CAHNRS > CAHNRS Marketing & Communications > Digital Accessibility > College Unit/Department Digital Accessibility Compliance Guide

College Unit/Department Digital Accessibility Compliance Guide

Overview

This guide helps CAHNRS and Extension units make their digital resources accessible. It covers websites, documents, media, forms, software, and other tools used in WSU programs and services.

WSU’s UPPM 10.45 addresses accessibility for electronic and information technology. Employees who create or publish digital content are responsible for making it accessible.

Use the steps in this guide to assign responsibilities, inventory resources, prevent new barriers, address existing issues, evaluate vendor products, and document progress. Prioritize current, required, frequently used, and public-facing resources. Consult the linked WSU, Washington State, and ADA requirements when making specific compliance decisions.

Step 1: Assign responsibility

Each unit should designate someone responsible for coordinating digital accessibility within the unit. For websites, WSU specifically requires a Website Owner, with an optional Accessibility Proxy; content publishers are responsible for the accessibility of what they publish. Learn more about Accessibility Roles and Responsibilities at WSU. To see who is assigned as your unit’s website owner and/or accessibility proxy, visit the CAHNRS and Extension Multisite Information page.

At the department level, identify at minimum:

the person accountable for the unit’s website;
employees who publish or update webpages;
employees who create PDFs, Word files, PowerPoints, spreadsheets, newsletters, forms, videos, or course/program materials;
employees who purchase or select software and online services; and
a contact who coordinates remediation and accessibility questions.

Responsibility should be built into normal job processes rather than assigned only when someone reports a barrier.

Suggested role checklist

Unit leadership confirms ownership, timelines, and escalation paths.
Website owners and site managers review pages, documents, forms, and DubBot reports.
Content creators use accessible templates and check documents before publishing.
Procurement or purchasing contacts request accessibility documentation before selecting or renewing tools. Review WSU’s Contracts and Purchasing page for guidance.
Course, program, and outreach staff verify that materials needed for participation are accessible or have an equally effective accessible method available.

Guide Contents

Overview
Step 1: Assign responsibility
- Suggested role checklist
Step 2: Complete accessibility training
- WSU Employees
- Without Percipio Access Assessment
Step 3: Create an inventory
Step 4: Prioritize the inventory
Step 5: Create accessible content
Step 6: Apply WCAG requirements
- Common Checks for Content Creators
Step 7: Test websites and applications
- DubBot
Step 8: Remediate existing barriers
Step 9: Build accessibility into purchasing
Step 10: Monitor and document compliance
How to decide whether an existing document must be remediated
Key Resources

Step 2: Complete accessibility training

Make sure employees complete WSU’s required Digital Accessibility Assessment. WSU states that the assessment is required annually under UPPM 10.45.

WSU Employees

The Digital Accessibility assessment in Percipio. It will be assigned yearly.

WSU Percipio

Without Percipio Access Assessment

This separate assessment is for people without access to Percipio, such as a friend account or a WSU student.

Friend Account Assessment

Employees with specialized responsibilities—web development, document remediation, multimedia production, software development, procurement, etc.—should pursue additional role-specific training.

View WSU's Digital Accessibility Training Calendar

Step 3: Create an inventory

Create an inventory of the digital content, tools, and technology your unit owns, publishes, selects, or controls. Include the main website, but do not stop there; accessibility responsibilities also apply to documents, media, forms, applications, platforms, and other digital resources that support WSU programs, services, and activities.

Include:

websites and webpages;
PDFs;
Word documents;
PowerPoint presentations;
Excel spreadsheets;
online forms;
Canvas/course materials;
videos, podcasts, and recorded presentations;
social media;
newsletters and significant email communications;
web applications;
kiosks and interactive systems;
third-party platforms, widgets, scheduling tools, payment systems, and embedded applications; and
software or systems purchased for student, public, or employee use.

The ADA rule generally covers web content and mobile apps a public entity provides or makes available, including through contractual or licensing arrangements. Using a vendor does not automatically transfer the accessibility obligation to the vendor.

Step 4: Prioritize the inventory

Prioritize barriers according to how much they affect access and how often the content or service is used. Address reported barriers and essential tasks first, including applying, registering, learning, working, paying, and requesting services. Record the owner and target date for each correction.

Start with content and systems that:

are required to access a program, service, benefit, or activity;
are used to apply, register, enroll, pay, submit information, or complete a required task;
affect students, employees, or the public frequently;
receive high traffic;
contain important safety, policy, financial, academic, or employment information;
are known to be used by people with disabilities;
have an existing accessibility complaint or reported barrier; or
are being substantially updated or replaced.

The Washington State Digital Accessibility Policy, USER-01, specifically directs agencies to consider user impact and frequency of use, particularly impacts on users with disabilities and assistive-technology users, when establishing remediation priorities.

For documents, review the How to decide whether an existing document must be remediated section.

Step 5: Create accessible content

Before publishing a new webpage, document, video, form, or other digital resource:

use accessible templates;
apply proper semantic structure;
provide alternatives for visual and audio information;
verify color contrast;
test keyboard operation;
run the application’s accessibility checker where available; and
perform appropriate manual testing.

Do not rely only on automated checkers. Many accessibility issues require human judgment and therefore require manual testing.

For information that can reasonably be presented as a webpage, consider HTML instead of a PDF.

Step 6: Apply WCAG requirements

Under the ADA Title II rule, Level AA conformity means satisfying all applicable WCAG 2.1 Level A and Level AA success criteria, not simply the Level AA criteria.

Common Checks for Content Creators

For most departmental content creators, the requirements translate into some of following practical checks. Please note: This is not a complete list of WCAG requirements.

Area	What departments should ensure
Images and graphics	Meaningful images have equivalent alternative text. Decorative images are ignored by assistive technology. Charts and complex graphics have an accessible description or equivalent data.
Headings and structure	Use real heading styles in a logical hierarchy. Use actual lists, paragraphs, tables, landmarks, and other semantic structure rather than visual formatting alone.
Color	Do not use color alone to communicate meaning. Normal text generally needs at least 4.5:1 contrast; large text generally needs 3:1. Important user-interface components and graphical objects generally require 3:1 contrast.
Keyboard access	All functionality must be usable without a mouse. Keyboard users must not become trapped in a component.
Keyboard focus	Users must be able to see where keyboard focus is located, and focus order must follow a meaningful sequence.
Links	Link text should communicate the destination or purpose. Avoid ambiguous links such as "click here" or “learn more” when context does not make the purpose clear.
Page/document titles	Give webpages and documents descriptive titles.
Forms	Every input needs an accessible label/instruction. Errors must be identified in text and, where possible, suggestions for correcting errors provided.
Tables	Use tables for data—not page layout—and identify row/column headers programmatically. Keep table structures as simple as possible.
Audio/video	Provide captions for prerecorded synchronized media and live synchronized audio where applicable. Provide audio description for prerecorded video when visual information is necessary to understand the content.
Moving content	Users need appropriate means to pause, stop, or hide certain automatically moving, blinking, or scrolling content.
Language	Identify the primary language of document and identify changes of language where required.

For PDFs, Word files, presentations, and spreadsheets, departments should additionally verify document titles and language, headings, lists, alternative text, meaningful links, table headers, reading order, PDF tags, form-field labels, color contrast, and the absence of image-only/scanned text. Run the Microsoft or Adobe accessibility checker where appropriate, but manually check reading order and usability as well.

Step 7: Test websites and applications

Use a combination of automated and manual testing.

At minimum, departments should:

run an accessibility scanner/checker;
navigate important pages using Tab, Shift+Tab, Enter, Space, and arrow keys;
confirm visible keyboard focus;
zoom and enlarge text;
inspect headings;
verify alternative text;
check color contrast;
test important forms, dialogs, menus, and error messages;
review on mobile/small-screen layouts; and
conduct screen-reader testing for high-impact workflows when practical.

DubBot

WSU uses DubBot, a quality assurance tool that scans websites for potential accessibility and site-quality issues.

DubBot helps support ongoing site quality and accessibility work. It does not replace manual review, but it can make content management more efficient.

What DubBot checks

DubBot reviews pages for accessibility, broken links, spelling, web governance, best practices, and SEO concerns. All CAHNRS and Extension websites are included in DubBot and scanned regularly.

What site owners and accessibility proxies should do

Website owners and site managers should review reports that flag items needing attention, including accessibility errors, broken links, and possible spelling issues. If you manage a CAHNRS or Extension website and are not receiving weekly reports, submit a web support ticket to request DubBot access.

Visit the DubBot help site for training materials, articles, and documentation.

If you are new to DubBot, start with the Beginner’s Guide to Using DubBot.

Step 8: Remediate existing barriers

Fix high-impact problems first. Examples include inaccessible application or enrollment forms, inaccessible required PDFs, videos without captions or needed audio description, and systems needed to receive a university service.

If remediation cannot happen immediately, establish an equally effective accessible method while the permanent solution is completed. Ensure effective communication, reasonable modifications, and equal opportunity are provided even when a technical exception applies.

Step 9: Build accessibility into purchasing

WSU advises units to obtain and review accessibility information such as a Voluntary Product Accessibility Template (VPAT) when evaluating products.

Before purchasing or renewing software, applications, online platforms, or other technology, require accessibility information from the vendor.

Ask for:

VPAT;
the WCAG version and level tested;
the date and scope of testing;
known failures or “Supports with Exceptions” items;
evidence of manual and assistive-technology testing;
a remediation roadmap for known issues;
accessibility support/escalation contacts; and
contractual accessibility commitments.

USER-01 requires accessibility considerations in procurement, design, project scope, budget, and maintenance and calls for accessibility validation.

Do not treat possession of a VPAT as proof that a product is accessible. Review the Accessibility for Contracts and Purchasing page for more information about purchasing and for suggested contract language usage.

Step 10: Monitor and document compliance

Accessibility is an ongoing responsibility, not a one-time project.

Recommended cadence:

Review new content before publication;
review DubBot and other automated reports at least monthly;
update the inventory when content, systems, or owners change;
review high-impact workflows each term or annually;
and revisit vendor accessibility documentation before renewals, major upgrades, or new purchases.

Each unit should maintain a simple accessibility record containing:

inventory;
responsible owners;
training completion;
test results;
identified barriers;
remediation priorities;
remediation dates/status;
accessibility complaints;
vendor accessibility documentation; and
any exception determinations.

How to decide whether an existing document must be remediated

This section helps units decide whether an existing PDF, word processing document, presentation, or spreadsheet should be remediated, documented as an exception, removed, or archived. When in doubt, prioritize access to current programs, services, activities, and required information over preserving old inaccessible files online.

The ADA Title II Fact Sheet contains five limited exceptions. For departmental document inventories, the most important are archived web content, preexisting conventional electronic documents, and individualized password-protected documents.

Use the following decision process for every existing PDF, word processing document, presentation, or spreadsheet.

1. Is the document currently required to access or participate in a WSU program, service, or activity?

Examples include an application, registration form, required instructions, current policy, syllabus, current program information, financial form, or document students/public users must complete.

Yes→ Remediate it.

The ADA’s preexisting-document exception does not apply to a document currently being used to apply for, access, or participate in a government service, program, or activity.

No → Continue to Step 2.

2. Was the document already available on the website/mobile app before the applicable ADA compliance date?

Yes→ Continue to Step 3.

No → Remediate it.

Newly posted documents generally must conform.

3. Is it a conventional electronic document?

The exception applies to:

PDF files;
word-processing files;
presentation files; and
spreadsheet files.

Yes→ Continue to Step 4.

No → Evaluate the content under the other ADA rules/exceptions.

4. Has the document been changed or updated?

If you update a previously exempt document and republish it—for example, replacing names, dates, contact information, policies, or other content—the updated document may no longer qualify as preexisting content.

Yes→ Remediate before republishing.

No → Continue to Step 5.

5. Does it qualify as archived web content?

To use the archived-content exception, all four conditions must be met:

It was created before the applicable compliance date, or reproduces older physical media;
it is kept only for reference, research, or recordkeeping;
it is stored in a special area designated for archived content; and
it has not been changed since it was archived.

If any one condition is missing, do not classify the document as archived under this exception.

Note: Under Washington State law, the applicable compliance date was August 2019; the ADA deadline is April 2027.

6. Is it an individualized, secured document?

A separate exception may apply only when all three conditions are present:

it is a word-processing, presentation, PDF, or spreadsheet file;
it concerns a specific person, property, or account; and
it is password-protected or otherwise secured.

A general document placed behind a login does not qualify merely because users must sign in.

7. Was it posted by an independent third party?

Content genuinely posted by a member of the public or another independent third party may qualify for the third-party-content exception.

However, this exception generally does not cover:

content the university posts that was created by a vendor;
content posted by a university contractor on WSU’s behalf; or
the third-party platform itself.

8. If an exception applies, can the unit simply ignore accessibility?

No. An ADA technical exception means the item may be excepted from the WCAG 2.1 AA requirement under that particular provision. It does not eliminate the university’s obligations to provide effective communication, reasonable modifications, and equal opportunity.

If an individual needs the information in an accessible format, the unit may still need to provide an accessible version promptly.

9. Recommended departmental disposition

Use four statuses in your inventory:

Remediate Now: current, required, frequently used, newly published, recently modified, or needed to participate in a program/service.
Remediate by Priority: active content that must be updated but has lower current use or impact.
Exception — Retain and Document: the item clearly meets every condition of an applicable ADA exception. Document which exception applies and why.
Remove/Archive: the item no longer serves an operational purpose. Follow WSU records-retention requirements rather than keeping outdated inaccessible material publicly available simply because it already exists.