“What the new rule is focusing on is the digital piece, which is often overlooked in K-12,” says Dr. Natalie Shaheen, an associate professor in both the Department of Special Education and the School of Teaching and Learning at Illinois State University. According to Shaheen, this emphasis is important because of a common misconception. “The biggest misunderstanding is that if something is digital, it’s accessible to disabled people,” she tells SchoolCEO. “And that is just not true. The increased use of instructional technologies and materials has magnified, not minimized, the access barriers that disabled students face.”

Take, for example, a dissection in a high school biology class. When these exercises take place in real life, blind students can participate by touching the physical specimen. “But now, dissections are often digital simulations,” Shaheen explains—and they’re often inaccessible. While sighted students see clickable buttons with clear functions, these buttons aren’t often labeled with alt text—brief written descriptions embedded in the code that can be read by screen readers. This leaves blind students with nothing but the word “button.” 

“So the blind student can figure out there are 10 buttons in this simulation. That is literally it,” says Shaheen. “What do those 10 buttons do? Who knows?” In other words, the blind student is completely shut out of the learning experience. That’s why the newest regulations focus on digital accessibility—to ensure that no matter how or where the learning takes place, disabled students can participate. 

In theory, the ADA has always required that public school districts’ digital presences be accessible. However, what was included in “digital presence”—and what constituted the standard for “accessibility”—were previously unclear. The new rule concretely defines these previously nebulous requirements.

The biggest change is naming the new standard for compliance: the Web Content Accessibility Guidelines (WCAG) 2.1 Level AA. These guidelines, developed by the World Wide Web Consortium (W3C), provide enhanced clarity regarding what districts can do to help ensure ADA compliance. We highly recommend consulting this list for a complete breakdown of new requirements. On the following page, we round up the biggest points to keep you on track. 

The current WCAG standards focus on four key principles of accessibility: perceivability, operability, understandability and robustness. Here we’ll give a short explanation of each principle based on guidance provided by the W3C, along with examples of WCAG requirements that fall under each one. While this isn’t a complete overview of WCAG 2.1 AA, it will give you an idea of what makes digital content accessible and the types of changes you may need to make to your district’s digital presence.

Perceivable

Visitors to your website, app, digital learning platform or other online tools must be able to consume your content—regardless of any disabilities they might have. Blind people who rely on screen readers, for example, must have the same access to information as sighted users. When families visit your website to find a bus route, enroll a child or read about a program, they should all be able to get what they need quickly and independently.

Examples:

• Images must have descriptive alt text that can be read by screen readers.

• Audio-only content (like podcasts) must have descriptive transcripts.

• Videos must have synchronized captions.

• Text must contrast with its background at a minimum ratio of 4.5:1.

Operable

Your digital content should be easy for anyone to navigate and use—including those with disabilities. This means your website should be easy to operate whether someone is using a screen reader, a joystick or simply a keyboard.

Examples:

• Users must have access to all functionality using only a keyboard.

• Webpages must have descriptive and informative page titles.

• Users should be able to determine where a link will take them from the linked text and its surrounding context.

Understandable

Your district’s digital content should be easy to understand and presented in a logical way. This will make it easier for your entire audience to navigate your digital spaces—but especially people using adaptive technologies.

Examples:

• A webpage’s code should indicate the language in which its content is written. 

• Elements that remain consistent throughout a website (such as the top navigation) should be labeled the same way and presented in the same order on every page.

• Online forms must clearly identify potential errors (such as a skipped input), provide easy access to the problematic element and indicate how the error can be fixed.

Robust

To be “robust,” your digital content must be able to be reliably interpreted by a variety of different browsers and assistive technologies. Your content should remain accessible even as these various technologies update and evolve.

Examples:

• Your content must be coded correctly and have complete start and end tags.

• Your content should be accessible even if someone is using an older version of an operating system or browser.

Believe it or not, our breakdown just scratches the surface of WCAG 2.1 AA—but the nonprofit Web Accessibility in Mind (WebAIM) offers even more detailed guidance and materials, including checklists, for meeting the new rule’s requirements. Click here to check them out.

Over the past few decades, your schools have likely accrued lots of what Shaheen calls “technical debt”—inaccessible apps, software, digital curricula or other technologies that will now have to be either replaced or brought into compliance. 

“That’s not a small thing,” she says. “But this work is an equity imperative. You can’t provide equitable education unless and until all of the digital technologies and instructional materials you use are accessible to all your students.” It’s a big job, but there are a few steps you can take to make your accessibility updates as smooth as possible. 

Make sure your staff understand what’s required.

One reason this process is complicated is that technology has become so prevalent even at the classroom level. Teachers often find and use their own digital tools to communicate with families or even to present curriculum. “I approve of teachers having some liberty to choose instructional materials and to be able to create content for their courses,” says Dr. Mary Rice, an associate professor of literacy at the University of New Mexico. “But they need some tools for how to evaluate those, especially for these basic things about accessibility.” 

And often, teachers don’t have these tools. Sometimes, no one in the district does. “A big, big challenge in all this is going to be the lack of knowledge about accessibility among educators—both teachers and administrators,” Shaheen says. Rice agrees: “For the most part, K-12 school districts don’t have, and maybe have not ever had, an administrator with responsibility for knowledge about digital accessibility,” she says. 

Coming into compliance is going to be too much work for one person or even one department. “Don’t just assign it to the special education department,” says Shaheen. “If you do that, you’ve already failed. Previous research has shown us that is not how to get it done.” Instead, she says, “the overall approach really does have to be collective. You need to establish accessibility as a collective districtwide priority.” 

So make sure your teachers and other staff members are aware of the updates to Title II. Send them the WCAG checklist. Run a professional development session on it. If each individual member of your team can identify the technical debt existing in their own work, it will be that much easier to catalog and address.

Tackle the areas of greatest need first.

With so much work to be done, you might be feeling overwhelmed. Where to begin? While all your digital assets need to be compliant by your deadline, Rice recommends starting with the assets most likely to be used by disabled students, family members or staff members. “Go to your special ed department and handle all of your stuff about IEPs first, because that’s one place you know you’ll have people with disabilities,” she says. “If you have a large number of children in a specific grade or subject matter area who have a specific kind of accessibility need, then do that first.” 

Think about it the same way you would physical accessibility issues. If a third grader in your district used a wheelchair, you’d prioritize making that child’s elementary school and classroom accessible over, say, the middle school or high school. It all has to get done—but you want to tackle the areas of highest need first.

Seek your vendors’ support.

Before the updates, the ADA’s rules for third-party digital content produced by vendors were unclear. “There used to be some sense that the regulations only applied to content that you generated as an institution, not that third-party vendors created for you,” Rice explains. “So the work-around was that schools would just third-party everything out.” But that is no longer the case. Whatever your district has done in the past, you’ll now need to make sure all your content—third-party or not—is ADA compliant.

At the end of the day, it’s your district—and not your vendors—that will be held responsible. “Even with these new regulations, vendors have no liability in this work whatsoever,” Shaheen explains. “If a school chooses to use some personalized learning app that is completely inaccessible, the app developers don’t get in trouble. The school district gets in trouble.” That’s why it’s crucial to contract with knowledgeable, trustworthy, supportive vendors who can partner with you through this transition.

Remember who it’s for. 

Shaheen, who has seen a lot of organizations go through this process, says people’s motivation for doing the work often goes through three distinct phases. “As it starts out, they’re doing it because they have to comply with the law. When that’s their motivation, they’re angry and resentful,” she explains. “Then, they progress to this idea that their purpose for doing this accessibility work is to help disabled people. When they’re at that place, they feel ownership of the work—but they also feel overwhelmed because they see how much there is to do.”

But the most significant shift, she says, comes when the people doing the accessibility work—whether they’re teachers, administrators, IT directors or even vendors—actually talk to students and families about their experiences with inaccessible technologies. “If you haven’t had to confront what happens when technology is inaccessible to a student, then you don’t realize the harm that’s happening,” Shaheen explains. “But when you have the opportunity to talk with those kids and learn about that harm, you realize you’re doing it because it’s an educational imperative. When you get to that place, you start to feel really fulfilled and proud of the work.” 

Shaheen is quick to point out that having this new perspective doesn’t magically make the work easy or make money grow on trees. “But it changes people’s motivation, and that helps them to feel a different way about the work, which creates a little bit less internal friction,” she says. “The school leaders I’ve talked to who’ve gone through the whole process say that though enacting digital accessibility was difficult, overwhelming, frustrating and definitely time-consuming, it was worth the effort—because addressing accessibility was imperative to their mission to provide education for all.”

So yes, ADA compliance is required by law, but it’s also an act of hospitality. By meeting all requirements, you are recognizing the individual needs of your community and showing up for every member. And while the deadline has been pushed back, don’t put it off until the very last minute. You have students and families who need it now—and serving them is both your mandate and your pleasure.