OCR Compliance Reviews: Are You Ready?

Student with white cane walking around school grounds. Compliance reviews help schools be accessible.

In a recent virtual summit, the US Department of Education announced that its Office of Civil Rights (OCR) would be conducting 100 new compliance reviews for federally funded educational organizations. The OCR will be evaluating digital resources like websites, learning management systems, and other communication platforms, to ensure they comply with legal standards prohibiting discrimination. 


OCR Compliance Reviews Coming

The Department of Education says it will be reviewing “elementary and secondary schools and districts, postsecondary institutions, state departments of education, libraries, and vocational rehabilitation services.” They will evaluate digital accessibility compliance for “online learning, public-facing websites, and parent-resource and communications platforms.” These organizations must comply with Section 504 of the Rehabilitation Act and Title II of the Americans with Disabilities Act. 


OCR Recent Resolutions

The OCR has received hundreds of digital accessibility complaints over the past several years. It has enforced accessibility laws by helping educational organizations and people with disabilities reach resolutions. Complaints aren’t just filed in states with strict digital accessibility laws, but across the country. The complaints cite a number of different digital accessibility violations, from keyboard navigation issues to inaccessible PDFs, lack of captioning on video content, and more. 

In January of 2022, the OCR sent a letter of complaint to Miami-Dade County Public Schools in Florida citing digital accessibility “compliance concerns” regarding their website’s keyboard navigation, visual focus indicators for people using keyboard navigation, and lack of alternative (alt) text. 

A letter sent in November of 2021 to North Slope Borough School District, Alaska, cited lack of keyboard navigation capabilities, inaccessible PDF documents, and a failure to include video captions. 

In July of 2021, the OCR sent a letter to Anacortes School District of Washington, citing keyboard navigation issues, links that were not meaningfully labeled, and poor color contrast as reasons for compliance concern.

Durham Public Schools (North Carolina) received an OCR violation letter for failing to clearly label links, providing inaccessible PDFs, and using a poorly contrasted background.

The OCR sent a letter to Saline County Library of Arkansas for noncompliance concerns regarding keyboard navigation, inaccessible PDFs, and insufficient color contrast.

Many of these schools, including all of the ones referenced above, have signed resolution agreements to voluntarily resolve complaints. 


How can educational organizations prepare?


Familiarize yourself with legal requirements


Section 504 requirements

Section 504 of the Rehabilitation Act requires schools and other federally-funded organizations to provide people with disabilities equal access to their programs and services. That includes making websites, learning management and testing systems, and other digital resources offered by federally-funded organizations accessible as well. 

Section 508 requirements

Section 508 specifically addresses electronic information technology, which includes websites and other digital resources. It functions as an extension of Section 504. You can read the full Section 508 requirements here.

Title II of the Americans with Disabilities Act

Title II of the ADA prohibits discrimination against people with disabilities by public entities and applies to all state and local governments. Like Section 504, it requires organizations to provide people with disabilities equal access to their programs and services. Title II extends to state and local governments, while Section 504 applies only to federal programs.


Watch the videos created by the Department of Education

The Department of Education has created a series of videos that schools and other institutions can use to learn more about what digital accessibility is, how people with disabilities access digital resources, digital accessibility laws, and more. These videos can help guide compliance initiatives and prepare for the OCR compliance reviews.


Decide how to address accessibility issues

Will you manage accessibility in-house or outsource to accessibility experts? Address accessibility on all new content, as well as existing and archived material. Many organizations choose to train their staff to make future content accessible. To address existing and archived digital resources, often it makes sense to bring in outside experts, particularly if you have an extensive backlog. 


Don’t forget PDFs

Because most websites and other digital platforms contain PDFs, those files also need to be compliant with Sections 504 and 508. To make PDFs accessible, they need to be tagged for accessibility. Explore your website and other platforms to find PDFs. Look for older, archived PDF material as well. Create a strategy for remediating all of your PDFs and work through them methodically. Equidox has developed one possible roadmap for this in a previous blog post


Equidox PDF Accessibility Solutions

It’s often easiest to make PDFs accessible as they’re produced, before being posted on a website or other platform. Equidox offers PDF remediation software that’s easy for anyone to learn, even those with no previous accessibility experience. That means even busy content creators can easily learn and use Equidox to make every PDF accessible before they are distributed or published.


For larger projects or more difficult existing documents, hiring an experienced, professional remediation team makes more sense. Outsourcing allows professionals to tackle these projects more quickly and efficiently, freeing up your team to address current documents. A professional team, like Equidox PDF remediation services offers, will remediate documents and also manually validate them using a screen reader to ensure they are accessible and fully usable by assistive technology users.


If you’re not sure where to start, contact Equidox. We can help you determine what PDFs need to be made accessible and provide software or services to make the remediation process easy. 



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Nina Overdorff

Nina comes to Equidox with years of sales and marketing experience from a variety of industries and holds a BS in Language Arts Education. Nina has a passion for words, storytelling, and information, which she believes everyone should have access to regardless of ability. After spending time as a teacher with a blind student, she became much more aware of the limitations and abilities of web accessibility, and how essential it is to those experiencing disabilities. “Being able to access information equally ensures that everyone has an equal opportunity for education, employment, and success in life.”

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