What Campus Leaders Need to Know About ADA Title II

Cynthia Golden: Hi, everybody and welcome to the Integrative CIO podcast. We recorded today's edition that you're about to see on April 16th, and that was shortly before the new ADA regulations were scheduled to take effect. These regs would, for the first time, explicitly codify a technical standard for websites and mobile apps and digital documents, and this would apply to public entities, including public colleges and universities. On April 17th, the DOJ issued an interim final rule that delays the deadlines by a year. Now, this doesn't change existing laws or I need to move forward in our institutions. But we have invited, one of our guests, Eudora Struble, back to the podcast to comment on this change. Eudora?

Eudora Struble: Thank you, Cynthia, and thanks for making sure everybody knows about the change. It's certainly important to stay abreast of what's going on with these laws and regulations. This is not a time for us to take our foot off the gas. We still have the laws in place. We have the international laws. We know that we have the same obligations to reduce risk in and increase in compliance, but also to increase the welcome to our community. Make sure our students succeed. Make sure we have great recruitment and retention of faculty and staff. All of those things are improved by doing this accessibility work. So I encourage you to continue with the enthusiasm and, resources that you've already been putting into it or more and take this year to build on the trainings you've already established to build on the knowledge and workflows you've already produced, and to make sure that a year from now we have even stronger, accessibility to offer to all of our constituents in higher education. So, the message is don't slow down. No, do not slow down. We've made great progress and now's the time to just keep going. This is a milestone. We can say, yep, we made it to that date and we've done well. But look how much more we can do now.

Cynthia Golden: Thank you so much, Eudora. And now onto the podcast.

Cynthia Golden: Hi everybody and welcome to the integrative CIO podcast. We're really happy to have you here today and let's get started. So higher education has spent a number of years digitizing the student experience. I think we're all aware of the impact that technology has had on teaching and learning and education. But it hasn't always made that experience accessible. Now with the new ADA requirements that are taking effect in April this month of 2026, our institutions are being asked to review and remediate not just their technology, but to think also about their assumptions about access. So what does it really mean to have systems that every student can use? How can CIOs leverage their deep knowledge of an institution and their relationships across key areas to amplify the impact of accessibility efforts? What areas and what stakeholders are great allies in reducing accessibility risks and promoting ongoing accessibility commitments? How do we build a campus culture where accessibility is a given? So these are the kind of things that we're going to explore in today's show. Michael.

Michael Cato: Thanks Cynthia Golden. And I'm excited because today our guests are Eudora Struble, Director for Technology Accessibility at Wake Forest University, and Jarrett Cummings, Senior Advisor for Policy and Government Relations at EDUCAUSE. Both of our guests have been closely involved with campus accessibility efforts and have been following the new requirements, as well as the work that campuses have been doing over the years. And we're happy to have both of you here today. Welcome Eudora and Jarrett.

Jarret Cummings: Thank you.

Eudora Struble: Thank you so much for having us.

Michael Cato: So before we turn to the regulations that are set to take effect later this month, could you give us a quick overview of the federal rules in case anyone listening isn't quite as familiar? And are there any new developments that we should be aware of?And Jarrett, how about we start with you?

Jarret Cummings: Well, sure, I'll go ahead and kick us off and I'll try to do this in a time efficient fashion given that we could take the entire half hour just talking about this. But essentially the dominant legislation in this space is really around the Americans with Disabilities Act, which has, at least in relation to higher education, the key focus is around Title II. which addresses the accessibility requirements for state and local governments, including public higher education institutions. And Title III, which addresses the accessibility requirements for places of public accommodation, which pretty much encompasses any entity that has something to do with interstate commerce. And so that largely covers private nonprofit higher education institutions as well. In the meantime though, there was a precursor law, the Rehabilitation Act of 1970, I want to say 72, but I could be wrong. was the early 70s. 73, that's close, not bad. And Section 504 of that act requires recipients of federal financial assistance, organizations in particular, to address accessibility requirements.

Eudora Struble: 73.

Jarret Cummings: So in that particular case, relative to the Department of Education, it doesn't matter whether you are a public or a private nonprofit or a for-profit institution of higher education, if you receive federal student aid funds, for example, or any Department of Education grants, you are required to follow Section 504. Meanwhile, for healthcare entities or other entities that receive grants from the Department of Health and Human Services, HHS has its Section 504 responsibilities that it enforces as well. So that's the basic framework. And then, of course, there are a variety of state accessibility requirements that we won't get into at this point. But needless to say, it's a pretty broad and varied landscape. Now, in terms of our current context, as Michael was mentioning, we're largely focused on ADA Title II because the web and mobile app accessibility regulations that were developed by the Biden administration, are set to take effect for most colleges and universities in, on April 24th. However, the Trump Department of Justice starting last fall indicated that it planned to pursue a new notice of proposed rulemaking, which kicks off a new regulatory process around the ADA Title II requirements to essentially lower the cost of compliance. And that's all the department said about its plans, but at least put out into the ether that it was planning to pursue a new regulatory process. Then at some point between the release of that information and earlier this year, the department instead shifted to proposing an interim final rule for review by the Office of Management and Budget, which if it cleared Office of Management and Budget approval, the department would be able to release and then that interim final rule would essentially take effect while the rest of the rulemaking process unfolds from there, which is different from how the regulatory process normally works. Again, though, the department has provided no actual information about what is covered by the interim final rule, how it might change or vary from what the pending regulations address. And so at this juncture, all we know for certain is that unless something happens prior to April 24th, most colleges and universities are going to need to be in compliance with, or at least very actively working in good faith toward compliance with, Title II rules that we know.

Michael Cato: I appreciate all of that Jared. I had to smile at that the encyclopedic knowledge of the dates and the details. Eudora, what would you add to this?

Eudora Struble: Yeah. I would add that it's been a stressful time for a lot of accessibility professionals in higher ed and probably elsewhere as well. With the interim final rule, we, because as Jarrett said, we don't know exactly what that might mean. There has been a lot of concern that somehow the regulation strengths would be diminished in whatever comes next. We still don't know. And between now and eight days from now and the regulations have their birth date. We will definitely, sorry, we don't know if we'll hear something new about this or if we'll hear nothing. And so we are all holding our breath a little bit. But the important thing, I think the important thing to know is that as Jarrett was mentioning, there's section 504, state laws, local laws, there's also international laws around accessibility. And what the regulations are pointing to, something called Web Content Accessibility Guidelines 2.1 AA, if you want to go Google it. That is something that's been a standard to look to for a long time and covers most of these different regulations and laws across the globe. So this is a set of work that a lot of us have been doing for a long time. And the regulations have been an excellent push and motivator to get more people on board, to get more resources allocated. But in terms of If a change in the regulation comes from this interim final rule, we will continue to do the same work and we have other laws and regulations that we have to follow. So, so don't feel like you can just go pause the podcast and go Google if the title to ADA regs changed. doesn't really, it matters, but it doesn't really matter to what we do next. We have to keep doing the work.

Jarret Cummings: And actually. I wanted to add a quick point because even though Title II of the ADA only applies to state and local government entities and therefore in our context, public higher education institutions, it's important for private nonprofit institutions or for-profit higher education institutions to pay attention to these Title II rules. Sorry, I can't say that five times very fast. Because they, start to set a paradigm for higher education generally. So even though, you know, on a formal basis, the regulations will not apply to private higher education institutions. It's something that they should be paying attention to as the baseline that will likely affect them at some point in the future.

Eudora Struble: Yeah, think, I mean, to that I would say most higher ed is always looking to be a little future proofed to be ready for whatever comes next. And I think now a lot of schools are thinking about that in a lot of different places. But this is a way that you can try to get ahead of whatever comes next if you're in that private institution that Jarrett was

Cynthia Golden: Yeah, and I think that's part of, you know, we'll talk a little bit later maybe about creating a culture of accessibility on campus. You know, whether you're required or not, it's always a good idea. And I think that that's really important. So if we look at the regulations that are on deck that are coming into effect this month. Can you talk a little bit more about ADA Title II and for people who might not be familiar with the details, why this, why now, what's really happening with these new regulations? Jarret?

Jarret Cummings: Sure, I'll go ahead and get the ball rolling. And actually, it's interesting that in some ways this discussion goes back over 10 years because the Obama administration originally tried to establish IT accessibility regulations under the ADA for both titles two and three and just wasn't able to get that process over the finish line before that administration ended. So the Trump administration took a different path. The Biden administration came in and already had that groundwork, so to speak, available to it from a prior Democratic administration. And so in some sense, it was just picking up the ball that had been dropped and trying to move it forward in this timeframe. And so in terms of the regulations themselves, essentially, the Department of Justice has under both Republican and Democratic administrations has long stated its view that the ADA covers IT accessibility, including web content, including mobile apps and other forms of software all along. There just wasn't a defined framework for what compliance with the ADA in relation to those technologies and the relative content, excuse me, what that meant. And so the Title II rules start to put in place a defined compliance standard in relation to the WCAG 2.1 AA requirements, as Eudora mentioned, and to set out some frameworks for how that has to be applied. in order for an institution that's covered by Title II to be compliant with the regulations. And in essence, I think it really boils down to if you have web content or if you're deploying mobile apps as a covered institution that are utilized in the delivery of your programs, activities, or services, then it should be WCAG 2.1 AA compliant under these regulations. Now there are some exceptions in the regulations for certain forms of content like archived web content or pre-existing conventional electronic documents such as PDFs. If a third party hosts content to your site that you are not responsible for per se. You haven't contracted for it. It's not provided under agreement. It's not something you're necessarily actively using in your services. You're just making it possible for, say, a student to share information on a part of your site. That's accepted as well. However, even within the context of those exceptions, if any of that content is actually being used for delivery of programs, activities, or services, then it has to be made compliant. So it really just comes down to, at this point, you have to assume if it's online and it's an active part of what you're doing as an institution to serve students or the public or even your staff, it probably needs to be WCAG 2.1A compliant.

Cynthia Golden: And yeah.

Michael Cato: Mm-hmm.

Eudora Struble: That was excellent. The one thing you didn't mention that people might care about is the social media. Old social media is an exception as well. However, going forward, it's not. And as Jarrett said, if it's something that is going to be used in your programs, activities, or services that you're recycling, has to be made accessible.

Cynthia Golden: So the amount of content that we're talking about at any given institution is really huge, right? As you are talking to people across higher ed IT, where do you think institutions are most at risk right now? Eudora?

Eudora Struble: will let Jared answer the like legal risk part, but I will tell you that I talk about risk a lot with my stakeholders because they look at their pile of classes and PDFs and their slide decks and all of the tools they're bringing into their classrooms and everything else. And they think this is too big. I can't even start. And we need people to start because really progress is the only way to make accessibility better. have to just keep going, especially in tech when technology is as AI has shown us, always changing and updating and making it so that there's something new. We have to keep tabs on it. And so I try really hard to explain to faculty and staff and colleagues and other places that the goal is to reduce our risk and increase our welcome and the success of our students, staff and faculty. And so we look for where we can have impact and where the biggest barriers are and where our biggest audience for impact is. Because we can't make every PDF, which is PDFs. I'm sure I'll say it at some point. PDFs are kind of my frenemy, maybe the bane of my existence. So we can't make every PDF instantly accessible. It's not yet possible, maybe someday. And so we have to start somewhere and focus on if I have a course that's required for all incoming freshmen, that is a great place to start because it's mission critical. Students will need it right away. And we know that lots of students are going to need that material. So that's a great place to start. I don't want us to ever stop. I want us to keep going until we're done with everything, but we really do have to start somewhere or we'll just get stuck.

Cynthia Golden: I think that required freshman course is a great example of where you could really make a big impact.

Michael Cato: Eudora, Cynthia Golden, I didn't mean to interrupt you. I was just going to reflect back. So Eudora use the phrase that I really appreciate of increase our welcome. I don't think I've heard it expressed quite that way before, but I really like that.

Cynthia Golden: I was just

Eudora Struble: It is not my turn of phrase. is something that we say a lot of things in my sort of professional groups that get repeated a lot. Progress over perfection every day, I say. And the idea that we're looking to make a bigger welcome for everyone and also to support the success. We want to keep everybody in place working and studying. We want everybody to have an equal chance to be successful. So you'll probably hear it again when you talk to any of my colleagues.

Cynthia Golden: do want to mention that there was an article in EDUCAUSE Review in February by Kyle Schachmutt from Harvard, and that gives a good overview, I think, of the regulations and what we've had, what's coming, and I just want to refer our listeners to that if you need a little more information.

Eudora Struble: Yeah, Kyle is a dear colleague and friend. He has worked a lot on the EDUCAUSE IT Accessibility Community Group along with me and others. And the article is a really good starting place if you are not sure how to think about why it matters or how to talk to other stakeholders about why it matters and where to get started. It can be a really good lift in your momentum, I think.

Michael Cato: I'd like to pick up on another part of what you'd shared, Eudora, which was AI, right? The magic words that seem to come up in so many different conversations. Could I ask you to describe a little bit, how do you think the new rules intersect with the explosion of AI tools in higher ed?

Eudora Struble: Mm.

Eudora Struble: So I won't say that the timing of AI, sorry, I won't say that the timing of all of the AI tools exploding and moving so quickly has been convenient for all of the work we've been doing with the regulations. But it does follow the pattern we already know from other tools and services that we have. So in terms of having a new tool come into our environment and have lots of different people try to pick up different services and vendors for that thing,

Michael Cato: And you don't know what to with, do Sorry.

Eudora Struble: That leaves us with the desire to confirm that everything is accessible, right? So that each of those tools is accessible. When AI really picked up steam, I'm sure you all noticed we had new tools or new services or updates all the time. And when that's happening, it's hard for any of us to keep tabs on what's coming in, what's going out. And so when we look to review accessibility for any third party tool, which we, think,  A lot of us spend a lot of time on that. Having something like AI come in and be so buzzy, so exciting that everybody wants to adopt it. And then all the vendors we already want to build it into what they are already giving us. It gives a lot to keep up with, but it does follow the same rules as everything else that we've been working towards in terms of third party vendors. We review those things that have. of the broadest reach, the biggest impact. We spend time reviewing down to as much as we can. We try to build good relationships with vendors. I will say some of the AI tools that the LLMs came out with not great accessibility experiences for people with disabilities who used assistive tech. And there have been many of my peers who have worked hard to push them. And some of those have gotten better. Some things have gotten fixed. It's really important that: as people are building things with AI or adopting tools that are, that bring in AI, that they think about accessibility, not just absolutely think about if the tool itself is accessible, but not just that also think about everything you're making, maybe at hyper speed now, because you can make it with AI is that accessible. If I make 20 slide decks in a day with AI, because I can, and then I put them out there and none of them have all text and all the reading order is messed up. and bad color contrast, that's not great. And right now the tools don't have something built in that allows most of the tools don't have anything that allows you to really easily check or confirm or apply accessibility. So vibe coding gives me a special kind of stress because I see people making little tools and apps and everything. And it's just really important that just like anything, when we make it something and put it out in the world that we take ownership of it, including its accessibility.

Michael Cato: I really appreciate that description. also am having quite a bit of heartburn about the idea of VypCoding, particularly for people who don't do software development and don't appreciate a range of considerations, including accessibility. Because some of the newer tools I've seen, there's more you can do if you do that at the same time. But if you build it, release it, and then try to worry about accessibility, that's just so much harder. I'm also curious then, from that description, Do you think that we're at a place yet where AI is helping institutions meet their mandates or is it just making compliance harder?

Eudora Struble: a little of both, I guess. It's, I don't know if it balances out because I haven't, I haven't been able to stop long enough to try to measure it out. But there are some really good AI products and tools that are helping support a lot of people with, with official accommodations. So if they have an official accommodation and they need something changed to a different format, AI might be able to do that more quickly. it's still requires that human overview because we want to make sure it's correct for our students. And then some tools are really, really phenomenal for actually applying a universal design for learning experience to different things. have one of my, this is the most boring use, but one of my favorite uses for Gemini is to put audio into it and get a transcript. Machine generated captions and transcripts are not perfect. They must be checked. Everyone please check them. But it is so fast and it is generally very good. And so it's something that if I'm a student and I'm in a library and my headphones break and I can't possibly listen to this out loud in the library, I can go find the transcript. can take that transcript and I can make that transcript in Gemini or in Copilot very quickly and have it ready for me to review the material. A lot of people have... I think a lot of us probably do this with streaming TV shows. We have captions on now because it helps us focus. The same thing applies for studying. A lot of people, if they read it and listen to it, they might have a better experience. They might be able to focus more. And so those kinds of things are definitely getting better. I think there's more in the future that's going to be amazing. All of you people who are developers out there, send me a message and I'll tell you the like five things that I wish that you would be working on with AI and accessibility. But I know it's gonna get better and more helpful over time. Right now, there's a lot of eagerness to solve problems with easy fixes. And AI has become a piece of that. So sometimes you'll hear about tools and it will imply that it will fix your PDF problem permanently, forever, like completely. or it will imply that it's, it will make it so you never have to write alt text again. There are ways that AI tools can be really helpful, but there, I think Michael, you called, you said something about magic a while ago with regard to AI. There is no magic. It's, it is an amazing tool and opportunity with lots of potential, but for accessibility as well, it is helpful, but it is not a magic wand.

Michael Cato: So with all that in mind, what do you suggest for institutions that we should be asking our vendors for now, given that we're legally responsible for their third-party tools as well?

Eudora Struble: Jared, you want to take this one?

Jarret Cummings: Oh, sure. Well, think it's, you know, the entire discussion around AI highlights what the key rationale for the ADA Title II regulations is, in that the whole focus is to try to get covered entities and ultimately the public in general to think about accessibility upfront as opposed to doing something and then recognizing after the fact that it has to be addressed, it has to be fixed for accessibility purposes because it just didn't occur to you. for most, I think honestly, for most companies and vendors and people and so forth, it's not an intentional oversight, but if it's not part of your common frame of reference, you're focused on what you're trying to achieve at that time. And then once whatever you're doing encounters the world, you are brought into the fact that you've missed an opportunity, you overlooked something that can't be overlooked, and that's really what the regulation is trying to get at. And so in that context, I think it's the same conversation with the third party vendors and institutions use for all aspects of our digital world. If we are, especially, come April 24th, if you're a public institution and you're using the vendor's system or you're using a vendor's content and that vendor has not been preparing and making sure that what it's providing to the institution is WCAG 2.1A compliant, then there's a problem. And it could be conceivably a significant problem depending on the degree of non-compliance that's involved. and how, if not the Department of Justice, third parties who might want to file lawsuits under the terms of the ADA, how they're going to approach that issue. it's really over the last, I mean, if you're just now having those conversations with your vendors, you're probably about what, 23 and a half months late, but you should still be having them now because when that compliance kicks in, if your institution's responsible for the use of that system or service online in terms of serving its students or the public, and whatever you're using isn't compliant, chances are you're gonna never.

Michael Cato: Really appreciate that, Jared. That's all helpful.

Cynthia Golden: Yeah, this is really good stuff. We have so much we want to still talk about during the show today. But one of the things that you sort of alluded to, Eudora, and I just wanted to see if you could mention a little bit about the benefits of an accessible environment that go beyond just focused on students with disabilities. Sorry. Anyway. Could you talk about that a little bit?

Eudora Struble: Sure. I mean, we don't want to separate anything out entirely from people with disabilities and their experiences because we know that accessibility as its pinpoint focus has to want to tear down the barriers that might be hard blocks for people with disabilities. We want to integrate the many people with disabilities, invisible, invisible into our society fully and give them chances to be a part of the rest of us in the community the things that happen in. One of the ways that we often look at accessibility actually goes back to something that's not very brand new, which is the curb cut. We talk about the curb cut effect. So curb cuts are those little bumpy slopes from the sidewalk into the street or parking lot. Curb cuts were designed to provide access for people who are using mobility devices. So most commonly people with disabilities, wheelchairs, maybe they have a cane and going off the curb is hard. All those things are benefited and, the curb cuts remove hard barriers for people with disabilities. But I don't know anyone in my life. And I sometimes sit and watch people around curb cuts, which is a little weird, but I do. I don't know anyone that doesn't gravitate towards them and use them. Everybody I know gravitates towards the curb cut and goes down. It's maybe more comfortable. It's certainly safer. It is great for if you have a scooter or a bike. or a stroller, or you're hauling luggage, or you have a cart full of event supplies and you're going to a party for student groups. All of those things are going to be benefited. All those experiences are going be benefited by that curb cut, even though the curb cut was designed for something more specific. So I think that that's something we should think about when we're trying to remember. It isn't just about if I know that I a person who maybe has low vision or is hard of hearing in my class or in my... So sorry. So sorry. If I have somebody who is hard of hearing or low vision in my class, is not just about that. And also I want to have, I want everyone to have an educational experience so they don't have to decide.

Cynthia Golden: Yeah.

Eudora Struble: if they are going to let everyone know that they have a disability. I want everyone to be able to ask if they want, tell if they want, but I don't want to create a situation that requires that. And so if we are proactively accessible with everything we do, as many things as we can do, we create an environment that really supports learning in multimodal formats, learning in different ways. It supports that universal design for learning concept that is very popular. It allows students to engage and be successful and faculty and staff to engage and be successful also in a way that is not just about, not only about people with disabilities, but it absolutely has to serve the needs of people with disabilities.

Cynthia Golden: Thank you. That point to me is really important when you think about building a culture of accessibility on your campus. So thank you. Sure.

Eudora Struble: Can I add one thing? Higher Ed is in a moment where we are thinking about enrollment numbers and we are thinking about how we keep them high and how we bring more people into our institutions and help them succeed. And in those scenarios, having really strongly accessible environments that support everyone, that don't other anyone from the start, that don't. How is anyone to feel like they're going to get behind in their class? That is so important in building a reputation and a culture that is all about everyone having the chance to succeed in the same way. Different, everybody's different. People will succeed in different ways, but I want everyone to have the opportunity to be at their best if they want to work towards that. The other place that's really relevant right now is as we have maybe a little bit of an aging older generation that many of them are still in the workforce. They have so much institutional knowledge and experience. Many of them, we wish they would stay forever and help us navigate various hurdles and situations. If our tools for staff and faculty are failing in the technology space, if we are not giving them accessible technology, then they also are going to be frustrated. I mean, I have an older mother who she gives up on tech very quickly if it's not easy to use. So I don't want anyone who is a holder of decades of institutional knowledge to feel like their retirement is being pushed by a lack of accessibility in the tools and in the services that they engage with to serve the university.

Cynthia Golden: Thank you.

Jarret Cummings: And then I would just add from the compliance standpoint, having a culture of accessibility is likely to reduce the risks of noncompliance substantially because it's something that's being incorporated into what the institution is doing in an upfront fashion. So it lessens the possibility that you're going to have mistakes made, that you're going to have non-compliant products integrated into some part of the institution and then have to figure out how to fix that and whether or not there are any legal or regulatory ramifications that come from that. it's, doing well by doing good, I guess is the old phrase. It matters from a compliance standpoint as well because it just sets you up to be more successful in relation to the responsibilities you have to fulfill.

Michael Cato: That makes a lot of sense, Jared. Thank you. Maybe one of the questions we could turn to is what suggestions might you have for how CIOs and other senior leaders can facilitate a successful adoption of regulations, yes, but also creating a culture of accessibility? Where do think they can make a difference? And Jared, how about we start with you this time?

Jarret Cummings: Sure. Well, think one of the things that we've, I think often talked about as an EDUCAUSE community is that above and beyond your legal or regulatory responsibility, there's an obvious moral responsibility to our students, to our communities, to our nation and our world. I think it's, you know, as a recovering philosopher, I think I like to start with the ethical realm because I think that is a great personal as well as organizational motivator for setting the right tone, setting the right direction, recognizing that this isn't just about avoiding compliance risk. It's about doing well by doing good. That said, I think it also matters that you understand and recognize where you have those compliance responsibilities and how problems in fulfilling them can create resource strains for the institution, can create difficulties as Eudora was saying with student and staff success and retention. I mean, there are just a great number of very practical issues that come into play  if you're not fulfilling your regulatory responsibilities. And so having that discussion within your organization, with your leadership team, down to the staff level, it doesn't have to be an all-consuming conversation, but it's important to have that conversation throughout the organization because just in many other aspects of our IT activities and operations. Frontline people can often be the first to help you find and address problems before they become big problems or even help you avoid problems altogether. So having that comprehensive awareness across the organization that this is something that leadership takes seriously because it has a moral component, has a strategic component, and it has a tactical and operational component and making sure that thread is pulled through the organization can just be incredibly powerful.

Michael Cato: Thanks for that Jared, those are really great ideas. Eudora, anything you'd add to that?

Eudora Struble: I really appreciate what Jared said. I think that one of the things he sort of hinted at or mentioned was that we have to go into all the spaces and talk to people about accessibility and bring them all on board with this culture shift and awareness. And the reason that's so important is because we love collectively to make lots of digital things and to send out lots of digital things and to get new technology. I don't know anybody, I'm sure they're out there, I don't know anyone that doesn't at least email somebody every day. That is all, every one of those pieces of our digital lives, we should think about accessibility. As Jarrett said, it doesn't have to be all consuming. This is not, it's not the job that all of us have to do in, no, that's not. That's not fair. It's not a job that has to take up all of our time, but it does have to be integrated in so we think about it in all spaces, similar to security, right? We have to think about it before we act, before we send something out. And accessibility has a similarity to that. It's really important that the staff at every level, the faculty at every level, know something about accessibility on my campus. And that's a hard mission. would say the question you asked was how can a CIO help? I would say from experience, but having a CIO who is willing to say it's important to have somebody dedicated to working on this is a really big win for moving things forward. You have the chance to have somebody who doesn't do all the work, but is able to track the work, to track the needs, to raise things to a level of getting done if they need to change. It's without a team or without a person sort of dedicated to it wherever they sit and they sit in all kinds of places all over higher ed. It becomes very difficult to know if we're making good progress and what we need to make better progress. And it's specifically because they're in so many different places. And as Jared said, we have hundreds of different priorities and obligations at any moment that we're thinking about. I can't expect even my dearest friends to think about accessibility every second, certainly not down in the weeds with me.I know they know about it and I know they do think about it in their work. And that is already a win because if they realize something is about to be inaccessible, they know where to find their resources, they know where to find help and to help move the needle forward.

Michael Cato: really appreciate that.

Cynthia Golden, I'm wondering for sake of time maybe we go to the next section.

Cynthia Golden: Yeah, well I was thinking we might want to just wrap it up right here. This has been a really great conversation. I would say though, very quickly, if a university is behind right now, what do think they should prioritize in the next six months?

Michael Cato: Okay.

Eudora Struble: There is somebody at every institution somewhere. It's probably not in their job description at a lot of places. They are working on accessibility. They already are thinking about accessibility. Try to find those people and let them be a of a hub for more learning and more exposure. From the point of view of kind of, I don't know, easy wins, that might not be so easy, but there are simple things that can be done, relatively simple. Get with your procurement department. Your contract language should have accessibility in it. Your request for proposals and quotes should have accessibility in them. When you are, when you're engaging with vendors that you're going to have in your system for decades or years and years, build a relationship with them and try to, try to make it so that them winning in accessibility is also you winning in accessibility. And the other thing that could be super helpful is Everyone has an information security process of some sort that is already probably looking at vendors as they're in your system. Try to align whatever new accessibility moves you're making with that already existing workflow and those people who already know your vendors. It's easy to sort of, well, it's relatively simple to move ahead when you have that connection and you can align with a process that already exists.

Cynthia Golden: Anything to add, Jared?

Jarret Cummings: Yeah, I would say two things. One, along the lines of the vendor discussion that Eudora was highlighting, our EDUCAUSE IT Accessibility Community Group, which Eudora helps to lead, has worked quite a bit with our cybersecurity community around the higher education community vendor assessment toolkit, HeckVet. And it includes accessibility questions for potential vendors or current vendors to address as the institution's trying to evaluate its options for procuring goods and services. So that's a very useful place for institutions to start, particularly if they're not familiar with it as they're trying to have these discussions with their vendors. And then I'd say secondly, at more of a macro level, I always find it much easier to address a challenge if I can see it clearly. And part of seeing it clearly is eliminating the things that are not relevant. And so looking at the pending regulations, looking at where the exceptions exist and how they apply, and thinking about those carefully can probably help an institution not completely clear the DAX, but really focus in on what are the immediate challenges we have to address in terms of content and apps that are in active use to support students or the institutional community as a whole? If you can get the stuff you don't have to worry about immediately out of the way, then hopefully that will help you zero in on really where you have to target your immediate actions and resources.

Eudora Struble: And I will add that, Jared, I love what you said, Jared, the community group, which I didn't mention, and I should have probably been the one to mention it. I didn't think of it. The community group is something I think about a lot of the time. And one of the reasons is if you don't know any accessibility professionals in your life, we love to share things that we've already made and workflows that we have designed and solutions or problems.

Cynthia Golden: Thank you

Eudora Struble: We love to share. So please join that IT accessibility community group. You don't have to be an expert to just listen in on our chats and our presentations. And you will probably find somebody who can give you a training that you can offer to faculty or to help train your communicators about social media. It is a very, it is a true community of people who want to engage and support each other. So again, if you could find somebody on your campus who's already doing this work a little bit and bring them into that community group. It would be a boost for any work you're doing.

Cynthia Golden: That is a terrifically rich resource I can attest. Thank you.

Michael Cato: Absolutely. And a wonderful way to end our conversation, Jarrett, Eudora, thank you so both very much for spending time with us and offering so many great insights and resources. And as one of the people who's benefited from the work of the community group, I just want to say tell you both thank you very much for all your work.