Skip to content

What the overlay order means for practice sites

The FTC has ordered an accessibility overlay vendor to drop its compliance claims. What to check in your practice footer, contract and booking path.

Three practice owners forwarded us the same link this month. The Federal Trade Commission has ordered one of the larger accessibility overlay vendors to stop telling businesses the product delivers compliance. The trade press is running it as an accessibility story. It is really a claims story, and that is what makes it a dental office’s problem, because the claim at the middle of it is sitting in a lot of practice footers right now.

We wrote last spring about why we take these widgets off sites rather than put them on. That reasoning has not changed. What has changed is that the sales pitch now has a regulator attached to it, so a practice still paying for one has two things to sort out instead of one.

What the order actually says

The order is not that overlays are illegal. It is about advertising. The product was sold as something that would bring a website into line with the Web Content Accessibility Guidelines automatically, from one line of code, with a certificate to show for it. The agency found that it did not do that, that the automatic fixes missed and mislabeled real things on real pages, and that businesses paid for a compliance outcome they did not get. The order also covers endorsements and reviews published without disclosing who was paying for them.

Read from the owner’s chair, it says two things to anybody running a practice site.

First, the widget was never a shield. That was already clear from the demand letters arriving at businesses that had one installed, but now it is on the record.

Second, if the vendor’s badge is in your footer, or you have a page saying your site is certified accessible, you are making that claim in your own name, to your own patients. The same agency’s rule on fake reviews and testimonials took effect in October. It is not an agency in the mood to treat a marketing claim as decoration.

Pull the paperwork before you pull the script

Before you touch the website, spend twenty minutes on what you bought.

  • Find the invoice. These run monthly per domain and they renew quietly.
  • Read the page the vendor sold you from, today. If the promise is compliance rather than assistance, that is the promise you have been passing on.
  • Read the support clause. “Litigation support” is not indemnity. Ask in writing whether they will defend you, who decides that, and what the limit is.
  • Look at your own footer, and any accessibility statement on the site. Anything claiming your site meets a standard either needs to be true or needs to come down this week.
  • Remember what happens when you cancel. The widget was covering for defects, not repairing them, so the defects are still there in the morning.

Spend the money on the three things patients come to do

A practice site has three jobs: book an appointment, fill in paperwork, and find out whether you take their insurance. Walk those three paths the way a patient using a screen reader, a keyboard or tired eyes would, and you will find everything worth fixing before anyone else does.

Booking. Unplug the mouse and book yourself in. Tab from the top of the homepage to the submit button. If your scheduler is an embedded third-party widget, tab into it, through it and back out again. Focus traps inside booking embeds are the single most common blocker we find on practice sites, and they are also why a patient gives up and calls someone else.

Paperwork. Health history as real form fields with real labels, not a scanned PDF and not placeholder text that disappears the moment typing starts. If the only way to complete your forms is to print them, that is the barrier, and it is costing you completed appointments as well as goodwill.

Insurance and fees. Check contrast on the actual list of plans, not on the marketing line above it. Then zoom the browser to 200 percent and read that page on a phone. Small grey text on white is the most common failure we find, and the people it fails are exactly the ones squinting at coverage details.

Around those three paths sit the template-level items we have written about before and still fix first on every site we take over: a focus outline you can see, alt text that describes the image, headings in order, link text that makes sense out of context, captions on the office tour video, and animation that switches itself off when the visitor has asked for less motion.

Make it part of how the site gets built

Practices end up buying a widget because accessibility gets treated as a project with a finish line. It is not one. Every new landing page, every seasonal offer, every quick change from a vendor puts the same defects back.

  • Put the checks in the build list, so no page goes live without labels, contrast and a keyboard pass.
  • Retest after any redesign, theme update or new scheduler.
  • Ask your booking and forms vendors, in writing, what standard their embed meets. Their answer is part of your exposure, not just theirs.
  • Keep a dated record of what you tested, what you found, what you fixed and when. A practice that can show a maintenance habit is in a very different conversation from one that can show a receipt.

What to do this month

  • Find out whether an overlay is running on your site. Check the footer and ask whoever built it.
  • Read the contract and the footer claim. Take down any statement that your site is certified or compliant unless you can back it up.
  • Do the keyboard test on the booking path and write down every place you lost track of the cursor.
  • Replace one scanned PDF with a real form this month, starting with new patient health history.
  • Fix contrast on buttons, the header and the insurance page.
  • Add a keyboard and contrast check to the list your web person works from, so this does not come back next quarter.

None of that work is spent on compliance alone, which is the useful part. Labels, contrast, honest alt text and forms that submit properly on a phone are what make a practice website book patients, and they are the first thing we audit for a dental practice before anything else gets touched. If you want to apply the same test to the claims you make elsewhere, start with the rules on reviews and testimonials, which come from the same agency and the same instinct: say only what you can show is true.

Written April 16, 2025, and kept as written. Platforms, features and policies mentioned here are described as they stood at the time.

Today, for your business

This is what we do for clients: Dental.

The platforms have moved on since this was written. We will show you where your business stands right now and what to do first.