Your First 90 Days Owning Digital Accessibility

Jeff Fryer
higher education accessibilityada coordinatoraccessible by defaultprocurementdisability services

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This article was written by a person and reviewed against accessibility.chat editorial standards. Treat it as research and education rather than legal advice. We prioritize primary sources and correct material errors.

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If your first deliverable feels political rather than technical, you're probably right about that.

You'll be tempted to announce a program. Don't — inventory before you announce anything, and if you're the accessibility lead at your institution, your very first deliverable might not be technical at all.

Week 1: draw the RACI before anything else

This role is often split between a disability services director and an IT accessibility coordinator who don't report to the same person. If that's your institution, ambiguity between two owners performs worse than one overloaded owner — so your first real deliverable is a one-page RACI: who owns web, who owns course content, who owns procurement, who answers complaints. Get it agreed and written down before you build anything on top of it.

Alongside that: publish or fix the accessibility statement, confirm the complaint route reaches a monitored mailbox and test it yourself, and open the intake log.

Weeks 2-4: find out what you own, at a scale most sectors don't face

Course materials, LMS content, library databases, research portals, and scanned readings — at a volume no other sector in this series approaches. You will never remediate all of it, and a defensible triage queue is the difference between a program and a pile. Ask every department "what else do you use?" and ask again, since departments run their own subscriptions more in this sector than almost any other.

Weeks 3-4: find who signs contracts — all of them

Procurement in higher ed is often decentralized to departments, which means a single clause library sitting in a policy PDF does nothing. It only works if it's embedded in the purchasing system itself, so no covered-technology purchase completes without an accessibility review, regardless of which department's card pays for it.

Month 2: build the two gates, sized for faculty

A pre-publication check for new content, and a vendor review workflow so nothing new gets bought broken. But in this sector, add a third: accessible-by-default templates in the LMS, so new course content starts accessible rather than needing remediation later. The academic-freedom-versus-accessibility fight is real and it's not won by a policy memo — it's won by making the accessible path the easy default, with remediation help faculty can actually request, and deans carrying the expectation rather than coordinators alone.

Month 2: meet your local disability organization and your students

Not personas — actual disabled students, who are already navigating your systems and already know where the real barriers are. One working relationship, paid for their time, will surface more than a semester of scanning.

Month 3: triage, score honestly, make the ask

Triage the document and course-content estate — rank legacy scans by enrollment and reuse, since a rarely-used reading from a course that ran once carries different stakes than a core text used every semester. Score your program's maturity honestly. Take one page to whoever holds the budget: what exists, what it costs, what happens at three funding levels.

If you only do four things: publish the statement, log every complaint, get the purchasing gate embedded in the actual procurement system, and stop broken content at publication with accessible-by-default templates. Almost none of it costs money, and together it removes most avoidable exposure.

This isn't legal advice on which regimes reach your institution — verify against your own counsel. If you want a fast first look at how a specific course page or document holds up, ask Luke to check it. Our accessibility statement shows this same discipline applied to our own site.

Your First 90 Days Owning Digital Accessibility (3 min). A practical 90-day guide for new digital accessibility leads at higher education institutions, covering governance, inventory, procurement gates, and triage. Open the episode on its own page · Download captions (WebVTT)
Transcript with visual descriptions

Your first deliverable may be political, not technical

On screen: Slide title: 'Your First 90 Days Owning Digital Accessibility' with subtitle: If your first deliverable feels political rather than technical, you are probably right.

Starting a digital accessibility role? Your first challenge may not be technical at all.

Do not announce a program. Inventory first, and sort out who owns what.

Week 1: draw the RACI before anything else

On screen: A three-step list. Step 1: Write the RACI — one page, agreed, covering web, course content, procurement, and complaints. Step 2: Publish or fix the accessibility statement and confirm the complaint route reaches a monitored mailbox. Step 3: Open the intake log.

In week one, draw the RACI before you do anything else.

A RACI names who owns web, course content, procurement, and complaints. Get it agreed and written down on one page.

Publish or fix the accessibility statement. Confirm the complaint route reaches a monitored mailbox and test it yourself.

Then open the intake log. Do not build anything on top of unclear ownership.

Weeks 2–4: find out what you own

On screen: Slide heading: Weeks 2–4 — Find what you own. Two points listed: The scope includes course materials, LMS content, library databases, research portals, and scanned readings. A defensible triage queue is the difference between a program and a pile.

In weeks two to four, find out what you actually own.

The scope includes course materials, LMS content, library databases, research portals, and scanned readings. Higher education faces a volume no other sector approaches.

Ask every department what else they use — and ask again. Departments run their own subscriptions more here than in almost any other sector.

Weeks 3–4: find who signs contracts

On screen: Slide heading: Procurement is decentralized. Two side-by-side panels. Works: accessibility review embedded in the purchasing system itself. Does not work: a clause sitting in a policy PDF.

Also in weeks three to four, find out who signs contracts — all of them.

The only thing that works is embedding the accessibility review in the purchasing system itself.

A clause sitting in a policy PDF does nothing. Departments bypass it without even noticing.

Month 2: build two gates and one default

On screen: A three-step list. Step 1: Pre-publication check — stop broken content before it goes live. Step 2: Vendor review workflow — nothing new gets bought broken. Step 3: Accessible-by-default LMS templates — new course content starts accessible rather than needing remediation later.

In month two, build two gates and one default for new content.

A pre-publication check stops broken content before it goes live.

A vendor review workflow means nothing new gets bought broken.

Accessible-by-default LMS templates mean new course content starts accessible rather than needing remediation later. That is how you win the academic-freedom debate — make the accessible path the easy path.

Month 2: meet actual disabled students

On screen: Slide heading: Not personas — real students. Key point: One working relationship, paid for their time, will surface more than a semester of scanning.

Also in month two, meet actual disabled students — not personas.

One working relationship, paid for their time, will surface more real barriers than a semester of automated scanning.

Month 3: triage, score honestly, make the ask

On screen: A three-step list. Step 1: Triage the document estate — rank legacy scans by enrollment and reuse. Step 2: Score your program's maturity honestly. Step 3: Take one page to whoever holds the budget — what exists, what it costs, what happens at three funding levels.

In month three, triage the document estate, score your program, and make the budget ask.

Rank legacy scans by enrollment and reuse. A rarely used reading carries different stakes than a core text used every semester.

Score your program's maturity honestly.

Then take one page to whoever holds the budget: what exists, what it costs, and what happens at three funding levels.

If you only do four things

On screen: Bar chart showing four priorities. Publish the statement, log every complaint, embed the purchasing gate in the procurement system, and stop broken content at publication with accessible-by-default templates. The chart notes these four actions together remove most avoidable exposure and almost none cost money.

If you can only do four things, these are them.

Publish the accessibility statement.

Log every complaint.

Embed the purchasing gate in the actual procurement system.

And stop broken content at publication with accessible-by-default templates. Almost none of this costs money, and together it removes most avoidable exposure.

The takeaway

On screen: Takeaway: Start with governance, not announcements. Inventory before you build. Embed the gate in the system. Make the accessible path the easy default. Sources listed from the article.

Inventory before you announce anything. Embed the gate in the system. Make the accessible path the easy default.

Read the full article for the law and detail behind each step.

Sources

Previous: the law behind the job · Next: document inventory and triage


Sources: DOJ-ED Joint Dear Colleague Letter on Online Accessibility (opens in new window) · 28 CFR Part 35, Subpart H — Web and Mobile Accessibility (opens in new window) · Web Content Accessibility Guidelines (WCAG) 2.1 (opens in new window) · 34 CFR Part 104 — Section 504 Regulations (opens in new window)

About Jeff Fryer

Jeff Fryer spent years working kitchens before moving into ADA compliance work for local government. He writes from that experience -- direct, plainspoken, allergic to compliance theater. Contributing writer at accessibility.chat.

Jeff Fryer is a person, not one of the AI analyst lenses this site also publishes under. A named human is accountable for this article.

Specialization: Local government ADA compliance, contributed from direct field experience

Authorship and Editorial Process

Jeff Fryer wrote this article. AI was not used to draft it. It went through the same editorial checks as everything else published here.