Background
In April 2024, the Department of Justice announced further guidance for how public-sector institutions may achieve digital accessibility compliance under Title II of the Americans with Disabilities Act (ADA). Digital accessibility compliance is designed to promote the equitable consumption by persons with disabilities of technologies and electronic content. This includes academic and website documents, the navigation of websites, streamed and recorded voice and video, and various mainstream and assistive applications.
Following this clarification, the Universities of Wisconsin (UWs) established the ADA Title II Core Team to coordinate efforts across the system. Upon assessing this guidance, the UWs established April 2026, as the digital accessibility compliance date for all campuses within the system. Utilizing this target date, the ADA Core Team then began efforts to help guide the activities of covered content and technologies.
Concurrently, UWM launched the Digital Accessibility Taskforce (DATF) in response to this guidance. Our purpose has been to identify the scope of content and technology which requires remediation and to establish the means for how this could be accomplished by the compliance date and sustained into the future. This work includes the development of strategies which can be leveraged to reduce this scope, prioritize efforts, and optimize the process for what needs to be remediated.
Taskforce Planning
Through the DATF, an Implementation Workgroup was established to define how UWM could achieve and sustain compliance. This work began with the development of strategies to optimize how we may achieve this outcome. Leveraging these strategies, an action plan was drafted to describe the major actions that are required to achieve our deliverables. This document captures the plan developed in this workgroup. To establish this effort as a project with milestones and a schedule, an implementation plan has been drafted drawing upon these actions.
Stages of the Action Plan
Through the Implementation Workgroup, 12 major actions were identified. These actions are split between what is required to achieve compliance and what is required to sustain it.
Achieving Compliance
- Conduct an Audit
- Establish Priorities
- Create Plan
- Host Initial Training
- Discovery and Remediation
- Assess Progress
Sustaining Compliance
- Define Policies and Guidelines
- Establish Governance and Practices
- Integrate Accessibility into Design
- Provide Ongoing Training
- Monitor for Effect
- Continuous Improvement
Following these actions, the Taskforce is promoting the theme of “Don’t wait. Act now.”
Achieving Compliance
1. Conduct an Audit
Start with identifying major stakeholders of covered content and technologies. With this awareness, reach out to them to conduct a thorough audit of all digital content and technologies to establish the scope of what requires remediation. This includes websites, electronic documents, videos, audio files, and applications. Identify the type and volume of work required for each group of covered content and technology identified. This will provide a forecast of the labor required to conduct this work with a basic understanding of where this work needs to be done.
2. Establish Priorities
Establish the criteria for how we prioritize content and technologies that require remediation. Leverage a risk management framework to establish this prioritization protocol. Frame up these priorities by population to help shape the work to be done. Utilize the following groupings:
- Academic Content – organize content to remediate by semester
- Web Content – organize content by student and employee lifecycles
- Web Sites – organize content by frequency of use
- Technologies – organize applications by frequency of use
3. Create a Plan
Identify major actions to achieve and sustain compliance. Establish milestones, timelines, and deliverables from this work. Create a communications plan to promote awareness and rally resources. Identify investments what will drive these outcomes. Establish a project plan based upon these milestones to create an implementation schedule. Identify tools to reduce workloads. Leverage audit to scope and forecast work and utilize priorities to focus upon highest risks first.
4. Host Initial Training
Develop and host remediation training to prepare content owners for this work. Leverage workshops to provide in-depth tool and remediation training for select content owners and self-service training to provide more limited training for a broad range of content owners. Seek to ensure as many content owners are trained in advance of the compliance date as possible focusing upon those who have more immediate needs.
5. Discovery and Remediation
Utilize training and tools to discover content to remediate. Leverage stakeholders to engage content owners to promote remediation activities utilizing project plan schedules.
6. Produce Reports
At specific milestones, develop reports which showcase remediation activities demonstrating progress towards compliance prioritized by risk.
Sustaining Compliance
1. Define Policy and Guidelines
Establish policy which defines expectations for what digital accessibility compliance looks like and how non-compliance is reported and addressed.
2. Establish Governance and Practices
Establish governance to develop and maintain a compliance framework to ensure consistent organizational practices. This includes assessing and prioritizing ongoing risks and ensuring compliance with evolving standards.
3. Integrate Accessibility into Design
Incorporate accessibility from the design phase to avoid future issues. Train designers and content creators on accessibility principles and use tools like Universal Design and the Accessible Design Principles and Heuristics Guide to significantly reduce the number of issues found during development and testing.
4. Provide Ongoing Training
Ensure everyone who develops applications, websites, and electronic content creators receive regular training on accessibility standards and best practices. This helps maintain a high level of awareness and competence across the organization.
5. Monitor for Effect
Regularly monitor the progress of your accessibility initiatives and adjust as needed. Use automated accessibility testing tools to regularly check for compliance.
6. Continuous Improvement
Monitor emerging technologies for non-compliance, new tools for enhanced discovery and remediation, and new practices to promote more effective equity for persons of disability and digital accessibility compliance.