Behind the Login Still Counts: Course Materials, the LMS and the ADA Title II Rule for Public Universities

Ask an accessibility office at a public university where its exposure sits and the answer is usually the website. Ask the same question of a student who uses a screen reader and the answer is almost always the course.

The public website is maintained by a central team, runs on a managed content system, and is probably already in better shape than most of the institution. The learning management system is different. It holds tens of thousands of files uploaded by hundreds of instructors over many years: scanned book chapters, slide decks exported to PDF, lecture recordings with automatic captions, spreadsheets of problem sets, syllabi in whatever template each department happened to use.

None of that is out of scope because it sits behind a login.

Does the Title II web rule really cover course content?

For public colleges and universities, yes. A public institution is a state or local government entity under ADA Title II, and the DOJ’s web accessibility rule applies to the web content and mobile apps it provides or makes available — including through contractual arrangements with vendors.

The rule’s exceptions are listed in 28 CFR 35.201, and there is no exception for course content. The exception for individualized documents in 35.201(d) covers files about a specific individual, their property or their account — a student’s own grade report or financial aid letter — not a reading assigned to a whole class. The exception for preexisting conventional electronic documents does not reach documents still used to participate in the institution’s programs, which is a difficult argument to make about the readings for a course students are taking now.

Private institutions are not covered by Title II. They are generally reached by ADA Title III and, where they receive federal financial assistance, by Section 504 of the Rehabilitation Act — so the obligation to provide accessible course materials to students with disabilities does not disappear, even though the DOJ rule’s specific technical standard does not apply to them.

The standard in the Title II rule is WCAG 2.1 Level AA. Compliance dates depend on the population of the governmental entity, and they were extended in 2026; the deadlines post sets them out and is kept current.

What actually fails in course materials?

A handful of patterns account for most of it.

Scanned readings. A photocopied chapter scanned to PDF is an image of text. To a screen reader it is silent. Optical character recognition gives it a text layer, but OCR alone does not produce headings, reading order, or correctly marked footnotes, and it mangles equations, tables and multi-column layouts. WCAG 1.1.1 and 1.3.1 are where these fail.

Slides exported to PDF. Presentation software can produce tagged PDFs, but only if the slides were built with real titles, real lists and alt text on images. Slides built from text boxes placed by eye export with a reading order that jumps around the page. Accessible Word, PowerPoint and Excel covers how to build them right at the source.

STEM content. Equations pasted as images, graphs with no description, chemical structures and circuit diagrams. These need math markup or meaningful text alternatives written by someone who understands what the figure is teaching, not a generic “chart” label.

Lecture video. Automatic captions are a starting point, not a deliverable. Technical vocabulary, proper names and formulas are exactly where they fail. WCAG 1.2.2 requires captions for prerecorded video, and 1.2.5 requires audio description where visual content carries information the narration does not — a professor working a problem on a whiteboard without saying what they are writing.

Syllabi. Short, high-stakes and universally used, syllabi are often in the worst shape: tables built for layout, colour used as the only indicator of deadlines, links labelled “click here”. Because every student in the course uses them, they are also the highest-value fix per page.

Publisher and third-party content. Courseware from textbook publishers, embedded simulations and homework platforms. When the institution provides this to students through a contract, it is not third-party content in the rule’s sense. The accessibility of the platform becomes a procurement question. Third-party content under Title II goes through how to handle it.

Why can’t the disability services office just handle it on request?

Because the model the rule is designed to replace is exactly that one.

The accommodation model — a student registers, the office is notified, materials are converted after the fact — still has a place for individual needs that no general standard can anticipate. But as the default it means students with disabilities receive their readings later than everyone else, often after the class has discussed them. It also funnels a whole institution’s inaccessible content through one small office, every term, indefinitely.

The rule moves the obligation to the point of publication. Accommodations continue for individual needs on top of that; they are no longer the whole plan.

What about international students and multilingual materials?

Many institutions translate a meaningful share of content already: admissions and orientation materials for international applicants, family communications, language-course materials, and research outputs in other languages. Every one of those is also subject to the accessibility obligation, and they add requirements.

A document in Spanish or Mandarin must declare its language so a screen reader uses the correct pronunciation — WCAG 3.1.1. A course reader in English that quotes passages in French or German needs those passages tagged separately under WCAG 3.1.2, or the quoted text is read with English phonetics and becomes unintelligible. Right-to-left languages such as Arabic and Hebrew need reading order rebuilt, not just translated. Translated documents and WCAG language of parts explains the mechanics.

A plan that does not try to fix everything at once

Start with what every student touches. Syllabi, course templates, the LMS navigation itself, and the documents used in the first weeks of term. Fix the templates and every new course inherits the fix.

Inventory by current use, not by count. A course that runs every semester with 400 students matters more than a retired elective. Courses no longer taught may qualify as archived content; courses in active use do not.

Fix at the source going forward. Instructor training and accessible templates prevent the backlog from growing while you work it down.

Remediate the heavy lifters professionally. Scanned readings, STEM documents, and video captioning are where faculty time is least productive and specialist work pays off.

Write accessibility into every courseware contract. Require an Accessibility Conformance Report and the right to test it. A VPAT or ACR is a representation you can hold a vendor to.

Test with people, not only tools. A scanner can tell you an image lacks alt text. It cannot tell you whether a diagram’s description teaches what the diagram teaches.

Where Taika fits

We remediate course documents — scanned readings, slide decks, syllabi, forms — into tagged, screen-reader-tested files, and we produce captions and transcripts for lecture video. Where materials are multilingual, we translate and remediate as one workflow, so the language tagging is correct in every file. We meet and exceed ISO 17100, 9001 and 27001 standards.

Planning course-material remediation for next term? Send us the number of courses, an estimate of documents and video hours per course, the share that are scanned or STEM-heavy, and any languages other than English — then request a quote. Our education language access page covers how we work with colleges and universities.