A Strategic Guide to Implementing Digital Accessibility in Higher Education

Part I: The Unmistakable Imperative: Why Digital Accessibility is Non-Negotiable

Introduction

The landscape of higher education has been irrevocably transformed by the digital revolution. The campus is no longer confined to physical spaces; it is an expansive ecosystem of websites, learning management systems (LMS), mobile applications, online libraries, and virtual classrooms. While this digital expansion has created unprecedented opportunities for learning and engagement, it has also erected new, often invisible, barriers for a significant portion of the university community. Digital accessibility—the practice of ensuring that all individuals, regardless of disability, can access, use, and benefit from digital resources—is therefore no longer a peripheral IT concern or a niche compliance issue. It has emerged as a strategic institutional priority, situated at the critical intersection of civil rights law, the core educational mission, and comprehensive risk management.

For university leaders, addressing digital accessibility is not merely about solving a technical problem. It is about fulfilling a legal and ethical mandate to provide equitable access to all. With approximately 20% of students in higher education reporting some form of disability, the failure to create an inclusive digital environment is a failure to serve a substantial segment of the student body. Furthermore, a recent and definitive ruling from the U.S. Department of Justice has eliminated any ambiguity, establishing a clear technical standard and firm deadlines for compliance. The question for institutions is no longer if they should implement a digital accessibility policy, but how they can do so effectively, sustainably, and in a way that transforms a legal obligation into a mission-driven enhancement of the academic experience for all. This report provides a comprehensive roadmap for that transformation, guiding university leadership through the legal imperatives, policy architecture, strategic implementation, and operational functions necessary to build a truly accessible digital campus.

1.1 The Legal Landscape: Understanding the Web of Federal Mandates

The requirement for digital accessibility in higher education is not a new phenomenon but rather the modern application of long-standing civil rights legislation. A complex web of federal laws establishes a clear, non-negotiable obligation for colleges and universities to ensure their digital programs and services are accessible to individuals with disabilities. Understanding the scope, requirements, and interplay of these laws is the foundational first step for any institutional leader.

Section 504 of the Rehabilitation Act of 1973

Often considered the first major civil rights law for people with disabilities, Section 504 is a "program access" statute. It states that "no otherwise qualified individual with a disability... shall, solely by the reason of her or his disability, be excluded from the participation in, be denied the benefits of, or be subjected to discrimination under any program or activity receiving Federal financial assistance". For higher education, its reach is nearly universal. Virtually all private and public colleges and universities receive some form of federal financial assistance, most commonly through their participation in federal student aid programs, thus subjecting them to Section 504's requirements.

Historically, compliance with Section 504 was often interpreted through a reactive, accommodation-based model. An institution was required to provide a "reasonable accommodation"—such as a sign language interpreter or a captioned video—when a student with a disability made a specific request. This approach places the burden on the individual to disclose their disability and navigate a bureaucratic process to gain access, a model that is increasingly viewed as insufficient in the digital age.

Section 508 of the Rehabilitation Act of 1973

Enacted as an amendment to the Rehabilitation Act, Section 508 was the first federal law to directly address the accessibility of technology. It requires federal agencies to make their electronic and information technology (EIT)—including websites, software, and digital documents—accessible to people with disabilities. While Section 508 directly binds only federal agencies, its influence on higher education is significant and multifaceted.

First, many states have enacted their own "Little 508" laws that apply similar standards to state-funded entities, including public universities. Second, and more critically, federal funding streams often carry Section 508 compliance requirements. For example, states receiving funds under the Assistive Technology Act must guarantee that all programs, including universities, comply with Section 508. This creates a powerful incentive for institutions to adopt its standards, which have been updated to harmonize with internationally recognized guidelines.

The Americans with Disabilities Act (ADA) of 1990

The ADA is a broader civil rights law that extended the protections of Section 504 to most areas of public life. For higher education, two titles are particularly relevant:

• Title II applies to state and local government entities, which includes all public colleges, universities, and community colleges. It prohibits discrimination on the basis of disability in all services, programs, and activities.
• Title III applies to "places of public accommodation," a category that covers private businesses open to the public. Courts have consistently ruled that this includes private colleges and universities. The legal interpretation has increasingly extended this concept to include digital "places," such as university websites and online application portals, even for entities with no physical storefront.

For years, the ADA's application to the digital realm was primarily defined through litigation and regulatory enforcement actions. Institutions faced a rising tide of lawsuits alleging that inaccessible websites, learning platforms, and mobile apps constituted a violation of the ADA. This legal pressure created a clear need for a more explicit standard.

The 2024 Department of Justice (DOJ) Final Rule on ADA Title II

This new rule, published in April 2024, represents a watershed moment for digital accessibility in public higher education. It codifies a specific, legally enforceable technical standard for what it means for a public entity's digital presence to be accessible under Title II of the ADA. The key provisions are:

• Mandated Standard: Public institutions must ensure their websites and mobile applications conform to the Web Content Accessibility Guidelines (WCAG) 2.1, Level AA. WCAG is the globally recognized benchmark for digital accessibility, providing a detailed framework of testable success criteria.
• Firm Compliance Deadlines: The rule establishes a clear timeline for compliance. Larger institutions (serving a population of 50,000 or more) must comply by April 24, 2026. Smaller institutions have until April 24, 2027.
• Broad Scope: The rule applies not only to main university websites but to the entire digital ecosystem, including admissions portals, online learning platforms, digital documents like PDFs, and even social media posts.

This DOJ rule fundamentally alters the legal landscape. It shifts the paradigm from a vague requirement to provide "access" to a clear mandate to meet a specific technical standard by a fixed date. This provides a clear benchmark for compliance and will undoubtedly shape the expectations for private institutions under Title III as well. The legal trend demonstrates a clear convergence of standards and a decisive shift from a reactive, accommodation-based model to a proactive, design-based one. The early focus of Section 504 was on not denying access and providing accommodations upon request, which placed the onus on the student. Section 508 then introduced technical standards for federal technology, signaling a move toward proactive design. Decades of litigation under the ADA further cemented the idea that inaccessible websites are a form of discrimination. The 2024 DOJ rule is the culmination of this evolution, mandating a specific, proactive technical standard (WCAG 2.1 AA) for public entities. This creates an unambiguous legal benchmark that will inevitably be adopted as the standard of care in Title III cases against private institutions. Consequently, the entire higher education sector is being compelled to move from a model of "fixing it when it breaks for someone" to "building it right for everyone from the start." This has profound implications for institutional strategy and resource allocation, demanding a shift in investment from solely the Disability Services Office to a broader institutional commitment encompassing IT, procurement, and faculty development.

Consequences of Non-Compliance

The risks associated with failing to meet these legal obligations are substantial and growing. While federal agencies like the Department of Education's Office for Civil Rights (OCR) and the DOJ can initiate compliance reviews and enter into resolution agreements with institutions, the most immediate and potent threat comes from private litigation. The number of web accessibility lawsuits filed in federal court has surged, with thousands filed between 2017 and 2022 alone.

Higher education has been a frequent target of these lawsuits, which can result in costly settlements, significant legal fees, and court-ordered remediation plans that can range from hundreds of thousands to millions of dollars. For example, a 2023 case involving the Los Angeles Community College District resulted in $240,000 in damages to just two students over inaccessible course materials and software. Beyond the financial costs, such lawsuits inflict considerable reputational damage and can lead to the potential loss of federal funding in cases of persistent non-compliance.

The most common accessibility barriers cited in these legal actions are often fundamental in nature, including:

• Missing alternative text ("alt text") for images, which prevents screen reader users from understanding the content of graphics.
• Lack of accurate, synchronized captions for videos, excluding deaf and hard-of-hearing users.
• Poor keyboard navigation, which makes it impossible for users who cannot operate a mouse to access all content and functions.
• Inaccessible PDF documents that lack the necessary tag structure for screen readers to interpret them correctly.

The prevalence and consistency of these lawsuits send a clear message: the risk of non-compliance is not a distant, abstract possibility of a federal review but a clear and present danger of costly and reputation-damaging litigation. This reality reframes the motivation for leadership from one of routine bureaucratic compliance to one of of urgent and strategic risk mitigation. The primary audience for a robust accessibility policy is not just a federal auditor, but a potential plaintiff's attorney.

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Table 1: Comparison of Federal Digital Accessibility Laws for Higher Education

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1.2 Beyond Compliance: The Ethical and Pedagogical Case for Inclusive Design

While the legal mandates provide a powerful and urgent impetus for action, a compliance-only mindset is both insufficient and a missed opportunity. An institution that views accessibility solely as a risk to be mitigated will perpetually be in a reactive posture, doing the bare minimum to avoid litigation. True institutional excellence requires a deeper commitment, one that embraces digital accessibility as a core component of the educational mission and a fundamental tenet of diversity, equity, and inclusion (DEI). This proactive approach is best realized through the pedagogical framework of Universal Design for Learning (UDL).

Accessibility as a DEI Imperative

The mission of higher education is to expand access to knowledge and opportunity. In an era where the campus is digital, inaccessible technology directly contradicts this mission. For the nearly one in five undergraduate students who report having a disability, an inaccessible LMS, uncaptioned lecture video, or unusable registration portal is the digital equivalent of a building with no wheelchair ramp. It is an exclusionary barrier that prevents full and equitable participation in the academic and social life of the university. Framing digital accessibility as an essential pillar of the institution's DEI strategy elevates the conversation from technical compliance to a matter of civil rights and social justice, aligning the initiative with the university's highest values.

Introduction to Universal Design for Learning (UDL)

Universal Design for Learning is a research-based educational framework that guides the design of learning environments and materials to be usable by all people, to the greatest extent possible, without the need for adaptation or specialized design. Developed by the organization CAST, UDL is based on scientific insights into how humans learn and is defined in the federal Higher Education Opportunity Act of 2008 as a scientifically valid framework for guiding educational practice.

Rather than a one-size-fits-all approach, UDL acknowledges that learner variability is the norm, not the exception. It proposes that curricula should be designed with flexibility from the outset to accommodate diverse learning needs and preferences. The framework is organized around three core principles:

1. Provide Multiple Means of Engagement (the "Why" of learning): This principle focuses on tapping into learners' interests, offering appropriate challenges, and increasing motivation. In practice, this could mean providing students with choices in assignment topics, fostering a collaborative and supportive classroom community, and making the material relevant to their lives and goals.
2. Provide Multiple Means of Representation (the "What" of learning): This principle centers on presenting information and content in different formats. For example, instead of relying solely on a text-based reading, an instructor might also provide an audio recording, a video summary, or a graphical organizer. This ensures that students with sensory disabilities (like blindness or deafness) or learning disabilities (like dyslexia) can access the content in a way that works for them.
3. Provide Multiple Means of Action and Expression (the "How" of learning): This principle involves providing learners with flexible options for demonstrating their knowledge and skills. Rather than requiring every student to write a traditional term paper, an instructor might allow them to choose between writing a paper, creating a podcast, developing a website, or giving a presentation.

UDL provides the ideal framework for university leaders to reframe the accessibility initiative from a costly legal burden to an investment in pedagogical innovation and student success. The legal mandates, particularly the technical criteria of WCAG 2.1 AA, can feel like a rigid, externally imposed checklist. Faculty members, already facing numerous demands, may resist these mandates as an infringement on their academic freedom or as yet another unfunded burden. UDL, however, is a framework rooted in learning science and pedagogy, designed to improve teaching effectiveness. By promoting UDL, leaders can create a powerful bridge between the technical requirements and the institution's educational mission. For instance, the WCAG requirement to "provide captions for all prerecorded audio content" can be connected directly to the UDL principle of "providing multiple means of representation." This transforms the conversation from a compliance-driven directive ("You must do this to avoid a lawsuit") to a pedagogically-driven best practice ("We should do this because it makes you a more effective teacher and improves learning outcomes for all our students"). This approach is far more likely to achieve genuine faculty buy-in and cultivate a sustainable, campus-wide culture of accessibility.

The "Curb-Cut Effect": How UDL Benefits All Learners

A core tenet of universal design is that creating solutions for individuals with disabilities often results in benefits for a much broader population—a phenomenon known as the "curb-cut effect." Just as curb cuts, originally designed for wheelchair users, also benefit people with strollers, delivery carts, and rolling luggage, features implemented for digital accessibility enhance the learning experience for everyone.

For example:

• Captions and Transcripts: Originally intended for students who are deaf or hard of hearing, captions are widely used by students who are non-native English speakers to improve comprehension, by students studying in noisy environments (like a library or coffee shop), and by all learners as a tool to search for key terms within a video lecture.
• Well-Structured Documents: Using proper heading structures in a Word document or on a webpage, a key requirement for screen reader navigation, also makes the document more scannable and easier to understand for all readers. It also enables the automatic generation of a table of contents, a benefit for everyone.
• Flexible Pacing: Online learning environments designed with flexibility for students with cognitive disabilities or chronic illnesses also benefit students who are working parents or have demanding schedules, allowing them to control the pace of their learning.

By adopting a UDL framework, an institution moves beyond a deficit-based model of "fixing" things for a small group of students and embraces an asset-based model of improving the learning environment for the entire community. This proactive approach also yields significant operational efficiencies. The traditional model of reactive accommodation places a heavy burden on Disability Resource Centers (DRCs) to process individual requests for things like captioned videos or accessible document formats. This process can be slow for the student and is highly resource-intensive for the institution. When a course is designed using UDL principles and meets WCAG standards from the start, many of these common accommodation needs are already met. If all lecture videos are proactively captioned, a deaf student no longer needs to file a request with the DRC to get access. This frees up the DRC's limited resources to focus on the more complex, highly individualized accommodations that cannot be addressed through universal design alone. Therefore, a strategic, up-front investment in campus-wide accessibility and UDL is not just an ethical imperative; it is a fiscally prudent strategy that enhances pedagogical quality and leads to long-term operational efficiencies in student support services.

Part II: Architecting the Foundation: Crafting a Comprehensive Digital Accessibility Policy

A formal, university-sanctioned policy is the foundational charter for a successful digital accessibility initiative. It is far more than a bureaucratic formality; it is the official expression of the institution's commitment, the primary instrument for assigning authority, and the definitive framework for establishing accountability across a complex and often decentralized organization. A well-crafted policy provides clarity, sets expectations, and empowers the individuals and offices tasked with leading the implementation effort. Without this formal architecture, any accessibility initiative risks becoming a collection of well-intentioned but uncoordinated, under-resourced, and ultimately unsustainable efforts.

2.1 The Anatomy of an Effective Policy

An effective digital accessibility policy must be comprehensive, clear, and actionable. It should serve as a central reference point for the entire university community. By examining the policies of institutions that have already undertaken this work, such as Princeton University, the University of Chicago, and the University of Georgia, a clear model of best practices emerges. A robust policy should contain the following essential components:

• Purpose/Policy Statement: The opening section must be a clear and unequivocal affirmation of the university's commitment to digital accessibility. This statement should ground the policy in both legal obligations and institutional values. It should explicitly reference the university's commitment to inclusion and equity, as well as its legal duties under federal laws like the Americans with Disabilities Act (ADA) and Section 504 of the Rehabilitation Act. This sets a strong, mission-aligned tone for the entire document.
• Scope and Applicability: This section must precisely define the policy's reach. To be effective, the scope should be defined broadly to cover all "Electronic and Information Technology" (EIT) or "Digital Content" that is developed, procured, used, or maintained for "University Business". It is critical to list specific examples to avoid ambiguity, including: public-facing websites, internal portals, the Learning Management System (LMS), mobile applications, digital course materials (documents, presentations, videos), library databases, software applications, and official university social media channels. The policy must also clearly state who is bound by its requirements, such as all faculty, staff, students, and third-party vendors providing digital services to the university.
• Definitions: A dedicated definitions section is crucial for providing legal and technical clarity and ensuring a shared understanding of key terms across the institution. This section should provide clear, concise definitions for terms such as "Accessibility," "Accommodation," "Digital Content," "Equally Effective Alternate Access," the official technical standard ("WCAG 2.1 Level AA"), and procurement-related terms like "Voluntary Product Accessibility Template (VPAT)".
• Technical Standard: The policy must eliminate ambiguity by formally adopting a specific, measurable technical standard. The overwhelming consensus and the legal standard set by the 2024 DOJ rule is the Web Content Accessibility Guidelines (WCAG) 2.1, Level AA. The policy must explicitly name this as the official standard to which all digital content and technology covered by the policy must conform.
• Procedures and Guidelines: While the main policy document sets the high-level requirements, it should reference or be accompanied by a set of detailed procedures that provide practical guidance on implementation. These procedures should cover key operational areas:
  • Procurement: A clear procedure must be established that requires an accessibility review for all new EIT purchases. This includes mandating that vendors provide a current VPAT and that accessibility considerations are a formal part of the vendor selection and contracting process.
  • Legacy Content: The policy must acknowledge the existence of vast amounts of pre-existing, inaccessible content and outline a process for addressing it. This typically involves a prioritization strategy, focusing first on high-impact, core institutional content, with a clear timeline for remediation.
  • Reporting and Grievances: A clear, accessible, and well-publicized process must be established for users to report accessibility barriers they encounter. The procedure should define the university's commitment to a timely response and resolution.
  • Exceptions: No policy can cover every eventuality. A formal process must be defined for requesting an exception in cases where compliance is not technically feasible or would constitute an "undue financial and administrative burden". Crucially, this procedure must require that any approved exception be accompanied by a documented "equally effective alternate access plan" to ensure that users with disabilities can still access the information or service.

2.2 Defining the Ecosystem: Roles, Responsibilities, and Accountability

A policy is only as effective as the accountability framework that supports it. A common point of failure for accessibility initiatives is the diffusion of responsibility, where accessibility becomes "everyone's job" and therefore "no one's job." An effective policy counteracts this by creating a clear ecosystem of roles and responsibilities, establishing that accessibility is a shared responsibility with clearly defined accountabilities for different stakeholders. This framework should include both centralized oversight and decentralized execution.

• Executive Sponsor(s): The initiative must be championed by a senior leader with significant institutional authority, such as a Provost, President, or Chief Information Officer (CIO). The Executive Sponsor's role is to provide visible leadership, advocate for the necessary resources (funding and staffing), resolve high-level conflicts, and hold the university community accountable for compliance with the policy. Without this top-level backing, the initiative will lack the authority and resources needed to succeed.
• Central Authority (e.g., Digital Accessibility Office/Coordinator): A central office or designated individual must serve as the operational hub for the initiative. This entity is responsible for the day-to-day management of the accessibility program. Its core functions include: overseeing policy implementation and updates, developing and delivering campus-wide training, providing expert consultation to departments and faculty, conducting accessibility audits and testing, managing the exceptions process, and reporting on institutional progress to leadership.
• Governance Body (e.g., Steering Committee/Task Force): A high-level, cross-functional governance body is essential for providing strategic direction and ensuring institution-wide coordination. This committee should be composed of representatives from key stakeholder units, including the Provost's office, IT, General Counsel, Disability Resources, Procurement, University Communications, and should include faculty and student representatives (ideally including individuals with disabilities). Its charge is to provide strategic oversight, review and approve exception requests, monitor institutional progress against established goals, and recommend policy revisions as needed. Models like the University of Washington's ADA Digital Accessibility Board or the University of Iowa's task force, which uses targeted subcommittees for areas like Teaching and Contracts, provide excellent templates.
• Decentralized Roles: To be effective at scale, responsibility must be distributed throughout the organization. The policy must clearly define the accessibility duties of various roles:
  • Site/Content Owners: Individuals or departments that manage websites or create digital content have the primary responsibility for ensuring that content is accessible.
  • Faculty/Instructors: Are responsible for ensuring that all their digital course materials—syllabi, lecture slides, videos, readings, and LMS content—are accessible to all students in their classes.
  • Procurement Officers: Are responsible for executing the accessible procurement procedure, including requesting and evaluating VPATs and ensuring accessibility clauses are included in vendor contracts.
  • Developers: Are responsible for writing code and building applications that conform to the university's adopted technical standard (WCAG 2.1 AA).

A common failure point for institutional policies is the expression of a noble commitment without the inclusion of corresponding enforcement mechanisms. In a decentralized university environment where academic and administrative units operate with considerable autonomy, a policy that merely "encourages" accessibility is likely to be overlooked amidst competing priorities and budget constraints. An effective policy must therefore explicitly grant authority to a central body. The policies of institutions like the University of Chicago and Yale University provide a powerful model: they explicitly state that a central governance committee can require a non-compliant website or application to be remediated and, crucially, can charge the expense of that work to the unit responsible for the non-compliant resource. This provision—the "teeth" of the policy—transforms it from a suggestion into a mandate. It provides the central accessibility office with the necessary leverage to compel action from deans and department heads, ensuring that compliance becomes a tangible, budgeted priority rather than an unfunded ideal.

Similarly, the exceptions process, while necessary for cases of genuine technical infeasibility, can become a loophole that undermines the policy if not managed with rigor. The key to a strong process is to shift the burden of proof to the unit requesting the exception and to mandate a concrete, timely, and effective alternative for users. A robust policy, like that of the University of Georgia, explicitly states that a lack of sufficient funding within a particular unit is not, by itself, a valid reason for an exception. Furthermore, it requires that any approved exception must be accompanied by a formal "equally effective alternate access plan". This ensures that even when a specific technology is not compliant, the university's fundamental obligation under Section 504 and the ADA to provide equal access to its programs and services is still met. This closes the potential loophole while maintaining the operational flexibility needed to handle legitimate edge cases.

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Table 2: Sample Governance Model: Roles and Responsibilities

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Part III: The Implementation Framework: Building a Sustainable Institutional Capability

Crafting a comprehensive policy is a critical first step, but it is only the beginning. The transition from policy on paper to an embedded institutional practice requires a formal governance structure to guide the effort and a deliberate, phased strategic plan to manage the immense scope of the work. A successful implementation is not a short-term project with a finish line, but rather the development of a permanent, sustainable institutional capability. This requires strong leadership, cross-functional collaboration, and a realistic, multi-year approach to tackling the challenge.

3.1 Establishing Governance: The Central Nervous System of Accessibility

Effective governance provides the structure, authority, and coordination necessary to drive a complex, university-wide initiative. Without a clear governance model, efforts will remain siloed, standards will be applied inconsistently, and accountability will be impossible to establish. The choice of a governance model has a direct causal relationship with the success of the initiative. A purely top-down mandate without distributed ownership will likely fail due to faculty and staff resistance. Conversely, a purely grassroots effort without executive authority will inevitably fail due to a lack of resources and enforcement power. The most effective approach, therefore, is a hybrid model that balances centralized authority with decentralized execution.

The Case for Executive Sponsorship

The foundation of any successful governance structure is visible, unwavering support from the highest levels of university leadership. An Executive Sponsor—typically the President, Provost, or CIO—lends their authority to the initiative, signaling to the entire community that digital accessibility is a non-negotiable institutional priority. This sponsorship is critical for securing the necessary multi-year funding, empowering the governance committee to make and enforce decisions, and resolving the inevitable political and budgetary conflicts that arise during implementation. Research on accessibility initiatives has shown that a key concern is that commitments made by senior managers are often not matched by the resources needed to deliver change; active executive sponsorship is the primary mechanism to close this gap.

Forming a Steering Committee or Task Force

The strategic direction of the initiative should be guided by a cross-functional steering committee or task force. This body serves as the central coordinating group, ensuring that the accessibility plan aligns with broader university goals and that all key stakeholder perspectives are represented. The composition of this committee is critical to its success. It must include senior representatives from:

• Academic Affairs (Provost's Office): To ensure alignment with the educational mission and to champion faculty engagement.
• Information Technology: To provide technical expertise and oversee the implementation of accessible systems.
• Office of the General Counsel: To advise on legal requirements and risk management.
• Disability Resource Services: To provide expertise on the needs of students with disabilities and the accommodation process.
• Procurement and Finance: To integrate accessibility into purchasing and budget processes.
• University Communications: To manage campus-wide messaging and ensure public-facing websites are prioritized.
• Faculty and Student Governance: To ensure the perspectives and concerns of these key constituencies are heard and addressed.

Institutions like the University of Washington have established a formal ADA Digital Accessibility Board within their IT Governance structure, while the University of Iowa has created a task force with specific subcommittees focused on distinct areas like Teaching, Web, Contracts, and Health Care, providing a model for how to organize this complex work.

Centralized vs. Decentralized Models: The Hub-and-Spoke Approach

Given that digital accessibility spans thousands of legacy course materials and involves distributed content creation across countless faculty and staff, a single central office cannot possibly perform all the necessary work. The most effective and scalable governance structure is a "hub-and-spoke" model.

• The Hub: This is the central Digital Accessibility Office or team. It serves as the university's center of excellence, providing the expertise, policy interpretation, training curriculum, enterprise-level tools, and oversight for the entire institution.
• The Spokes: These are designated Digital Accessibility Liaisons or Coordinators embedded within each college, school, and major administrative unit. These individuals act as the local champions and first point of contact for accessibility within their areas. They receive in-depth training from the central hub and are responsible for disseminating information, coordinating local remediation efforts, and providing front-line support to their colleagues.

This model, exemplified by the Digital Accessibility Coordinators program at The Ohio State University, masterfully balances centralized authority and standards with the decentralized execution needed to navigate the complex political and operational landscape of a large university. It empowers local units to manage their own content while ensuring they are supported by and accountable to a central, expert authority.

3.2 The Strategic Roadmap: From Audit to Transformation

With a governance structure in place, the institution can develop a multi-year, phased strategic roadmap for implementation. This plan should be realistic, acknowledging that achieving full accessibility is a long-term process, and should be based on a clear understanding of the current state of the university's digital ecosystem.

Phase 1: Discover & Initiate (Years 0-1)

The initial phase is focused on understanding the full scope of the challenge and establishing the foundational elements of the program.

• Conduct a Comprehensive Digital Asset Audit: The first and most critical step is to conduct a thorough inventory and assessment of the university's digital assets. This involves identifying all public-facing websites, internal portals, the LMS, mobile applications, and critical administrative systems. The initial audit serves a purpose that is as much political and financial as it is technical. While it does identify technical issues, its primary strategic function is to quantify the scope of the problem in a way that is undeniable to senior leadership. University leaders are accustomed to making data-driven decisions. A vague statement like "we need to be more accessible" is an abstract goal that is easily deferred. However, an audit report that states, "We have 500 public-facing websites with an average of 15 critical WCAG 2.1 AA violations per page, placing the institution at significant and immediate legal risk," presents a concrete, quantifiable problem. This hard data provides the business case for a multi-million dollar, multi-year investment in remediation, tools, and staffing. Without this initial, comprehensive data, requests for the necessary resources are easily dismissed. The audit is the lever that unlocks the institutional investment required for success.
• Employ a Hybrid Testing Approach: The audit must use a combination of automated and manual testing methods.
  • Automated Testing: Tools like WAVE, Axe, Siteimprove, or Pope Tech can rapidly scan thousands of pages to identify common, code-based accessibility issues such as missing alt text, low color contrast, or missing form labels. This provides a broad, quantitative baseline of the institution's accessibility posture.
  • Manual Testing: Automated tools can only detect a fraction of potential accessibility barriers. Expert manual testing is essential to evaluate the user experience for people who rely on assistive technologies. This involves trained testers navigating key user flows (e.g., applying for admission, registering for a course, submitting an assignment) using only a keyboard and with a screen reader, such as JAWS or NVDA. This qualitative testing uncovers complex issues that automated scans cannot, such as illogical reading order, confusing link text, or inaccessible interactive elements.
• Prioritize for Impact: The results of the audit will likely be overwhelming. The institution must develop a risk-based prioritization matrix to guide remediation efforts. Priority should be given to digital assets that are most critical to the university's mission and pose the greatest legal risk. This typically includes:
  • Core institutional functions: Admissions, registration, financial aid, and the main university homepage.
  • High-traffic websites and student-facing services: The LMS, library website, and major departmental sites.
  • Public-facing content that is essential for interacting with the university.

Phase 2: Build & Refine (Years 1-3)

This phase focuses on active remediation and the development of the institutional infrastructure needed for long-term success.

• Launch Remediation Sprints: Based on the audit's prioritization, launch targeted projects to fix the most critical accessibility barriers on the highest-priority systems and websites.
• Implement Core Processes: Formally roll out the new accessible procurement process across the university. Launch the first wave of the campus-wide training program, focusing initially on web developers, content managers, and instructional designers in high-priority areas.
• Develop Support Infrastructure: Create a central, public-facing accessibility website to house the policy, standards, training materials, and best-practice guides. Establish clear channels for help and support, including a dedicated help desk queue and consultation services offered by the central accessibility office.

Phase 3: Transform & Sustain (Year 3 and beyond)

The final phase is about embedding accessibility into the fabric of the university's culture and daily operations, moving from a project-based mindset to a continuous improvement model.

• Embed Accessibility into Workflows: The goal is to shift from a reactive "find-and-fix" model to a proactive "build-it-right-from-the-start" model. Accessibility should become a standard requirement in all web development lifecycles, course design templates, and content creation guidelines.
• Establish Ongoing Monitoring and Reporting: Implement enterprise-level tools for ongoing, automated scanning of university websites to monitor for new issues. Conduct periodic manual audits of critical systems to ensure continued compliance. The governance committee should establish key performance indicators (KPIs) and develop annual reports or public-facing dashboards to track progress and maintain institutional accountability. This creates a cycle of continuous improvement and ensures that accessibility remains a visible priority long after the initial compliance deadline has passed.

Part IV: Operationalizing Accessibility: Core Functions and Best Practices

A robust policy and a strategic plan provide the necessary framework, but the success of a digital accessibility initiative ultimately hinges on its execution within the core operational functions of the university. Policies and plans are ineffective without skilled people to implement them and well-defined processes to guide their daily work. Three operational pillars are most critical to building a sustainable accessibility program: procurement, which prevents new barriers from entering the ecosystem; training, which builds the necessary human capital; and content management, which provides a strategy for addressing the vast amount of existing digital material.

4.1 Procurement as a Gateway: Ensuring New Technology is Born Accessible

The university procurement process is the single most strategic point of intervention for long-term accessibility success. Every time a department purchases a new piece of software, renews a subscription to a cloud-based platform, or contracts with a vendor to build a mobile application without a thorough accessibility review, it is potentially acquiring a new, costly accessibility problem and adding to the institution's legal liability. A rigorous, accessibility-conscious procurement process acts as a gatekeeper, preventing inaccessible technology from entering the university ecosystem in the first place. This approach is exponentially more cost-effective and efficient than attempting to remediate an inaccessible product after it has already been purchased and deployed. Stopping the influx of new barriers allows the institution to focus its limited remediation resources on existing problems, rather than constantly fighting new fires. Therefore, establishing and enforcing an accessible procurement policy is the most critical long-term strategic action an institution can take.

This requires integrating accessibility into every stage of the procurement lifecycle. Key components of an accessible procurement process include:

• Mandatory Accessibility Review: The university policy must mandate that accessibility is a required factor in all EIT procurement decisions. No software, platform, or digital service should be purchased without a formal accessibility review.
• The Role of the Voluntary Product Accessibility Template (VPAT): The VPAT is the primary tool for this review.
  • Definition and Purpose: A VPAT is a standardized document created by a vendor to describe how their product conforms to accessibility standards like Section 508 and WCAG. When completed, the document is referred to as an Accessibility Conformance Report (ACR). The university should require a current ACR for any product under consideration.
  • Utility in Procurement: ACRs allow procurement officers and accessibility specialists to conduct a preliminary assessment, compare the accessibility of competing products, and identify specific areas of concern to discuss with the vendor. They also create a formal record of a vendor's accessibility claims, which can be used to promote accountability.
  • Critical Evaluation and Limitations: It is crucial to understand that an ACR is a vendor's self-reported claim, not an independent third-party certification. It must be scrutinized with a critical eye. Procurement teams should be trained to spot red flags, such as: an outdated report (older than one or two years), a report that claims 100% "supports" for all criteria with no detailed explanations, or a vendor who is unfamiliar with the term VPAT. The university must always reserve the right to conduct its own independent testing of a product, especially for high-impact, enterprise-level systems.
• Legally Binding Contract Language: Standard university contracts must be updated to include accessibility clauses. This language should require vendors to:
  • Warrant that their product conforms to the WCAG 2.1 Level AA standard.
  • Commit to remediating any accessibility issues discovered after purchase in a timely manner and at no additional cost to the university.
  • Provide an updated and accurate ACR with each new version or major update of the product.

4.2 Building Human Capital: A Framework for Campus-Wide Training and Support

Tools and policies are rendered ineffective if faculty and staff lack the knowledge and skills to implement them. A comprehensive, ongoing training program is essential for building the human capital necessary to create a truly accessible digital environment. A small central accessibility team cannot possibly train every member of a large university community. The only scalable model is one that builds local expertise and fosters a community of practice. This involves a "train the trainer" approach, where the central team provides intensive training to a cohort of departmental liaisons, who then become the local experts and front-line support for their colleagues. This structure distributes expertise, fosters peer accountability, and makes support more immediate and context-relevant, which is the key to moving from a small group of experts to a campus-wide culture of accessibility.

A successful training program should be multi-faceted and tailored to the specific needs of different roles within the university.

• A Role-Based Curriculum: One-size-fits-all training is inefficient. The curriculum should be designed with specific audiences in mind:
  • For Faculty and Instructors: Training should focus on practical skills for creating accessible course materials. This includes how to properly structure Word documents and PowerPoint slides, how to create accessible PDFs, how to add accurate captions to videos, and how to use the accessibility features within the LMS. This training should also introduce the principles of Universal Design for Learning to connect these technical skills to a pedagogical framework.
  • For Web Developers and IT Staff: This group requires in-depth technical training on WCAG 2.1 AA standards, accessible coding practices (such as the proper use of ARIA), and manual testing techniques with assistive technologies.
  • For Content Creators and Communications Staff: Training should cover best practices for web content, such as writing meaningful alt text for images, using proper heading structures, writing descriptive link text, and creating accessible social media posts.
  • For Procurement Officers and Administrators: This group needs high-level training on the legal requirements, the university's procurement policy, and how to request and interpret a VPAT.
• A Multi-Modal Delivery Strategy: To accommodate diverse schedules and learning preferences, training should be offered in a variety of formats:
  • Self-Paced, Asynchronous Learning: This is the most scalable option and should form the foundation of the program. It can include online modules, a library of on-demand training videos (leveraging resources like LinkedIn Learning, which is often available to university communities), checklists, and quick-start guides. The University of Minnesota's Digital Accessibility Badging Program serves as an exemplary model, offering a structured, self-paced curriculum of courses on topics from "Foundations" to "Accessible PDFs," awarding digital badges to validate the skills learned.
  • Live, Synchronous Training: These sessions allow for interaction and hands-on practice. They can be offered as university-wide workshops (both virtual and in-person), customized trainings delivered by request to specific departments or colleges, and regular "office hours" where individuals can get one-on-one consultation on their specific projects.
• An Integrated Support Ecosystem: Training is most effective when it is part of a broader support system. This includes a central accessibility website with comprehensive resources, clear help desk support channels, and the deployment of tools that provide real-time feedback, such as accessibility checkers like Blackboard Ally or the Universal Design Online Content Inspection Tool (UDOIT) integrated directly into the LMS.

4.3 Addressing the Legacy: Managing Existing Digital Content

Perhaps the most daunting task in any accessibility initiative is addressing the mountains of existing, inaccessible digital content spread across thousands of websites and course shells. A comprehensive remediation of every legacy document and webpage is often not feasible. Therefore, a strategic and pragmatic approach to triaging this content is essential. The University of Minnesota provides a practical "3 Rs" framework for this work:

1. Remove: The first and often easiest step is to conduct a content audit and remove or archive digital content that is outdated, redundant, or unused (ROT). A significant portion of the compliance burden can often be eliminated simply by deleting old web pages and files that are no longer needed.
2. Replace: Before investing significant time in remediating an inaccessible resource, investigate whether an accessible alternative already exists. For example, instead of painstakingly fixing a poorly scanned, inaccessible PDF of a textbook chapter provided by an instructor, the better solution is to replace it with a link to a "born-accessible" electronic version available through the university library's databases or e-reserves system.
3. Remediate: For high-value, high-use, and essential content that cannot be removed or replaced, a plan for remediation must be developed. This is where the prioritization established during the initial audit becomes critical. Remediation efforts should focus on the most important student-facing services and public-facing content first. The responsibility for this remediation can be managed through a hybrid model: a central team can handle the complex remediation of enterprise-level systems and the main university website, while departments are empowered and trained to fix the content on their own sites and in their own courses over time.

By operationalizing accessibility through these core functions, an institution can move beyond a state of perpetual crisis management. A strong procurement process stems the tide of new problems, a robust training program builds the capacity to create accessible content, and a strategic approach to legacy content makes the existing challenge manageable. Together, these pillars form the operational engine that drives a sustainable culture of access.

Part V: Cultivating a Culture of Access: Sustaining Momentum for the Long Term

The ultimate goal of a digital accessibility initiative extends beyond meeting a one-time compliance deadline. A truly successful program is one that becomes deeply embedded in the university's culture, transforming from a top-down mandate into a shared institutional value. This requires a sustained effort focused on communication, community engagement, and a commitment to continuous improvement. The long-term success of a digital accessibility policy is measured not by the ability to pass a single audit, but by the extent to which inclusive design becomes an unconscious, routine practice across the institution. The initial push for accessibility is often driven by the legal deadline, which can create a culture of compliance focused on checklists and avoiding penalties. While necessary, this is not sustainable. Momentum can fade once the deadline passes. The most mature institutions reframe the work around their core mission of education and inclusion. This cultural shift is achieved through sustained training, celebrating accessibility champions, sharing success stories, and eventually integrating accessibility into faculty and staff performance expectations. When an instructor automatically captions their videos not because a policy requires it, but because they recognize it as a hallmark of excellent teaching, the culture has truly shifted. This is the final stage of institutional maturity: moving beyond the mandate to fully embrace the mission.

5.1 Communication and Community Engagement

Fostering a culture of access requires a deliberate and ongoing communication strategy designed to raise awareness, build buy-in, and empower the community.

• Develop a Strategic Communication Plan: The governance committee should oversee a multi-channel communication plan that keeps the university community informed and engaged. This should include regular campus-wide emails from senior leadership announcing the policy and celebrating milestones, articles in university news publications highlighting success stories and available resources, and targeted social media campaigns. Presentations to key governance bodies like the Faculty Senate and the Council of Deans are also critical for securing leadership buy-in at the college and department level.
• Establish Clear Feedback Channels: It is essential to create a simple, clear, and highly visible process for all users to report accessibility barriers they encounter. A prominent "Report a Barrier" or "Accessibility Issue" link should be included in the footer of all university websites. This link should lead to a simple form that routes the issue to the central accessibility office for triage and resolution. This system serves a dual purpose. On one hand, it is a crucial customer service tool that allows the university to respond to individual needs in a timely manner. On the other hand, it functions as a critical, real-time data source for risk management. An increase in reports about a specific system—such as a newly procured student information portal—provides an early warning of a potential systemic issue. This data allows the accessibility office to proactively engage with the vendor or the responsible campus unit to address the problem before it escalates into a formal grievance or lawsuit. By tracking the volume, type, and location of reported barriers, the institution can identify patterns and hotspots of inaccessibility, which can then inform future training priorities and audit schedules. In essence, the feedback loop created by this system transforms individual user complaints into actionable institutional intelligence, enabling a more agile and responsive approach to accessibility management.
• Actively Engage the Disability Community: The most valuable resource in any accessibility initiative is the lived experience of students, faculty, and staff with disabilities. The university must actively involve this community in the process. This can be achieved through the inclusion of individuals with disabilities on the governance committee, the formation of a disability advisory group, and the regular use of focus groups and usability testing sessions involving users of assistive technologies. Their direct feedback is invaluable for identifying the most significant barriers and validating the effectiveness of proposed solutions.

5.2 Looking Ahead: The Future of Accessibility and Emerging Technologies

The digital landscape is in a constant state of flux. A successful accessibility program must be designed not just to meet today's standards, but to be resilient and adaptable enough to meet the challenges of tomorrow.

• Navigating Emerging Technologies like Artificial Intelligence (AI): AI presents both immense opportunities and significant challenges for accessibility. On one hand, AI-powered tools can be a powerful force for good, automating the generation of captions for videos and alt text for images, and providing new ways for users to interact with technology through voice commands. On the other hand, if AI-driven platforms and chatbots are not designed with accessibility in mind from the outset, they can create entirely new and complex barriers. The university's accessibility policy and governance structure must be prepared to address this duality. The procurement process must be adapted to evaluate the accessibility of AI-powered tools, and guidelines must be developed for the responsible and inclusive implementation of AI in teaching, learning, and administrative functions.
• A Commitment to Continuous Improvement: Digital accessibility is not a destination that can be reached, but an ongoing journey. The policy itself should be a living document, subject to periodic review (e.g., every two years) to ensure it remains aligned with evolving legal standards (such as the eventual release of WCAG 3.0), new technologies, and feedback from the university community. The institution should strive to build a program that is capable of continuous monitoring, evaluation, and refinement, ensuring that the commitment to an inclusive digital campus is a permanent one.

Conclusion

Implementing a comprehensive digital accessibility policy is a complex and challenging undertaking, but it is an absolute necessity for the modern university. The legal landscape, culminating in the 2024 DOJ rule, has removed all ambiguity, establishing clear standards and firm deadlines that carry significant financial and reputational risk for non-compliance. Yet, the imperative for action runs far deeper than legal exposure. Digital accessibility is a fundamental issue of equity and inclusion, inextricably linked to the core mission of higher education to provide access to knowledge and opportunity for all.

For university leaders, the path forward requires a strategic, institution-wide commitment that reframes this challenge from a compliance burden into a mission-driven investment in excellence. This transformation is built upon several key pillars:

1. A Foundation of Policy and Governance: A formal, authoritative policy that establishes clear standards, defines roles and responsibilities, and is backed by a cross-functional governance structure with executive sponsorship is non-negotiable.
2. A Proactive, Design-First Philosophy: The institution must shift its mindset from a reactive model of accommodating individual requests to a proactive model of inclusive design, guided by the pedagogical principles of Universal Design for Learning.
3. Strategic, Data-Driven Implementation: A multi-year roadmap, beginning with a comprehensive audit to define the scope of the problem, allows the institution to prioritize its efforts and manage the work in a realistic, phased manner.
4. Investment in Core Operational Capabilities: Sustainable success depends on embedding accessibility into the university's daily operations, particularly through a rigorous procurement process that stops new barriers at the gate and a comprehensive training program that builds the necessary skills across the campus community.

By embracing this holistic approach, a college or university can do more than simply comply with the law. It can create a more inclusive, effective, and welcoming digital environment that lowers barriers, enhances learning, and empowers every member of its community to participate fully and achieve their highest potential. This is the ultimate promise of digital accessibility—the alignment of legal mandate with institutional mission.