To assure that all of the College’s content is ADA compliant and follows the WCAG 2.1 AA standards, the ADA Compliance Working Group is planning and developing a resource guide. This guide will enable our community to design and remediate future password-protected content to be ADA compliant. By spring 2027, both content and tools that we use in teaching and in collaborations across and beyond campus need to move towards WCAG 2.1 AA compliance. We are happy to offer these resources for everyone: here, you can learn how to edit your existing content and how to create future content that is ADA compliant. The following pages focus on password protected content that you may be sharing through Moodle, Google Drive, Dropbox, and password protected websites.

ADA Compliance Working Group

  • Sam Thayer, Director of the Office of Accessibility Resources (co-lead)
  • Wiebke Kuhn, Director of Academic Technology, ITS (co-lead)
  • Christina Sinkler-Miller, Head of Resource Acquisition & Discovery Services (RADS), Gould Library
  • Don Vosburg, Academic Technologist of Learning Innovation
  • Rebecca Brückmann, Associate Professor of History

The Larger Team

While the ADA Compliance Working Group is developing strategies and resources, it is relying on a larger network to ensure everyone on campus understands the basic principles of web-based ADA compliance and how to apply them to digital materials shared with groups across campus. Members of this larger network include the Academic Technologists in ITS, Librarians, the Office of Accessibility Resources, individual staff members who are stepping up to work on particular tasks, and student workers.

To start reviewing and remediating materials in Google Drive or Moodle, Academic Technologists have trained a couple of students and staff members for the summer.  Send an email to at@carleton.edu if you want to explore this service starting immediately.

Background

What do we mean by ADA compliance?  And why do we need to apply these rules to password protected materials?

In April 2024, the Department of Justice (DOJ) issued a new rule under Title II of the ADA, which outlines clear requirements (WCAG 2.1 AA) for ensuring web content and mobile applications are accessible to individuals with disabilities. All state and local governments, including public schools and universities, have until April 2027 to comply with this rule, depending on the size of the population they serve. 

While Carleton is not a public entity subject to Title II, private colleges are subject to Title III of the ADA, which applies to “places of public accommodations,” such as businesses open to the public. Courts have consistently upheld that web accessibility barriers constitute violations of Title III requirements, and private educational entities risk legal action if they fail to meet ADA requirements. 

The DOJ ruling does not include exceptions for password-protected course content in postsecondary schools, which means that course materials are required to meet WCAG 2.1 AA requirements by April 2027, despite being password-protected in Carleton’s internal system (Moodle, Google suite documents, etc.). It is more efficient and effective to make course content proactively, rather than scramble to remediate content retroactively in response to a specific user’s request.

What web-based content is included? 

Any digital content that you are sharing with groups of others starting April 2027 is affected. The following list does not include all digital storage spaces we have at Carleton. Consider where you save files and which ones you share with a group of people.

  1. Moodle:  any content added directly into Moodle word boxes (e.g., discussion posts, quiz questions, assignments); any files uploaded to Moodle (e.g., pdf files, MSOffice files), any content linked from Moodle (e.g. Google files, Youtube videos, third party websites)
  2. Google Drive:  any content in Shared Drives that is shared with a larger group of folks (e.g., committee files, policy drafts, meeting minutes, anything available to an entire dept)
  3. Dropbox:  any content in Team folders that is shared with a larger group of folks (e.g., committee files, policy drafts, meeting minutes, anything available to an entire dept)
  4. Carlsites: any web content that is available over Carlsites

What are exceptions? What content does not need to be ADA compliant even though it is shared with a group?

  1. If you present materials like Google Slides or PowerPoint presentations in class only, without uploading them to Moodle or sharing them otherwise, these presentations do not need to be ADA compliant.
  2. Archived materials: this is not about redoing everything stored in a Shared Google Drive or in older Moodle courses. We are focusing on materials that are shared with a larger group of people (a class, department, campus group) starting April 2027.

Breaking down the process

Step 1: Learn

Learn about and understand digital accessibility and WCAG

What are the accessibility requirements for digital content?

In a nutshell, the current requirement is adhering to the Web Content Accessibility Guidelines (WCAG) 2.1 AA.

Resources for Carleton Community

We are developing online resources and will offer a number of workshops, training and working sessions. Review the Ed Tech Tea page for upcoming events.

What are the consequences? What if I just want to go analog?

Failure to comply with this guidance and new ruling will put the institution at risk for legal action in the event that an individual with a disability is unable to access required material. Additionally, this could put the disabled student at a disadvantage, compared to their peers, if there is a delay in being able to access course material when it is needed.

While it is true that there is currently no specific guidance regarding “analog” materials such as course packets, physical handouts, etc., this material would need to be addressed in the event that a student with an approved accommodation is enrolled. As discussed above, retrofits are extremely burdensome, and sometimes impossible if there is a short turnaround time. If print course materials are being utilized for pedagogical purposes, a recommendation would be to identify an accessible version of the document(s) and have that information readily available in the event that someone encounters an accessibility issue.

Step 2: Review

Review spring 2027 course content flagging any that aren’t in compliance

  • Note issues with non-compliant content
  • Remove content you do not need to share right now and delete content you no longer need 
  • Evaluate and test, using the tools Carleton provides.

Step 3: Remediate

Remediate any non-compliant materials. Update, replace, or remove content using the available tools & resources ensuring that course materials meet the requirements

  • Update any digital content you need to share
  • Check library resources for updated content, links, etc.

Step 4: Evaluate

Evaluate progress and remedy any remaining issues

  • Continue reviewing existing content for future courses beyond Spring ‘27
  • Create new content with digital accessibility in mind

Step 5: Continue

Continue the process with course content for future terms and keep compliance in mind when creating new content

  • Continue reviewing existing content for future courses beyond Spring ‘27
  • Create new content with digital accessibility in mind
  • Develop habits to build in accessibility into your content creation workflow

Training & Resources at Carleton

Upcoming Training

Academic Technologists will offer workshops throughout the academic year.  The Library will also offer sessions on ADA compliant materials and how they can help with requests for ADA compliant materials (e.g. scans)

  • September 1st, 1:00-3:30pm, online: Making Moodle Accessible, repeat of summer workshop
  • Ed Tech Teas during Fall term, focusing on pdf files, how to use Grackle for Google files, how to use Ally for Moodle – Tuesdays, 3:30-4:30pm
  • Winter conference session in December

Asynchronous Resources

Other Options

  • Come to the AT Drop In Hours for quick one-on-one consultations, M+R, 2-4pm, online
  • Invite members of the ADA Compliance Working Group to a department meeting
  • Schedule a longer consultation with an Academic Technologist
  • Schedule a session with a librarian to learn about library databases and ADA compliance
  • Turn over remediation to student workers in Academic Technology

Readings/Listenings/Viewings

Other Helpful Resources

Consider how your learning materials can be adjusted to offer all students lower hurdles to engage with the materials of your courses. UDL and TILT both have significant research connected to them, showing the validity of these approaches.

  1. Universal Design for Learning (UDL) principles of redesigning a course have shown to reduce the need for individual accommodations as the principles focus on learner agency. The three core principles are designing multiple means of Engagement, Representation, and Action & Expression.
    CAST’s Universal Design for Learning Guidelines 3.0
    ITS blog series (2022)
  2. Transparency in Learning and Teaching (TILT) offers strategies to design assignments and learning materials with full transparency in mind. In particular, a TILT assignment focuses on how an assignment can be successsfully completed, with a strong argument for why the assignment is relevant to the student, closed out with what a student needs to accomplish.