Accessibility of Web Content & Mobile Apps

In 2024, both the Department of Justice (DOJ) and the Department of Health and Human Services (HHS) finalized updates for the Americans with Disabilities Act (ADA) Title II and Rehabilitation Act of 1973 Section 504 (Section 504) regulations. These updates require identified entities to ensure that any web content and mobile apps they provide or make available are accessible to specific technical standards. All public colleges and universities, and many private ones, have (or are creating) local compliance plans, fact sheets, and checklists for campus-wide efforts. The documents below take different approaches because local guidelines will fulfill most generalized needs.

Summaries

  • ADA Title II Summary: This four-page Google Doc summarizes the DOJ’s 2024 revision to the ADA Title II regulations and highlights sections that are especially relevant to academic libraries. The document includes the final rule’s background and core premise, requirements, definitions, exceptions, additional compliance guidelines, and library-specific responses from the DOJ’s section-by-section analysis and response to public comments.
  • HHS Section 504 Summary: This four-page Google Doc summarizes the HHS 2024 updates to the Section 504 regulations and highlights sections that are especially relevant to academic libraries. The document includes the final rule’s background and core premise, requirements, definitions, exceptions, additional compliance guidelines, and library-specific items from the HHS section-by-section responses to public comments.

Considerations

The considerations document (a five-page Google Doc) explores proposed connections and questions to consider for some of the more complex or situational aspects of digital accessibility for web content and mobile apps provided by academic libraries. The questions are organized in three sections (organizational commitments, contextualizing content, and cooperative relationships), which offer perspectives to identify how a library’s local contexts align with the updated regulations. Because the questions cross multiple areas of library work, responses will likely be contributed by multiple library workers. (There is only one considerations document because the updates for both ADA Title II and Section 504 align regarding requirements, exceptions, and related compliance guidelines.)

Comparison

The comparison spreadsheet (Google Sheet) reviews the updates for ADA Title II and HHS Section 504 by both the language in the final rules and the identified entities.

  • The Regulation Comparisons sheet frames the final rules based on four sections:
    • Requirements: who, what, how, when
    • Exceptions: overview; archived web content; preexisting conventional electronic documents; content posted by a third party; individualized, secured electronic documents; preexisting social media posts
    • Additional compliance guidelines: conforming alternate versions, equivalent facilitation, fundamental alteration or undue burden, effect of technical noncompliance
    • Library-specific responses: archived web content, libraries as identified entities, intellectual property law, EPUBs and digital textbooks, content from third-party vendors
  • The Identified Entities sheet determines identified entity status for Alliance members for both ADA Title II and HHS Section 504.
    • ADA Title II: public entities
    • HHS Section 504: recipients of Federal financial assistance from the Department of Health and Human Services
      Limited to estimates (noted as Possibly, Maybe, and Unknown) due to multiple unknown factors: fund distribution may obligate the entire institution or a specific unit; grants or contracts may or may not continue/renew; an institution may receive other forms of HHS funds (e.g., Medicare or Medicaid) directly or through contractual, licensing, or other arrangements

Selected Resources

Responses to the updated regulations will vary based on context and type of web content or mobile app. These are selected resources for planning and support across different library functional work areas.