Board of Regents Policy CSCU Digital Accessibility Policy

This policy establishes requirements for digital accessibility across the Connecticut State Colleges and Universities (CSCU) system to ensure equal access to digital information, services, and technologies for all individuals, including those with disabilities. This policy implements CSCU’s obligations under Title II of the Americans with Disabilities Act (ADA), Section 504 of the Rehabilitation Act of 1973, and Connecticut state law. 

CSCU is committed to creating an inclusive digital environment where students, employees, and visitors, regardless of ability, can independently access, interact with, and benefit from web content, mobile applications, and digital technologies used in the provision of educational programs, services, and activities.

Archived Web Content: Web content that (1) was created before April 26, 2027, reproduces paper documents created before that date, or reproduces contents of other physical media created before that date; (2) is retained exclusively for reference, research, or recordkeeping; (3) is not altered or updated after the date of archiving; and (4) is organized and stored in a dedicated area or areas clearly identified as being archived. 

Assistive Technology: Any item, piece of equipment, software program, or product system that is used to increase, maintain, or improve the functional capabilities of persons with disabilities. Examples include screen readers, screen magnifiers, speech recognition software, alternative keyboards, and refreshable Braille displays. 

Conforming Alternate Version: A version of web content that conforms to WCAG 2.1 Level AA and provides all the same information and functionality as the non-conforming content in the same or an alternate language, as defined by WCAG 2.1. Conforming alternate versions may only be used when it is not possible to make web content directly accessible due to technical or legal limitations.

Conventional Electronic Documents: Web content or content in mobile apps that is in the following electronic file formats: portable document formats (PDF), word processor file formats, presentation file formats, and spreadsheet file formats. 

CSCU: Connecticut State Colleges and Universities. This includes all institutions, collectively or singularly, in the CSCU system including Central Connecticut State University, Eastern Connecticut State University, Southern Connecticut State University, Western Connecticut State University, Connecticut State Community College (CT State), Charter Oak State College, and the CSCU System Office. 

Digital Content: Information and sensory experience communicated to users through electronic means, including but not limited to web content, mobile applications, electronic documents, multimedia, and learning management systems (LMS). 

Fundamental Alteration: A modification that would fundamentally change the nature of a service, program, or activity of a CSCU institution. 

Mobile Applications (Apps): Software applications that are downloaded and designed to run on mobile devices, such as smartphones and tablets. 

Preexisting: Content that was available prior to April 26, 2027. 

Readily Accessible to and Usable By: Digital content that individuals with disabilities can access and use with substantially equivalent ease of use, timeliness, privacy, and independence as individuals without disabilities.

Third-Party Content or Service: Digital content, applications, platforms, or services provided or made available by CSCU through contractual, licensing, or other arrangements with external vendors, contractors, or other entities. 

Undue Burden: Significant difficulty or expense in relation to the size, resources, and nature of the institution.

User Agent: Any software that retrieves and presents web content for users. Examples include web browsers, media players, and assistive technologies. 

WCAG 2.1 Level AA: Web Content Accessibility Guidelines 2.1, Level AA, published by the World Wide Web Consortium (W3C) on June 5, 2018. 

Web Content: The information and sensory experience to be communicated to the user by means of a user agent, including code or markup that defines the content’s structure, presentation, and interactions. Examples include text, images, sounds, videos, controls, animations, and conventional electronic documents.

A. General Requirements

• All CSCU institutions and the System Office must ensure that web content and mobile applications that the institution provides or makes available, directly or through contractual, licensing, or other arrangements, are readily accessible to and usable by individuals with disabilities. This requirement applies to all digital platforms, services, and content used in the provision of educational programs, student services, employment activities, and institutional operations.
• Web content and mobile applications must comply with the Web Content Accessibility Guidelines (WCAG) 2.1 Level AA success criteria and conformance requirements, except where:
  • Compliance would result in a fundamental alteration in the nature of a service, program, or activity; or
  • Compliance would result in undue financial and administrative burdens, as documented in accordance with Fundamental Alteration and Undue Burden section of this policy.
• CSCU institutions and the System Office remain responsible for ensuring the accessibility of all digital content and services provided or made available through third-party vendors, contractors, or other external arrangements on behalf of CSCU.
• Accessibility is an ongoing obligation. Institutions must maintain compliance with this policy for all covered web content and mobile applications throughout their operational lifecycle, including when content is updated, modified, or replaced.

B. Exceptions

While CSCU seeks to make all digital content accessible, the requirements of this policy do not apply to the following content: 

• Archived Web Content
• Preexisting Conventional Electronic Documents unless updated or actively used to provide relevant and timely information.
• Preexisting Social Media Posts
• Content Posted by Third Parties: Content posted by third parties where the institution does not control or have a contractual, licensing, or other arrangement with the third party (e.g., comments posted by the public on an institutional social media page).
• Individualized, Password-Protected Documents: Documents uploaded by students, faculty, or staff for password-protected, user-specific, individual use (e.g., documents uploaded for grading by one instructor). However, documents made broadly available in the LMS must be accessible (e.g., course syllabi, lesson plans, etc.).

C. Rights and Responsibilities

1. Student Rights and Responsibilities

   Students have the right to: 

   • Access digital content, services, and technologies provided by CSCU institutions and the System Office with substantially equivalent ease of use, timeliness, privacy, and independence as students without disabilities;
   • Request and receive accessible versions of digital materials in a timely manner;
   • File complaints regarding inaccessible digital content through established grievance procedures;
   • Receive reasonable accommodations when digital content cannot immediately be made accessible, in coordination with campus disability services offices.

   Students have the responsibility for: 

   • Promptly notifying instructors and/or the institution’s designated accessibility contacts, if they encounter digital accessibility barriers and contacting disability services should they require-disability related accommodations;
   • Working collaboratively with faculty and staff to identify effective solutions to accessibility issues;
   • Providing necessary documentation to disability services offices to facilitate appropriate accommodations, as required by institutional procedure.
      

2. Employee Rights and Responsibilities

   Employees have the right to:

   • Access digital tools, platforms, and content necessary to perform their job duties with substantially equivalent ease of use as employees without disabilities;
   • Request reasonable accommodations related to digital accessibility through institutional human resources or other designated offices processes;
   • Receive training and technical support for creating and maintaining accessible digital content; and
   • File complaints regarding inaccessible digital content through established institutional grievance procedures.

   Employees have the responsibility for:

   • Creating, purchasing, and maintaining digital content that complies with WCAG 2.1 Level AA standards;
   • Completing any required digital accessibility training as designated by their institution;
   • Responding promptly to student or colleague requests for accessible digital materials;
   • Ensuring that third-party digital tools and platforms used in courses, programs, or services meet accessibility requirements;
   • Consulting with the designated institutional accessibility contacts when digital accessibility questions or issues arise. 

3. Visitor Rights

   Visitors to CSCU digital spaces (including prospective students, alumni, community members, and the general public) have the right to access publicly available institutional web content and mobile applications with substantially equivalent ease of use, timeliness, privacy, and independence as visitors without disabilities. 

4. Institutional Responsibilities

   CSCU Institutions and the System Office are responsible for:

   • Ensuring compliance with all requirements of this policy and applicable federal and state accessibility laws;
   • Designating an ADA/504 Coordinator or equivalent position responsible for overseeing institutional compliance;
   • Developing and maintaining institutional digital accessibility standards, procedures, and guidelines consistent with this policy;
   • Providing regular training and professional development opportunities for faculty, staff, and administrators on digital accessibility requirements and best practices;
   • Conducting regular accessibility reviews of institutional websites, applications, and digital platforms;
   • Maintaining processes for users to request accessible versions of digital content and to report accessibility barriers;
   • Establishing and enforcing procurement requirements to ensure that purchased or licensed digital products and services meet accessibility standards;
   • Maintaining documentation of accessibility efforts, including reviews, remediation plans, and barrier removal activities;
   • Publishing a public accessibility statement on the institution’s website that includes contact information for reporting accessibility issues;
   • Allocating sufficient resources to support accessibility initiatives, remediation efforts, and staff training. 

D. Fundamental Alteration and Undue Burden

Where an institution can demonstrate that compliance with WCAG 2.1 Level AA would result in a fundamental alteration in the nature of a service, program, or activity, or in undue financial and administrative burdens, compliance is required to the extent that it does not result in such alteration or burdens.

• The institution has the burden of proving that compliance would result in a fundamental alteration or undue burden.
• Any determination that compliance would result in a fundamental alteration or undue burden must be made by the institution’s president or their designee after considering all institutional resources available for use in the service, program, or activity, and must be accompanied by a written statement of the reasons for reaching that conclusion.
• Even where compliance would result in a fundamental alteration or undue burden, the institution must provide individuals with disabilities access to the benefits of the service, program, or activity through alternative means that do not result in a fundamental alteration or undue burden.
• All determinations of fundamental alteration or undue burden must be documented and maintained by the institution.

E. Procurement and Contracting Requirements

• All procurement processes for digital products, services, platforms, and content must include accessibility requirements based on WCAG 2.1 Level AA standards. Vendor responses must be evaluated for accessibility compliance as part of the selection criteria.
• Vendors providing digital products or services are required to provide a Voluntary Product Accessibility Template or equivalent documentation demonstrating adherence to WCAG 2.1 Level AA standards prior to contract execution.
• All contracts for digital products, services, or content must include provisions requiring vendors to maintain accessibility throughout the contract period, provide accessible documentation and support materials, and remediate identified accessibility issues in a timely manner, which may be defined by the contract.
• Prior to deployment, all purchased or licensed digital products must be reviewed for accessibility compliance by designated institution personnel or third-party accessibility consultants.
• Where an existing contract involves digital products or services that do not meet accessibility standards, the institution must work with the vendor to develop and implement a remediation plan with specific timelines. If remediation is not feasible, the institution must provide alternative means of access or seek alternative accessible solutions.

F. Conforming Alternate Versions and Equivalent Facilitation

Institutions may use conforming alternate versions of web content to comply with accessibility requirements only where it is not possible to make web content directly accessible due to technical or legal limitations. Institutions may use alternative designs, methods, or techniques that result in substantially equivalent or greater accessibility and usability of web content or mobile applications. Any such alternatives must provide users with disabilities with the same information and functionality with substantially equivalent ease of use as provided to users without disabilities.

G. Training and Professional Development

CSCU institutions and the System Office should provide regular training and professional development opportunities on digital accessibility for all employees involved in creating, purchasing, maintaining, or managing digital content, including but not limited to faculty, instructional designers, web developers, IT staff, content creators, and procurement personnel. Training may address WCAG 2.1 Level AA standards, accessible document creation, accessible media production, accessible LMS use, procurement of accessible technologies, and the legal requirements of Title II of the ADA.

H. Monitoring, Reporting, and Remediation

Each institution must conduct regular accessibility reviews of its web content and mobile applications using a combination of automated testing tools and manual evaluation. When accessibility barriers are identified and not immediately remediable, institutions should develop and implement remediation plans with specific timelines for barrier removal. Priority should be given to content and services that are frequently accessed or are essential to core institutional functions. 

Beginning in 2027 and each year after, each institution must submit an annual digital accessibility report by May 1 of each year to the CSCU Office of Compliance documenting accessibility review results, remediation efforts, barrier removal activities, training provided, and progress toward full compliance. This report must include a review of both public facing web pages and LMS content. 

CSCU Executive Director of Civil Rights Compliance will produce and publish guidelines and necessary criteria to include in the annual reports. 

Institutions must maintain and promote accessible mechanisms for students, employees, and visitors to report accessibility barriers and request accessible formats.

Enforcement

1. The CSCU Office of Compliance, in coordination with CSCU General Counsel, CSCU Information Technology, and CSCU Academic Affairs, will provide oversight and guidance to institutions regarding implementation of this policy. The System Office will, at a minimum, conduct annual reviews of institutional compliance and require corrective action where deficiencies are identified.
2. Each CSCU institution is responsible for ensuring institutional compliance with this policy. Institutions must designate appropriate personnel to coordinate accessibility efforts and allocate sufficient resources to support compliance activities.
3. Failure by employees to comply with digital accessibility requirements may result in appropriate corrective action, up to and including disciplinary measures, in accordance with applicable collective bargaining agreements, employment policies, and procedures.
4. This policy is meant to be interpreted and implemented in accordance with Title II of the Americans with Disabilities Act, Section 504 of the Rehabilitation Act of 1973, any relevant implementing regulations, and applicable Connecticut state law. Nothing in this policy shall be construed to reduce or limit CSCU’s obligations under federal or state law.