R&D notes

Verifying the Disability Equality Index

Jonathan Robert Pool

Accessibility scores for 272 web pages of DEI winners


A new analysis reveals wide variation in conformity to web-accessibility standards by organizations that have won high scores on the Disability Equality Index (DEI). That is not a surprise, since the DEI is based on self-reporting by organizations, not measured performance.


The Disability Equality Index (DEI) is a measure of disability inclusion and equality in organizations in the United States with 500 or more employees.

Organizations that choose to participate in the DEI complete a questionnaire and, on the basis of their answers, receive scores. If their scores are 80% or more, their scores are published and they are considered DEI winners.

Some of the questions in the questionnaire deal with digital accessibility: the design and implementation of websites and other digital content to avoid barriers to use. Digital accessibility is covered by questions 3 through 7 of the 7 weighted questions in the Enterprise-wide access section of the DEI questionnaire, and that section contributes 10 points toward the total of 100 points. For example, question 4c asks the organization, please estimate the percentage of your entire externally facing digital products that are accessible.

Accessible content is essential for many people with disabilities. It also benefits users dealing with challenges such as poor lighting, small screens, and moving vehicles. Given this connection, do DEI winners actually have accessible websites?


In August 2022 I used the software packages Testaro and Testilo to measure the accessibility of the home pages of all 272 of the DEI winners for 2021.

The 1230 tests performed on those pages were created by Deque, IBM, Utah State University, Level Access, Siteimprove, Squiz Labs, Tenon, and individual contributors. Human testing was not performed, so the tests could not detect all accessibility problems, but thousands of problems were identified.

The results are shown in the following table.

Test results

In this table, the lower the score, the better. A score of 0 would indicate that a page passed all the tests. A perfect score is unlikely, though, because even suspected accessibility problems add small amounts to a score.

The first link on each row names an organization and its DEI score. That link will take you to the page that was tested. The second link gives the page’s accessibility score. That link goes to a detailed report explaining the page’s discovered or suspected defects and how the accessibility score was computed.

Accessibility scores of 2021 DEI winners
PageScore (lower is better)
Fifth Third Bank (100%)324
Grainger (90%)351
True Value Company (80%)523
Siemens Corporation (100%)552
Starbucks (100%)595
PPL Corporation (100%)598
Google (100%)602
The Walt Disney Company (100%)615
Centene Corporation (100%)684
Altice USA (90%)768
Walmart (100%)791
Stellantis (90%)801
Dominion Energy (100%)815
Northrop Grumman (100%)828
Microsoft (100%)861
American Water (100%)868
Snap (80%)869
American International Group (90%)878
Facebook (100%)897
UnitedHealth Group (100%)898
Simon Property Group (90%)917
Shelter Mutual Insurance Company (90%)927
TracFone Wireless (100%)974
Froedtert & The Medical College of Wisconsin (100%)1012
Sanofi US (90%)1014
RRD (80%)1015
XPO Logistics (90%)1037
Capital One (100%)1042
DXC Technology (100%)1053
Twitter (100%)1056
Teva Pharmaceuticals USA (90%)1058
Boston Scientific Corporation (100%)1065
Northwestern Medicine (90%)1070
Fox Corporation (90%)1090
TIAA (90%)1094
Blue Cross & Blue Shield of Rhode Island (90%)1115
Steptoe and Johnson (90%)1130
USAA (100%)1132
Cigna (100%)1142
ManpowerGroup (100%)1143
Numotion (100%)1172
Spaulding Rehabilitation Network (100%)1176
Experian North America (90%)1183
Barclays (100%)1185
Merck (100%)1204
Equitable (100%)1216
LinkedIn (100%)1221
TD Bank (100%)1230
General Dynamics (100%)1251
Withum (90%)1268
Salesforce (100%)1270
Southern Company (100%)1270
MITRE (100%)1277
Florida Blue (100%)1281
Lockheed Martin (100%)1287
Brown-Forman Corporation (90%)1303
Macmillan Learning (100%)1304
Exelon Corporation (90%)1327
CVS Health (100%)1348
CUNA Mutual Group (90%)1361
Fannie Mae (100%)1365
Eli Lilly and Company (100%)1366
Lincoln Financial Group (100%)1373
Indeed (100%)1375
Reed Smith (90%)1391
BNY Mellon (100%)1393
Trane Technologies (90%)1429
Chemonics International (90%)1445
The Coca-Cola Company (90%)1456
Ralph Lauren Corporation (80%)1470
Shepherd Center (90%)1473
Baxter International (90%)1499
L3Harris Technologies (90%)1502
Rush University Medical Center (80%)1508
Cargill (100%)1510
Yext (90%)1521
Epstein Becker Green (90%)1529
KPMG (100%)1542
Ultimate Kronos Group (100%)1545
Unisys (100%)1546
GE Healthcare (90%)1562
International Flavors & Fragrances (100%)1565
Wells Fargo (100%)1567
Fiserv (90%)1572
Delta Air Lines (100%)1573
Brown Brothers Harriman (90%)1576
Astellas Pharma US (100%)1579
Excellus BlueCross BlueShield (100%)1579
Adobe (100%)1616
American Airlines (100%)1618
Chevron (100%)1642
Children's Hospital of Philadelphia (100%)1651
Whirlpool Corporation (100%)1656
Mathematica (100%)1673
Voya Financial (100%)1676
Ernst & Young (100%)1677
Blue Cross Blue Shield of Michigan (100%)1683
Ameren Corporation (100%)1686
Argonne National Laboratory (90%)1691
Randstad US (100%)1693
Land O'Lakes (100%)1695
BD (90%)1696
Sony Electronics (100%)1726
NetApp (100%)1758
SAP America (100%)1764
Sodexo (100%)1788
JPMorgan Chase (100%)1806
Jacobs (100%)1812
Johnson Financial Group (90%)1824
Bristol Myers Squibb (100%)1826
M&T Bank (100%)1841
Brown and Caldwell (80%)1844
Unum (100%)1847
Gartner (100%)1853
Pearson (100%)1855
AMC Theatres (80%)1859
Nestlé Health Science (100%)1895
Compass Group USA (100%)1896
Nestlé Purina PetCare Company (100%)1899
Comcast NBCUniversal (100%)1909
Regions Bank (100%)1939
TEKsystems (90%)1940
Edison International (100%)1942
Verizon (100%)1943
Discover Financial Services (100%)1955
The Boeing Company (100%)1960
Uber (100%)1968
Highmark Health (100%)1981
CSX Transportation (90%)1984
Northwestern Mutual (100%)1990
Prudential Financial (100%)2038
GlaxoSmithKline (100%)2074
TDS Telecommunications (90%)2097
McKesson Corporation (100%)2098
3M (100%)2129
Charles Schwab (100%)2140
Nestlé USA (100%)2158
Principal Financial Group (100%)2214
Financial Industry Regulatory Authority (90%)2220
Anthem (100%)2223
Choice Hotels (100%)2242
Corning Incorporated (100%)2286
Blue Cross Blue Shield of Massachusetts (100%)2299
CBRE (100%)2324
Covestro (80%)2337
Visa (100%)2337
Health Care Service Corporation (100%)2338
Target (100%)2362
Bank of America (100%)2374
Boehringer Ingelheim (100%)2377
Biogen (100%)2392
State Farm (80%)2405
Alexion Pharmaceuticals (80%)2437
Citizens Financial Group (90%)2485
The Kroger Company (100%)2485
Expedia Group (90%)2541
State Street (100%)2548
General Motors (100%)2586
The University of Texas MD Anderson Cancer Center (100%)2597
Palo Alto Networks (80%)2607
Cox Communications (100%)2609
Ally Financial (100%)2632
Quest Diagnostics (90%)2673
Micron Technology (80%)2688
ZVRS and Purple Communications (100%)2703
Cintas Corporation (90%)2725
UScellular (100%)2725
Oracle Corporation (100%)2730
L'Oreal USA (100%)2761
BlueCross BlueShield of Tennessee (90%)2780
Old National Bank (100%)2810
BMO Harris Bank (100%)2815
Colgate-Palmolive Company (100%)2832
Procter & Gamble Company (100%)2835
Dow (100%)2837
Micro Focus (80%)2845
Novant Health (100%)2857
Best Buy (100%)2858
Jabil (100%)2907
Pillsbury Winthrop Shaw Pittman (80%)2908
Deloitte (100%)2953
U.S. Bank (100%)2978
United States Steel Corporation (80%)3013
Pfizer (100%)3023
AbbVie (100%)3049
CAI (100%)3065
Raytheon Technologies (100%)3097
The Hanover Insurance Group (80%)3110
JLL (100%)3119
Blue Shield of California (100%)3121
Caesars Entertainment (80%)3134
S&P Global (100%)3178
Chubb (90%)3185
Eaton Corporation (90%)3231
Dun & Bradstreet (100%)3275
Humana (100%)3275
lululemon (80%)3275
Mastercard (100%)3275
Northern Trust (100%)3275
PNC Financial Services Group (100%)3275
PwC (100%)3275
Thermo Fisher Scientific (100%)3275
United Airlines (100%)3275
Huntington Bank (100%)3275
Johnson & Johnson (100%)3291
Southwest Airlines (100%)3291
Qualcomm (100%)3358
Change Healthcare (90%)3374
ADP (90%)3388
Enel North America (80%)3398
Workday (80%)3406
Xcel Energy (90%)3431
Dell Technologies (100%)3441
Accenture (100%)3444
T-Mobile USA (100%)3460
Intel (100%)3469
Fidelity Investments (100%)3485
Lowe's Companies (100%)3517
Cubic Corporation (100%)3528
Travelers (100%)3529
Royal Caribbean Group (100%)3532
AT&T (100%)3539
Meijer (100%)3540
Deluxe (100%)3551
Pacific Gas and Electric Company (100%)3558
Booz Allen Hamilton (100%)3570
American Electric Power (100%)3581
Lenovo (100%)3587
The Hartford (100%)3626
Leidos (100%)3672
Airbus (90%)3695
Bayer U.S. (100%)3718
VMware (90%)3718
Goldman Sachs (100%)3755
Iron Mountain (90%)3941
Bank of the West (90%)3989
World Wide Technology (100%)3994
NVIDIA (100%)4052
UPS (100%)4066
Tufts Health Plan (100%)4141
Mayo Clinic (100%)4165
Synchrony (100%)4224
Ford Motor Company (100%)4239
Sony Interactive Entertainment (100%)4240
Grant Thornton (100%)4509
Baylor Scott & White Health (90%)4525
NIKE (90%)4581
Medtronic (100%)4734
Amazon (90%)4916
Kaiser Permanente (100%)4978
MassMutual (100%)4985
DuPont (100%)5004
Citrix (100%)5025
Ecolab (80%)5068
Lumen (100%)5225
RSM (90%)5234
Ameriprise Financial (90%)5332
Cummins (100%)5465
Franklin Templeton (80%)5577
DTE Energy (100%)6607
BAE Systems (100%)6750
HP (100%)6906
PepsiCo (80%)7454
Cisco Systems (100%)8253
Motorola Solutions (100%)8299
Walgreens (100%)9045
Hewlett Packard Enterprise (100%)12161
Marriott International (100%)12459
CDW (90%)20895
Airbnb (100%)24419
MetLife (100%)41082
Aramark (100%)119448

The range of accessibility scores is large enough to make proportionally sized bars impractical. So, the bars in the table are sized proportionally to the square roots of the accessibility scores as fractions of the largest accessibility score. If one bar is 2 times as long as another bar, the first score is 4 times as large (i.e. bad) as the other score.


Not a single home page was found that could not be made more accessible. For example, the page with the best accessibility score, belonging to Fifth Third Bank, contains several embedded web pages (in iframe elements). Each such embedded page needs to declare what language its content is written in, so blind or other users who are listening to the page by means of a screen reader will hear the correct pronunciation. But these embedded pages do not declare their language.

Moreover, among the DEI winners, the DEI score is not a good predictor of the accessibility score. The 80%, 90%, and 100% winners are found throughout the table. In fact, the 90% winners have the best median accessibility score. The medians are:

This weak association makes sense, given that:


This analysis discovered that the DEI winners publish web content with accessibility defects. Automated tests like these are not perfect and not complete, but they can discover and diagnose many accessibility defects at trivial cost.

DEI scores are not accurate predictors of digital accessibility. We therefore have reason to question whether organizations should reap reputational benefits from their DEI scores. Inaccessible websites create substantial risk of litigation, loss of reputation, and loss of market share.

DEI scores are based on what organizations claim. If they claim digital accessibility, they earn DEI points. But it is feasible to subject their public websites to accessibility testing and award points for real performance. So, why not do that, instead of believing the claims?