At a Glance Vendor Status
Why this matters: Courts have consistently held that organizations cannot outsource their accessibility obligations. If EveryAction’s donation form traps a keyboard user, or ApplyToJob’s cookie banner blocks a screen reader, Laradon is the defendant — not the vendor. The only vendor that can currently document compliance is FreeWill.
Under the "non-delegable duty" doctrine, Laradon is legally responsible for every tool embedded on its site — even vendor-built ones. Only one of five vendors (FreeWill) can produce a valid VPAT. The rest represent compounding legal and accessibility risk.
"No covered entity shall discriminate against a qualified individual on the basis of disability in regard to… contractual or other arrangements or relationships."
Detail Vendor-by-Vendor Analysis
No accessibility mention on their site. Same Elementor bugs on their own homepage. Delivered
lorem ipsum to production. No skip nav,
broken contact links, inaccessible navigation — all within their scope of work.
Action: Review MSA for potential breach of contract. Add a11y acceptance criteria to all tickets. Require regression checklist. Quarterly automated scan + annual manual audit.
EveryAction (Bonterra) — Donation Forms
Wrong VPAT
Bonterra claims WCAG 2.0 AA for Apricot (case management) —
not for the EveryAction donation forms Laradon actually uses. FastAction loads repeated modals on the
Donations page. Errors not announced to screen readers. Neither audit tool could inspect the iframe contents. Gap between claimed 2.0 AA and required 2.1/2.2 AA.
Highest vendor risk — donation flow is inaccessible + no valid VPAT
Action: Request VPAT for the specific EveryAction donation product. Require remediation roadmap as a condition of contract renewal. Provide a fallback accessible path (e.g., phone donation).
Model vendor. Comprehensive documentation + published accessibility statement (WCAG 2.1 AA+).
Strategic advantage: publicly linking to FreeWill's a11y statement demonstrates "good faith" in vendor selection — a key defense under
CO HB21-1110.
Action: Fix HTTP→HTTPS link (currently http://freewill.com/laradon). Use as model for future procurement language.
Known heading/landmark issues. Generates complex DOM structures. Limited keyboard support in widgets.
Their own docs acknowledge a11y issues.
Action: Consider Ally plugin. Ensure developer overrides Elementor defaults where needed (headings, ARIA, focus).
ApplyToJob — Job Applications
Unknown VPAT
Cookie banner on
Careers page traps keyboard focus. Form fields lack
<label> elements. ADA Title I intersection — employment discrimination compounds the web accessibility exposure.
Action: Request VPAT immediately. Evaluate accessible alternatives. If no VPAT, document risk and timeline for replacement.
EdTech Compound Failure Risk
Accessibility failure can compound across three layers for Laradon's students:
1
Website
43 barriers documented in this audit
2
Learning Tools
Unknown — no VPATs collected from EdTech vendors
3
PDFs
IEP documents, policies, annual reports, the ADA/Title VI plan itself
7 PDFs untested; ADA/Title VI plan PDF returns 403 error
Every touchpoint: A student with IDD may encounter barriers at every digital touchpoint, not just the public website.
n2y / Unique Learning System (ULS) — widely used in special education — should be investigated. If a vendor can't provide a compliant VPAT, Laradon must document an
"EEAAP" under
Section 504.
Governance Vendor Contract Recommendations
1
Require VPAT / ACR from all vendors
Not a marketing claim — a document mapping to specific WCAG criteria.
2
Add contract language
Require remediation timelines and AT-tested regression prevention.
3
Establish fallback accessible paths
When third-party components fail (e.g., phone donation, accessible form alternative).
For Point A Solutions: A11y acceptance criteria in all tickets · regression checklist for templates · quarterly automated scan + annual manual audit · contract review — if the MSA stipulates industry standards, delivering lorem ipsum + basic WCAG violations may constitute breach of contract and provide leverage for remediation at vendor's cost.