Case in Point

Each month in Case in Point we attempt to highlight new and emerging risks. The accessibility of our online content is facing heightened scrutiny with the recent updates to Title II of the ADA. We could see increased enforcement actions in the near future in this area. I've asked our Director of Institutional Compliance & Privacy, Kristin Roberts, who has been coordinating the effort here at Auburn, to provide some practical guidance.

With the ADA Title II impending deadline April 24, we are feeling the pressures of digital accessibility requirements. However, public institution risk managers should treat digital accessibility as a continuous compliance effort—not a one-time remediation sprint. Your goal is to strategically prioritize efforts to reduce near-term exposure and user harm while building a repeatable program that can withstand audits, complaints, and future waves of content generation.

Here are eight items to focus on to strengthen your WCAG compliance posture:

1. Conduct an internal accessibility audit: confirm what is in scope (websites, web apps, documents, digital marketing, LMS content, third-party tools, etc.) and who “owns” the content.
2. Name an executive sponsor: identify a single program owner and a cross-functional working group (IT, disability services, communications, procurement, academic affairs, faculty support, general counsel) to coordinate efforts.
3. Prioritize your highest-traffic/highest-risk entry points: public-facing, virtual “doors” to your institution (admissions, enrollment, employment, libraries, athletics) and student-facing portals (LMS, housing, dining, advising, student organizations) are hotspots.
4. Evaluate PDFs: What are critical documents? Can the content be provided in an alternative format (HTML)? Can you archive preexisting content that is only for research or reference purposes? Do you still need the content at all? Consider a third-party tool or AI to assist in the PDF remediation process.
5. Fix the low-hanging fruit: correct titles, headings/structure, color contrast, alt text, captions/transcripts, and create accessible templates using these core tenets of accessibility.
6. Deliver training: the most sustainable option is teaching your people how to fish. At some level, people are just going to need to know how to make their own content accessible. Everyone needs a minimum knowledge of accessibility.
7. Put third parties on notice: document vendor accessibility commitments, collect VPATs/ACRs where available, and create interim alternatives for tools you can’t fix.
8. Create a plan: publish a clear accessibility statement and reporting channel, and document an internal playbook for acknowledging, triaging, and remediating issues on a defined timeline.

It is difficult, if not impossible, to achieve 100% digital accessibility compliance living in an environment where content changes rapidly and hundreds of people in your organization create content daily. What regulators and users look for is a credible, resourced plan—standards you follow, training that reaches content owners, checkpoints in your publishing lifecycle, and proof that issues get fixed. Build accessibility into “how we work” (authoring templates, procurement gates, QA before launch, routine scanning, and quarterly reporting) and document your decisions and timelines so you can show good-faith progress. The deadline is real, but the best approach is an operating model that keeps you moving toward accessibility every week after April 24.

Thank you, Kristin, for this great information and advice. Achieving accessibility requires continual improvement and risk mitigation like many other compliance challenges we face. Therefore, we invite you to review the events of the prior month with a view toward proactively managing risks. As always, we welcome your feedback.

Mar 24: UPMC: Some patient records may have been 'improperly accessed' - Data Breach: Some UPMC patients may have had their medical records improperly accessed, according to officials with UPMC. UPMC said it was notified by its electronic health vendor that some patient records may have been accessed through a national network used to exchange medical information.

Mar 23: Detroit woman pleads guilty to stealing $2.5 million in decades-long student aid fraud scheme - Financial Aid Fraud: A Detroit woman accused of running a decade-long student aid scheme, obtaining $2.5 million, has pleaded guilty to wire fraud, according to the U.S. Attorney's Office. Federal prosecutors say that between July 2015 and July 2025, [the woman] submitted aid applications for more than 80 people who appeared as eligible students at Wayne County Community College.

Mar 01: Former university medical center manager indicted for embezzlement and purchasing card fraud - Occupational Fraud: A former manager at a university medical center in the Eastern Panhandle was indicted Tuesday on 25 counts of fraudulent use of a state purchasing card and embezzlement following an investigation by the West Virginia State Auditor’s Office. Investigators with the State Auditor’s Public Integrity and Fraud Unit allege [the manager] conducted 25 fraudulent transactions totaling $10,075.78 between March 1, 2023, and Nov. 15, 2024.

Mar 23: Trump administration launches more probes into Harvard - Title VI: The Trump administration said on Monday it launched two ​more probes against Harvard University in its latest escalation against the Cambridge, Massachusetts-based Ivy League school and ‌other top U.S. universities. The U.S. Education Department said its civil rights office "opened two new investigations into Harvard University amid allegations that it continues to discriminate against students on the basis of race, color, and national origin" in violation of federal law.

Mar 19: Trump Administration Surveys Cornell Employees About Antisemitism - Title VI: The Trump administration is pursuing a civil rights investigation into antisemitism at Cornell University, months after the Ivy League school signed a settlement intended to end a pressure campaign by the federal government. The inquiry, which the U.S. Equal Employment Opportunity Commission is leading and that Cornell publicly acknowledged on Thursday, appears focused on whether the university allowed antisemitic discrimination against workers.

Mar 18: N.J. college dean, 66, charged with sexually assaulting child - Employee Conduct: A college dean and professor in Ocean County has been charged with sexually assaulting a child, the Atlantic County Prosecutor’s Office said Monday. [The man] recently began serving as the dean of the School of Business and Social Sciences at Ocean County College, according to his LinkedIn profile. He also worked as a lecturer at the community college and as an adjunct professor at Kean University, in addition to participating in various volunteer activities involving children.

Mar 13: Texas Southern University athletic director fired following sexual assault allegations - Employee Conduct: Texas Southern University's athletic director has been fired less than a year after he was sued for allegedly assaulting a university staff member. In a statement, TSU said the decision to terminate came after the university conducted two independent administrative inquiries into the allegations.

Mar 09: Regents order University of Iowa to discipline employee discussing DEI on undercover video aired on Fox News - DEI: A conservative private law firm hired to investigate two University of Iowa employees captured on undercover video discussing the campus’ compliance with state diversity, equity and inclusion laws is recommending the UI "initiate disciplinary proceedings" against just one of the employees.

Mar 10: Culture at Columbia Shielded Sexual Assault by Physician, Report Finds - Employee Conduct: Two prominent doctors from Columbia University and NewYork-Presbyterian Hospital stepped down on Tuesday after a report found that staff members were discouraged from reporting abuse committed by Robert Hadden, who sexually assaulted hundreds of patients while employed at both institutions.

Mar 09: Ohio State President Resigns Over ‘Inappropriate Relationship’ - Employee Conduct: The president of Ohio State University has resigned after he disclosed to trustees that he had an "inappropriate relationship," the school said in a statement on Monday.

Mar 03: Columbia Is Investigated for Handling of Sex-Abuse Claims Against Doctor - Employee Conduct: The New York attorney general is investigating Columbia University for its handling of allegations against, a former university gynecologist who continued to work at one of its hospitals for weeks after his 2012 arrest on sex crimes. While the full scope of the attorney general’s investigation is unclear, Ms. James’s office is probing what university leaders did after [the doctor's] arrest in 2012. Columbia allowed[him] to continue treating patients for five weeks.

Mar 23: University of Alabama students sue over shutdown of campus magazines - Speech: University of Alabama students are suing the college after they say it violated their First Amendment rights. Eight UA students filed a federal lawsuit against UA’s board of trustees and Gov. Kay Ivey over the decision to shut down the magazines Alice and Nineteen Fifty-Six in 2025.

Mar 23: Boston University Pulls Pride Flags, Raising Free Speech Worries - Speech: Boston University removed Pride flags that were displayed in campus buildings this month, angering professors who believe school leaders may be suppressing expression because they fear the Trump administration. University officials have suggested the displays could imply the school endorses them, violating its pledge to be evenhanded with its standards around speech.

Mar 14: UF disbands College Republican chapter, citing antisemitic activity - Antisemitism: The University of Florida deactivated its College Republicans chapter after the Florida Federation of College Republicans alerted the university to a photo showing a student leader performing a Nazi salute.

Mar 12: ROTC students at Old Dominion University subdued and killed shooter who left 1 dead, 2 hurt - Shooting: A former Army National Guard member who had spent eight years in prison for attempting to aid the Islamic State opened fire on a classroom at Virginia’s Old Dominion University on Thursday before ROTC students subdued and killed him, authorities said.