Making DOJ Compliance Simple: Closing Accessibility and Reporting Gaps in Education

Meeting an accessibility deadline on day one is an important milestone, but it is only the start of maintaining lasting compliance. Digital accessibility is now a core part of how public institutions serve their communities, and the DOJ’s Americans with Disabilities Act (ADA) Title II requirements—phasing in for certain institutions in 2026—set clear expectations for how public K–12 districts, colleges, and universities must maintain accessible digital content, services, and communication.

Many schools are already preparing for the initial deadlines. While reaching those milestones represents progress, long-term accessibility readiness depends on identifying and closing the gaps that develop as websites expand, new materials are published, and older systems continue circulating content that no longer meets modern standards.

What is Digital Accessibility?

Digital accessibility refers to the practice of designing and maintaining websites, documents, and online services so that people of all abilities can use them without barriers. This includes students, parents, staff, and community members who may have visual, auditory, cognitive, and mobility disabilities, or situational limitations when interacting with digital content.

Done well, digital accessibility helps every user better access information, complete tasks, and participate fully in online experiences. This engagement includes using a school or campus website, opening documents, completing forms, viewing meeting minutes and leadership decisions, and accessing online services regardless of ability or device.

What Creates Accessibility Gaps?

Accessibility gaps often form for predictable reasons: growing website ecosystems, expanding digital services, and decentralized publishing across academic units. These issues often remain invisible until a user reports a barrier, an audit uncovers noncompliant content, or a reporting requirement highlights areas that need attention. They can be addressed with modern technologies and systems that support continuous compliance and accessibility.

This article outlines where the most common accessibility gaps appear, why they create risk, and how institutions can strengthen their long-term readiness through practical, repeatable steps.

After the Deadline: Key Risk Areas Affecting Long-Term Compliance

Long-term compliance depends on what happens after the first requirements are met.

Institutions across K–12 and higher education often begin with structured steps such as policy updates, annual reviews, or early remediation efforts. These actions create a starting point, but long-term readiness requires ongoing attention to how content is created, updated, and maintained throughout the year.

Real gaps emerge in daily publishing, decentralized workflows, and the steady flow of documents, pages, and materials added to school and campus websites. As digital ecosystems grow, accessibility issues can reappear quickly if teams do not have shared processes, updated tools, or a consistent approach to maintaining standards over time.

Long-term readiness is shaped by how teams manage everyday content, document updates, and the systems that support accessibility at scale. Institutions that lack structure in these areas face greater risk as materials accumulate and accessibility-related legal and policy expectations evolve.

Common Risk Points

These risk points reflect the common operational, technical, and procedural factors that create accessibility gaps. Identifying them early helps institutions prioritize updates and streamline ongoing compliance efforts.

• Missing steps
  Policies are documented, but day-to-day execution varies. Staff across departments create pages, upload documents, and post updates without consistent workflows that keep accessibility aligned from the moment content is added.
• Aging systems
  Legacy CMS platforms or content tools do not support modern needs. Older templates, limited publishing controls, and outdated document upload processes create frequent points of failure.
• Fragmented ownership
  Accessibility responsibilities sit in multiple places across campus and departments. Communications, IT, academic units, libraries, student services, and administrative teams manually manage their own digital materials with different levels of training, guidance, and expectations.
• Uneven adoption of standards
  Some departments—and at the K–12 level, such as individual schools or program offices—use accessible templates and structured document formatting. Others rely on scanned PDFs, older files, or outdated forms. This creates a sprawling digital patchwork that complicates audits and reporting.
• Inconsistent document practices
  Departments and administrative offices upload materials in various formats (e.g., Word files, PDFs, scanned images, screenshots) without a shared approach to headings, tags, or readability.
• Outdated content in circulation
  Old program pages, outdated documents, and obsolete templates continue to reappear because they are stored in shared drives, personal folders, or departmental reference files.

What Are the Four Core Accessibility Gaps in Education?

Accessibility gaps in education often fall into four predictable categories.

These gaps appear in day-to-day publishing, departmental processes and workflows, and document management practices across campus. Understanding where each gap comes from makes it easier to build structures to help prevent them while increasing efficiency and lowering staff burden.

1. The Accessibility Gap

This gap forms when websites, portals, learning resources, and documents do not meet ADA or WCAG standards. It often includes:

• Pages with missing headings or poor structure
• PDFs that are scanned, unlabeled, or unreadable by assistive technology
• Forms without clear fields, instructions, or error messaging
• Multimedia content without captions or transcripts
• Outdated templates that no longer align with accessibility expectations

Accessibility gaps grow quickly when many contributors upload content without shared workflows or accessible starting points.

2. The Consistency Gap

This gap appears when departments follow different processes or interpret the requirements in different ways. Common signs include:

• Each unit uses its own set of templates or document formats
• Some teams have accessibility training while others do not
• Faculty or administrative staff publish materials directly to pages they manage
• Separate portals, microsites, and calendars use different standards

Even when the institution has strong policies, uneven adoption across academic and administrative areas can produce unpredictable results.

3. The Sustainability Gap

This gap forms when institutions lack the technology, review structure, or workflows needed to keep accessibility aligned as the volume of content grows. It often shows up through:

• Manual reviews that cannot scale with campus publishing volume
• Legacy systems that do not support structured content or automated checks
• Outdated forms and documents that accumulate over semesters
• Departments re-creating files without guidance or accessible templates
• Limited visibility into issues before they become complaints

Without purpose-built remediation tools that help staff maintain accessibility and ADA Title II compliance over time, the institution stays in a cycle of catching up instead of staying ready.

4. The Technology Gap

This gap appears when teams lack the purpose-built technology solutions that reduce workload burdens while supporting scalable accessibility practices. It often becomes visible through:

• Heavy workloads created by large backlogs of documents, pages, and forms that staff must process, review, and update manually
• Time-intensive reviews completed by hand across pages, PDFs, and forms
• No automated checks to surface issues early or help staff fix them
• Platforms that do not support structured content, templates, or guided steps
• No centralized place to track issues or assign tasks
• Hours spent rechecking content accessibility requirements

Without technology that supports consistent and scalable workflows, institutions shoulder an unnecessary workload and remain in a cycle of reacting instead of maintaining readiness.

Quick Checklist: Are You at Risk for Growing Accessibility Gaps?

Run down this quick list and confirm whether any of these patterns appear in your current workflows. Even one of them can indicate an emerging accessibility gap that needs attention.

Your CMS relies on older templates that lack built-in checks.
Departmental sites or microsites use independent document libraries.
Staff publish content through channels not connected to your central workflow.
Accessibility reviews stop once a redesign or annual update is completed.
Forms, PDFs, recordings, formal documentation, and online processes live across multiple systems without a single review point.

The Bottom Line
True compliance is about sustaining accessibility long-term.

Why Accessibility Gaps Are So Risky—and Costly

Accessibility gaps that violate the DOJ’s ADA mandates for publicly funded educational institutions introduce operational, legal, and community-level consequences. Schools, colleges, and universities may have strong policies in place but still face risk if tools or workflows do not support consistent, day-to-day compliance.

Read more about enforcement: What can the DOJ do?

Legal and Financial Exposure

DOJ Title II enforcement activity and regulatory oversight at the educational level continue to expand. Investigations increasingly focus on digital communication, service delivery, and the usability of core academic and administrative content. Institutions may face corrective actions, structured reporting requirements, or settlement agreements that permanently affect workflows, staffing, and budgets.

Recent case law further lowers the barrier for disability-related claims in education. In A.J.T. v. Osseo Area Schools (2025), the U.S. Supreme Court unanimously ruled that students may pursue ADA and Section 504 claims under the same liability standards applied in other disability discrimination contexts, eliminating a higher proof threshold previously used by some courts. Legal analysts expect this decision to increase the volume and viability of disability-related complaints and litigation across K–12 and postsecondary education.

Education-related website accessibility complaints and enforcement actions remain common, with ongoing DOJ and Department of Education oversight of digital accessibility in postsecondary institutions.

• Common issues can include:
  • Inaccessible PDFs
  • Missing form labels
  • Low-contrast text
  • Navigation barriers

Each case can introduce significant expenses while demanding time, staff effort, and legal resources.

Trust and Community Confidence

• Students, families, and faculty rely on digital information for enrollment, schedules, communication, and services. When navigation fails or content is not accessible through assistive technology, users lose confidence in the institution’s ability to support their needs and perform key duties. Accessibility directly affects perception and satisfaction.

Operational Strain and Staff Burnout

• Gaps often lead to repeated work. Staff remediate pages, rebuild documents, and handle requests that could have been prevented through structured processes and automated checks. When teams lack support systems, accessibility becomes an ongoing catch-up task rather than a predictable part of content publishing.
• Small breakdowns in processes create larger waves of necessary corrective work, especially during peak campus activity.

Closing the Gaps: A Practical Checklist

Institutions can strengthen DOJ readiness by organizing how digital content is created, reviewed, and maintained.

The steps below give teams a clear place to start and can help keep these practices steady across departments. The goal is to build a framework that works throughout the year and supports long-term accessibility.

Step 1. Audit Websites, Portals, and Digital Documents

Conduct a full inventory of public-facing content, including departmental pages, files, calendars, course materials, and enrollment resources.
Identify outdated templates, older PDFs, or unstructured navigation.

Step 2. Standardize Processes Across Departments

Create shared rules for uploading content, reusing templates, and preparing documents while following safeguards to protect student privacy.
Provide accessible versions of common materials such as event flyers, syllabi, and administrative forms.
Establish consistent naming, formatting, and publishing guidelines.

Step 3. Provide Training and Clear Workflows for Teams

Offer simple training modules for staff who publish content.
Include expected turnaround times, routing paths, and practical examples of accessible formatting.
Make accessibility checks part of onboarding, so expectations stay consistent as teams change.
Provide training, support, and documentation across departments and roles to help reduce errors, speed up publishing, and keep practices aligned throughout the year.

Step 4. Automate Routine Checks and Compliance Programs and Tasks

Put solutions in place that automatically scan website pages, PDFs, forms, and uploaded documents.
Flag issues before publishing so staff can correct problems at the source.
Streamline PDF accessibility to reduce repeat work and keep standards consistent across departments.
Use automation to track new content and surface accessibility issues early, before they compound.

To learn more about accessibility, steps to follow, and the DOJ deadlines, download the Road to Accessibility Infographic.

How CivicPlus Supports Schools and Campuses with Sustainable DOJ Compliance

CivicPlus® supports K–12 and higher education institutions with tools built for sustainable digital compliance. This ecosystem includes:

• Municipal Websites + Website Accessibility: Accessibility support integrated into modern web platforms and workflows.
• Process Automation and Digital Services: Automated form processes that can reduce accessibility risks in outdated PDFs and manual submissions.
• Agenda and Meeting Management: Structured publishing for agendas, minutes, and public governance materials that must meet accessibility and transparency requirements.

Educational institutions, from K–12 to colleges and universities, use these tools to reduce manual workloads, strengthen consistency, and align daily publishing with long-term ADA readiness.

Move Your Institution Toward Stronger, Sustainable Accessibility

Deadline readiness establishes a starting point, but closing accessibility gaps is what strengthens trust, improves efficiency, and supports equitable access across campuses at both the K–12 and higher ed levels.

Educational institutions that centralize their processes, systems, and digital content within a single CivicPlus ecosystem gain more consistent alignment with DOJ accessibility requirements and deliver a smoother digital experience for users.

Read our resource on digital accessibility requirements and compliance expectations for K–12 education.

Disclaimer:
This content is provided for informational purposes only and does not constitute legal advice. It should not be relied on as a substitute for guidance from qualified legal counsel. Use of this material does not create an attorney–client relationship. Always consult your city, county, or institutional legal team for interpretation of laws, regulations, and compliance requirements.