You Ask, Experts Answer: A Community Q&A on ADA Title II Compliance

LILY BOND: Thank you for joining this session today. It's titled "You Ask, Experts Answer, A Community Q&A on ADA Title II Compliance". My name is Lily Bond. I use she/her pronouns, and I'll be moderating today's conversation. With that taken care of, I'd like to welcome today's panelists.

Today, I'm joined by Brian Smith from the University of Florida, Angela Jackson from the University of South Dakota, Megan Cox from Utah State, and Kyle Shachmut from Harvard. Thank you all for being here today. I'm really excited about the expertise on this panel and the conversation we're going to have today. Before we get started, I want to give everyone a chance to introduce yourselves, share a little bit about your institution and what role you play in its accessibility efforts. Megan, why don't we go ahead and start with you?

MEGAN COX: Yeah, so Utah State University is a land grant institution with multiple statewide campuses across Utah. We're also an R1 research institution, so medium to large size. But I am the digital accessibility officer. So I cover all things digital accessibility, like websites, software courses, social media, anything you can think of accessibility-wise. I also help a touch with caption accommodations as well. I have a team of two full-time staff and eight student employees.

LILY BOND: Thanks, Megan. Kyle, how about you?

KYLE SHACHMUT: Sure. Hi, I'm Kyle Shachmut. I'm senior director of digital accessibility at Harvard, right across the river from Lily in Cambridge, Massachusetts. And I lead a team that helps provide university-wide support for proactive digital accessibility. I help work on governance, policy, implementation, reporting, monitoring, kind of soup to nuts on all aspects of IT accessibility across a large research university.

LILY BOND: Thanks, Kyle. And one question. Harvard is a private university, but we're having you here to talk about Title II, which applies to public universities. Can you share about how you think about Harvard's responsibilities in that context?

KYLE SHACHMUT: Sure. Briefly, a couple thoughts on that. So like many of us on the call today know, yes, not a Title II institution. The specific recent regulations related to Title II aren't the only obligations higher ed institutions have related to accessibility. So whether or not you're public or private, we have other legal obligations related to accessibility that we work to follow.

And then we're all part of a higher ed technology ecosystem. So Harvard shares products and services and contributes to open-source projects that are used by universities across that regulatory spectrum, so maybe not specifically applied to Title II, but certainly in the same ecosystem, and working toward requirements that we hold for ourselves for policy, just like the Title II requirements.

LILY BOND: Thanks, Kyle. That's really helpful context. Angela, why don't you go ahead and introduce yourself?

ANGELA JACKSON: Yeah, thank you. I'm with the University of South Dakota. We are a medium-sized R2 institution and the state's flagship liberal arts institution, with a medical school and a law school. And we serve students across a range of programs, from undergraduate through doctoral and professional degrees.

In my role as a director of accessibility, we have five full-time staff. And I work to ensure students with disabilities have equal access to their educational experience through an opportunity for all lens. And that work expands significantly through the Center for Digital Accessibility, which I lead across the university as well as the public.

It's a public service activity, meaning we extend our expertise beyond USD to support institutions and organizations across the state of South Dakota and the region. So we provide technical assistance, research, training, and consultation to camp to campus, as well as other colleges and K-12 schools across the state.

LILY BOND: Thanks, Angela. And Brian, let's finish it off with you.

BRIAN SMITH: I'm Brian Smith, the manager of video and collaboration services at the University of Florida. We're a fairly large land grant research university in Florida. My team manages UF's primary video platform, Mediasite, and it supports lecture capture and streaming across campus. In terms of accessibility, I lead our video compliance efforts in Mediasite, focusing on captioning workflows, budgeting, and vendor strategy, and work closely with leadership and academic partners to make those processes scalable and sustainable.

LILY BOND: Thanks, Brian. And I think a lot of our attendees have joined us for several of the episodes in the series. And you were on one with us back in December, where you talked about budgeting for compliance at UF. Just for those who are continuing along the series, could you give a quick update on anything that's changed since then and what looks different now than it did a few months ago?

BRIAN SMITH: Of course. Thanks for having me again. Since that earlier conversation, we've continued to purge content from our servers. We've removed over 5 million minutes of legacy content since that time-- and that's mostly older, unused presentations-- moving them to archive or deleting them entirely.

We've continued to work with content creators across campus to help them become better stewards of their own content inventories. We went from having 60% of all the Mediasite content captioned to over 90% by the time of the original compliance deadline. What looks different now is more consistency and predictability, clearer guidance to departments, stronger adoption of workflows, and better alignment between budget volume and actual demand. We're spending less time estimating and more time delivering.

LILY BOND: Great update. Thanks, Brian. And I realized I didn't fully introduce myself. I'm the chief growth officer at 3Play Media. I've been with 3Play for just over 12 years. And in that time, I've worked heavily with higher education, partnering with everyone on this call and many others, and really focused on understanding the regulatory environment and driving a lot of our content and presentations around that.

So when we scheduled this webinar, Title II was phasing in this week-- or actually, last week, but a few days ago. And at the beginning of last week, that deadline was pushed a year, to 2027. So I think we should start by addressing the elephant in the room, which is, this deadline is now a year out. I would love to start just with a quick, honest gut reaction. What was your gut reaction when you heard the news? Angela, let's start with you.

ANGELA JACKSON: For us, it really didn't change anything. For us, we were already well on our way. And we've walked through an OCR investigation and complaint in the past. And so we are very clear-- we clearly knew what we needed to do. I believe this is critically important. I think the compliance extension that the DOJ granted only delays the deadline, but it didn't really pause the obligation. I think the obligation currently exists.

And so the ADA and 504 have always required that institutions provide accessible programs and services. The Dear Colleague letters were sent to our president going way back. So it was clear for us that we just were going to continue the course we were on. No changes. We're still moving ahead as planned.

LILY BOND: I love the way you put that, that it moved the deadline, but it didn't pause the obligation. I think that's a great way to position it. Kyle, what was your gut reaction when you heard the news?

KYLE SHACHMUT: Honestly, as an individual, as a person that relies on accessible technology, it was frustration. We've been waiting on more specific deadlines for years, decades. And so as someone that wants all the government services that I use to be accessible, honestly, pretty frustrated with the delay.

But as Angela said, institutionally speaking, we're in a little bit different place, being not a Title II entity. But we've had a policy on the books for years stating that we expect and want our technologies to be WCAG 2.1 AA compliant. So from a tactical and strategic standpoint at what we're doing at the institution, it buys a little more time before various compliance deadlines might check in or with resources that we're providing. But personally, it was just frustration.

LILY BOND: I am sure that is the case. And for something that you have been waiting literally decades for, getting it pushed again at the last minute must have been brutal. And I'm really sorry for you and for everyone with disabilities that's been waiting on this. But I think hearing that institutions are continuing to drive forward is helpful in context. Megan, what was your gut reaction?

MEGAN COX: Yeah, same kind of response as Angela. We're going to stay the course. It doesn't change much. Actually, the same day that happened, we released our updated digital accessibility policy. So we've got that on the back end, too, that people will still be accountable to meet. So it didn't really change much. But I guess the one positive is it did give us a little bit more time to figure out some last outstanding issues, like trying to work with vendors on a couple things, or just some random things we're still working on. But most of all, we're staying the course.

LILY BOND: Yeah, that's great. And Brian, how about you?

BRIAN SMITH: I pretty much echo all of that. It didn't really change our trajectory at all. We're still moving forward at the same pace. It just gives us extra time to be more intentional and sustainable rather than being reactive.

LILY BOND: Yeah, great. So everyone on this call is still charging forward against these goals and not letting go of the momentum that you've been pushing towards. We have an audience question that I think is probably relevant to drop in here.

I know with the Title II deadline pushing, some institutions are covered under the HHS deadline, which is coming up in May. That has very similar obligations to Title II for anyone receiving funding from HHS. Has anyone heard about that date changing, or would you view that as a continued push forward for the May 11 deadline, even with the Title II deadline pushing?

ANGELA JACKSON: Well, I can speak from the perspective of the University of South Dakota. We have a medical school, and we receive HHS funding. We work very closely with Sanford Health.

And I have had conversations with the dean and the assistant dean of the medical school for quite a while. In fact, the associate dean, I think, sits on our digital accessibility committee. So I think it's-- we've been talking about it for a couple of years, so they're well aware of it.

And they're, again, just moving forward and doing everything they can to prepare. I have not-- and I've advised our team that I have not seen anything happening for sure yet. So we're just moving forward with that date as well.

LILY BOND: Great.

KYLE SHACHMUT: I--

LILY BOND: Kyle, do you have something to add?

KYLE SHACHMUT: Yeah, I'll just chime in and say I agree with what Angela said, that has officially changed. I think it's under consideration for review in a similar way to the Title II regulations were before the deadline was pushed.

Given the fact that they were released within a couple weeks of each other two years ago and stayed in sync, I wouldn't be shocked if something similar happened, but that has not happened yet. But last time, the Title II swap deadline change came within days before the deadline. But wouldn't be shocked if something similar happened in the next few weeks.

LILY BOND: Yeah, and Kyle, you've been advising policymakers on digital accessibility for years. I guess more generally, what's your read on what this push signals and the note that came out around it?

KYLE SHACHMUT: Well, as I mentioned earlier, I think it's not great news for the needs of disabled people trying to access content. And yet as many of the other panelists have mentioned, these are clarifying regulations under existing laws that have been around for 30-- 50-plus years. So the Title II regulations are under the Americans with Disabilities Act. The HHS regulations are under Section 504 of the Rehabilitation Act. That's, again, 50-plus years old.

So the newness of the requirements was around the technical standards specificity, saying that technology needed to meet, proactively, the WCAG 2.1 AA standard. It was not new and is not new, should not be new, to anyone that they were saying things should be accessible, so that the clarity was around the specificity of the standard. But the legal obligation and requirements themselves generally, even if deadlines are pushed for the technical conformance, they're not changing. They have not changed because the underlying laws have not changed.

So no matter when this transition happens, happened, will happen, whatever tense we need to use, it's going to be a little messy. We are essentially confronting decades of technical debt, in a sense. And so it's going to be a little messy transitioning from loosey-goosey, ambiguous, needs to be accessible, but not to a specific standard, to suddenly saying, now a specific technical standard applies. And whether that happened in 2020, 2026, or 2036-- let's hope not. But no matter when that happens, it's going to be messy bridging that gap.

And so I don't think it's going to be infinitely better waiting a year. But I think it signals the conflicting signals from different constituencies that the government has. But the obligations remain. And those of us who work in accessibility, this is-- we're going to have to just bite the bullet at some point and work toward this and help the industry make a transition.

LILY BOND: Yeah, I think that's really, really helpful framing around the obligation not changing at all, the technical specifications being the thing that was added on in this ruling, and the tech debt associated with delay and further delay on designing towards the WCAG specs. I think that's really helpful framing to go into this conversation with. I want to shift gears into implementation.

So thinking about Title II, all of you said you are powering forward with Title II compliance plans. That could mean a lot of different things to a lot of different people. So I would love to start by hearing a little bit about how prepared you feel your institution is right now, where you feel you are really strong in implementation, and what areas you're still solving for. Megan, why don't we go ahead and start with you?

MEGAN COX: I think the reality a little bit is that we're always going to be trying to figure some things out. I think that there's some areas that are still a little bit tougher. For us, maybe STEM content is one of those that we're still trying to find a really good solution to make sure that that is helpful for everybody. We've played with a few things, but just haven't quite figured it out.

So I would think at our institution, we're doing a really great job on our websites and doing some work there. Also with our courses, we've done a lot of work as well. Honestly, social media is a tough one for us right now. There just hasn't been a list of even all the accounts that are out there.

So we're trying to put that together, figure out who's even running stuff, and then figure out what's unused and still being used. So there's some of that. And software can be challenging, too, all of the software that we've purchased in the past that is maybe older that didn't go through accessibility review. And now we've got to figure out how to update that, find a new solution, or whatever it might be.

LILY BOND: Yeah, 100%. I think the social media problem is one that we've heard from a lot of people. There are so many different owners of it, too. It's really difficult to figure out a remediation plan for that content. Angela, would love to hear from you.

ANGELA JACKSON: Yeah, I think for smaller institutions and organizations like ourselves, we're facing a very real and honest challenge, and that is resources. And the landscape does look a little bit different, I think, for smaller institutions that don't have dedicated teams. They often have one person or no dedicated people or a stakeholder body that's responsible for accessibility. And they're trying to balance that alongside all their other work duties.

And so what we see across South Dakota is a very wide spectrum. Some institutions have made meaningful progress through commitment and creativity, and others are barely aware of where they stand. So there are common gaps that include accessibility and procurement practices, faculty with little or no training in creating accessible course materials, and websites that haven't been fully tested for user functionality with screen readers and keyboard-only navigation at 200% magnification, which is a big thing for us.

And so through the Center for Digital Accessibility, we help to meet institutions and organizations where they are, the smaller, under-resourced organizations that maybe can't afford or access these resources independently. So our goal is to help them build capacity gradually and affordably and sustainably across the state of South Dakota, because we believe that something is always better than nothing. And so progress does matter, even if it's small steps.

LILY BOND: I love the approach you're taking at a statewide level to really ensure everyone is getting resources and expertise in approaching this. I think that's a great model. Brian, how about you?

BRIAN SMITH: At UF, I'd say we're in a strong, progressing position. We have the core infrastructure, a central budget, improved workflows, and governance in place. And we're actively scaling execution. We're still working on consistency at the edges, identifying all the content creators, handling legacy video, improving live captioning workflows, and refining processes for higher-complexity needs like audio descriptions. We've really started having that conversation in the past month or so.

LILY BOND: Great. And, Brian, a quick follow-up question on this. You manage video content, and specifically, a very large amount of video at UF. And one of the challenges we hear a lot is how to assess that much video content and make smart decisions about remediation. What's your advice for people struggling with assessing a large video library and trying to think through where to start and how to move forward with compliance against that video library?

BRIAN SMITH: Sure. With the Mediasite platform, we've had clear visibility into the volume, ownership, and usage of all the content we have. We started with over 11 million minutes of content last summer that we had to remediate. With the help of massive amounts of reporting within the Mediasite infrastructure, we've really layered our prioritization.

We focused first on active course content, high-enrollment materials, and public-facing videos. We continue our efforts to purge legacy content, and efforts that we had started years before just to maintain the storage size that we were using. And for the final stretch, we've been working a lot on that older content that may be sparingly viewed, but still requires remediation. So my best advice is use the information that you have available. If you have a platform that can run reports, make use of them.

LILY BOND: Yeah, it's a data analysis project and a prioritization effort. So those two skills together are important to make this happen. Kyle, I want to give you a chance to jump in. You've been at this for a long time on Harvard's remediation approach to digital accessibility. Where do you think you stand, and what lessons have you learned along the way?

KYLE SHACHMUT: Yeah, sure. I mean, we will be done working on digital accessibility collectively when our institutions stop producing content, which, in one way of looking at it, that's the business we're in. It's for teaching and learning, and research, and disseminating it, and making the world a better place.

But our institutions are all about creating and disseminating content with the world. And so it's trying to embed the work of accessibility into processes and systems and tools, and then making sure everybody-- at most of our institutions, it's probably thousands, if not tens of thousands of people, that are content creators on behalf of the institution.

And so it doesn't matter if Kyle knows what to do or Kyle's team knows what to do, because there's no way that small of a unit can review every piece of content that a large university creates and disseminates. So it's taking that knowledge and expertise and embedding it in the tools and the processes and the implementation strategies that is implemented by hundreds or thousands or tens of thousands of people producing content on behalf of the institution.

LILY BOND: That's a great approach. And Kyle, you touched on something at the beginning that I want to dig into a little bit, which is, you said you'll be done with digital accessibility when content stops being produced. And it raises a really good point about how people approach compliance and accessibility.

There's a lot of content that exists already that needs a plan, and then there is content that doesn't exist yet that needs a process. And how do you think about tackling those two things together? Do you recommend starting with what exists and then building a process for moving forward? Do you recommend parallelizing those, just starting with the ongoing and then going to the backlog?

KYLE SHACHMUT: Yeah, there has to be a little bit of a both/and approach because of the scale at which it's happening, probably. But I think the best bet is whenever your institution starts to take accessibility seriously, or in a specific domain or a department or whatever the case may be, starting with new content, starting on today or on X date that you choose, and have your ducks in a row for, saying, let's not make things less accessible going forward, right?

Plant a flag. Pick a day. And say, that day, we're going to really prioritize this and work on it. And then that then defines your back catalog, if you will, of what you're working on. But you're not going to be doing yourself any favors if you know what needs to happen and then you're perpetuating the cycle of producing inaccessible content. That backlog just gets bigger and bigger.

LILY BOND: Yeah, great way to approach that. And I think we're starting to talk a little bit about digital accessibility maturity here, too. And Angela, you've developed a framework for evaluating this. Can you tell us a little bit about the framework and what a meaningful self-assessment would actually look like?

ANGELA JACKSON: Yeah, so the J4P framework is a maturity model that I developed in 2018, specifically to assist our university in an OCR response. It ended up morphing into a larger framework to help small to medium-sized public institutions, state and local government agencies honestly assess where they are in their accessibility journey across key domains of policy, people, planning, and practices. And rather than including a simple checklist, it actually-- what it does is it recognizes that accessibility maturity is a continuum.

So it's a meaningful self-assessment. So it starts with an honest self-assessment of where you are and the data where you are by auditing a sample of your digital assets, and surveying your faculty and staff and awareness, and just reviewing your procurement practices.

What it does is it helps institutions start where they are and then plan where they want to be. So the framework gives a roadmap to institutions in a structured way that identifies gaps. It prioritizes action items and tracks growth over time, turning what can feel, for a lot of people, like an overwhelming amount of work into a manageable, phased roadmap that works for public higher education.

LILY BOND: I've been privileged to get a little bit of a preview conversation with Angela about this, and it's really cool. How are you thinking about letting other institutions access this framework?

ANGELA JACKSON: Well, I have actually been teaching it as a facilitator through EDUCAUSE since 2018. In fact, when they contacted me to do it the first time, I told them. I said, the framework is just draft. It's not even done yet. I did publish it as part of my dissertation, and I'm currently working on publishing a workbook and a type of-- it's more of a practitioner's handbook on how to roll this out. So I'm hoping to get that published here in the near future.

LILY BOND: That's exciting.

KYLE SHACHMUT: Can I chime in on that?

LILY BOND: You can, Kyle.

KYLE SHACHMUT: I love Angela's framework. I think it's really good. It's a practical step for institutions to take, right? Ways of assessing your content or your maturity or your processes can take different forms, and it might depend on where you have sponsorship or leadership or buy-in most for accessibility. At my institution, my team, we're in the central IT unit. We're a part of the security and privacy team, so we have-- privacy, security, and accessibility are three legs of our stool of high-quality IT, no matter what kind of IT you're talking about.

And we already had processes built in on an annual basis and other periodic bases for assessments that happen in the security realm and the privacy realm. And so we built on those and embedded accessibility into those practices that we now run on an annual basis. So whatever your framework is of assessment or whatever it is, you might have ways in your organization already that you can piggyback on and help try to accelerate how quickly you can do something that's not starting from zero.

LILY BOND: I think that's a great tip, Kyle. Megan, you really sparked a fire in the audience when you mentioned social media. And I want to jump back to you because we have a lot of questions here about social media accessibility. Everyone is struggling with it.

Social platforms aren't set up well for accessibility. Specifically, some callouts around audio description support, YouTube/Instagram issues with support for these features. And people are wondering if you have any tips, or if anyone on the call has tips. But we'll start with you, Megan.

MEGAN COX: Yeah, honestly, at this point, we're doing the best we can to try to figure it out. I go into these platforms pretty often now and just see what's new, what's there, what we can do, what we can't. The other day, I was actually just playing with captions, and I actually did a training on social media.

And it's like, some platforms will let me upload captions, some won't. So odds are, we're probably going to have to burn them in. And you just have to be really adaptable and flexible and go back and look often to see what's changed.

Yesterday, I also had somebody report that they couldn't see the alt text tag option in Meta Business Suite anymore either. And so we have to be really, really on top of some of this. But honestly, my advice to the people on campus has just been, please just start now. Make it a habit. Do the best you can. I'll help you figure this out. You're not in this alone. But let's use what we do have. And then we can complain. We can try to make some other things happen with these platforms. But that's where we're at.

LILY BOND: Does anyone else have any tips for social that they want to chime in with? No tips. Everyone is struggling with it, I think, is the answer.

ANGELA JACKSON: We just--

LILY BOND: Oh.

ANGELA JACKSON: At the University of South Dakota, we just created a social media guide in collaboration with marketing, and we just distribute that through our office. And just the same, I can echo what Megan said. It's from this point forward. You just need to do this.

LILY BOND: Yeah. I do know that YouTube is releasing audio description support. Not all channels have it available yet, but it does seem like it is finally on its way, and hopefully will be available for everyone soon. It is available for some now, but yeah, not an ideal barrier for a lot of people. Kyle, do you have something to add?

KYLE SHACHMUT: Yeah, I've got one tip just that goes beyond the creation. Megan and Angela covered that well. But something that we've had success in working with our content and channel owners of different social channels is making sure that the folks that work on those channels across the institution are bought in and aware of accessibility. That doesn't mean something can go out that is missed occasionally. But one of the biggest carrots that many-- we have hundreds or thousands of labs and teams and individual faculty profiles and channels that are around the institution, that are tied to it.

And some of the biggest carrots we have is, can that get featured by my school's channel or my university's channel? And when the people that are in charge of those bigger channels say, we're not going to spotlight it unless you make your content accessible, if you have your video captioned, alternative text on your post-- if you do that, we will pick it up and help broadcast it to a wider audience. I would say that does wonders in terms of incentivizing the behavior we want in ways that a stick just can't.

Because that is what they want. That is part of why they are on social media. And so if you can get those gatekeepers and social media coordinators on board, that's a huge leverage point to accelerate accessibility progress.

LILY BOND: That's a really cool idea, Kyle. And so imagine you're talking to a school that has just audited their YouTube instance and has found that their school has 150 different YouTube channels. And they're like, how do I even find the owners of these? Do you find that type of incentive program has them come to you, or did you still have to go track people down to get YouTube channels under control at Harvard?

KYLE SHACHMUT: I mean, it's always a little bit of both, right?

LILY BOND: Yeah.

KYLE SHACHMUT: But it certainly helps for the most prolific ones or the ones that are paying attention to it the most, for sure.

LILY BOND: Yeah, cool. Brian, I want to go to you. A lot of institutions have-- we've talked about a lot of the needs for accessibility, but a lot of institutions don't have enough budget or a dedicated budget for this. How have you had success budgeting for Title II compliance, and what advice do you have for people? You're muted.

BRIAN SMITH: We were very fortunate that we had an existing budget for captioning. It was primarily dedicated to needs requests, accommodation requests, where we did one-day, quick turnarounds on captions that had to be there for accommodation requests. So we had that built-in budget, and we did not have to expand far beyond it with the combination of tools from 3Play Media and built into the Mediasite platform.

Mediasite's automated captioning has allowed us to caption 5 million minutes in the past year. The quality is not up to accommodation compliance standards, but tackling that many minutes, we really had no choice but to do our best effort. And then we combined that with our existing budget for 3Play Media, where we've bought into their ASR tool, now called Pulse, I believe. But we've used that to do automated ASR captioning. And anything above, we've set it at a 90% predicted score, has been elevated to human-reviewed captioning.

So that's allowed us to caption a lot of the brand-new lecture capture content and accommodation requests at a higher-quality level than the Mediasite captioning provides, but have that human element turned on if we had to get up to that higher accuracy score. So like I said, we've been fortunate. We've had a budget in place. And you just need to talk to your leadership and make them understand this isn't a needs-based thing anymore. It's a requirement. So the budget has to be there.

LILY BOND: Yeah, that's awesome, Brian. And I think you took a really creative approach in how to get more out of the budget that you had available. And I think that type of creative thinking is necessary for a lot of teams struggling with getting buy-in for extra budget for this. So I think it's a great example.

BRIAN SMITH: And I do see a quick question, a follow-up on what I said there.

LILY BOND: Yeah.

BRIAN SMITH: No, we have not used any of that budget for audio description. That is all for captioning. We currently do not have any budget for audio description. So we're in that same boat right there.

LILY BOND: Yeah, I think a lot of people are-- audio description's the next up. People are to have a lot of conversations with universities, really thinking about implementation of audio description for the first time and how to do that at scale. And I think that that's the next frontier. And I'm hopeful that technology is in a place that enables it at scale for the first time, because it's a huge need that is often behind captioning.

Angela, there's some questions here around procurement and how important procurement is when you're considering these long-term accessibility initiatives and when you're getting leadership buy-in. How do you approach accessibility in the procurement process to ensure that the tools you're getting are also compliant with the regulations that you're working towards complying with?

ANGELA JACKSON: Yeah, so for us, procurement is one of the highest-leverage points in accessibility work. One thing I didn't mention before is that we do operate under a [INAUDIBLE] system, and the BOR tries to leverage cost savings by purchasing system-wide. But at the local level, we do have a prioritized and organized procurement process that includes a review committee.

So for us, we feel like it's a high-leverage point. Procurement needs to be involved. And there's a lot of accessibility work that needs to be done in that space. And even from my-- we still have work to do. I think it's chronically under-prioritized at institutions. I think every inaccessible tool purchased becomes an accessibility problem that's now owned by the institution.

So at USD, we require vendors to provide a current VPAT, which is a Voluntary Product Accessibility Template, and the HECVAT as part of the evaluation process. But we don't just accept the VPAT at face value. We review it critically, because many are incomplete. They're overstated.

And we also ask vendors, what is your remediation roadmap? What's your response time for accessibility issues? And these questions signal to vendors that we're serious. And in the long term, the goal is to ensure accessibility criteria that carries real weight in the final purchasing decision, not just a checkbox. And so when institutions buy right the first time, which we're trying to do at USD, then they avoid those costly retrofits and protect students from day one.

LILY BOND: Awesome. And Kyle, there are also some questions here about vendor accountability. I know that you've worked with many vendors for many years. How do you think about vendor accountability when you are building scaled accessibility programs? You go through procurement. You get these vendors. Then how do you hold them accountable moving forward as you scale your initiatives?

KYLE SHACHMUT: Yeah, we cannot do this without vendors that we work with, the vendor community. And the good news/bad news on that is that all of us in higher ed use the same three to five vendors in every space. And so sometimes the bad news is that none of them are great options. And the good news is, if any of them are, we've got a really good opportunity to help the market move in that direction.

I think that's a great opportunity for us to work together with consortia, buying power collectively, like Angela was mentioning, on a state level, if that's something that your institution is a part of. But there's no substitute for having language in a contract, both requiring accessibility, and in an ideal case, having penalties or something that you can claw back part of your fees, maybe, if they're not delivering on accessibility. And that's one place I think that the vendor community hasn't moved as far as we need them to yet.

But the deadlines and the specificity of the technical requirements has been really helpful in ways that us as a market asking for it hasn't been able to produce, even in the past 10 years. So I hope that we continue to use this year extension that's been granted as a higher ed purchasing market to really continue to push and collaborate with, where needed, the vendor community, to make sure that we're working together, in a sense, to drive the market toward more accessibility.

LILY BOND: Yeah. As a vendor, Kyle, I love that response. I think we should be partnering with you and thinking about this. In the context of the market, how can we drive towards this together and be real partners to each other in solving this and building great accessibility programs? So I look forward to those conversations over the next year with all of you.

Along these lines, Angela, there's a very specific question that I think you could weigh in on. I think your comment earlier around how you're thinking about this, cross-institution, in the state, how are you thinking specifically about vendor agreements and getting stronger vendor contracts at a state level versus an institution level?

ANGELA JACKSON: Yeah, it's definitely happening at the state level. There are discussions about getting that language built into every contract. So we use Contracts Plus. And there's actually a policy now, I believe, at the Board of Regents level that requires accessibility to be baked into those contracts. And so it is happening, I think, across the Board of Regents. It's also happening, I think, at the local level. It is still a bit challenging, but we're making progress in that space.

LILY BOND: Great. There are some questions here. Brian, I think this one might be a good one for you. How are you balancing Title II compliance with scalability across courses and faculty, especially when you're working within the constraints of your LMS?

BRIAN SMITH: Taking the LMS out of the conversation, because I deal mostly with Mediasite, and we just embed those videos in Canvas, scalability, that's why we've had the combination of the Mediasite AI captioning and the Pulse tool from 3Play. It's given us the ability to tackle our backlog of content with the Mediasite AI captioning while doing the majority of our brand-new and highly visible content with the 3Play Pulse tool.

And we've just had to incorporate it into all our workflows in order to scale it up across the board so that all new content is just-- it's what we're going to be doing going forward. And it's no longer extra work that we have to tackle down the road. Have it in there from day 1, and it doesn't become a backlog anymore. I believe Kyle mentioned something along those lines earlier.

LILY BOND: Yeah, that's great. Megan, I wonder if maybe you could weigh in here, too. How are you thinking about this particularly? I know you're looking at a lot beyond video, and you're dealing with faculty. How do you think about those constraints and the forward momentum you want to drive?

ANGELA JACKSON: Yeah, when we started out just looking at all of this, we scoped everything, and we did a lot of data analysis, like has been mentioned. And we really tried to analyze, what are reasonable asks to start from? And we wanted to be strategic, especially with faculty. Because we knew if we sent them to remediate a PDF first thing, we were going to lose them, and it was not going to go well. So we've tried to really start out with asks that are simple, that are manageable, and that we know will help them learn, too.

So for example, we said, will you please just clean out content from your course? We did some data, and we found that over 50% of our stuff in courses was being unused. And so just to get rid of that is a huge, huge improvement, too. Then we don't have to spend time remediating it.

And then we asked them, can you just work on your course pages right now? Fix the issues there. Then we'll build up to documents, and we'll just keep going. So they're also learning the skills that they need to be able to do harder things. But we're continuing that momentum and fixing things as we go, too.

LILY BOND: And Megan, who do you think are the key partners to your role to get buy-in to then work with faculty in an effective way to get the right vendors in place? Who are you partnering with? What are those roles?

MEGAN COX: Yeah, so on our campus, our instructional design team is an incredible partner. They're already working with a lot of these faculty members on their course. So while they're working with them, they can say, hey, did you know that you should just be using the built-in list tool instead of typing this manually? They can give those tips as they're working with them.

We use Ally as our institution-wide tool. So that's in place for every faculty to use, and we have that for them. We also have some things set up in our-- we use Kaltura. We have captioning and things set up there as well.

So another thing I would add on is you have to be strategic about what things you can do systemically, what things you can do internally, and what you have to ask people to do. So for some of the captioning stuff, we felt like we could handle that a little bit internally, but we can't go through every course. So that's going to have to be something that faculty help us do.

LILY BOND: Yeah, I think that's great. A great call to instructional design, too. A really strong partner to accessibility. Angela, I think there's a good attendee question for you. Do you have any good recommendations for training materials on how to read a VPAT, and how do you tell the good from the bad?

ANGELA JACKSON: So we actually developed an in-house training for how to do that. And we trained our internal teams on our particular office. We do the VPAT and software reviews for the university, and we have assisted in training other organizations how to do this.

So we have a guide. And oftentimes-- and then we'll do a video tutorial with them along with the guide, and it just walks them through. It's not an-- and others on this webinar can speak to it maybe more than I can. But our experts on our team do-- so we do hundreds of VPAT reviews every year. Hundreds.

And so you get to know the vendors. You get to know, when you're looking at a VPAT, if there's something wrong, if something doesn't look right. In our scoring process, we use an integrity score. We actually give the vendor an integrity score.

If that integrity score is an F, we then consider that VPAT unreliable, and we can't use it. I think anything lower than a C-minus, we won't-- we are like, OK, we're at a point where we believe we can't trust this VPAT. We can't trust this information.

And we've been collecting research on how many VPATs are actually unreliable, and it's statistically shocking. Last year, it was 20% of the VPATs we received were graded as unreliable, and we could not rely on them. We had to go through a different process for evaluation.

LILY BOND: You told me about your integrity score a few weeks ago, and I had never heard of that. I love it. Can you tell us a little bit about what you consider as input into that integrity score?

ANGELA JACKSON: Yeah, I mean, they're basic questions. Actually, I have to give a shout-out to the HECVAT that Kyle was such a huge part of. It has been instrumental at our organization for a long time. There is an accessibility portion of the HECVAT that often, organizations do not include in their scoring, and they should. That's why it was put in there. And it's hugely valuable. And a lot of people just ignore that. And we don't. We actually look at that. And we place equal value on that as we do the VPAT.

And so there's indicators in that that can tell us if they have a roadmap. And we've found just big inconsistencies between who filled out the HECVAT and who filled out the VPAT. And if you've got things like that that's not lining up-- or for instance, we email an organization, and they say-- we say, well, can you verify this on your VPAT? And they don't have a clue what you're talking about.

And we're like, you were the person who filled this out. So clearly, there's things that just give that away. But we do actually engage the organization. We don't just take the VPAT at face level. We always engage them in an email or in some other way to actually have a conversation with them.

LILY BOND: Really cool, and I think, a great model for how schools should be thinking about this. And I see a lot of questions and thumbs up, too, in the audience as well. With only 10 minutes left, I want to move to a concluding question. There have been some great ones coming in from the audience.

But I want to-- oh, I said going into this that I was looking at a long list of questions. And all of them are so important. And I want to get to all of them, and I just can't. So I am going to leave that alone and move forward, but with regret that I can't talk to this group for many more hours.

So you're all very impressive examples of progress towards compliance, and you've shared a lot of the different pieces of that. You've talked about leadership buy-in, about internal process planning, about auditing, vendor evaluation, budget approval, remediation, many other things. What's one thing that you think you and your team really nailed to get where you are today? Or on the flip side, is there a challenge you overcame with part of this process that you're really proud of that other people can learn from? Brian, I'll start with you.

BRIAN SMITH: The biggest challenge we overcame was the sheer amount of content that we had on Mediasite. We've been using it for 20 years now, so we had way more content on there than we absolutely needed to have. So just being able to scale that down was a huge step in getting us to where we are today.

Yeah, we archived low-value content, focused on what was actively being used. And then we were able to just lock in sustainable workflows for new content. And I think we're in a great position now to move forward.

LILY BOND: Yeah, and I think that's great, super actionable advice for people looking at the same problem. Really exciting, Brian. Megan, why don't you go next?

MEGAN COX: Yeah, the area that immediately came to mind is, I'm super proud of our YouTube captioning work. We implemented a standard in July of 2022 that required just all new videos to be captioned from there on. And then we built an internal tool that actually audits all of these channels monthly. And we're able to send reports to owners and work with them if we find any issues.

And so to this day, we haven't ever had to escalate a channel or anything. There's been some that have missed videos here and there, and we've worked with them to fix it. But that's gone really, really well. And so taking some of that experience, and we're now applying it to different areas. And we've been doing a lot of that same work on websites as well.

LILY BOND: Awesome. And I think a good, positive social story after a lot of challenges that everyone raised earlier. Angela, what about you?

ANGELA JACKSON: I would have to say that it was when we had or got senior leadership buy-in all the way up to the president, and having her talk about integrating this into our strategic plan, for our next strategic plan, and making it a thing. Naming it, claiming it, putting it in the strategic plan as a priority. That's when you know you've hit maturity.

That, for us, was, I think, a big turning point, is when we started to see, throughout the entire institution, that it was integrated in everybody's workflow. It was in conversation. And now everybody's talking about it. It's everywhere.

And it took a mindset shift and a culture-- integrating this culture into every department, everything we do, from the students and starting the USD Student Access Organization, which led it from the grassroots level, through Student Affairs, all the way through Academic Affairs, and then meeting in the middle. And I think that, for us, was a real turning point, that we hit that about three, four-- three years ago. And things have just really taken off since then.

LILY BOND: That's really exciting. And you mentioned at the beginning that it was-- the exciting moment was getting the buy-in all the way up to the president. Was it this holistic experience that finally caught the attention of the president, or was there something in particular that you did or someone did at your institution that got that high-level leadership buy-in?

ANGELA JACKSON: It was definitely-- actually, I believe it was probably led through her executive-- the executive counsel and legal counsel, honestly, who started engaging with me a lot more about digital accessibility and the importance of it. And then they took it to executive counsel and then started sharing it with her.

The Center for Digital Accessibility came out of the executive counsel at the University of South Dakota. That was not my idea. That was a top-down decision to be able to open up our services to the whole state. And so that's what I mean. It just impacted her. We saw the importance of it. And the students wanted it. The students started saying, hey, this is something that we want more of on our campus.

LILY BOND: Yeah, that's great. I think two more great partners there. Students and general counsel and legal teams can be great partners in pushing this forward. Kyle, I'll end with you. What do you feel like you've really nailed, or what are you really proud of that you've been able to overcome?

KYLE SHACHMUT: Yeah, I'm really proud of the overall institutional shift we've had in a relatively short amount of time. I work in an institution that's coming up on its 400th birthday. So it can take a while to shift things sometimes at institutions that have been around so long.

You can go back and see-- when I started my first job here, we were on the front page of the Chronicle pretty often for not doing everything that we could have been doing in the accessibility realm. And so to see transformation over a 10-plus-year period is pretty dramatic. And I think that goes somewhat to what Angela was saying about leadership buy-in.

And that doesn't just happen all at once, magically. But I think relationships are the coin of the realm in higher ed, and building relationships and helping show people why accessibility is important. So I put two links in the chat. One is, we love to spin up committees in higher ed. But we have a higher ed executive leadership committee. We call it our University Accessibility Committee. I actually just so happened to meet with them this morning.

But it's senior leaders from across the whole institution-- vice presidents, vice provosts, executive deans from different schools. And they talk about and have discussions on and hear updates about accessibility in lots of different fashions-- digital, physical, student experience, employee experience, lots of these areas.

And that way, when decisions come up in their areas that are impacted by accessibility, it's not the first time they've heard about it. And that's reinforced and supported from our president, our provost, seniormost leaders at our institution, our executive vice president that are bought-in and understand why it's important. And if you go through the legal process related to accessibility, your institution's going to spend a lot of money and a lot of time, and it's not fixing the stuff for accessibility.

And so if there's going to be an investment made, I would say, let's make sure that investment is at least improving the accessibility that we have. And so that's really well-done, supported by leaders, supported by all of our processes, the tools we were talking about. But that's helping our institutions live up to that promise that we want with these regulations of making a more equitable, accessible educational experience.

LILY BOND: I think that is a perfect note to end on. Thank you for that sound bite, Kyle. And thank you, Megan, Angela, Brian, and Kyle for just a really fantastic conversation. The audience had so many questions we couldn't get to, so much commentary on everything you said.

I, as I said earlier, would love to talk to you for many more hours, and I think we have some requests for that already in the chat. But we will not keep everyone for hours more. This was a wonderful way to close out our Countdown to Compliance series. And thank you to our audience for tuning in, and really for being so engaged in this session. Thank you everyone so much for your time. And I hope--