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Voices: Thomas Lavallee, Senior Director of Compliance, G5

This article is sponsored by G5. In this Voices interview, Senior Housing News sits down with G5 Senior Director of Compliance Thomas Lavallee to learn the top ways owners and operators can implement and maintain accessibility on the web. He also shares insights into the risks and challenges associated with navigating accessibility, plus best practices for staying ahead of the rapidly changing guidelines for online marketing to the aging population.

Senior Housing News: Can you give a brief overview of your career path and what you draw from most in your current role as senior director of compliance for G5?

Thomas Lavallee: I started my career as a project manager in the heavily regulated field of finance, then transitioned into corporate litigation with several large financial institutions among my clients. Most recently, I started with G5 nearly six years ago where I’ve been able to combine my business operations experience with my legal expertise to help guide the company through the recent evolution of fair housing, data privacy, cybersecurity, and digital accessibility — all of which are now critical aspects of digital marketing in our industry.

Some organizations have taken a head-in-the-sand approach to website accessibility or simply don’t know what they need to do. Can you provide a general overview of website accessibility and explain why it is important?

Lavallee: Yes. Thank you for that question because this is a complex topic that I would like everyone reading to become familiar with. Fundamentally, when we build websites, we want to reach as many people as possible, and this should include the estimated 20% of people who have some type of disability. For your digital marketing to be efficient and inclusive, it needs to be accessible.

Now, on the legal side, it’s currently unsettled in the United States whether the Americans with Disabilities Act (ADA) applies to websites. The level of accessibility needed for your website is also not clear. The courts are divided on this and state laws can also have an impact. From a legal perspective, we just don’t have a lot of clarity right now and we’re seeing certain law firms exploit this gap through lawsuits and demand letters

What this means for senior housing is that if you’re not accessible, you’re missing a chunk of your audience. It also puts you at risk of being sued for allegations that your website doesn’t meet current industry standards for accessibility. Senior housing hasn’t been hit too aggressively by this yet, but I want to be clear that this risk is very real.

The most recent information shows there were over 3,500 website accessibility lawsuits filed in the U.S. last year. It’s also estimated that plaintiff law firms sent another quarter-million settlement demand letters on this topic, seeking attorney’s fees last year. This topic is very important, and we want everybody today to be aware of the benefits associated with maintaining accessible websites and the risks of failing to do so.

The W3C Web Accessibility Initiative creates web content accessibility guidelines and updates them periodically. What’s the latest? and what do providers need to know?

Lavallee: The latest on Web Content Accessibility Guidelines, or WCAG, is that we’re still working with three different levels: A, AA, and AAA. These are increasingly difficult to meet from an accessibility standpoint, with Level A being the least strenuous of the three. The focus in Level A is primarily on the website code to ensure compatibility with different types of accessibility tools that folks will be using. Visually, it is difficult to differentiate a site that meets Level A requirements versus one that does not. Most of the work is under the hood in the code of the website.

Level AA then adds criteria on top of this. These additional criteria are focused on the aesthetics of the website. Level AA websites will likely look different from Level A websites because they’ll have larger fonts, as well as better contrast ratios between texts, images and background colors. The goal here is to make it easier for a person with mild visual impairments to interact with the website. Then we go all the way up to level AAA, and this is a severe standard. AAA is not recommended for websites that are targeted for marketing or lead generation.

To make things a little bit more complicated, there are also different versions of WCAG, and these versions are updated from time to time. Right now, the most current version is 2.1. We expect iteration 2.2 to come out this summer, followed by a big update from WCAG in early 2022 — that’ll be version 3.0. We have a lot of known quantities for WCAG, but when you’re trying to meet these requirements, you have to keep looking forward to what’s coming down the pipeline.

What are some of the risks involved in not having a comprehensive approach to website accessibility in a senior-focused market?

Lavallee: There are three big ones. The first is that you’re not going to reach as wide of an audience. You’ll miss out on a significant portion of the population if you don’t have an accessible website. Two —and this is something that’s often overlooked — is that website accessibility can have a positive impact on your search engine optimization. If you’re not focused on this, it’s going to be harder for people to find your website when they search for it.

Third — and this is the one I’ve focused on quite a bit as an attorney — is that you’re increasing your risk of receiving an accessibility demand letter or being pulled into a lawsuit. This risk is very real. I’ve talked to a few different senior housing owners and operators who remember being pulled into cases where someone would drive by a property and file a suit or send a letter claiming the physical structure didn’t comply with the Americans with Disabilities Act.

Some would argue that many of these suits don’t have merit, but at the end of the day, they are still frustrating and expensive to deal with. The same risk exists with website accessibility, except the term we’re using now is called “surf-by.” An attorney surfs by your website and then makes similar, meritless allegations, filing lawsuits or sending letters based on a failure of compliance. You’re exposing yourself to risk by not having an accessible website and it makes you vulnerable to the frustrations and costs associated with these surf-by lawsuits.

How do you help senior living companies with website accessibility and compliance in your role specifically with G5?

Lavallee: At G5, we are a very accessibility-focused company. We launch all websites to materially conform with current WCAG Level A standards. We also launch sites at Level AA for any of our customers who request that. Additionally, we can perform ongoing monitoring services where we check to see if there have been changes to the sites, integrations or technologies.

We do the work, keeping the site up to date and in conformance with standards. More importantly, when the versions change, we bring sites up to the most current standard. As we see W3C issue new standards more frequently, it will become increasingly important to stay on top of this.

I also want to point out that we approach website accessibility through a collaboration of our product, engineering, design and implementation teams. We’re not just slapping a widget on your site and pretending that alone makes it accessible, because it doesn’t. That’s a whole separate topic I could talk about in a different interview. Accessibility needs to be built into the core of your product, process and people. It can’t just be an afterthought, and that’s what we bring to the table with our compliance perspective at G5.

Can you share a few best practices when it comes to website accessibility and compliance?

Lavallee: When you launch your site, you want to meet WCAG standards right out of the gate. Don’t rush to publish an inaccessible site with plans to get it there later. You’re exposed to risk the entire time you’re doing that, and you’re not reaching as many people as you could if you don’t focus on accessibility right away.

To do this, you want to make sure you work with your website service provider to ensure you’re launching at that standard, and checking in on a regular basis to ensure that you’re meeting these standards. You also want to have access to those records that show a history of your efforts to meet WCAG standards.

If you do receive one of these surf-by demand letters, this type of history shows that you had good intentions to begin with, and that you stayed on top of accessibility on an ongoing basis. This creates a healthy paper trail that evidences your commitment to accessibility and potentially makes that demand letter or lawsuit go away.

Finally, I think putting an accessibility statement on your website often gets overlooked. This is a short statement telling visitors that this topic is important to you, and that you’re striving to make your website a welcoming place for people of all abilities.

With websites being dynamic, how can marketers stay up to date with their accessibility measures? What kinds of systems can they use to help stay on top of updates?

Lavallee: When evaluating website service providers, it is important to ask questions about this. Honestly, they should be doing the work for you. The technical requirements of this subject continue to evolve and the service provider needs to be your subject matter expert.

Despite what some companies are advertising, there’s no current system that alone can ensure your website is accessible. There are too many nuances in website code and load times. There are also over 160 different accessibility scanning tools that provide varying results to let you know if your website meets WCAG criteria or not.

Unfortunately, the result is that trying to go at it alone is quite tricky. The best advice I could share today is that accessibility takes a combination of both people and technology to ensure you’re conforming with requirements. You want to maintain your relationship with your website service provider to stay on top of this.

No one really knew what to expect coming into the year. What is the biggest surprise in terms of senior living marketing? And what will be the impact of that surprise for the remainder of the year?

Lavallee: This past year has been something else. It has dramatically changed the way that we see seniors interacting with technology. They’ve been forced to adopt different technologies that they weren’t previously comfortable with to do everything from grocery shopping to banking to researching senior living communities. This has been, in essence, a paradigm shift, and we don’t expect this trend to reverse course.

We now have a group of seniors that are more tech-savvy. They will expect to continue to do everything online, and that makes website accessibility all the more important.

Lastly, we’ve seen a massive increase in virtual tours. We want to make sure our accessibility adjustments aren’t just applied to static website elements or forms. We want to make sure that we’re doing this to create an inclusive experience because we see this shift continuing as well. People are going to rely more and more on that immersive digital experience to make a decision on where they’re going to move.

Editor’s note: This interview has been edited for length and clarity.

G5 is the leading digital marketing software and services platform for senior living communities. To learn more about G5 and website accessibility, watch this recent webinar from July 2021.

The Voices Series is a sponsored content program featuring leading executives discussing trends, topics and more — shaping their industry in a question-and-answer format. For more information on Voices, please contact

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