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DISABILITY COMPLIANCE FOR HIGHER EDUCATION
An overview of the key topics faced by disability services providers with citations
to noteworthy cases, statutes, regulations, and additional sources.
All pages of an institution’s website must be accessibility to individuals with disabilities. Review recent
Office for Civil Rights ndings on web accessibility.
❑ A complainant claimed to OCR he was unable to register through Mt. Hood Community College’s website
for a summer 2014 online class because the website was inaccessible to him as a screen-reader user and
didn’t offer any alternative way to register for the class. The college signed a resolution agreeing to take steps
to resolve the complaint, including ensuring that all online programs, services, and activities are accessible
to individuals with disabilities. Letter to: Mt. Hood Community College, No. 10142224 (OCR 09/11/14).
❑ OCR performed a compliance review of accessibility of the University of Cincinnati’s websites, focus-
ing on the needs of individuals with sensory impairments who may require assistive technology to access
the sites. OCR’s review identied several compliance issues, including a lack of a formal process to ensure
compliance with policies; an absence of policies or procedures concerning the purchase of technology
and/or its compatibility with assistive technology; and multiple technical deciencies in website accessibil-
ity, including images lacking alternative text equivalents. Letter to: University of Cincinnati, No. 15-13-6001
❑ A complainant alleged that Bay Mills Community College discriminated by failing to make all its web-
pages accessible to individuals with certain kinds of disabilities, including visual, print, physical, and hearing
impairments. The agency used an accessibility tool as well to conduct a preliminary review of some of the
pages listed in the complaint. Its review raised some red ags, including a lack of skip navigation, keyboard
controls that did not allow equivalent ease of use, and lack of meaningful alternate text. Before OCR could
complete its investigation and issue a nding, the institution entered into a resolution agreement to resolve
the issues identied. Letter to: Bay Mills Community College, No.
15-16-2187 (OCR 10/14/16).
❑ A complainant claimed that Michigan Virtual University discrimi-
nated because some of its webpages were not accessible to individuals
with disabilities like visual impairments. OCR conducted a preliminary
accessibility review of those pages, resulting in various accessibility
alerts, which pointed to issues with the skip navigation, keyboard
controls, nontrivial graphics’ alternate text, link labeling, and visual
contrast. Even though OCR’s preliminary investigation, while pointing
to areas of concern, did not determine that sufficient evidence existed
that a violation of Title II had occurred, the institution offered to resolve
the complaint voluntarily. The agreement’s provisions included that
it would ensure that the institution’s online content is fully accessible
by established accessibility standards and that the institution would
designate at least one individual as a web accessibility coordinator
and provide that person with the resources and authority needed to
implement the accessibility policy. Letter to: Michigan Virtual University,
No. 15-16-2146 (OCR 10/13/16). ■
What You Should Know
• Web-based campus services
such as registration must be acces-
sible to students with disabilities.
• An institution’s website must be
accessible to individuals with sensory
impairments who require assistive
technology to access web content.
• Websites should include fea-
tures such as skip navigation,
keyboard controls that allow equiva-
lent ease of use, and meaningful
• Institutions must establish poli-
cies and procedures for ensuring
web accessibility. ■