Digital Accessibility FAQ

The what and why of Title II

Title II of the Americans with Disabilities Act (external link) is a federal civil rights law requiring public institutions to ensure individuals with disabilities have equal access to programs, services, and activities, including courses.

The new Title II ruling (External Site) states that all public colleges, universities, and other state and local government agencies must make their websites, mobile applications, online materials, and any other digital tools or content accessible so people with disabilities can use them. Digital accessibility ensures that technology and digital content can be used by everyone, regardless of their abilities.

The deadline to meet this requirement is April 24, 2026.

Title II changes impact us all. 

All digital content, whether it is used internally between departments or colleagues, in the classroom setting, online, or on a webpage, must be created to be accessible. This means following WCAG 2.1 Level AA accessibility standards (External Site) when creating and sharing digital content.

ADA Title II: A Complete Guide for Public Entities (External Site) helps us understand more about our responsibilities and requirements.

The University of Maine System is committed to fostering an inclusive digital environment that serves our entire community. Making sure we meet the most recent requirements for digital accessibility under the Americans with Disabilities Act (ADA) will remove barriers that prevent people with disabilities from fully participating in our community. These updates also improve usability for everyone. This creates a more equitable and inclusive learning environment where all students, faculty, and staff have an equal opportunity to thrive.

Digital Accessibility in Courses and Brightspace

Start with the materials you use most often, especially those used every semester, such as syllabi or documents that are frequently used within your department. Give priority to required readings and content for the first few weeks of class. UMaine has developed an Accessible Syllabus Challenge (External Site) that can help faculty with syllabi.

The Accessibility Checklist (Word Doc) provides additional guidance and resources for a variety of documents and media.

Digital course content should be treated like any other public web or mobile app content, meaning accessibility requirements apply to everything you provide to students online. This includes syllabi, readings and textbooks, recorded lectures and videos, slide decks, Brightspace pages, assignments, handouts, images, diagrams, and course websites. In practice, you should prioritize making accessible the materials you actually use and share with students—such as required readings, videos, and documents.

While you are not required to post resources online if you do not already do so, any content you choose to host digitally must be made accessible.

No, not posting materials is not an acceptable compliance strategy for required course content.

While faculty have discretion over what to share with their classes, we strongly discourage using non-posting as a way to avoid Title II compliance.

Here’s how it breaks down:

Supplemental/optional materials: You can choose not to post these to avoid remediation work. But if they are posted they must meet the WCAG 2.1 AA standards.

Required course materials: You cannot avoid compliance by not posting. Students must have access to an accessible version or an equally effective alternative.

What we recommend: Instructional designers and campus resources can provide training, guidance, hands-on support, and consultation to help you develop accessible materials. However, faculty are ultimately responsible for ensuring their course content meets compliance standards. Reach out early to learn the skills and get support.

Bottom line: All content shared through any web-based platform must meet accessibility standards. If you choose to stop sharing specific content, that’s your decision and your responsibility to ensure students still have what they need to succeed in the course.

Faculty are responsible for communicating their course content decisions to students.

However, you won’t be expected to explain Title II law on your own. We are working to provide:

  • System-wide messaging about what Title II is and why it matters
  • Standard language templates you can use when communicating with students about course materials

What this means for you: You decide what to share in your course and communicate those decisions to students. We’ll provide the supporting language about Title II so you don’t have to become a legal expert.

The accessibility obligation is ours, not theirs—even when materials come from accrediting agencies or professional boards.

If students must use these materials to complete program requirements, we must provide equal access.

Your options, in order of preference:

1. Request an accessible version from the source

  • Ask the accrediting agency or board for accessible materials
  • Document your request (keep records)

2. Create an accessible equivalent

  • Remediate the materials ourselves (if our license permits)
  • Provide an accessible summary of required information
  • Offer an accessible alternative that covers the same requirement

3. Work with Student Accessibility Services

  • If materials cannot be made accessible to a student with a known disability who has requested accommodations before students need them, coordinate with SAS immediately
  • Critical deadline: Accommodation requests for accessible digital materials must be fulfilled within 48 hours
  • Ensure students receive accessible versions in time to meet all course and program deadlines

Important: Paper copies alone do not satisfy accessibility requirements. Students may need digital accessible formats to participate on equal terms.

The accessibility obligation is ours, not theirs, even when materials come from outside organizations such as vendors, government agencies, accrediting bodies, testing services, or professional associations.

If a person must use those materials to apply, complete a process, meet a requirement, or access a university service, we are responsible for providing equal access.

Your options, in order of preference:

  1. Request an accessible version from the source
  • Ask the outside organization to provide an accessible version of the material.
  • Document the request and keep records of the response.
  1. Create an accessible equivalent
  • If permitted by license or terms of use, remediate the material ourselves.
  • Provide an accessible version, summary, or alternative format that gives the person access to the same required information or function.
  1. Coordinate with the appropriate campus offices immediately
  • If the material cannot be made accessible before it is needed, work right away with the relevant campus partners to identify an equally effective alternative and ensure timely access. Depending on the situation, that may include HR, Admissions, Student Accessibility Services, Equal Opportunity, or other responsible offices.

What this looks like in practice:

  • If Admissions requires applicants to use guidance or forms from an outside testing or credentialing body, the university must ensure applicants can access that information.
  • If HR or a search committee relies on external materials as part of a hiring process, applicants must be able to access them without barriers.
  • If a university office directs students, employees, or the public to third-party content in order to complete a required process, the office remains responsible for access to that process.

Bottom line: We cannot shift accessibility responsibility to an outside organization when the material is part of a university requirement, service, or process. If we require it, assign it, or rely on it, we must make sure people can access it.

No, accessibility standards do not differ by modality—but the specific requirements for live vs. pre-recorded content are different.

For live synchronous classes (including HyFlex):

  • Live captions are required
  • Captions do NOT need to be 99-100% accurate (unlike pre-recorded videos)
  • Real-time audio description is NOT required under WCAG 2.1 AA

For pre-recorded videos:

  • Captions must be highly accurate (99-100%)
  • Audio description IS required (Level AA)

Important distinction: These are the baseline WCAG standards. Individual students may still request additional accommodations through Disability Services (for students) or HR ADA Coordinator (for staff). Those accommodation requirements come from disability law, not WCAG, and may require higher levels of support than the baseline standards.

Training: No separate training is required by modality, though Instructional Designers can share best practices for presenting live to diverse audiences.

The Office of Equal Opportunity and Title IX Services has final authority on accessibility compliance.

About automated tools (Ally, DubBot, etc.):

  • These are helpful for identifying potential issues
  • They are NOT the final authority on compliance
  • Contradictory results are normal—different tools use different rulesets and detection methods
  • Treat their results as a starting point, not a final decision

How compliance is actually determined: Automated scores may trigger manual review and testing with assistive technology to determine what actually needs fixing.

Why you can’t rely on scores alone:

  • High score ≠ compliant: A course or web content with a 90% Ally/DubBot score could still have inaccessible essential content
  • Low score ≠ non-compliant: A course or web content may score lower after fixes, depending on how the tool weights remaining items

Bottom line: Automated tools point you toward problems, but they don’t make the final call. When in doubt, consult with campus accessibility resources or the Office of Equal Opportunity and Title IX Services.

Yes, you can disable Ally’s alternative formats on a per-document basis.

Use this option when:

  • The alternative format is inaccurate or misleading
  • It undermines instructional goals (for example, a language assessment where the alternative format reveals answers students are being tested on)
  • The output is counterproductive to student learning

Important: Disabling alternative formats doesn’t remove your accessibility obligation. You still need to provide accessible versions to meet WCAG 2.1 AA through another method when students need them per an accommodation.

No. Ally cannot be disabled for an entire department or unit.

That said, Ally’s alternative formats can be disabled on a document-by-document basis when the output is not useful or creates confusion.

A few helpful points of context:

PDFs and accessibility

The legal expectation under ADA Title II is that content meet WCAG 2.1 Level AA outcomes. PDF/UA is a technical standard for how PDFs can be constructed accessibly, and it can be helpful evidence of good practice, but it is not itself the legal standard.

In practice, accessibility depends on whether the content works for users. For PDFs, that often includes things like proper structure, readable text, meaningful headings, alt text where needed, clear navigation, labeled form fields, and making sure the file is not just a scanned image.

Math content and Ally

It is fair to say that math content can be challenging for Ally, especially when equations are embedded as images or flattened into inaccessible PDF content. At the same time, it would be inaccurate to say Ally cannot work with math at all. Support has improved, particularly for equations authored in more accessible ways.

For example:

What this means for faculty

For faculty teaching math-intensive courses, the goal is not to impose a single workflow or tool. Different disciplines, course designs, and teaching styles may call for different approaches.

Brightspace’s equation editor (MathML/LaTeX) for LMS content (guide opens in a new tab)

and Word’s equation tools for documents (guide opens in a new tab) are two available options because they can produce math in forms that are generally more usable for accessibility tools and assistive technology. They are not being presented as the only options, and they may not be every faculty member’s preferred approach.

The broader point is that when math is authored as real equation content rather than as an image, accessibility usually improves, and Ally tends to produce more useful results.

Resources: Accessibility Handbook for Teaching and Learning – Accessible Math

Managing Ally in math-heavy courses

When Ally flags become excessive or misleading:

  • Alternative formats can be turned off for specific documents.
  • Faculty can focus on improving the source content where practical.
  • Ally should be treated as one indicator, not the final authority on whether material is accessible.

Important note

Turning off Ally features for a specific file does not remove the underlying accessibility responsibility. The expectation to provide accessible course materials remains, regardless of whether Ally is enabled for that document.

Footnotes can be accessible, but only if properly formatted. You can continue using them if you follow specific requirements.

The accessibility problem: Traditional footnotes force users to jump to the bottom of a page and navigate back—difficult for screen reader users and people with cognitive disabilities.

Three requirements for accessible footnotes:

1. Bidirectional links

  • The footnote number links to the note
  • The note has a “return” link back to the exact reference point
  • Without both links, users get stranded

2. Semantic tagging

  • HTML: use role=”note” or <aside>
  • PDFs: use <Note> and <Reference> tags
  • This tells assistive technology what the element is

3. Descriptive labels

  • Use aria-label or hidden text (e.g., “Footnote 1”)
  • Without this, screen readers just announce “One”—meaningless out of context

Bottom line: If you can implement all three requirements, footnotes are acceptable. If not, consider inline citations or endnotes with proper links instead.

We follow both laws. Title II doesn’t override copyright, but copyright includes exceptions that allow accessibility modifications.

The framework:

All content in Brightspace must be accessible under Title II—no exceptions. For third-party copyrighted materials, here’s your approach:

Step 1: Request from the publisher Ask the original content creator for an accessible version first.

Step 2: Remediate under fair use (generally permitted) We believe it’s allowable to remediate inaccessible content if you:

  • Include a citation noting the formatting was altered to comply with WCAG 2.1 AA
  • Don’t redistribute beyond your course

Step 3: If license prohibits modification

  • Disable Ally Alternative Formats for that item (rights management step)
  • Provide accessible version through a permitted pathway:
    • Publisher-provided accessible file
    • Licensed accessible equivalent
    • Controlled delivery to eligible students only

Consult librarians for help determining what your license allows.

Important: Disabling alternate formats doesn’t eliminate your accessibility obligation—you must still ensure timely, equally effective access.

Copyright exceptions for accessibility:

Copyright law includes specific exceptions (17 U.S.C. §121) that allow authorized entities to create and distribute accessible-format copies for eligible individuals (e.g., students with print disabilities), with reasonable controls to ensure copies reach only eligible users.

Bottom line: Copyright doesn’t say “only by request.” It limits broad distribution but includes pathways for accessibility. Your responsibility is finding the right pathway for each situation.

Yes, but only if tied to actual learning outcomes or licensing requirements—and you must focus on the competency, not the physical trait.

What are technical standards?

Technical standards define essential non-academic skills (physical, cognitive, behavioral) that students need for professional practice. Traditionally used in medical, health sciences, and vocational programs (nursing, welding, commercial driving), they’re potentially relevant across disciplines.

The critical distinction:

❌ Wrong approach: “Students must have vision to take video editing.” ✅ Right approach: “Students must be able to evaluate color balance, identify visual continuity errors, and assess composition.”

Key principle: Focus on the outcome, not the method

Write requirements based on:

  • What competency must the student demonstrate?
  • Why is it essential to the learning outcome or licensing requirement?

Don’t write requirements based on:

  • One assumed way of achieving the outcome
  • A particular physical or sensory trait

Exception: You can specify a method only when that specific method is itself essential to the learning outcome or license.

Students with disabilities still have rights:

Even with technical standards, students are entitled to reasonable modifications and auxiliary aids unless these would fundamentally alter the course or program.

Practical example for video editing:

  • Learning outcome: Evaluate visual composition and color grading
  • Technical standard: Student must be able to make aesthetic judgments about visual elements
  • Accommodation question: Could assistive technology, color identification tools, or collaboration methods allow a student with visual impairment to demonstrate this competency without fundamentally altering the outcome?

Bottom line: Define what students must be able to DO, not what physical abilities they must HAVE. Then work with Disability Services to determine if accommodations can meet those outcomes.

The accessibility standard (WCAG 2.1 AA) is the same for all modalities—what changes is how you implement it. In-person teaching requires creating persistence for ephemeral content (post materials early, describe visuals verbally, use the microphone, repeat questions aloud). Asynchronous online teaching shifts you into a design role where you build multiple pathways to information (chunked videos with captions and transcripts, predictable structure, alt text on images). Synchronous online/HyFlex is the most challenging because you’re balancing live and digital audiences simultaneously (live captions required but not 99% accurate, verbal descriptions in real-time, and if you record the session it becomes asynchronous content requiring full accessibility). Regardless of format, ask yourself: Can students who are blind, deaf, have motor disabilities, or are neurodivergent access this information without barriers? If not, you’ve found your gap. We’re developing modality-specific training and communities of practice to help you meet the same standard in different teaching contexts—because accessible teaching is just better teaching, period.

Yes. UMS provides system-level training, and campus instructional designers are trained to help you interpret your reports.

For faculty:

  • Work with your campus teaching and learning center or instructional designer for personalized support with your Ally reports
  • Attend system-wide training sessions (offered regularly and ongoing)

For instructional designers:

  • Trained on interpreting Ally reports and helping faculty prioritize fixes
  • Receive ongoing system-level training and support

General Accessibility Questions

Title II compliance means meeting WCAG 2.1 Level AA standards. Good faith efforts are not sufficient—you must actually achieve compliance.

What Title II requires at universities:

All web content and mobile apps must be accessible, including:

  • Public websites
  • Learning platforms (Brightspace, etc.)
  • Student/faculty portals
  • Any web-based systems used for university programs, services, or activities

DOJ Final Rule

UMS reinforcement: Board Policy 902 applies these same accessibility expectations to all information and communication technology. Policy Manual – Information and Communications Technology Accessibility Policy – University of Maine System (opens in new tab)

Good faith efforts vs. compliance:

Good faith efforts are important but not the legal standard. They include:

  • Building accessibility into new content and technology
  • Training employees
  • Reviewing tools before adoption
  • Identifying and fixing known barriers
  • Responding promptly to reported accessibility problems

Critical distinction: These efforts demonstrate the University is taking compliance seriously, but compliance means actually meeting the WCAG 2.1 AA standard, not just working toward it.

Think of it like a speed limit: driving more carefully shows good intent, but you still have to stay under the posted limit.

No, not posting materials is not an acceptable compliance strategy for required public-facing or operational content.

University offices have some discretion about what they choose to publish online, but we strongly discourage removing content simply to avoid Title II compliance obligations.

Here is the practical distinction:

Optional or supplemental content: An office may choose not to post certain nonessential materials if it does not want to invest resources in remediation. But if those materials are posted on a university website or other web-based platform, they must meet WCAG 2.1 AA standards.

Required or essential content: An office cannot avoid compliance by taking down or withholding content that people need in order to access services, complete processes, understand requirements, or participate fully in university programs. That content must be provided in an accessible format, or the office must provide an equally effective alternative.

What we recommend: Work with the appropriate campus partners to remediate content and improve accessibility rather than removing important information. For offices like Admissions, Human Resources, Financial Aid, or Hiring, this means making sure people can access the information and complete the steps they need without barriers.

Generally, no. Providing two versions can violate ADA principles of inclusion and integration.

You may only provide both an accessible and non-accessible version when a technical or legal limitation makes it impossible to create a single accessible version (§ 35.202).

Why this matters: The Department of Justice warns that offering separate “accessible” and “regular” versions when not technically necessary creates segregation of people with disabilities and is inconsistent with the ADA’s core principles.

If you must provide two versions due to legitimate technical/legal constraints, both must:

  1. Be clearly labeled – users must know which is which
  2. Provide equal information and functionality – the accessible version can’t be a watered-down summary
  3. Stay synchronized – when you update one, you must update the other
  4. Be reachable from an accessible page – don’t hide the accessible version behind inaccessible navigation

Better approach: Instead of maintaining two versions, work with instructional designers to create one accessible version that serves everyone.

Accessibility in MS Office and Google Workspace

This is a known Microsoft platform limitation, not a user error. The workaround: always add and edit alt text in desktop Word.

Why this happens:

Word Online doesn’t display the alt text editor for certain image types:

  • Images in headers/footers
  • Floating images (not set to “In line with text”)
  • Images inside text boxes, shapes, or grouped objects

Best practice to avoid this issue:

Set all images to “In line with text” positioning. This improves screen reader compatibility AND makes alt text visible across all Word platforms. Microsoft guidance

Your workflow should be:

  • Desktop Word (Windows/Mac): Add and edit all alt text here
  • Word Online: Use only for light edits; treat alt text as view-only

If you must work in Word Online:

Try these options (results vary):

  1. Right-click the image → View/Edit Alt Text (if available)
  2. Review → Check Accessibility (locate alt text issues from the pane)
  3. Change image to “In line with text” (usually requires desktop Word)

Bottom line: Alt text saves in the document but Word Online doesn’t reliably show or edit it. Use desktop Word as your source of truth for accessibility work.

Note to support staff: As we implement accessibility practices, we’ll encounter more platform limitations like this. Share workarounds with your campus teaching and learning centers.

No, you must use ‘Insert > Table’ (or Ctrl+T). Excel does not automatically recognize cell ranges as tables.

Why this matters: To a screen reader, a cell range without the formal Table designation is just a grid of numbers. Users with assistive technology must manually track which column they’re in and what the headers mean.

What ‘Insert > Table’ provides:

1. Header announcements

  • Explicitly marks the top row as headers
  • Screen readers announce the header with each cell value (e.g., “Amount: $500” instead of just “$500”)

2. Defined boundaries

  • Tells assistive technology where data starts and ends
  • Prevents users from “wandering” into empty cells and losing their place

3. Better keyboard navigation

  • “Ctrl + Arrow” navigation respects table edges
  • More efficient movement through data

4. Automatic naming

  • Tables get unique names (e.g., Table1)
  • Appears in “Go To” list for quick navigation

Microsoft training resources:

Bottom line: Always use ‘Insert > Table’ for data ranges. Formatted cell ranges look like tables visually but lack the metadata screen readers need.

Procurement and accessibility

All RFPs and vendor contracts include the following language:

Accessibility: If the solution, services or deliverables include any Information or Communication Technology (ICT) containing a human-interface, such as an end-user software component, web pages or site, video or audio playback, file upload system, mobile device components, control panel, reports, documents, keypad, etc., the Contractor hereby warrants that the products and/or services to be provided under this agreement comply with the W3C’s Web Content Accessibility Guidelines (WCAG) 2.1 Level AA and the Web Accessibility Initiative Accessible Rich Internet Applications Suite (WAI-ARIA) 1.1 for web content

The Contractor agrees to promptly respond to and resolve any complaint regarding accessibility of its products or services which is brought to its attention and Contractor further agrees to indemnify and hold harmless the University of Maine System from any claim arising out of its failure to comply with the aforesaid requirements.

The University, at its discretion, may at any time test the Contractor’s products or services covered by this agreement to ensure compliance with the above standards.

Complaints, or testing, that results in findings of non-compliance, that are not corrected within 30 days of being reported to the Contractor in writing, shall constitute a breach of this agreement and shall be grounds for termination of this agreement and a pro-rated refund of fees paid by the University.

Questions about older documents

Yes, if the document is still accessible to others, it needs to be remediated—regardless of when it was created. The April 2026 deadline applies to all web content and documents you’re currently making available through web-based platforms (Brightspace, SharePoint, public webpages, shared Google Drive links, etc.).

A ‘shared document’ is any document someone else can access through these platforms—whether that’s the general public, a specific campus group, or even a single individual.

‘Continue to use’ means the document serves a current university function: course materials, forms, policies, instructions, or resources people need to participate in programs or activities.

The key exception: Documents that are only stored (not shared or linked anywhere others can access them) are not covered by this requirement.

No. Simply labeling something ‘Archived’ does not exempt it from accessibility requirements.

To qualify for the archived content exception, all four of these conditions must be met:

Stored in a clearly separated archived area – distinctly apart from current, active content (labeling can help with this, but location matters more than the label)

Not modified since archiving – no updates or material changes after being archived

Created before the compliance date (April 2026) or is a reproduction of older physical media

No longer used for current university business – kept only for reference, research, or recordkeeping

Unconventional electronic content

Yes, dashboards have significant accessibility requirements beyond alt text.

PowerBI and Tableau dashboards are classified as ‘web content’ (not conventional documents like PDFs or Word files), so they must meet WCAG 2.1 Level AA standards by April 2026.

The core test: Can someone operate the dashboard using only a keyboard and understand the information without relying on vision?

Before deploying any dashboard in a course, program, or activity, you must complete an Information Technology Review (opens in new tab).

Four critical accessibility areas:

1. Keyboard navigation

  • Users must be able to navigate the entire dashboard using only the Tab key
  • Common failure: users get trapped in a visual or can’t reach key controls
  • Fix: Set a logical tab order (Title → Filters → Main KPI → Chart 1 → Chart 2) using your platform’s ordering features

2. Data alternatives for screen readers

  • Complex visuals (maps, scatter plots, dense charts) need text equivalents
  • Provide both:
    • Accessible data tables with clear headers and labels
    • Summary narratives explaining key insights (not just “Bar chart of sales”)

3. Don’t rely on color alone

  • Use patterns, markers, and text labels so categories are distinguishable without color
  • Color and Contrast: Text and background colors must meet minimum contrast  ratios (4.5:1 for normal text, 3:1 for large text). Information cannot rely on color  alone for meaning.. You can learn more about contrast requirements here (opens in a new tab).
  • Never use directional language like “see the chart on the right”—use descriptive titles instead

4. Filter and control accessibility

  • Common failure: filters without programmatically associated labels
  • Every filter needs a clear label that screen readers can announce
  • Prefer standard dropdowns over custom click-to-filter interactions