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ADA Compliance
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ADA Title II

On April 24, 2024, the Federal Register published the Department of Justice’s (Department) final rule updating its regulations for Title II of the Americans with Disabilities Act (ADA). The final rule has specific requirements about how to ensure that web content and mobile applications (apps) are accessible to people with disabilities.

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WHAT IS TITLE II?

Nondiscrimination On The Basis Of Disability; Accessibility Of Web Information And Services Of State And Local Government Entities.

Legal Update

Title II of the Americans with Disabilities Act (“ADA”) was updated in April 2024, requiring all web and mobile apps offered by state and government entities to be accessible to people with disabilities. This rule covers all web and mobile apps UNF provides directly or through contractual, licensing, or other arrangements with 3rd Parties.

The update establishes WCAG 2.1 levels A & AA as Title II’s technical compliance standard.

Deadline to Comply

Universities of UNF’s size have until April 24, 2026, to come into compliance with the new rule.

What is WCAG?

The Web Content Accessibility Guidelines (WCAG) Version 2.1, Level AA is the technical standard for state and local governments’ web content and mobile apps.

ADA Title II’s digital compliance update sets WCAG 2.1 level AA specific technical standard that state and local governments must follow to meet their existing obligations under Title II of the ADA for web and mobile app accessibility.

WCAG, the Web Content Accessibility Guidelines, is a set of guidelines that say what is needed for web accessibility, such as requirements for captions for videos. WCAG is developed by the World Wide Web Consortium (W3C).

A technical standard says specifically what is needed for something to be accessible. For example, the existing ADA Standards for Accessible Design are technical standards that say what is needed for a building to be physically accessible under the ADA, such as how wide a door must be or how steep a ramp can be.

GROUPS AFFECTED

General Counsel’s rule is all websites, mobile apps, and digital documents made available to students, or the public must comply with the Title II digital accessibility rule.

This includes content students access through login or password. Anything students can access through their role as students must be compliant

Per general counsel, web and mobile apps exclusively used by employees or faculty with no student-facing components are excluded from the ADA title II compliance scope.

Note: Some web and mobile apps contain both student-facing and employee-only parts; the employee-only parts are exempt per General Counsel’s rule, but the student-facing parts are not exempt and must be compliant.

 

Key Terms Defined 

Website Vs. Webpage: A webpage is a single page within a website, while a website is a collection of interconnected webpages, accessible under a shared web domain name.

Web Domain: A domain name is the unique name or address of a website.

The websites below are separate web addresses, which makes each site a unique web domain.

Domains and Examples of Web pages within a domain
 Examples of Domains:  Examples of Webpages Within a Domain:
www.unf.edu Domain Name  www.unf.edu (Cascade) 

Domain name: unfospreys.com

Domain name: iptm.unf.edu

unfospreys.com https://www.unf.edu/scholarships/ https://unfospreys.com/sports/baseball https://iptm.unf.edu/tuitionfree.html
iptm.unf.edu https://www.unf.edu/financialaid/ https://unfospreys.com/sports/mens-golf https://iptm.unf.edu/catalog.html
mocajacksonville.unf.edu https://www.unf.edu/emergency/ https://unfospreys.com/staff-directory https://iptm.unf.edu/travel.html
unfgolfcomplex.com https://www.unf.edu/emergency/safe-ospreys.html
domains.unf.edu
dineoncampus.com/unf

 

UNF'S Unique Domains 

UNF’s Unique Domains is a catch-all term for all the websites or applications outside the main Cascade www.unf.edu web domain.

The Unique Domains are public or student-facing websites and mobile apps that are required to be compliant under ADA Title II’s digital accessibility rule.

UNF’s total web presence includes more sites and apps than what’s under Cascade’s www.UNF.edu web pages.

IPTM & MOCA are unique domains because their web domains are subdomains of www.unf.edu with their URL domains being https://iptm.unf.edu/ & https://mocajacksonville.unf.edu/, respectively.

 

Examples of UNF'S Unique Domains (Sites Outside Cascade): 

  • The Athletics site (unfospreys.com), uses the Sidearm content management system (CMS). 

  • Websites created using WordPress for example, unfprintguild.wordpress.com or www.unfsae.org/.

  • Websites created using programs such as Wix, Drupal, or GoDaddy (for example, https://unfgolfcomplex.com/, which uses GoDaddy).

  • Blog sites created using platforms such as, but not limited to Blogger, Weebly, Squarespace, or Tumblr (for example, http://unfprintguild.tumblr.com. 

  • Websites created through UNF Faculty Domains (https://domains.unf.edu/).

  • Any other website created, maintained, and edited with a CMS that isn’t Cascade, such as https://dineoncampus.com/unf/ or https://studyabroad.unf.edu/_portal/.

Note: personal blogs or sites created by employees/students to represent themselves (i.e., they don’t represent UNF as a public entity) are out of scope. Sites in scope are ones created and maintained for university departments, units, clubs, events, etc.

 

PROJECT SCOPE

What Has Not Changed

  • UNF’s web compliance standard hasn’t changed with the ADA Title II digital accessibility update; ADA Title II requires WCAG 2.1 Level A and AA compliance. UNF’s web compliance standard has been WCAG 2.1 level A and AA since 2018.

  • Cascade WWW.UNF.EDU Web Pages have been reviewed and certified since 2017.

What Has Changed (New)

  • ADA Title II’s digital accessibility update has expanded the scope of what digital content that must be compliant and set a deadline for public entities to meet compliance.

  • Universities of UNF’s size have until April 24, 2026, to come into compliance with the new rule.

  • For questions and assistance, Email UNF ADA Digital Compliance Help at ADAdigitalhelp@unf.edu.

ADA Title II Archive Introduction

    • Title II restricts what can be archived; pages and documents actively needed for ongoing services, events, or activities cannot be archived.

    • After the April 2026 deadline, you cannot archive new content.

    • Title II requires that you create an archive and move archive content to that archive location.

    • Web pages and documents that are not deleted or archived must be reviewed and made WCAG compliant.

ADA Title II Qualification Requirements

 

The content MUST meet all four of the following points to qualify.
If the content doesn’t meet any one of the following requirements, then it can’t be archived and must be compliant with the DOJ rule or deleted.
    1. The web content was created before the date of April 24, 2026, or reproduces paper documents or other physical media that were created before April 24, 2026, (The DOJ anticipates that public entities may identify or discover historic paper documents or historic content contained on physical media that they wish to post in an online archive following the time they are required to comply), AND

    2. The content is retained only for reference, research, or recordkeeping , AND,

    3. The content is kept in a special area for archived content, AND,

    4. The content has not been changed since it was archived.

THE PROJECT TEAM

  • Executive Committee ADA Title II Digital Accessibility| Rocelia Roman de Gonzalez, Director, ADA Compliance
  • Executive Committee ADA Title II Digital Accessibility| Justin Sorrell, Senior Assoicate, General Counsel
  • Executive Committee ADA Title II Digital Accessibility| Megan Kuehner, Assistant Vice President, Enterprise & Strategy
  • Executive Committee ADA Title II Digital Accessibility| Courtenay McLeland, Head of, Digital Strategies & Technology
  • Executive Committee ADA Title II Digital Accessibility| Rozy Parlette, Director, CIRT
  • Executive Committee ADA Title II Digital Accessibility| Michael Binder, Professor
  • ADA Compliance Department| Rocelia Roman de Gonzalez, Director, ADA Compliance
  • ADA Compliance Department| Rachel Fieschko, Tech Analyst I, Accessibility
  • ADA Compliance Department| Jay Patel, Student Assistant, Accessibility

 

 

 

PROJECT TIMELINE

Milestone Date
Executive Committee Title II Digital Accessibility formed February 10, 2025
Project Begins April 09, 2025
ADA Title II Digital Inventory & Training April 28, 2025
Project Deadline April 24, 2026

RESOURCES

 

AMP

Unique Domain URL and AMP Reference

UNF Digital Compliance Processes

Inventory Templates

WCAG 2.1 Level AA Review Checklist

Submit AMP Reports to ADA for Certification Review

Document Compliance

 

Digital Compliance Testing Tools

 Training Demo Compliance Pages to Use During Training

  1. https://www.unf.edu/adacompliance/TEST/BLANK.html
  2. https://www.unf.edu/adacompliance/TEST/Demo2.html
  3. https://www.unf.edu/adacompliance/TEST/Demo3.html 

Additional Resouces