ADA Title II Web Accessibility: A Compliance Guide for Small K–12 Districts

Building Your Compliance Roadmap: A Five-Step Action Plan

The extended deadline to conform to WCAG 2.1 sounds generous, until you factor in the reality that most small districts are working with limited budgets, lean IT teams, aging infrastructure and websites with years’ worth of content not built for accessibility. 

When district leaders dig into their existing repository of digital content, the task of getting everything up to ADA standards can feel insurmountable. But they can learn from industry experts and districts that have done the work before. This practical guide is meant to help schools more clearly and smoothly navigate their journey toward web accessibility. 

Step 1: Inventory Your Digital Assets: Websites, Documents and Apps

Lindsay Jones, CEO of education nonprofit CAST, says that taking inventory of digital assets goes hand in hand with making sure you’re not creating new content that’s inaccessible.

“The starting place for that is an understanding that any content you’re creating today and going forward is created in an accessible way,” Jones says. “You’ll want to invest in a little bit of training for that.”

And that training will be the responsibility of the person or team in charge of overseeing the compliance project.

Sara Kloek, vice president of education and youth policy for the Software and Information Industry Association, says that the biggest question revolves around what older content is necessary for a school to keep.

“How do you make sure that you have transparency for your community members, taxpayers, those that support the school?” she asks. “How are you making sure that the older content is still available, so people can do the reviews that they want to do and access information they want without the barriers to entry?”

The overall goal, Kloek says, is to make sure that all people can access information. To that end, the Universal Design for Learning framework, developed by CAST, is one common way for schools to fulfill the ADA Title II web accessibility requirements. CAST offers many resources to help schools make progress in their journey toward compliance:

• How To Create Accessible Websites 
• How To Create Accessible Documents
• How To Create Accessible Social Media Posts 
• How To Create Accessible Video
• AEMing for Access: Accessible Presentations
• AEMing for Access: Title II Prep 

Step 2: Audit for WCAG 2.1 AA Compliance

While two years might feel like a long time, districts should keep in mind that the auditing process is no small task — and it depends largely on the capabilities and the available time of the staff. IT teams should start early and schedule time to work through a comprehensive content audit.

“If they have a lot of staff time in the summer to do this work, then they’ll want to prioritize it over the summer. Or, if the IT departments will have a slower time in a certain month, then really dig in on that time. But it has to get done. There is a possibility of lawsuits for noncompliance,” Kloek explains. 

Step 3: Prioritize High-Impact Wins First

One quick win is to ensure that you’re not purchasing any new products that don’t meet accessibility standards. 

“Now that schools are coming to the end of their budget year, this is the perfect time to be thinking about what you are purchasing next year,” says Jones. “What RFPs are you putting out that have to do with web accessibility and digital tools and products?”

Schools can also figure out which of their current vendors are already compliant, “and then cross that off, because it feels good to cross things off the list,” Kloek says. 

Step 4: Update Vendor Contracts and Platform Accessibility Requirements

Speaking of vendors, the starting place for any school district is usually the same: reviewing procurement processes, understanding contracts with vendors and assessing the school’s digital accessibility ecosystem.

“Schools have great power in procurement, and they control the language in the contract. They can talk to vendors proactively about what their needs are and how those vendors are going to provide support to ensure that they will be able to comply with the law,” Jones says.

Of course, before making any purchases, it’s important to first update the language in any vendor contracts “to make sure that you aren’t purchasing something you then have to remediate,” Jones adds. CAST offers resources and templates for contract language that schools can use, such as this one on procuring accessible educational materials, which includes sample generic RFP language and district RFP examples.

School districts should also ask to see a vendor’s Voluntary Product Accessibility Template, which explains how their product is accessible and to determine if it conforms to current WCAG standards.

While many vendors are working hard to comply to WCAG standards, “there are not a lot of vendors who post those proactively on their websites, so the schools need to look at vendor websites and see their VPATs, and see what they conform to,” Kloek recommends. “School districts also need to make sure that the version of the tools they are using is aligned to the required version of WCAG 2.1. Because if they are using older versions or tools that were developed years ago, then they might want to review those and see if they have been updated to conform to the required accessibility.”

However, keeping vendors accountable over time, when platforms need to be updated, should be on the radar for districts. “I do think these rules are pushing vendors in a really good direction, because this expands the market for them,” Jones says. “This is something their clients need. It’s removing barriers, and more people can use their products. So ultimately, they should be doing it. There’s a market imperative in addition to the compliance imperative.” 

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Step 5: Train Staff and Build Accessibility Into Ongoing Content Workflows

Wendy Kemling-Horner, executive director of student services at Scottsbluff Public Schools in Nebraska, says that one of the biggest challenges in progressing toward compliance has been “prioritizing the extensive requirements while balancing the ongoing responsibilities of district staff without additional personnel.” Like many rural school systems, Scottsbluff is working to integrate accessibility improvements into existing workflows and responsibilities rather than hiring additional staff. “To address this challenge, we have prioritized high-impact areas first. Collaboration, ongoing training and a phased implementation approach will help us make steady progress,” Kemling-Horner says.

For Moore County Schools in North Carolina, Neil Waters, chief administrator for exceptional children’s services, says that it’s “the tendency to work in silos that makes it difficult to drive change for a whole system. Being a part of the CAST CITES cohort has helped our team come together to find all the crossover between our roles that we never knew existed. Our work with CITES is helping us use this common ground and common language to plan a way forward that will put accessibility front of mind in our work with all students, employees and parents.”

Beyond the Deadline: How To Sustain Accessibility Compliance Over Time

As schools move through the compliance journey, it helps to keep in mind that the real challenge takes place at the beginning of the process.

Jones acknowledges that it can feel overwhelming at the outset. “But I think once people start to take stock of what they’ve done that is accessible, they start to see, ‘Oh, we actually have some of these practices in place.’ And then what appears to be this overwhelming project, you break it into small pieces,” she says. “What we have found is that districts are surprised. They’re doing a lot, they are creating things right now that are accessible, and so they’re homing in on certain areas, and they have a whole extra year to do it. So, it’s a great time to start planning how to attack that.”