As of April 17, 2026, the U.S. Department of Justice has extended the compliance date that applies to U-M to April 26, 2027. The work to meet the ADA Title II requirements continues, and more information can be found on the university’s Digital Accessibility website.

Section 504 of the Rehabilitation Act of 1973 and the Americans with Disabilities Act (ADA) define an individual with a disability as a person who (A) has a physical or mental impairment that substantially limits one or more major life activities; (B) has a record of such an impairment; or (C) is regarded as having such an impairment. Institutions of higher education have legal and ethical obligations to provide qualified students with disabilities with individualized, reasonable accommodations to ensure that they have equal access to the learning experiences entailed in the programs, including in online learning environments.

 
In 2024, the U.S. Department of Justice (DOJ) published a new digital accessibility rule, “Accessibility of Web Information and Services of State and Local Government Entities” (DOJ Accessibility Rule), which applies to public institutions of higher education along with other entities defined under Title II of the ADA. This rule reaffirms the requirement to create inclusive online courses and sets a specific technical standard for digital accessibility, the Web Content Accessibility Guidelines (WCAG) 2.1, Level AA. All digital content, with very few exceptions, must meet WCAG 2.1 AA standards by April 24, 2026.

In Practice

In practice, addressing the needs of students with disabilities in online education settings consists of both proactive and reactive efforts.

Proactive Design

The DOJ Accessibility Rule requires that public institutions like the University of Michigan ensure all services, programs, and activities offered to the public through the web and mobile applications are accessible. By designing with accessibility in mind when creating a course, you are considering the needs of students with disabilities immediately and reducing the difficulties they may face taking your course. Courses must, specifically, be designed in accordance with WCAG 2.1 AA, an international technical standard set by the Web Accessibility Initiative of W3C, the World Wide Web Consortium, an organization that sets standards for web design. This includes, but is not limited to, providing captions and transcripts for all video and audio based course assets, creating course material such as lecture slides following these accessibility standards, and reviewing the accessibility of any third-party tools before introducing them to students. 

It may be helpful to reference Accessibility in Online Learning to see if your course meets accessibility standards. In addition, U-M offers resources for Faculty to understand the basics and learn digital accessibility skills for their work. Additionally, Universal Design for Learning (UDL) is a popular educational framework that can guide course design teams when creating accessible learning experiences.

Reactive Actions

Designing a course with accessibility needs in mind does not mean that students with disabilities will not need to or should not request reasonable accommodations. In that case, reactive actions are needed. These are modifications or accommodations made after the initial online course development (specifically after receiving requests from students with disabilities), such as providing additional time to complete tests. Appropriate accommodations aim to “level the playing field” for students with disabilities and provide students with disabilities equal access to educational opportunities, programs and activities. 

At most post-secondary institutions, students are expected to self-disclose their disabilities so that an individualized assessment can be made to ensure appropriate academic accommodations are granted. Here at U-M, completing the Student Intake Form is the first step in the process for students to register their disabilities with the Services for Students with Disabilities (SSD).

FAQs

As an instructor, am I allowed to encourage students to indicate their disability-related needs so that I can be better prepared?

Yes, you are able to encourage students to indicate their disability related needs. Appropriate ways include:

  • Introducing the Student Intake Form and the process to register with SSD in early stages, such as during the first class, in language including in a course syllabus, or during orientation
  • Cultivating an inclusive learning environment so that students feel comfortable to ask for help
  • Making it clear to students that they do not need to wait until just before the accommodation becomes necessary to register with SSD
    • Students can activate the accommodation any time after registering, and by reaching out to SSD earlier, they can expect a quicker turnaround
What are some examples of accommodations that can be requested by students in online and hybrid programs?

Accommodations can vary widely depending on the disability, its severity, and the student’s unique needs and preferences but may include:

  • Allowing additional time for completion of exams
  • Modifying attendance and participation policies for students with chronic health and/or mental health conditions
  • Modifying performance evaluations (e.g., performance in a verbal presentation) for students with speaking disabilities
  • Providing live captioning or qualified interpreters for students with hearing disabilities
Where can I find additional resources on this topic?

The Center for Academic Innovation maintains this Collection of Additional Resources.

1 Section 504 of the Rehabilitation Act

2 Introduction to the Americans with Disabilities Act

3 Note however, U-M requires students to register with Services for Students with Disabilities (SSD) before they will be eligible to receive certain accommodations

4 Universal Design for Learning (UDL) Guidelines

5 Services for Students with Disabilities