Program accessibility · ADA Title II · Section 504
Title II and Section 504 require each program, service and activity, viewed in its entirety, to be readily accessible to and usable by people with disabilities. That covers the building, the counter, the phone line, the policy and the record. The website, apps and documents are part of it, not the whole of it.
A program accessibility firm serving as the outsourced ADA function for public entities and for any organization that receives federal financial assistance. The practice performs the coordinator function, administers accommodation and grievance processes, produces the self-evaluation and transition plan, and tests websites, apps and documents by hand to WCAG 2.1 AA. One obligation, under one accountable signature.
A conformant website is not a compliant organization. The strongest technical evaluation available, WCAG 2.1 and 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 and FCC requirements each reach past the interface into how an organization operates.
Entrances, routes, rooms and restrooms where services are delivered. Existing buildings need not all be accessible, but the program must be: relocated, delivered another way, or reached through scheduled structural work. Design and sealed drawings are referred to licensed architects.
Program access, 28 CFR 35.150
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
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)
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
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
Application systems, onboarding platforms and the internal tools staff are required to use, plus the accommodation process behind them.
Title I and Section 501
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)
Policies that admit service animals, wheelchairs, walkers and other mobility devices as the regulation requires, with staff who know the few questions they may ask and the documentation they may not demand.
28 CFR 35.136 and 35.137
Websites, mobile apps, portals and documents, tested by hand to WCAG 2.1 AA using the Department of Homeland Security Trusted Tester process. The 2027 and 2028 web and mobile compliance dates apply to this channel. The rest of the obligation already applies.
28 CFR 35.200 and 45 CFR 84.84
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 the program work with conformance testing of the digital channels that deliver it.
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
A program review against whichever rule binds you, and manual conformance testing against WCAG 2.1 Level AA using the Department of Homeland Security Trusted Tester process. Both halves assessed together, because an inquiry will ask about both.
You keepA findings report, mapped to the governing rule and to WCAG success criteria.
STAGE 02
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
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
Programs change, sites change, vendors ship, staff turn over. A continuing record of program and conformance work is what demonstrates good faith when someone asks two years from now.
You keepA dated, continuous evidence trail.
None of these are optional. 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.
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.
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.
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 nonprofitPlaces 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 pathEvery credential here carries an identifier your procurement office or general counsel can look up in the issuing registry.
ADA Coordinator Certification is the program credential. 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.
Formal comment filed on both interim final rules that moved these dates. The full submissions are available on request.
DOJ · ADA TITLE II
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.
SECTION 504 RULEMAKING
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.
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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