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Countdown to Compliance

On February 25th, our latest Digital Meetup kicked off with Scott Troxel, Senior Director of Brand Strategy, who shared updates on our internal process improvements and introduced the newest faces joining the UMC team. The heart of the session focused on the "Countdown to Compliance" and the essential steps needed to meet the April 2026 ADA Title II deadline. Sravi Garikipati walked us through the new WCAG 2.1 AA requirements, the categories of digital content in scope, and the strategic "Born Accessible" workflows that will keep our digital presence inclusive. Did you miss it? No worries, you can find the recording and a detailed recap of the session below.

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Presentation Materials

Countdown to Compliance

Presented by Sravi Garikipati, Associate Director of Digital Research & Operations at UMC Digital

The February 2026 Digital Meetup served as a critical briefing for the University of Utah community, centered on a singular, high-stakes objective: the countdown to the April 24, 2026, ADA Title II compliance deadline. Led by Sravi Garikipati from UMC Digital, the session moved through a deep dive on the legal, technical, and operational shifts required to meet federal standards.

The Road to April 2026: The Requirement

The presentation began by establishing the new "ground truth" for university digital content. Under the Department of Justice's updated Title II regulations, all public entities are now legally mandated to ensure their digital presence meets the WCAG 2.1 Level AA standard.

The deadline of April 24, 2026, is a firm cut-off. This requirement is not just a suggestion but a legal necessity for everything public-facing, everything used to participate in university programs or classes, and everything required to access university services. The core philosophy shifting across the university is "Proactive over Reactive"—moving away from fixing content after a complaint is filed and toward a "Born Accessible" workflow.

Defining the Scope of Compliance

A significant portion of the meeting was dedicated to defining exactly what falls under the Title II umbrella.

  1. Web Content & Applications: This includes all utah.edu websites, Canvas LMS portals, and even the university’s mobile apps.

  2. Electronic Documents: The "Bane of Everyone's Existence"—standard formats like PDFs, Word documents, PowerPoints, and Excel sheets.

  3. Multimedia: Video lectures, webinars, and podcasts, which must now include accurate captions and audio descriptions.

  4. Social Media: Any content posted to official university accounts.

  5. Third-Party Content: Platforms or services provided by vendors (like ticketing systems or employee portals) that are licensed by the university.

Navigating Exceptions: The Decision Tree

  • The Archive Test: Content is exempt if it was created before April 2026, is held strictly for reference or record-keeping, is stored in a clearly labeled "Archive" section, and remains unedited. If you change a single word in an old file, it loses its archived status and must be made accessible.

  • The "Active Use" Rule: Pre-existing documents (posted before the deadline) are only exempt if they are not currently being used for university services. For example, a 2022 campus flyer is safe to leave as-is, but a 2024 syllabus or safety manual still in use in 2026 must be remediated.

  • The Independence Test: The university is not responsible for content it doesn't control (like a link to a New York Times article). However, if the university licenses a vendor platform, the university is legally responsible for that vendor's accessibility.

  • Highly Personal Documents: One-to-one documents (like a specific student’s financial aid letter) are exempt from proactive remediation but must be made accessible "in a timely manner" if the individual requests it.

5-Step Decision Process for Documents

STEP 1: Ownership & Control

Did we create this document, host it, or provide it as part of official university business (including via contract or license)?

YES → Official University Business
The University created it, distributes it, or provides it under contract/license.

Examples:

  • Department newsletters
  • Course syllabi
  • HR benefits guides
  • Admissions forms
  • Vendor-provided documents hosted on university systems

Result:
 Proceed to Step 2.

NO → Outside University Legal Control
The University does not own or control the content.

Examples:

  • A link to an external news article (NYTimes, etc)
  • A faculty member linking to a third-party research paper
  • A student uploading a resume to a discussion forum
  • Embedded content hosted entirely on another organization’s website

Result:
 Not exempt — but not your responsibility to remediate.
 You are not required to fix content you do not control.

Best Practice:
 When possible, link rather than upload copies of third-party inaccessible documents.

Strategic Remediation: The 80/20 Rule:

Recognizing the scale of the task, the 80/20 Rule suggests that 80% of the university's web traffic typically lands on just 20% of its pages. By using Axe Monitor—the university-wide licensed tool for accessibility scanning—teams are encouraged to find their high-traffic "Critical" issues first. This ensures the greatest legal and functional impact in the shortest amount of time.

Remediation Chart

"Born Accessible" Workflows:

The presentation concluded with a call to action for all content creators to adopt "Born Accessible" habits today to avoid a mountain of work in 2026:

  • HTML First: The most sustainable choice is to convert PDFs into accessible web pages whenever possible. HTML is inherently easier for screen readers to navigate than tagged PDFs.

  • Structure over Style: Creators must use true semantic headings (H1, H2, H3) rather than just bolding text to create visual headers.

  • Meaningful Links: Moving away from "Click Here" and toward descriptive links like "Download the Spring 2026 Syllabus."

  • Early Verification: Using the built-in accessibility checkers in Microsoft Word and Adobe Acrobat before any file is ever uploaded.

Resources and Support:

Key Contacts:

  • UMC Sites: Sravi Garikipati

  • UIT Sites: Barb Iannucci

  • U of U Health: Makenna Homer.

  • Classes/Course Materials: Digital Learning Technologies (DLT) - classhelp@utah.edu

Be Part of the Conversation

Effortless Access with Microsoft Teams: Joining our web community meetups is simple! We'll be hosting all sessions on Microsoft Teams for easy access.

Stay in the Loop - Recordings and Summaries Available: Life happens! If you can't make a live session, we've got you covered. We'll share a comprehensive summary and a recording of each meetup right here on our website, so you never miss out on valuable information.

We look forward to connecting with you and encourage your active participation in our web community!

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