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Title II regulations apply to Ohio State as a public institution. They set a technical standard for access that covers documents as well as software. 

The newer standards that we are currently implementing were passed almost two years ago. The biggest change is that the regulation requires us to go from a reactive model to one that is proactive and integrated into our processes. 

Before, “reasonable accommodation” only required us to make materials accessible if a student asked; the system now focuses on ensuring digital content is usable by all students from the start, rather than waiting for a request. 

The new regulations are more consistent with building construction standards in the ADA, building access ins up front. You don't wait until after the building is built to add an elevator because somebody can't use the stairs. 

The good news is that regulators recognize that this is a big lift, and they don’t expect perfection on day one. In addition, with the recent announcement by the US Department of Justice, Ohio State's compliance deadline has move from April 24, 2026 to April 24, 2027.

They do expect thoughtful, diligent progress. If you're doing what's been asked of you – if you're using the tools that are provided – that's a demonstration of a diligent process. Ohio State has been encouraging and helping people to use the tools that have been made available centrally, or that are integrated into other tools that we’re already using. 

Of course, because the deadline has been delayed, instructors still have plenty of time to remediate anything that is not accessible. We encourage you to continue to make progress, as it will put you in a good position next year.

Content for specific disciplines adds a level of complexity. For example, creating an accessible planetarium presentation is much different than doing an accessible presentation in Intro to Psych, which is different than doing statistics, dance notation, notation in math, physics or chemistry, etc. 

There will be places where a unit recognizes that the ADA Coordinator’s Office may need to give you help with a particular hurdle. The office is trying to anticipate as many of those as possible and has started a process to look at them, but it's a large university and there will be surprises. We are creating a path for departments to report these issues.

Because the ADA is a civil rights law, assessing our compliance isn’t one-dimensional—it requires evaluating accessibility, usability, and equity across multiple areas rather than asking a single question like ‘how equitable are we?

For some courses, for example, Intro to Psych, most of that material is fairly flexible, fairly workable and subject to the scans available in Ally and the tools available in Word and Adobe.  But if someone is teaching statistics, it's going to be a different kind of progress because some of it may be training and tool acquisition and learning how to use LaTex to set up formulas rather than trying to use an image of the formula. 

The regulations recognize both the transition hump and the fact that a digital environment is always in constant change, so they assume imperfection and assume there will always be something in progress – new material, new software that isn't always up to speed as it comes out the gate and is being worked on. 

The critical piece of progress in round one is ensuring you know your priorities, and you are working on the ones that are at the top of the priority list. Have you taken those first steps? No one is talking about being 100% accessible. We will look at our progress and ensure that progress is being made across multiple areas. 

Because the ADA is a piece of civil rights legislation, and it's kind of hard to talk about it from one dimension as “how equitable are we?” There’s not an ordinal measure (e.g 80% accessible) that really works. 

Ally is an imperfect machine. We're trying to get “good scores,” but that number is not the only measure that you need to look at to ensure you are where you need to be. 

All accessibility tools are partial tools with universal design links to help you make things more accessible. They can help you make things more accessible. 

Even a perfect score in Ally is not necessarily an indication that there are no barriers in your documents; it is likely that there are still some problems that need to be fixed. The scanning tool is robust and is a good starting point.

We’re working to clarify what counts as technical infeasibility or a fundamental alteration under the updated Title II digital accessibility requirements, and how to turn that into a process that works for both individual faculty and across courses. 

Our goal is to avoid requiring a detailed review of every piece of content. Instead, we’re asking for reasonable, good-faith efforts that don’t disrupt teaching. Faculty should continue using the materials that work best, and direct students who need additional support to start the appropriate process. 

We’ll partner with you on accessible formats as needed. As a starting point, adding short captions or descriptions can help students decide if they need assistance. Often, more detailed explanations already exist in lectures or other materials and can be reused or adapted—sometimes with help from AI tools.

Archiving Carmen courses does more than free up space—it helps keep your course content current and effective. As you revisit archived courses each semester, you have a natural opportunity to review and update materials, ensuring everything stays accurate, relevant, and accessible for students. Built into your regular course development workflow, this process makes continuous improvement more manageable. 

Rather than adding extra reporting steps, most accessibility and content insights can be gathered automatically through system scans. 

The ADA Coordinator’s Office will do repeated scans to help instructors meet the new guidelines. We are working on dashboards that would give feedback at the instructor level. 

Feedback from course-level checkers provides insights that can be leveraged at multiple levels: at the department level, it can be coordinated across course sequences to ensure consistency and alignment and at the college level, it can inform priority setting and help identify resources that may be needed. 

The university will be able to rely on that scanning history for some of the documentation. As semesters change, as courses change, we know specific content will be different from semester to semester, so our baseline will change. On the aggregate, we need to be able to show progress between the scans in terms of our digital environment as a whole, even though some of the specific content changes. 

The ADA Coordinator’s Office will look at data on several levels. We will be doing regular scans and audits of spaces. When we do our annual report for accessibility coordinators, we will incorporate some of this information about course accessibility to enable us to provide feedback to deans and chairs so they can see what progress is being made within their space. 

The ADA Coordinator’s Office will be responding to the aggregate information in those scans and the information we collect from the annual reports. The Digital Access Center has an existing broader auditing cycle plan that will incorporate checks on curriculum on a fairly large scale, unit by unit. Lastly, some of what we discover isn't working will be because a student hits a wall, and we'll be responsive to that. We don't want to create a cumbersome reporting process.