Digital Accessibility

• First determine if the information in your PDF could just be put directly on the website as HTML text. This will make the content searchable on the website. 
• If you must publish a PDF, it needs to be made accessible and may require third-party remediation. Not all PDFs can be remediated—complex documents may be rejected.
• PDFs require extra tagging for screen readers and limit resizing for low-vision users. 
• Your documents will need proper headings, lists, and tables for accessibility. Check out the Best Practices below. 
• Scanned documents are not accessible because they are images and not text and can not be read by screen readers. You will need to make the original source documents accessible. 
• The university has purchased Grackle Workspace for Google products so it is recommended you use Google Docs, Sheets and Slides for your documents. Once you have made your document accessible it can be Exported to PDF from Grackle and then submitted via a website content request for addition to the website. 

• Use headings, lists, and tables correctly
• Add document titles and specify the language of the document
• Provide descriptive hyperlinks
• Add alt text for images, charts, and graphs
• Ensure sufficient color contrast
• Caption all videos and provide transcripts for audio

• Accessibility Toolkit for Course Materials
• Embedding Library and Open Resources

Under the Americans with Disabilities Act of 1990 (ADA), as amended, and its implementing regulations (28 CFR § 35.200), the university must provide accessible online content so that individuals with disabilities can obtain the same information, engage in the same interactions, and receive the same benefits and services as individuals without disabilities.

This work touches every corner of campus. Accessibility is everyone’s responsibility. Each of us plays a role in ensuring that what we create, post, or share is accessible to all members of our community.

The U.S. Department of Justice (DOJ) has issued new Web and Mobile Accessibility regulations (28 CFR Part 35, Subpart H). These require that by April 24, 2026, all public entities serving populations of over 50,000 people, including public colleges and universities, comply with the Web Content Accessibility Guidelines (WCAG) 2.1, Level AA (WCAG 2.1).

WCAG 2.1 Level AA is the benchmark for digital accessibility under ADA Title II. It requires websites, documents, and apps to be perceivable, operable, understandable, and robust for all users, including those with disabilities. This includes providing text alternatives for images, captions, and transcripts for audio/video, using headings and structure properly, ensuring keyboard navigation, maintaining clear and consistent design, ensuring sufficient color contrast, and ensuring compatibility with assistive technologies. Meeting Level AA ensures digital content is usable and accessible to the broadest possible audience.

To support campus-wide compliance, Fitchburg State has assembled a Digital Accessibility Working Group (DAWG). This group includes representatives from Personnel Services, Disability Services, Equal Opportunity, Academic Affairs, Student Affairs, Marketing and Communications, and the Technology Department. Updates and resources will be posted on this page as they become available.

• WCAG 2.1, Level AA is the required technical standard
  • Fitchburg State University requires all software and system vendors to submit a current Voluntary Product Accessibility Template (VPAT®) as part of the procurement process. The VPAT must demonstrate conformance with WCAG 2.1 Level AA or higher, clearly outlining accessibility features, known limitations, and plans for addressing any gaps. No purchase will be executed without a compliant VPAT on file.
• The university has adopted the same benchmark as the Massachusetts Enterprise Digital Accessibility Policy
• Accessibility must be proactive: digital content should be accessible from the start, not addressed later only through accommodations

Minimum WCAG 2.1 standards include:

• Perceivable: Text alternatives for non-text content, captions for audio/video, adaptable presentation
• Operable: Keyboard accessibility, enough time to read/use content, and no seizures triggered by flashing content
• Understandable: Clear navigation, readable text, predictable web page behavior
• Robust: Compatible with assistive technologies

Each unit within the university must ensure that its digital materials meet the minimum accessibility requirements as required by ADA Title II. At Fitchburg State, we are all responsible for our digital communications. Whether you author or request web content, email to distribution lists, use apps or systems to chat or share documents with a group, or teach using an electronic course shell, you are the owner and manager of the information you share. To support this university-wide initiative, training and tools will be shared for all to access and utilize.

We recommend that your department or group begin by identifying all of your digital sources of information.

• Do you post information on the website?
• Do you utilize an additional website, social media, or other public-facing system to communicate information?
• Do you post or send PDFs electronically?
• Do you have charts, images, or videos online? 

Once you have established an inventory, determine which content is still actively used and which content can be deleted or archived. Then you are ready to conduct a basic assessment of your online content against the new regulations.

Web Content Accessibility Guidelines (WCAG) 2.1, Level AA

The university has purchased Grackle Workshop, which is an add-on to Google Docs, Sheets, and Slides. This will provide guidance to correct issues, generate alternate formats for instructional content, and provide reports for leadership and key stakeholders.

Visit the Web Accessibility Tools page for information on how to make your website accessible.

Some examples include instructional content hosted in the Blackboard or Canva learning management system, online textbooks, all department webpages (including websites behind a login), online portals for registration and other transactions, library databases, forms, mobile apps, emails, online videos, webinars, live-streamed and recorded events, digital documents and materials (i.e. PDF files and PowerPoint presentations) and information shared through software and web-based platforms that the university manages.

As these standards will be enforced nationwide, we are hopeful vendors will be prepared to ensure they can meet the standards. Third-party digital information and services provided or made available through contractual, licensing, or other arrangements with the university must be readily accessible and conform to WCAG 2.1, just as all other digital information and services. Legal responsibility for ensuring the accessibility of third-party digital content falls to the university.

If your department contracts with a third party to provide information, they may be able to provide verification of compliance with WCAG 2.1. New contracts must include language to ensure compliance with federal law.  The Technology Department and Procurement must review all new and renewed contracts before executing. 

The enhanced requirements do not apply to these five (5) categories of online content:

1. Archived web content
2. Preexisting conventional electronic documents that are no longer used (e.g., a nursing handbook published before April 2026 that is no longer in use)
3. Individual password-protected documents for a specific person
4. Preexisting social media posts
5. Content posted by a third party

Older digital content that meets specific criteria may be archived on the website. This exception is used sparingly to enable continued access to historical and reference content.  It reduces the need to remediate content no longer in active use while maintaining accessibility for people with disabilities through alternative formats when needed.

To apply this exception, the content must meet all four of these requirements:

1. Created before 04/24/2026, or is a reproduction of something that was (such as a scanned handout, audiotapes, film negatives, or CD) created before that date; AND
2. Used only for research, reference, or recordkeeping. It is not being kept for use in current instruction, programs, services, or public communication; AND
3. Stored in a clearly labeled archive section, so users understand it may not meet accessibility standards; AND
4. Not changed after being archived. Any edits, however minor, disqualify the content from this exception

Guides and checklists are available here:  https://www.mass.gov/info-details/creating-accessible-electronic-documents-and-communications

In these cases, the university must provide a conforming alternate version. This acts as a temporary way of providing access to digital content that hasn’t or can’t be made accessible. Units are only allowed to do this when technical or legal constraints make it impossible to ensure accessibility. The Disability Services Office must approve these alternatives.

Digital content is accessible when it follows WCAG 2.1 A and AA guidelines. This involves using features across all digital programs (such as Google Docs, Microsoft Word, PowerPoint, Excel, PDFs, Video production software, etc.) that enable assistive technologies to navigate the content. A few examples include using headers, using the bulleted list feature, adding alt text to images, and adding captions to videos. The University has created the Digital Accessibility Hub to help you learn how to make your content accessible.

The ruling took effect on June 24, 2024, but the stated compliance grace period ends on April 24, 2026.

All required course materials, including textbooks, must adhere to established accessibility standards. Publishers are generally well-informed about these requirements. Therefore, your initial action should be to contact the publisher directly to confirm their commitment to accessibility, specifically regarding features such as screen reader compatibility, keyboard navigation, alternative text for images, and accessible PowerPoint files. Should you require assistance in vetting materials or finding suitable alternatives, the Library is available to help. Additionally, the Library provides resources on its accessibility practices and course reserves, along with contact information for subject specialists who can provide further support.

As public entities, universities must comply with the new Title II digital accessibility standards by April 24, 2026. This is a serious civil rights issue - and one that’s being taken seriously.

The emphasis will be on achieving compliance. Therefore, the initial response to noncompliance will usually involve explaining the violations to the responsible party and requesting corrective action. However, persistent noncompliance may result in civil rights complaints or enforcement actions by the relevant federal agency.

While there is no current, university-wide, course-by-course accessibility audit, the university must comply with the law. This means that in the event of a student complaint, federal investigation, or court case, the institution must be able to demonstrate that reasonable efforts were made to ensure course content is accessible.

Non-compliant course content can create barriers for students and pose a legal risk to the university. However, the primary focus is on the shared goal of ensuring all students have access to learning, not on penalizing individual instructors.

You're not required to toss all your PDFs, but any PDFs you use for your course must be accessible to all students. Unfortunately, many older or scanned PDFs are not accessible, and PDFs are more challenging to remediate than other document formats. In those cases, it’s best to look for more accessible formats, request remediated versions, or talk to your library or accessibility team for help converting key materials. The “don’t use PDFs” advice is really about avoiding inaccessible formats whenever possible. For example, for accessibility, it is better to leave Word Documents and PowerPoints in their original file format rather than converting those document types into a PDF format. See this PDF Accessibility Checklist for more information on what is required to make a PDF fully accessible.

You are not required to eliminate all PDFs, but any used in your course must be accessible to all students. The preference to "don't use PDFs" is primarily about avoiding inaccessible formats whenever possible, as older or scanned PDFs are often inaccessible and difficult to remediate.

For better accessibility, it is recommended to keep files like Word Documents and PowerPoint presentations in their native format rather than converting them to PDF. If you must use a PDF that is not accessible, you should look for alternative accessible formats, request remediated versions, or consult with your library or accessibility team for help converting essential materials.

Refer to the Library’s PDF Accessibility Checklist for detailed information on what is necessary to make a PDF fully accessible.

Digital accessibility standards must be met by all content required for your course. This includes student-to-student work, such as peer review, if it is a mandatory assignment. Incorporating accessibility into these assignments offers a valuable chance to educate your students on digital accessibility—a skill they will likely need to apply when they enter the workforce and create digital materials.

Moving to a paper-only format is not a practical solution for most modern courses. The primary motivation for offering digital materials is the inherent advantages for both you and your students. Restricting digital access can disadvantage many learners and complicate course management over time.

In fact, digital materials are crucial for enhancing accessibility. Many students depend on tools like screen readers, digital note-taking, and flexible formats to be successful. The aim is not to dictate your teaching methods, but to guarantee equitable access to your course content for every student. Instructors often find that once they learn to utilize the accessibility features in their preferred programs, creating accessible documents is surprisingly straightforward!

No, Title II doesn’t change anything about the content that you cover in your course. As an instructor, you still have the ability to determine what you teach and which pedagogical tools you use. The goal of this law is just to ensure that all students have equal access to the content you choose to use for the course. National statistics indicated that 1/5 of college students have a disability (this includes registered and unregistered disabilities). Adding features to increase access will meaningfully support students even when they don’t disclose their disability. When materials are accessible from the start, it benefits everyone, including students using mobile devices, those with temporary impairments, or even students who simply learn better with captions, transcripts, or readable documents.

Title II does not dictate the content or pedagogy of your course. As the instructor, you retain full autonomy to decide what you teach and which tools you use. The law's sole purpose is to guarantee that all students have equal access to the materials you choose.

It is worth noting that national statistics indicate one in five college students has a disability (including both registered and unregistered disabilities). By ensuring your materials are accessible from the outset, you meaningfully support these students, even those who do not disclose their needs. Furthermore, accessibility features benefit everyone, including students using mobile devices, those with temporary impairments, or anyone who learns better with options like captions, transcripts, or readable documents.

Proactive accessibility is a core requirement under Title II of the ADA, which mandates that public institutions provide equal access to all students by default, not just those who request an accommodation.

A reactive approach, which waits until a student discloses a disability, can lead to harmful delays that prevent full course participation. Furthermore, many students do not disclose their disabilities due to factors like stigma, lack of a diagnosis, or uncertainty about their rights, leaving them unsupported if materials are not accessible from the start.

Ultimately, designing for accessibility benefits everyone: it supports students using mobile devices, those with temporary impairments, and all learners who find features such as captions, transcripts, or accessible documents helpful. Our goal is to reduce barriers before they become problems.