Accessibility in Higher Education: What ADA Title II Means for Institutions

Accessibility has been a longstanding conversation in higher education. In the past, institutions made their websites, apps, and online tools user friendly for individuals with disabilities to improve experiences and make obtaining a degree more attainable for all. For many institutions today, however, digital accessibility is not so much an innovation, but a requirement.

In April 2024, the Department of Justice (DOJ) updated its rules for Title II of the Americans with Disabilities Act (ADA), outlining specific requirements for state and local governments to ensure online content and resources are more accessible to people with disabilities. For public institutions, this means complying with Web Content Accessibility Guidelines (WCAG) 2.1 AA and its four principles that make content perceivable, operable, understandable, and robust (POUR).

Let’s explore what this new regulation means for public institutions and why it matters.

An Overview of Title II of the ADA

Title II of the ADA requires state and local governments to make sure their content, services, programs, and activities available online or through digital or mobile apps are accessible to people with disabilities. For higher education, this applies to public institutions and community colleges.

The specific guidelines outlined by the World Wide Web (W3) consortium, the organization that created and maintains WCAG through its Web Accessibility Initiative (WAI), include making content that is POUR:

• Perceivable: People must be able to notice and access the information. Nothing important should be hidden or only available in one way. For example, images should have text descriptions, and videos should include captions so users can understand the content even if they can’t see or hear it.
• Operable: People must be able to use and navigate the content. The site or system shouldn’t require actions that some users can’t perform. For example, users should be able to navigate using a keyboard or voice commands, not just a mouse.
• Understandable: People must be able to read and make sense of the information. Content should be clear, readable, and predictable. For example, text should be easy to read, and instructions should be straightforward and consistent.
• Robust: The content should work with a wide range of devices and assistive technologies, now and in the future. For example, screen readers and other accessibility tools should be able to correctly interpret the content.

Effective in June 2024 (and updated in April 2026), the DOJ also provided a timeline for when institutions need to comply with the new regulations. The timeline is based on the population served by the state or local government.

But these dates are not a one-and-done implementation. According to the DOJ, institutions must continue to make sure their web content and mobile apps meet WCAG 2.1 Level AA after their compliance date.

Why Does April Matter for Institutions?

The April 2027 and April 2028 deadlines are important for institutions, as failure to comply with these regulations can lead to lawsuits, loss of public funding, as well as damage to their brand and reputation—all of which can have a lasting impact in today’s hyper competitive, financially strained higher education environment.

This applies to every institution: Public institutions are specifically required to adhere to the regulations. Private institutions, meanwhile, will often still need to meet state-level WCAG rules as well as Section 504 of the Rehabilitation Act, which requires equal access to free appropriate public education to students with disabilities.

When institutions prioritize accessibility, everyone wins. Not only are online experiences and content more inclusive, but the overall quality of learning is better.

Operate With a Single Source of Truth

As the April deadlines approach, institutions should take a few actions:

1. Confirm the Applicable Deadline
   Institutions should identify the population they serve and plan for the earliest applicable date. This will ensure they do not miss the deadline.
2. Assess Current Accessibility Approach
   Institutions should audit their web and mobile platforms, as well as all third-party tools, to ensure their content and experiences are up to code with WCAG 2.1 Level AA. Campus leaders should also ensure that all vendors provide WCAG 2.1 voluntary product accessibility templates (VPATs), which are standardized documents that demonstrate how vendor products comply with accessibility regulations.
   
3. Address Issues and Plan to Adapt Over Time
   One of the most important things for institutions to do is to fix any tools, processes, or resources that do not comply with WCAG 2.1 Level AA. Prioritize these issues, fix them, and schedule ongoing reviews to ensure there are no breaches in compliance down the road. Similarly, institutions should train staff in developing and using accessible content.
4. Integrate Accessibility Into Operations
   Internally developed, homegrown applications are not exempt. Institutions must ensure that all content creation processes and platforms across campus adhere to WCAG requirements. This entails building accessibility approaches into day-to-day operations so all learners and staff can leverage the tools and resources they need for success.

How Can Jenzabar Help?

Jenzabar is committed to making higher education accessible and available to all. We have adopted a product-wide standard for compliance with WCAG 2.1 AA, and we have WCAG 2.1 VPATs for many of our products (we continue to expand our coverage).

Additionally, we have embedded accessibility across design, development, and quality assurance processes, standardizing the testing tools we use so our systems are functional for individuals with disabilities. We have also implemented continuous monitoring, leveraging automated scans, manual testing, and independent audits with industry experts (Level Access) to assist with compliance.

Accessibility is a complex but important part of higher education. These updated requirements expand and reinforce equity as a compliance obligation to maintain equitable student experiences. Institutions must now take action to meet regulations, mitigate risk, and improve experiences.

If you'd like to learn more about accessibility or how Jenzabar incorporates accessibility into its systems, click here to meet with us. If you're an institution already using Jenzabar's solutions and would like to learn more, you can access an FAQ here. If you’d like to have a more detailed conversation, please contact your Customer Success Manager today.