Digital Accessibility in Higher Education – No longer an afterthought

Is an OCR letter in your college or university’s future?

Did you know that the U.S. Department of Education’s Office for Civil Rights (OCR) has enforced and settled more than 250 digital accessibility complaints against higher education institutions?

To avoid legal action from the OCR, it’s time to make sure that all web pages and web content on your college or university’s website meet accessibility guidelines and are equally accessible to students and parents with disabilities, as well as their non-disabled peers.

But how do you go about implementing such a broad, complex rule?

In this white paper, you’ll gain an understanding of what it means to be accessible, why is accessibility important to higher education institutions, most common digital content issues, digital accessibility roadmap, steps to ensure digital content are made accessible, as well as a long-term accessibility plan.


Higher education institutions are increasingly striving to produce a diverse student body on campus that includes students with disabilities and their non-disabled peers. These institutions have realized that in addition to providing disabled-friendly student accommodations, the digital content distributed to students during lectures and uploaded to websites must also be converted to an accessible format.

Higher education student disability data in the United States

The U.S. Census Bureau has released the National disability data for undergraduate and post-graduate students with disabilities across the U.S.

  • The total student population in the US: 80.5 million*
  • Students with dyslexia: 8.5 million**
  • The dyslexic to total student population ratio: 10.6%***

* ** *** Source: U.S. Census Bureau

Understanding Disability Laws

Section 504

Section 504 of the American Rehabilitation act states that, people with disabilities should not:

  • Be denied benefits
  • Be excluded from participating in programs
  • Face discrimination of any form under any program or activity receiving National federation financial assistance.

To be protected under Section 504, students must qualify and meet all academic and technical standards for admission and participation in education programs and activities. They must also have a disability like:

  • A physical or mental impairment that limits one or more major life activities like seeing, hearing, concentrating, reading, and thinking
  • Proof of such an impairment
  • Being regarded as suffering from such an impairment

Americans with Disabilities Act:

The ADA focuses on the accessibility of physical locations, Title III is clear that one of the ‘Places of Accommodation is “Places of Education.’ So it means that schools, courses, and examinations should be accessible to even people with disabilities.

Institutions of higher learning have by now realized that all website, web pages, electronic assets, and education documents including PDFs should be accessible.

Electronic and information technology accessibility standards

WCAG 2.0

The Web Accessibility Initiative (WAI) of the World Wide Web Consortium has developed guidelines for web accessibility through the web content accessibility guidelines (WCAG). Higher education institutions can refer to these guidelines for web accessibility.

WCAG 2.0 is the most recent version of these international guidelines and comprises 12 broad guidelines under these four accessibility principles:

1. Perceivable

The digital product and website information and interface components should be perceivable to students. For example, it should provide text alternatives for non-text content, like images. And students with disabilities should easily hear and see content, including foreground content on the background.

2. Operable

All the user interface components and navigation links should be operable, and functionality should be made possible via the keyboard. Educational establishments should also provide students with a means to navigate, locate content and determine where they are on the site.

3. Understandable

User interface information and operation should be understandable. For example, all text content should be both readable and understandable. And all web pages should appear and operate predictably.

4. Robust

The site and digital product’s content should be robust enough to be reliably interpreted by multiple user agents, including assistive technologies. There should be maximum compatibility with current and future user agents, including assistive technologies.

The WAI also has a total of 78 ‘successful criteria’ for the WCAG 2.1 to follow and evaluate each guideline’s conformance. There are a total of three levels of conformance for these guidelines, which are:

  • Level A defines essential accessibility
  • Level AA determines a more comprehensive level of accessibility
  • Level AAA for maximum accessibility
  • WCAG 2.0 success criteria apply specifically to web content. However, the WAI has also released guidance to apply WCAG 2.0 standards to non-web-based information and communication technology, especially non-web-based software and documents.

Rise in ADA lawsuits against colleges and universities

There is an increase in the number of ADA lawsuits filed against colleges and universities due to inaccessible websites, online courses, textbooks, or classroom materials. There is also an increase in the number of complaints filed with the Office for Civil Rights (OCR) Department about inaccessible digital documents, technologies, and online delivery systems.

The federal education department has closed 550 of the 600 website accessibility investigations of higher education institutions it opened in 2020. Many higher education institutions like the George Washington University, MIT, and Harvard University to name a notable few have settled the lawsuits filed against them by committing to developing digital documents in PDF formats accessible to everyone.

Higher education accessibility lawsuits and settlements

The Justice Department settles with Louisiana Tech University over inaccessible course materials

Excerpt: The Justice Department announced today that it has reached a settlement with Louisiana Tech University and the Board of Supervisors for the University of Louisiana System to remedy alleged violations of the Americans with Disabilities Act (ADA).  The settlement resolves allegations that the University violated the ADA by using a version of an online learning product that was inaccessible to a blind student.  The student’s lack of access to the course materials persisted nearly one month into the University quarter, at which point the student was so far behind in his coursework that he felt compelled to withdraw from the course.  The settlement also resolves allegations that in a subsequent course, the same student was not provided accessible course materials for in-class discussion or exam preparation in a timely manner.

Justice Department Moves to Intervene in Disability Discrimination Lawsuit Alleging that Miami University Uses Inaccessible Educational Technologies and Course Materials

Excerpt: The Justice Department announced today that it has moved to intervene in Aleeha Dudley versus Miami University, a private lawsuit alleging disability discrimination by Miami University in Oxford, Ohio.  In the United States’ motion to intervene and complaint, the United States alleges that Miami University has violated Title II of the Americans with Disabilities Act (ADA) by requiring current and former students with disabilities to use inaccessible websites and learning management system software, and by providing these students with inaccessible course materials. 

Settlement between Penn State University and National Federation of the Blind

Excerpt: The Penn State University and the National Federation of the Blind (“NFB”) have mutually agreed that the University will an accessibility audit of all its electronic and information technologies, develop an EIT Accessibility Policy Statement, conduct training and provide support for staff, make its website and web content, and course management systems accessible to students with disabilities.

Digital accessibility

Digital accessibility refers to the concept of designing electronic and information material that is available to all, including those with disabilities. In other words, in higher education, it means teaching material is available to students with disabilities as well as non-disabled students.

Generally, digital accessibility refers to the needs of students depending on specially designed technology to complete computer and mobile device tasks. These devices and software applications are called access technology that provides students with disabilities equal employment, education, and opportunity in life.

Today, educators, colleges, and universities have a legal responsibility to provide accessible platforms and instructional materials to all their students. Besides, accessible materials like PDF files, Word, Excel documents ensure all students can participate and benefit through equal learning opportunities.

Why is digital accessibility so important in higher education?

In the context of online courses, accessibility means making it possible for all students, regardless of physical or developmental impairment, to use all course materials and tools. A course is accessible to the degree that every student can get to, perceive, and navigate course content and assignments; submit assignments; and successfully use all course tools.

Accessibility of online courses is important

A significant number of students have disabilities that can make it difficult for them to take an online course.

According to the National Center for Education Statistics, 17% of undergraduate students and 12% of postgraduate students enrolled full-time through the year report having a disability. 21% of undergraduate students and 12% of postgraduate students enrolled part-time or for part of the academic year report having a disability.

Many students with disabilities prefer online courses to face-to-face courses. An accessible online course enables students with disabilities to participate on more equal footing with other students, without drawing attention to their disabilities, or being held back by them.

Accessibility features benefit many students, not just those with documented disabilities. Just as physical accessibility measures have made life easier for many people not categorized as disabled (e.g., ramps assist people with carts, strollers, knee injuries, etc.), many of the accessibility features in online courses help a wide range of students.

Here is a brief look at some common disorders and accommodations that can be adopted by higher education institutions

  • Attention Deficit Disorder/Attention Deficit Hyperactivity Disorder


ADD and ADHD are neurological conditions affecting both learning and behaviour. ADD and/or ADHD affects three to six percent of the population.

Considerations and Instructional Strategies

  • Effective instructional strategies include providing opportunities for students to learn using visual, auditory and hands-on approaches.

Accommodations (may include)

  • Syllabus provided before the start of the semester, copies of classmates and/or instructor’s notes or overheads.
  • Calculator, spellchecker, thesaurus, reader, and/or scribe during exams, tape recorders and/or laptop computers, taped texts, classroom materials, hand-outs and visual aids.
  • Blindness/Low Vision


The following terms are used in an educational context to describe students with visual disabilities:

  • “Totally blind” students learn via Braille or other nonvisual media.
  • “Legally blind” indicates that a student has less than 20/200 vision in the more functional eye or a very limited field of vision (20 degrees at its widest point).
  • “Low vision” refers to a severe vision loss in distance and near vision. Students use a combination of vision and other senses to learn, and they may require adaptations in lighting or the print size, and, in some cases, Braille.

Considerations and Instructional Strategies

  • When giving directions, be clear: say “left” or “right,” “step up,” or “step down.”
  • Allow the student to determine the most ideal seating location so he or she can see, hear and, if possible, touch as much of the presented material as possible.

Accommodations (may include)

  • Adapted computer with features such as, large print, speech synthesizer and Braille printer output.
  • Class assignments available in electronic format, such as computer disk.
  • Videos with audio description.
  • Accessible websites.
  • Deaf/Hard of hearing


Students who are deaf or hard of hearing require different accommodations depending on several factors, including the degree of hearing loss, the age of onset, and the type of language or communication system they use.

Considerations and Instructional Strategies

  • Look directly at the student during a conversation, even when an interpreter is present, and speak in natural tones.
  • Make sure you have the student’s attention before speaking. A light touch on the shoulder, wave or other visual signal will help.

Accommodations (may include)

  • Visual aids whenever possible, including captioned versions of videos and films.
  • The student can use a read-aloud tool to access the text transcript on a computer.
  • Learning disabilities


Learning disabilities are neurologically-based and may interfere with the acquisition and use of listening, speaking, reading, writing, reasoning, or mathematical skills.

Considerations and Instructional Strategies

Instructors who use a variety of instructional modes will enhance learning for students with learning disabilities.

Accommodations (may include)

  • Provide syllabus before the start of the semester, tape recorders and/or laptop computers, copies of classmates and/or instructor’s notes or overheads.
  • Allow the use of calculator, spellchecker, thesaurus, reader, and/or scribe during exams.
  • Allow use of taped texts, classroom materials, hand-outs and visual aids.

Most problematic digital content issues faced by higher education institutions and possible solutions

Higher education institutions more often than not struggle to make their digital content accessible mainly because of two reasons: lack of skilled content creators on campus who can create accessible learning content and faculty who don’t have the time to create and maintain accessible learning content.

  • Inappropriate headings
  • Inaccessible documents
  • Useless alt text

Digital Accessibility Roadmap for Higher Education Institutions

Higher education institutions must have a clear roadmap in place to implement digital accessibility on their campus. The roadmap includes various stakeholders and resources who perform specific roles and report to their superior in a time-bound manner.

Roles and responsibilities

  1. Chief Information Officer responsible for digital accessibility compliance.
  2. Director of digital accessibility responsible for all accessibility efforts and serves as a point of contact for the Accessibility Committee.
  3. Digital Accessibility Committee discusses high-level strategies to ensure the institution is on track for digital accessibility compliance.
  4. Digital Strategy Representatives participate in the Accessibility Committee and oversee new major digital initiatives.
  5. Student Disability Resource Center Representatives serve on the Committee and guide accessibility related to educational efforts.
  6. Accessibility liaisons oversee technology initiatives for a department, college, or division.
  7. Faculty and instructors provide accessible educational material to students.
  8. Deans and Chairs own the final responsibility for digital accessibility in their unit.
  9. Digital platform business owners build or implement new digital products, tools or services that comply with accessibility standards.
  10. Site managers are responsible for the content uploaded to the department websites.
  11. Content creators create content, make content changes and updates to the website.
  12. IT division are responsible for developing new content and properties with accessibility in mind.
  13. Procurement review new digital contracts to ensure accessibility compliance.

Accessibility Hierarchy at Higher Education institutions

The first level is the Chief Information Officer (CIO). The second level is the Accessibility committee. The core group comprising of the Director of Digital Accessibility, Digital Strategy Representatives, and Student Disability Resource Center Representatives are responsible for the overall digital product accessibility compliance. The third level is the Implementation Team comprising of Accessibility Liaisons, Site Managers/Business Owners, and Content creators. The group manages and updates the digital content and properties on a daily basis. They must be trained and conversant in accessibility guidelines and best practices.

Implementation team:

Higher education institutions can adopt a few practical steps to ensure the institution’s digital content, online delivery systems, and technologies are fully accessible to their blind students and those with disabilities. These steps include:

  • They check all electronic and information technology like digital content, websites, learning management systems, classroom technology, library databases, academic resources, and online delivery for accessibility standards.
  • They involve students, staff, and faculty in the usability testing process to get different perspectives and develop a proactive plan to remediate any detected accessibility issues.
  • They prioritize maintaining optimal accessibility standards right from the start and including it in the acquisition and procurement process.
  • Make it mandatory that all vendors provide an accurate product Voluntary product accessibility template.
  • They train the staff, faculty, and students about accessibility issues and standards.
  • They adopt a proactive approach to digital and document accessibility by testing and getting all the highest priority documents first fixed.
  • Last but not least, spreading the word about the institution’s efforts at digital accessibility.

Lastly, accessibility isn’t a project—it’s a long-term commitment to bring your campus into accessibility compliance in all aspects of campus life. Digital accessibility is only one small piece that should be integrated into the bigger plan.

Even as your school works to become compliant, you should create a separate long-term digital accessibility plan to ensure that your website meets all WCAG and ADA compliance standards.

Form a collaborative planning team with various contributors and stakeholders.

2. Assess needs and challenges.

3. Integrate accessibility into your school’s procurement process.

4. Determine who owns what.

5. Perform an accessibility audit.

6. Develop goals and objectives to put an actionable accessibility plan in place.

7. Introduce cross-campus training.

8. Conduct ongoing evaluations.

Digital Access and Inclusion for Higher Education Institutions

codemantra enables higher education institutions to provide accessible learning content to students with disabilities. Our AI-driven platform automates digital document accessibility compliance; captures; classifies and extracts data from documents; and transforms documents to any format.

  • Compliance at scale

Large volume of complex documents remediated at scale.

  • Data accuracy

99% data accuracy through automation and machine learning.

  • Minimal disruption

Seamless integration with existing workflows via APIs.


Web accessibility compliance is a complicated, complex process that benefits anyone who uses your website. The legal implications mean that you can no longer wait to enforce accessibility, so the sooner you can implement a plan, the better.

Furthermore, greater accessibility means that more people can access your website, which will increase the potential size of your site’s audience. Greater audience size means more potential students—and that ultimately increases enrolment.

Fortunately, there is technology available that will assist you in your journey to full web accessibility as well as plentiful resources from higher education organizations and peer colleges and universities. With the tips, guidelines, information, and tools provided in this white paper, you are well on your way to transforming your college or university’s website into a fully accessible site.