Public schools, universities, and other educational entities covered by ADA Title II must ensure their digital assets conform to WCAG 2.1 AA. This guide covers which institutions are affected, where to start with procurement and LMS evaluation, and how to prepare before the compliance deadline.
- What types of educational entities are covered by Title II of the ADA
- Why your LMS platform provider might cause you to violate the ADA
- What aspects of accessibility are most pertinent to online learning and digital classrooms
- Why everyone at your school – including principals, deans, and chair people – need training on WCAG 2.1 AA
Table of Contents
New Web Accessibility Rule
The new ADA Title II rule generally requires digital assets, content, and documents are WCAG 2.1 AA conformant. There are five exceptions for certain content.
Digital assets include websites and mobile apps. Digital content includes video, audio, and images. Documents are word processing documents, PDFs, spreadsheets, and presentations.
Who is Covered by Title II?
Title II of the Americans with Disabilities Act prohibits discrimination on the basis of disability by public entities, including state and local governments, and their departments and agencies. Under ADA Title II, these entities are required to ensure equal access to programs, services, and activities for people with disabilities.
Amongst other public entities, public schools must be compliant with Title II. Here are examples of different types of public schools and educational institutions covered:
- Public schools
- Public universities
- Community colleges
- Technical schools
- School districts
- Education departments
- Education programs
- Education centers
- Vocational schools
- Public charter schools
- State colleges
- Special education programs
- Adult education programs
Private contractors working with educational institutions must also be compliant with ADA Title II when providing services or products funded by or on behalf of these entities.
For example, if a non-profit or company is providing virtual classes for part of a public school’s class curriculum, that organization must provide an accessible learning environment.
A Sense of Urgency
Schools typically maintain more digital assets and content than most public entities. The ADA Title II compliance deadline is April 26, 2027 for entities serving populations of 50,000 or more, and April 26, 2028 for smaller entities and special district governments. Educational entities should start working towards WCAG 2.1 AA conformance now.
Where to Start
Many proactive steps will be necessary for all websites, mobile apps, learning software, content, and digital content to be WCAG 2.1 AA conformant ahead of the ADA Title II deadline.
Here are some of the most crucial actions public schools can take early on:
Take Inventory
Schools must inventory all digital assets, including websites, documents, and media to know exactly what needs to be accessible.
From websites and content to learning management systems (LMS) and social media, schools need to be aware of all of their digital experiences.
Procurement
Not only must existing digital experiences be accessible, but all future purchases must be vetted for WCAG 2.1 AA conformance. This includes digital products such as:
- software
- apps
- tools
- content
- embeds
- integrations
- portals
- platforms
Learning Management Systems (LMS)
Because so much of learning and classroom activity is based around the learning management system (LMS) for the school, it is essential that the LMS is fully WCAG 2.1 AA conformant.
Thus, the current LMS needs to be closely evaluated to ensure ADA compliance. Many people commonly request VPATs (Voluntary Product Accessibility Templates) to review the accessibility of a product or service, but a VPAT is just the blank template and the technically correct term is an Accessibility Conformance Report (ACR) which is the filled in and completed VPAT.
Here are several items that should be closely examined:
- Verify that the LMS platform can provide an ACR.
- Ensure that the ACR covers all features and functions of the LMS.
- Check to see who issued the ACR.
- The LMS should be recently issued and cover the latest version of the platform.
- Check which issues are listed as non-conformant.
- Note the level of detail in the remarks and explanations session.
It is highly recommended that some preliminary evaluation takes place on behalf of the school to ensure a basic level of accessibility is in place.
Preliminary testing can include screen reader and keyboard testing. Other cautionary measures include scanning and inspecting the website for the LMS.
Learning Content
Certain content is frequently used in the classroom so it’s critical that any educational programs account for:
- audio descriptions
- closed captions
- text alternatives
- interactive elements
Teachers
Teachers or instructors must also do their part to ensure content and learning is made accessible. This is why all teachers should be required to take WCAG 2.1 AA training.
Similarly, other employees, contractors, and staff of the school need to take WCAG 2.1 AA training. This helps in several ways:
- Strict accessibility requirements are met by vendors
- Sufficient budget is allotted for digital accessibility
- Communications from all participants follow best practices for accessibility
- Precedent for prioritizing accessibility is established
Summary
Digital accessibility is essential for learning, but many public education entities are not aware of the details involved in WCAG 2.1 AA conformance. By taking inventory, tracking remediation progress, and requiring vendors to provide verifiable documentation of conformance, public schools can advance towards ADA Title II compliance.
Services
Learn more about how we can help you reach WCAG 2.1 AA conformance with our audit, remediation, and user testing services. Go to Accessible.org to learn more about how we can help you not only make your digital assets and content accessible but integrate accessibility into your processes.
