From Audit to Action: Improving Our Online Learning Portfolio for Digital Accessibility

Background

More than 12 million learners around the world have developed new skills and expanded their opportunities through online courses created by the University of Michigan’s Center for Academic Innovation. Each course is the result of collaboration between U-M faculty and an array of center teams to create online learning experiences that reach global audiences well beyond the traditional residential student audience. Online learning offers many advantages to learners looking to access high-quality educational experiences outside a traditional four-walled classroom environment. It has the potential to provide equitable access for learners who may be balancing work and school, live in rural areas, or need flexibility due to medical needs, for example. 

Over the past decade, the center has developed more than 280 courses for learners with a wide range of skill levels and professional interests. This global reach comes with the responsibility of ensuring that learners with various backgrounds, preferences, and needs, including those with disabilities, can benefit from our online learning experiences. Worldwide, around 1 in 6 people live with a disability, totaling approximately one billion people. In the United States, it is 1 in 4. For many people, elements such as rapidly flashing content, inoperable keyboard functionality, weak color contrast, or lack of audio descriptions in video present major barriers to learning. 

Faculty members are overwhelmingly dependent on digital content to teach courses, both residentially and online. Incorporating podcasts, generative AI tools, clips from YouTube, or links to articles from third-party sites has become the standard practice for learner engagement. From a design and compliance perspective, however, this content is often inaccessible to learners with disabilities due to numerous digital barriers. For example, if a learner with a hearing disability needs to watch a lecture video or listen to a podcast to complete an assignment, but the media does not have captions or a transcript, they are unable to complete the activity. This is not only inequitable but discriminatory.

Additionally, in April 2024, the U.S. Department of Justice updated ADA Title II regulations to require all government entities to have their digital content meet WCAG 2.1 Level AA standards with limited exceptions. This requirement also applies to public universities, like the University of Michigan, with a deadline for digital accessibility compliance of April 26, 2026.

Recognizing both the opportunity and urgency, Pam Saca, continuous improvement specialist on the center’s learning experience design team, and Caroline Damren, accessibility coordinator on the compliance and policy team, worked together to conduct a comprehensive internal accessibility audit of the center’s course portfolio. Following the audit, we gathered leadership support and led the remediation process in order to achieve a more accessible portfolio.

Audit Approach and Process

To make meaningful progress and keep the scope realistic, we started with the following question: Which accessibility improvements would make the biggest impact for learners right now? Aligning with WCAG 2.1 Level AA standards and with our own CAI Accessibility Guidelines, we focused on the most high-impact elements. Our top priorities included:

• In-platform formatting, including properly tagged text headers, descriptive hyperlinks such as “ITS Assessment Resources” instead of “Click Here,” and meaningful alt text to identify some future quick wins.
• Properly tagged documents and files, and noting non-PDF inaccessible file types for future remediation.
• Spot-checking accuracy of lecture video transcripts to prioritize future remediation needs.
• Documenting instances of third-party tools for further review.
• Noting the use of third-party content, such as podcasts and external videos, to identify potential barriers and ensure compliance.

Working in tandem, we began the audit on our full portfolio in May 2024. To ensure the sustainability of our process, we first beta-tested it on our 10 highest enrolled courses. Using our predefined categories, we documented the findings in a spreadsheet to get a sense of the overall state of the portfolio and size of remediation work. From there, we scaled up and divided the portfolio in half, reviewing each individual live course on our two main platforms, Coursera and edX. The audit review process for over two hundred courses was completed about two months later, on July 1, 2024.

Discoveries

Unsurprisingly, we uncovered more accessibility barriers in older courses that were generally designed prior to 2020. We also saw noticeable accessibility improvements as staff and faculty accessibility awareness increased over time. To summarize our findings from the audit, we asked the questions: What common errors exist? How can we best address them through remediation efforts? And how effective have design team upskilling efforts been in reducing errors over time? 

Common errors documented included:

• Heading tags (H1, H2, etc.) used for font styling purposes, resulting in headings not being properly nested in numerical order. This impacts how screen readers progress and skip through material.
• Long URLs used in readings, as opposed to descriptive hyperlinks. Long URLs can create confusion and barriers for users—especially those using screen readers—by being difficult to interpret, remember, and navigate.
• Absent or insufficient/poor quality alt text for images.
• Inaccessibly designed and untagged PDFs, including lecture slide decks available for learner download.

We were pleased to discover that the number of accessibility errors was greatly reduced in our newer courses, which we attribute to our upskilling and professional development efforts for our learning experience designers and faculty partners. Over the years, we’ve improved our processes by:

• Flagging potential accessibility concerns earlier in the planning stage and course design process.
• Creating a more robust third-party tool review process before any learner-facing tool is used within a course.
• Reteaching best practices and familiarity of WCAG standards on a regular cadence and including these topics in new employee onboarding efforts.

Portfolio Remediation

After sorting through our findings, we entered the most intensive phase of our project –  remediating course content within our portfolio. Using a divide-and-conquer approach, we worked through quick and easy fixes first. To accomplish this, we asked: What simple in-platform issues can we resolve right now without additional expertise or tools? 

We identified a number of opportunities for quick wins. For example, we ensured our courses had:

• Updated accessibility statements in all syllabi, to include a form for learners to report digital accessibility barriers directly to us.
• Improved in-platform formatting, including:
  • Properly tagged text headers.
  • Descriptive hyperlinks in favor of long URLs or “click here.”
  • Meaningful alt text.

With easy fixes out of the way, we turned to the more complex work – remediating PDFs and lecture slides. At this stage, we asked: What time consuming or technically complex issues do we need outside expertise or additional tools to fix?

Luckily, this is where help from our colleagues began. Members of our learning experience design and course operations teams, including student fellows, supported these efforts by: 

• Remediating inaccessible documents, lecture slides, and PDFs to improve their functionality for learners.
• Creating additional file formats to provide learners more than one way to access a document or PDF.
• Updating learner activities that included involvement of third-party content to improve learner engagement and access. 
• Recreating inaccessible PDFs as text-based readings on-platform.

To encourage consistency, we created a remediation process guide with clear instructions, decision trees, and training resources. We wanted teammates to have the autonomy to make their best professional choices on how to remediate content and do some forward thinking, as well. For example, could a short assignment that was originally created as an inaccessible PDF turn into an on-platform reading instead? Was an inaccessible file redundant or out-of-date and ready to be archived? Could a link to an article provide an accessible alternative for some learners? 

The work was detailed and required a significant investment of time. It was, however, critical and deeply rewarding. From November 2024 through November 2025, we addressed our entire list of identified issues. Along the way, we updated design documentation and refined our processes to help our efforts of designing accessibly from the start. 

Some pending issues still remain, such as adding audio descriptions to identified videos and working through the remediation of technically complex and outdated materials, which we are aiming to complete by April 2026.

Final Thoughts

Throughout the audit and remediation of our large portfolio, we adopted the philosophy of “progress, not perfection.” While we have made significant strides toward meeting WCAG 2.1 Level AA standards, we recognize that some learners may still encounter accessibility barriers and not everything will be 100% accessible to all learners. As such, our commitment to digital accessibility extends to supporting any learner who requires accommodations beyond the current improvements. 

When thinking about the future, we often ask: What can we do to prevent known digital accessibility barriers? 

Vendor-provided digital content, websites, or applications used at U-M are required to meet the same accessibility standards as the content created in-house. We need to hold these vendors accountable during the procurement process to ensure they are maintaining accessible products for our faculty, staff, and learners to use.  

As we move forward, we continue to refine our internal processes to ensure accessibility is integrated into every stage of course design and across every platform our courses use. Proactive design techniques and consideration for all types of learners are essential, not only for compliance, but also as an inclusive approach aligned with Universal Design for Learning principles. By thoughtfully designing course content to be as accessible as possible from the outset, we provide equitable learning opportunities for everyone. 

We are also taking time to celebrate how far we’ve come as a team and to recognize the depth of our growing digital accessibility knowledge. While our collective efforts are just a few steps in a larger journey, they represent meaningful progress toward our goal of making our digital environment more inclusive for all.

Resources

Understanding WCAG (Web Content Accessibility Guidelines)

• W3C: Web Content Accessibility Guidelines (WCAG) Overview – Comprehensive summary, quick reference, and explanation of accessibility principles.

• WCAG 2.1 Quick Reference – Searchable, filterable checklist of WCAG success criteria.

ADA Title II and Digital Accessibility Regulations

• ADA.gov: New Rule on the Accessibility of Web Content and Mobile Apps Provided by State and Local Governments – Official resources outlining ADA Title II requirements and digital accessibility.

• DOJ Guidance on Web Accessibility and the ADA – U.S. Department of Justice guidance on website accessibility for state/local governments and businesses.

Accessibility in Online Learning

• CAST: Universal Design for Learning (UDL) Guidelines – Practical framework for improving and optimizing online learning for all people.

• University of Michigan: Digital Accessibility Faculty Resources – U-M’s faculty resources for best practices and resources related to accessible teaching and course design.

Tools for Testing

• WAVE Web Accessibility Evaluation Tool – Simple tool for checking accessibility issues on web pages.

• WebAIM: Color Contrast Checker – Determine if foreground and background color combinations meet the WCAG Level 2.1 AA standard.