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Building a Program with Two FTEs and a Full-Audit Proposal

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Building a Program with Two FTEs and a Full-Audit Proposal

A 5,000-employee retailer has no accessibility program. It has 60 public web pages, a mobile app, 300 stores with self-checkout kiosks, and $80 million in annual procurement spend. Legal has one ADA complaint about a store ramp; HR handles ad hoc accommodation requests. The new VP asks for a 12-month plan with 2 full-time employees and $250,000. Consultants propose a full WCAG audit of all digital properties first.

1. How should the VP sequence the 12-month plan, and why is a full digital audit first a poor fit?

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A full audit of 60 pages, an app, and 300 kiosk environments would consume the budget before the organization builds capacity or fixes anything. Sequence by risk and leverage. Months 1–2: inventory digital properties, stores, and procurement; resolve the ramp complaint; establish an owner and cross-functional council. Months 3–5: assess high-impact customer journeys-find a store, check out, apply for a job, request an accommodation-using manual and assistive-technology testing. Months 6–9: fix priority defects, create a design-system accessibility baseline, and add procurement requirements. Months 10–12: train content and store teams, publish an accessibility statement, and set a repeatable test cycle. Defer exhaustive auditing until the remediation and governance process exists.

2. What governance and procurement moves would create durable change with only 2 FTEs?

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Use governance to multiply limited staff. Create a cross-functional accessibility council with representatives from digital, stores, HR, legal, procurement, and customer service. Assign product and store owners accountable for fixes in their areas. In procurement, add mandatory accessibility requirements to RFPs, require conformance reports and evidence, test critical flows before award, and include contract remedies. For the 300 stores, standardize kiosk requirements and staff-assisted alternatives rather than inspecting every unit manually. Publish an intake and escalation path so accommodation requests and complaints feed the program. Two FTEs should coordinate, set standards, and verify-not personally remediate everything.

3. Which metrics would show whether the program is working?

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Use outcome and leading indicators, not violation counts alone. Outcomes: successful completion rates for priority journeys by disabled users, reduction in accessibility-related complaints and accommodation escalations, and time to resolve reported barriers. Leading indicators: percentage of new procurements with accessibility requirements, percentage of priority digital properties tested each quarter, design-system components meeting the baseline, and training completion for content and store staff. Track store kiosk issues and assisted-service usage. Include a small number of user-testing participants with disabilities each quarter. Report trends to the VP with owners and due dates, so the metrics drive remediation rather than an audit score.