Accommodation
An interactive process for employees and for members of the public, with intake, analysis, a written outcome and a file that holds up on review. No test suite produces this.
29 CFR 1630 and 28 CFR 35
Section 504 · ADA Title II · Section 508
Your accessibility obligation, as a finite path with a defined end.
Four stages: know where you stand, hold the documentation you are required to hold, remediate in priority order, and keep the record that proves it. For most entities the whole sequence runs about a quarter.
A federally-credentialed practice for public entities and organizations that receive HHS funding. Manual testing to the federal standard, and the program documentation that has to sit behind it, under one accountable signature.
May 11, 2027Section 504 web and mobile conformance, recipients with 15 or more employees
April 26, 2027ADA Title II web and mobile conformance, larger public entities
In force nowThe underlying nondiscrimination duty, and OCR complaint investigation
A conformant website is not a compliant organization
The strongest technical evaluation available, EN 301 549 evaluation and WCAG 2.2 AA validation with automated testing, manual assessment, assistive technology testing and functional workflow verification, proves one thing: that accessibility was intentionally designed, tested and governed in the product. That evidence is real and it matters.
It is also not the whole obligation. The ADA, Section 504, Section 508, the European Accessibility Act and FCC requirements each reach past the interface into how an organization operates.
Organizational process
Designated ownership with real authority, written policy, an exception path, and accessibility requirements carried into procurement so the next platform arrives conformant.
28 CFR 35.107(a)
Customer service and support
The channels a person reaches for when something fails. A conformant page is little help if the phone line, the intake form and the staff response are not equally usable.
Effective communication, 28 CFR 35.160
Documentation
Self-evaluations, transition plans, grievance procedures, public notice and a dated conformance record. These are the first items an investigator requests and none of them are code.
28 CFR 35.105 and 35.150
Employment practice
Application systems, onboarding platforms and the internal tools staff are required to use, plus the accommodation process behind them.
Title I and Section 501
Procedure and timeline
Notice, complaint intake, response windows and escalation. Entities lose these matters on process and record far more often than on the underlying technology.
28 CFR 35.107(b)
No testing gate, however rigorous, guarantees statutory compliance on its own. An organization can pass every automated and manual check on its public site and still be exposed, because nobody owns the function, the grievance procedure was never published, or staff cannot handle a request when one arrives.
Accessibility is finally about whether a person can do the thing they came to do. Testing establishes whether the interface permits it. The organization determines whether it happens. This practice covers both, which is why the engagements on this site pair conformance testing with the program work behind it.
What the work involves
The regulation runs long, but the work is finite and it has an order. Every engagement moves through the same four stages, and each one ends in a document you keep.
STAGE 01
Know where you stand
Manual conformance testing against WCAG 2.1 Level AA using the DHS Trusted Tester process, plus a program review against whichever rule binds you.
You keepA findings report, mapped to success criteria and to the governing rule.
STAGE 02
Hold the documentation
Self-evaluation, transition plan with a schedule, grievance procedure, Coordinator designation, public notice. The regulation requires you to have these on hand.
You keepA documentation set that answers an inquiry without rework.
STAGE 03
Remediate in priority order
Findings sequenced by legal exposure and user impact rather than ticket count. Fixes get specified for your developers or vendors, then retested by hand.
You keepA remediation plan with validated closure on each item.
STAGE 04
Keep the record
Sites change, vendors ship, staff turn over. A continuing record of conformance work is what demonstrates good faith when someone asks two years from now.
You keepA dated, continuous evidence trail.
Five things you should be able to produce on request
None of these are best practices. Each is required of covered entities, and each gets requested early when a complaint or an inquiry arrives. Check what you could hand over this week.
0 of 5Check the boxes above to see where you stand.
Why these five
These are the documents an OCR or DOJ inquiry asks for first, and the ones a plaintiff's counsel looks for before deciding whether to file. They are also the slowest to produce, because a self-evaluation and a transition plan describe work an entity has to carry out rather than language it can adopt.
Note what is missing from the list: your website vendor. A vendor can fix a contrast ratio or add alt text. None of them can write your transition plan, run your self-evaluation, or sign your Coordinator designation. That work sits with the entity, and it is where the exposure concentrates.
Which obligation applies to you
The standard is broadly the same. The rule that binds you, the enforcement path, and the documentation you owe are not.
Either door leads to the same two halves. An organization that needs someone to run the accessibility program fits here. So does an organization that needs someone to own digital conformance. Most need both, and the practice is scoped to be engaged for either one or for the pair.
Public sector and HHS-funded
Government, schools, health systems
Municipalities, counties, school districts, public authorities, health centers and behavioral health organizations. Program access across public-facing programs, services and activities, and conformance of the digital assets that deliver them. Title II, Section 504 and Section 508.
See the public-sector path Business and nonprofitPrivate entities and litigation exposure
Places of public accommodation, ed-tech and health-tech vendors, and nonprofits delivering public-facing programs, services and digital assets. Title III policy and staff practice, digital conformance, demand letter response, and vendor conformance reporting.
See the private-sector pathCredentials with identifiers you can look up
Every credential here carries an identifier your procurement office or general counsel can look up in the issuing registry.
- DHS Trusted Tester for WebTT-2604-08987
- ADA Coordinator Cert. (ADACC)55147918-4622
- NYC Minority Business EnterpriseMWCERT2025-1083
- Federal UEI, SAM.govE2Q7D9LYPM54
- NYC Vendor, PASSPortVS00099772
- Primary NAICS541511
Trusted Tester is the manual process federal agencies use to validate Section 508 conformance. Credentials are held by the practitioner and are not an endorsement of this firm by any agency.
The practice participates in the rulemaking it advises on
Formal comment filed on both interim final rules that moved these dates. The full submissions are available on request.
DOJ · ADA TITLE II
Comment on the Title II web and mobile accessibility interim final rule
Argued that additional time defers rather than resolves private-right-of-action exposure, and recommended a good-faith remediation safe harbor modeled on existing state cure-period frameworks.
HHS · SECTION 504
Comment on the Section 504 web and mobile accessibility interim final rule
Supported the extension while identifying the gap it leaves for recipients acting in good faith, with reference to county and municipal association recommendations on cure periods.
Start with stage one
A 30-minute call establishes which rule binds you, what you already hold, and what it would take to close the gap. No obligation, and no prepared pitch.
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