of excellent healthcare and health improvement to the patients and public of England by ensuring that the workforce of today and tomorrow has the right numbers, skills, values and behaviours, at the right time and in the right place. We plan for, fund and oversee the delivery of the highest quality education and training, resulting in world class health professionals working together for the benefit of patients. As well as planning for and training our future workforce, we work alongside employers and other stakeholders to develop our current workforce. Precious public resources are limited for the delivery of this broad remit.

During 2020 we have also been forced to re-prioritise resources owing to the coronavirus (COVID-19) pandemic, ensuring business continuity of essential services. 

We have a long-term project, currently entering beta phase, designed to specifically address the rationalisation and reduction of the existing legacy web estate and make all of our websites accessible. This project will create a digital service that aims to replace the multiple website management systems with a single platform for all of our websites, including national, regional, local and programmes – like gov.uk or BBC.co.uk. Central to this service will be ensuring accessibility and a fully inclusive user experience. Redirecting resources away from this project, to complete detailed accessibility checks and fix documents on all legacy websites (which will eventually be replaced through this project), will delay the delivery of this Government Digital Service (GDS) approved, user-centric service.

We do not provide services that specifically address the needs of, or are meant for, persons with disabilities.  However, where appropriate we make reasonable adjustments for people who use our services.

The estimated costs and benefits for our organisation: accessibility checks

We believe the potential of paying the substantial costs set out above on audits (before we've actually fixed anything) is unreasonable and not a good use of valuable public resources.  It could also have an impact of the delivery of the services themselves that the websites relate to.

Many of the teams that maintain sites independent of our main websites provide services to the NHS workforce, e.g. training and education programmes and resources.

We believe that:

  • maintaining these essential public services should be prioritised over paying for audits of our websites
  • it would be reasonable  for our services to carry out basic checks of their independent websites, and use any available budget to fix the main issues found on their sites

Our teams will be assisted in their basic checks by:

  • automated accessibility monitoring software (Sitemorse or Siteimprove).
  • internal guidance and support from our Communications Team

Our Digital Communications Team (DCT) is leading the detailed check of our main websites. However, the DCT is a small team, and the scale of co-ordinating the auditing and fixing of our main websites leading up to 23 September 2020 - in addition to their other essential functions - means they lack the capacity to carry out a detailed audit of our other sites.

The Health Careers Team (HCT) is leading on the detailed check of healthcareers.nhs.uk.

The estimated costs and benefits for our organisation: fixing documents 

The vast majority of this work would have little to no benefit to users with disabilities due to the low usage of the majority of online documents. 

The estimated benefits to users

Our users with disabilities will benefit from us making our websites and online documents accessible.

For our main websites, we already undertaking detailed accessibility checks, fixing the most accessed documents, and ensuring that new documents are accessible where they are required for essential services or specifically address the needs of, or are meant for, persons with disabilities.  This focuses our accessibility improvements where they will provide the most benefits to people with disabilities.

However, for the majority of our websites, we do not believe that the limited additional improvements that could be gained from detailed checks or more document fixes would justify the substantial costs of doing so. 

How to request content in an accessible format

If you need information in a different format contact us and tell us: 

  • the web address (URL) of the content 
  • your name and email address 
  • the format you need, for example, audio CD, braille, BSL or large print, accessible PDF 

We’ll consider your request and get back to you as soon as possible. 

Last updated

This assessment was last updated on 22 September 2020.