Accessibility in Education: Practical Answers to Common Questions Ahead of Title 2 Deadlines

[MarisaBluestone]

The digital accessibility landscape is evolving, and pretty fast at that. The Department of Justice's new web and mobile accessibility rules have given public institutions clearer expectations, but also much tighter deadlines. 

From documentation to what “accessible” really looks like in practice, institutions are navigating both practical and philosophical shifts. And while aligning with WCAG 2.1 Level AA is the technical requirement, the broader goal is clear: to create digital experiences that work for everyone, from day one. This moment is about more than checking boxes. 

In Part 1, we shared the FAQ that educators have about Title 2 late last year, and how Macmillan Learning has been preparing for the changes.  Now, we’re digging into even more of the questions that campuses, instructors, and administrators are asking as they work toward compliance. 

Here are answers to some of the questions keeping campus administrators, instructors and IT teams up at night:

Can AI tools (like generative AI or educational assistants) serve as “reasonable accommodations”?

Short answer: Not yet. The reality is that AI tools are exciting, but they’re more like supplements than substitutes. As of now, they aren’t a substitute for legally required accommodations. 

Many institutions are experimenting with them, but students can’t be left wondering if their accommodations will be replaced by tools that don’t fully meet their needs. That undermines both equity and trust. For example, an AI note-taking tool might assist students with processing lectures, but institutions still need to provide official note-takers or captions if required under a student’s accommodation plan. If accommodations depend on students having their own devices or premium AI subscriptions, another barrier was just created, not removed.

Are Macmillan Learning’s products WCAG 2.1, Level AA compliant?

Yes. Our digital textbooks are accessible. They provide text-to-speech functionality, are compatible with screen readers, include text alternatives, have good contrast, and more. 

We recognize that every student’s learning experience is different. Even when a product meets established accessibility standards, it may not meet a students’ individual need. That’s why we partner with colleges to provide tailored alternatives, whether it’s WCAG-compliant digital formats or versions designed for use with Braille devices. We want each student to have access to the resources that work best for them.

Achieve and iClicker meet WCAG 2.1 standards with some exceptions (detailed in our VPAT.) We’re happy to meet with schools to discuss these exceptions, potential accommodations, and our roadmap for addressing them.

What accessibility challenges arise with OER and third-party digital content, and how can institutions manage them?

Open Educational Resources (OER) could be considered to be an affordable alternative to professional course materials, but uneven accessibility can create barriers for the very students it’s supposed to help. OER and third-party platforms often vary in accessibility.  Without a process in place, instructors may be stuck retrofitting materials on the fly.

Common challenges include missing alt text, inaccessible PDFs, lack of captions in videos, or tools that don’t work well with screen readers. Institutions can manage these risks by:

• Vetting content against WCAG or Section 508 standards before adoption.
• Building accessibility checks into procurement and vendor review processes.
• Training faculty to create accessible OER.
• Providing a remediation pathway. If a course relies on inaccessible material, consider an alternative set of course materials for all students.

It's easier to choose accessible materials from the start than to retrofit problematic content later.

What’s the difference between all the major accessibility laws and regulations, like Section 504, Section 508, Title II, and IDEA?

Acronym soup is real. But knowing which law applies helps them respond confidently to student needs and institutional obligations. Confusion here often leads to delayed responses or compliance missteps. To that end, each law applies to a slightly different “who” and “what”. Here’s the cheat sheet: 

• Section 504: Equal access for anyone in programs that get federal funds (most schools).
• Section 508: Accessible technology and digital content for federal agencies and contractors.
• Title II (of the ADA): Accessibility in programs run by state/local governments, including public schools and universities.
• IDEA: Guarantees individualized support for K–12 students with disabilities in public schools.

What practical steps can institutions take to begin their compliance journey?

Accessibility isn't just a box you can check, it's more of a culture shift. Starting small, but starting now, is the best strategy. Institutions don’t have to do everything at once. Starting points include:

• Audit what you have, including current digital platforms and course materials for accessibility gaps.
• Review vendors and procurement contracts to ensure accessibility standards are part of purchasing decisions.
• Train your team to help faculty and staff create or procure accessible content from the start.
• Get help, whether it's from internal accessibility officers or external consultants; this is one where you should not go it alone.
• Create clear policies so that students and employees know how to request accommodations and report issues.

What documentation will auditors want to have?

Institutions don’t just want to “pass” an audit, they want to demonstrate a clear and ongoing commitment. Auditors typically look for evidence that accessibility isn’t an afterthought. Useful documentation to support this can include:

• Written accessibility policies and procedures.
• Records of accessibility audits and remediation efforts.
• Procurement contracts with accessibility requirements.
• Training records for faculty and staff.
• Documentation of how accommodation requests are processed and resolved.
• Timelines, budgets, and progress reports toward compliance.
• Having a “paper trail” that shows proactive effort and accountability is as important as the technical fixes themselves.

The goal is to demonstrate that accessibility isn't an afterthought; rather, that it's woven into how your institution operates.

How should institutions plan around Title II’s compliance deadlines (April 2026 for larger and April 2027 for smaller institutions)?

Deadlines sound distant until you realize how much content, tech, and training need to be brought up to standard. It’s about sustained progress and continuous improvement. Think of the timeline as a runway, where the earlier you start the smoother you land.

Now through 2025:

• Complete comprehensive audits
• Identify and prioritize high-impact areas (LMS, library systems, widely-used OER)
• Update procurement processes
• Begin staff training

Year 2 (2025-2026/2027):

• Focus on remediation of identified issues
• Expand training programs
• Implement ongoing monitoring systems
• Refine processes based on what you've learned

Remember as you do this to keep leadership, faculty, and students informed about progress. Transparency builds trust and support for the work ahead. This moment in higher education isn't just about compliance, it's about creating campuses where every student can succeed. The regulations are just the framework. 

The real work is building inclusive digital experiences that remove barriers instead of creating them. At Macmillan Learning our digital textbooks are Global Certified Accessible, but whether or not you use them we're still here to help as we navigate this together. Because when accessibility works for everyone, education works better for everyone. Contact us at Webaccessibility@macmillan.com.