Accessibility Processes and Procedures

Prepared by Mark Mende, Director of Digital Communications
August 2018


Since the University receives federal funding, we are required to abide by federal laws regarding access to information and services that we provide in the digital environment for all people who need to access them. Beyond the legal requirements, the University has made a moral commitment to provide access to everyone. In other words, while we might be required by law to make all digital content accessible, it is something we endeavor to do because it the right and correct thing to do.

The University made its first statement regarding digital content accessibility in 2002. In 2015, we engaged with a firm to do an assessment of our digital assets from an accessibility standpoint, and in 2017, we brought a higher education accessibility expert to campus through an innovation grant. All of these steps brought us closer to our goal of access to all information for everyone, though we knew we had more work to do.

In August of 2017, we received a directive from the Department of Education’s Office of Civil Rights to review our website and remediate any pages that did not confirm to WCAG2.0 guidelines, described below. Since we already had been addressing this need for inclusive content, and with great energy and dedication of several staff, we were able to remediate the remaining issues OCR identified by December of 2017.

As a result of that effort, the main University website, as well as the Libraries, Information Technology and Athletics websites, are deemed in full compliance. We need to maintain that status as compliant with law and best practice for an inclusive community.  Many of the accessibility issues that we manage are accomplished through the content management system (CMS), so individual content managers across campus do not have to worry about them. In addition, we have set up the CMS so that content managers are required to do certain things that assure compliance.

Compliance Requirements

The University will use the most recent version of the Web Content Accessibility Guidelines (WCAG) for determining compliance. Many of the high-level accessibility issues are managed at the Content Management System (CMS) level. University Communications and Library and Information Technology staff will regularly assess the University’s main Internet-based assets and their structure to be sure we are in compliance. In addition, all future decisions about the design and other aspects of those assets will include requirements for compliance.

Implications for Campus Content Managers

There are two significant areas where people who manage department websites need to be aware of – heading structure on pages and documents.

Heading Structure

To be compliant, all pages need to have appropriate heading structures. By heading structures, we are referring to the way that the headings above sections of content on pages are styled and tagged. People with certain accessibility issues use various forms of technology which scan the content on a webpage to allow users to skim text and skip to the sections they are interested in consuming. Those technologies generally use headings to accomplish that.

Each page should have a single Heading 1 or H1, which should be the title of the page. This is set at the CMS level. When the content on the page warrants being broken up into sections with titles, or headings, then those need to be structured correctly. All main headings should be tagged as Heading 2 or H2. If there is a sub heading underneath a specific section, those should be labeled H3. Here is an example of a correct page structure:

H1 – Page Title

H2 – First Section Heading

H2 – Second Section Heading

H3 – Subsection under Second Section

H2 – Third Section Heading

H3 – Subsection under Third Section

H4 – Subsection to the H3 under Third Section


Documents uploaded to our websites are required to be accessibility compliant, and in many ways, have the same requirements as web pages, with some additional issues that need to be dealt with. In addition, any documents that are also forms that are required to be filled out and submitted must be structured so that they can be filled out on a computer and then printed out. Also, unlike web pages, document creators are responsible for all aspects of compliance. The issues involved with creating compliant documents, specific to Microsoft Word and Adobe PDF, as well as the process of actually creating accessible documents, can be found here:

Processes and Procedures

Having a clear understanding of what the issues are surrounding the creation of accessible content is important to ensure we are doing everything we can to prevent future problems, and, most importantly, make sure we are providing the best experience for all of users. Therefore, there will now be certain requirements for the creation of content on the website by content managers.

  1. Headings

In cases where headings are needed to organize content on a page, the proscribed structure must be followed. The heading settings in the content editor should not be used to style text, only to format headers. There will be a separate set of styles added to the editor soon.

  1. Documents

All documents uploaded to one of our Internet assets will be required to meet accessibility standards. Documents uploaded to the main website will be reviewed by University Communications staff and either approved or returned for correction. Documents provided by third parties and vendors will also need to be compliant. The appropriate standards will be available to communicate with those third parties. University Communications and Library and Information Technology staff will be providing on-going training and support.