A recent DOJ settlement requiring a state university system to meet WCAG 2.1 Level AA standards across all digital learning materials represents something more significant than another compliance milestone. Having worked with numerous university systems across the Northeast on similar challenges, I see this agreement as a blueprint for institutional transformation that prioritizes equal access for students with disabilities—something other higher education leaders should study carefully.

The settlement's emphasis on accessible procurement policies particularly catches my attention. Too often, universities treat accessibility as a retrofit problem—something to fix after purchasing decisions have already locked them into systems that exclude students with disabilities. This reactive approach creates expensive, perpetual remediation cycles that exhaust IT budgets and frustrate faculty who find themselves caught between pedagogical goals and their obligation to serve all students equitably.

The Procurement Policy Foundation

What makes this settlement strategically sound is its focus on systematic procurement reform. Universities are complex ecosystems where dozens of departments independently purchase software, learning management systems, and digital tools. Without centralized accessibility requirements, each purchase decision becomes a potential barrier that excludes students with disabilities from equal participation in their education.

Accessible procurement guidance has long emphasized that prevention costs significantly less than remediation while better serving students with disabilities. When universities require vendors to demonstrate WCAG 2.1 Level AA compliance before contract signing, they shift accessibility responsibility upstream—where it belongs and where it's most effective to ensure equal access for all students.

From my experience with university procurement offices, the challenge isn't usually resistance to accessibility requirements. It's the lack of institutional knowledge about how to evaluate vendor claims and the absence of standardized accessibility language in RFPs. This settlement likely includes specific procurement protocols that other institutions can adapt to better serve their students with disabilities.

Staff Training as Cultural Infrastructure

The settlement's training component addresses what I consider the most critical gap in higher education accessibility: the assumption that equal access is purely a technical problem. Universities often approach Title II obligations by hiring a single accessibility coordinator and expecting them to somehow ensure campus-wide equal access through individual heroics.

Effective accessibility training in higher education must be role-specific. Faculty need different knowledge than IT staff, who need different skills than procurement officers. The training mentioned in this settlement likely includes specialized tracks for different university functions—a recognition that the capacity to serve students with disabilities must be distributed across institutional roles, not concentrated in a single office.

I've observed that successful university accessibility initiatives create what I call "accessibility fluency" rather than just awareness. Fluency means faculty can evaluate whether their Canvas course provides equal access to all students, IT staff can conduct meaningful vendor accessibility reviews, and procurement officers can write enforceable accessibility contract language that protects students' rights to equal access.

The WCAG 2.1 Level AA Standard

The settlement's specification of WCAG 2.1 Level AA standards deserves particular attention. This isn't just about meeting minimum legal requirements—it represents a strategic choice about institutional commitment to serving students with disabilities.

Level AA compliance addresses many of the barriers that most significantly impact students with disabilities in digital learning environments: keyboard navigation, color contrast, screen reader compatibility, and video captions. While some universities have argued that Level AA creates undue burden, this settlement suggests the DOJ views Level AA as the reasonable standard for ensuring equal educational access.

For university systems evaluating their own digital accessibility programs, this settlement provides useful precedent about DOJ expectations for serving students with disabilities. The days of arguing that basic accessibility features constitute undue burden appear to be ending, particularly for public institutions with significant federal funding and clear obligations to provide equal access.

Systemic Change vs. Surface Compliance

What intrigues me most about this settlement is its apparent focus on institutional capacity to serve students with disabilities rather than just immediate remediation. Many accessibility settlements require organizations to fix specific barriers but don't address the organizational systems that created those barriers in the first place.

The combination of procurement policy reform and comprehensive staff training suggests this settlement aims to prevent future barriers for students with disabilities, not just resolve current ones. This approach aligns with research showing that sustainable accessibility programs require institutional systems change focused on equal access, not just individual behavior modification.

Universities considering proactive accessibility improvements should note this settlement's systematic approach. Rather than starting with expensive campus-wide audits or massive remediation projects, the most effective strategy appears to be building institutional capacity to serve students with disabilities through procurement reform and targeted training.

Implementation Realities

The practical challenge for this university system—and others watching this case—will be implementation coordination across multiple campuses with varying technical sophistication and resource levels. State university systems often include research universities with robust IT departments alongside smaller regional campuses with limited technical staff.

Successful implementation will likely require differentiated support based on campus capacity, shared resources for smaller institutions, and clear escalation procedures when individual campuses encounter implementation challenges. The settlement probably includes specific timelines and milestone requirements that will test the system's ability to coordinate accessibility improvements that genuinely serve students with disabilities across diverse institutional contexts.

For university leaders evaluating their own accessibility programs, this settlement demonstrates that comprehensive approaches—combining policy reform, training, and technical standards—represent the new baseline for institutional commitment to equal access. The question isn't whether to invest in systematic accessibility improvements, but how quickly institutions can build the capacity to serve all students equitably.

The broader implications extend beyond higher education. This settlement's emphasis on procurement policy and staff training provides a model for how large, complex organizations can approach accessibility as institutional transformation focused on equal access rather than mere compliance theater.