GMU ADA Title II Plan

About the ADA Title II Updates

ADA Title II now requires all state and local government entities, including George Mason, to ensure their websites and mobile apps meet the Web Content Accessibility Guidelines (WCAG) 2.1 AA opens a new window by April 26, 2027. WCAG is a set of guidelines developed by the World Wide Web Consortium (W3C) through the Web Accessibility Initiative (WAI). It provides a set of recommendations and standards to make web content more accessible to people with disabilities, including those with visual, auditory, physical, speech, cognitive, language, learning, and neurological impairments.

ADA Title II explicitly adopts these guidelines and outlines the scope of compliance for public entities, including websites, digital platforms, documents, audio/video content, and third-party applications. To ensure Mason meets these standards by the above-mentioned deadline, the Assistive Technology Initiative (ATI) has developed the Digital Content Accessibility Action Plan (DCAAP).

Learn More about ADA Title II Updates WCAG at a Glance

The DOJ delayed ADA Title II enforcement until April 26, 2027. See below for important updates:

How does this delay impact Virginia's Information Technology Access Act (ITAA)?

The federal government has delayed enforcement of ADA Title II digital accessibility requirements, but this delay does not change Virginia law. The Virginia Information Technology Access Act (ITAA) is still in effect, and state agencies and covered entities are expected to continue working toward accessibility compliance.

Virginia's AG Office has recommended a two‑tiered approach during this period:

New technology purchases must still be accessible. Agencies should not enter into new IT contracts unless vendors provide documentation showing their products meet accessibility standards or include a clear plan to become accessible.
Existing accessibility issues should continue to be addressed. Agencies should keep improving the accessibility of current systems, document ongoing remediation efforts, and report non‑compliant technology as required under Virginia law. The federal delay may be cited to support a phased or planned approach, but it should not be treated as a pause on accessibility responsibilities.

Overall, the delayed federal enforcement is intended to provide flexibility—not an exemption—and agencies are expected to make steady, good‑faith progress toward accessibility under both state and federal requirements.

How should we respond to this at George Mason?

Despite the 1-year delay to ADA Title II's digital accessibility requirements, the guidance from HHS (for those programs receiving financial assistance), Virginia's AG Office regarding ITAA, past enforcement by both DOJ and OCR (based upon existing ADA Title II and 504 requirements), and the needs of our existing students suggests that Mason has still has some legal risk. We should not focus on a technical deadline of a year from now.

Our position is that all content, whether newly developed or reused from past resources (e.g., website, course, document, etc.), should be made accessible. Faculty amd staff should be actively remediating that content now and continuing through the next year. This strategy aligns with our existing DCAAP guidance (e.g., see our Top Tips Resources) and supports the needs of current and future members of the George Mason community.

Digital Content Accessibility Action Plan (DCAAP)

The DCAAP provides a structured approach aimed at helping units achieve digital accessibility compliance by Fall 2026. It focuses on digital content (i.e. websites, documents, audio/video content, and supplemental apps) hosted on public-facing websites and in Mason courses. It is divided into five phases, each focusing on different aspects of the digital accessibility remediation process: auditing and assessment, targeted training and consultation, remediation planning, remediation, and ongoing monitoring. ATI staff will support units at every phase of this effort, ensuring a smooth and successful transition toward compliance with the updated ADA Title II standards.

See below for more details:

Phase 1: Auditing and Assessment

Units will identify/assign key personnel responsible for ensuring digital access and perform an initial review of existing digital resources (documents, websites, audio/video, and supplemental applications) to identify accessibility issues. This includes ensuring existing websites are added to DubBot, assessing the accessibility of public-facing documents and videos, and identifying supplement apps used in their courses and/or respective offices.

Phase 2: Targeted Training & Consultation

ATI will provided targeted training and consultation meetings for faculty, staff, and/or units responsible for the creation and maintenance of digital content.

Phase 3: Remediation Planning

Units will develop action plans for remediating existing inaccessible content. This may involve fixing the issues in-house or sending content to the ATI for remediation.

Phase 4: Remediation

Units will partner with ATI and key strategic partners to ensure inaccessible content meets WCAG 2.1 AA guidelines.

Phase 5: Develop a Monitoring Plan

Units will establish ongoing processes to ensure that all new and updated digital content adheres to accessibility standards, using tools like Microsoft 365, Panorama, DubBOT, etc.