Title II Compliance Strategy  (DRAFT)

Key Points of the New Title II Rule

• The Web Content Accessibility Guidelines (WCAG) Version 2.1 is now the official technical standard for web content and mobile apps for state and local governments.
• The WCAG standard applies to all web content and mobile apps provided or made available by UNI, including any created and/or managed by third parties.
• The deadline for full compliance for UNI is April 2026.
• Limited exceptions are specified in the ruling, mainly pertaining to archived materials and pre-existing conventional electronic documents.

The charge of the Title II Team is to develop and implement a comprehensive strategy to ensure UNI’s digital content meets new ADA Title II rules including required Web Content Accessibility Guidelines (WCAG) (Version 2.1 Level AA) by April 2026.

Guiding Principles for UNI Compliance

• Focus on areas that have the greatest impact with the resources available.
• Use a user centered approach in all efforts.
• Create sustainable solutions.
• Provide clear communication to the campus community.

Steps to Compliance

1. Assess Needs:  Identify/Inventory Systems and Content (see Iowa’s template)
   1. Identify systems needing a compliance plan (create plan)
   2. Identify systems that have a plan underway (review plan)
   3. For systems/content managed externally, ensure plans are in place
   4. Add new systems and content as they are discovered
2. Prioritize Needs: Create Prioritization Framework based on
   1. Usage and importance of the content/system
   2. Current level of accessibility
   3. Complexity of required remediation
   4. Available resources for the specific work needed
3. Remediate:  Establish Systematic Approach to Remediate Identified Needs
   1. Adhere to WCAG standards
   2. Train content creators on required standards
   3. Create/implement tools and processes for ongoing testing for accessibility
   4. Engage with third party vendors to ensure compliance
   5. Ensure procurement process is compliant with adoption of required standards
4. Exceptions:  Develop/Implement Procedures for Evaluating/Tracking Exceptions
   1. Archived web content
   2. Pre-existing conventional electronic documents
   3. Individualized, password-protected documents
5. Monitoring:  Implement Auditing and Testing Procedures
   1. Ensure ongoing compliance
   2. Review feedback mechanisms for users to report accessibility issues
   3. Make improvements as needs are identified
6. Policy/Governance: Assure Ongoing Campus-wide Compliance
   1. Review policies and procedures on digital accessibility and update as needed
   2. Establish accountability roles and responsibilities for maintaining accessibility
   3. Develop procurement guidelines to ensure new services meet standards
7. Communication: Develop/Implement Campus-Wide Communication Plan
   1. Review the ruling and how it will impact campus units
   2. Outline changes being made to meet and maintain compliance standards
   3. Generate buy-in and support to ensure success
8. Timeline/Reporting: Establish Timeline for Progress Reports to Stakeholders/Cabinet
9. Resources: Identify Additional Resources Necessary for Compliance
   1. Provide details of any additional resources needed to meet deadline
   2. Provide details of any additional resources needed for sustainability