ADA Access for All Guillaume & Co. LLC

ADA · Section 504 · Section 508

An outsourced ADA function for organizations without an accessibility team.

Most organizations will never have an accessibility department, and the law doesn't ask for one. It asks for a named owner, a short set of documents, a process that works when a request arrives, and a record that shows it did. The practice performs that function remotely for public entities, nonprofits, and businesses that need the support but lack the in-house expertise, and for the vendors that sell to them, from the front desk to the website.

The work is performed and signed by a certified ADA coordinator who is also a Department of Homeland Security Trusted Tester. Websites, apps and documents are tested by hand to WCAG 2.1 AA, as one channel of the obligation, not the whole of it.

Book a 30-minute call Find your stage

Find your stage

Pick the table that fits. Each one runs from nothing in place to kept current, with who does the work at each stage and the rule it turns on. Find the row that describes you today. The row under it is the work.

Nonprofits and businessesADA Title III, and Section 504 when federal money reaches a program

Title III reaches what a nonprofit or business opens to the public: a class, a clinic, a food pantry, a performance, a gallery, a convening, and the pages people use to sign up. It covers the rules, how the organization communicates and who it lets take part, including what a vendor provides on its behalf, and it has applied since January 26, 1992. When federal money reaches a program, even through a city, a state or another nonprofit, Section 504 applies as well.

  1. Stage 1: Nobody owns it

    What it looks like
    No written policy and no named owner. A request for an interpreter, a service animal or a schedule change gets whatever answer the person on shift gives.
    Who does the work
    Nobody.

    28 CFR 36.302(a) and 36.303(c)

  2. Stage 2: Answered on complaint

    What it looks like
    Requests get handled one at a time, often after a complaint, and two staff members give two different answers. Nothing records what was asked, what was decided or why.
    Who does the work
    Whoever runs operations or HR, on top of the regular job.

    28 CFR 36.302(a)

  3. Stage 3: Written down

    What it looks like
    A written policy covers changes to rules and practices, communication aids, service animals, mobility devices and eligibility rules, and there's a clear way to ask at registration, ticketing and the front desk.
    Who does the work
    A named owner inside. The practice writes the policies and the request path, remotely.

    28 CFR 36.301, 36.302 and 36.303

  4. Stage 4: Running

    What it looks like
    Requests come to one place and get an answer in time to matter. The person is asked what works where possible, and the outcome goes in writing. Staff know their part, and the vendor's checkout works too.
    Who does the work
    Your staff deliver on the day. The practice handles intake and the conversation with the person by phone, email and video, and keeps the record.

    28 CFR 36.303(c)(1)(ii) and 36.202(a)

  5. Stage 5: Kept current

    What it looks like
    Policies are reviewed each year and whenever a program changes. Every request, decision and outcome sits in a dated record that leadership and counsel can read.
    Who does the work
    Programs, operations and procurement share it. The practice holds the record and runs the yearly review.

    28 CFR 36.302 and 36.303

A row describes how the work runs. It isn't a finding that the law is met. Barrier removal in existing buildings is a separate duty, and design work goes to licensed architects. 28 CFR 36.304.

The full page for nonprofits and businesses

GovernmentADA Title II and Section 504

Every public entity owed a self-evaluation of its services, policies and practices by January 1993, and entities with 50 or more employees also owed a designated coordinator and a grievance procedure. Program access is judged program by program, viewed in its entirety, and the rule lets a program reach people another way rather than altering every building.

  1. Stage 1: Nobody named

    What it looks like
    No designated coordinator, no self-evaluation on file, no grievance procedure. Access questions go to whoever answers the phone.
    Who does the work
    Nobody named.

    28 CFR 35.105 and 35.107

  2. Stage 2: Named

    What it looks like
    A coordinator is designated and the grievance procedure is posted. Requests are still handled one complaint at a time, and no one has listed which programs people can't fully use.
    Who does the work
    One employee holds the title, part-time on top of another job.

    28 CFR 35.107(a) and (b)

  3. Stage 3: Evaluated

    What it looks like
    A self-evaluation of services, policies and practices, with a chance for the public to comment, and a list of the programs people can't fully use today. Where a building has to change, a transition plan sets the schedule and the official responsible.
    Who does the work
    The designated employee stays the owner. The practice performs the self-evaluation remotely, from your documents and interviews with program staff.

    28 CFR 35.105 and 35.150(d)

  4. Stage 4: Delivering

    What it looks like
    Programs reach people now by the methods the rule allows, most integrated setting first: changing a policy, providing an interpreter or an accessible document, moving a class to an accessible room, delivering a service another way. People can find out where accessible services are.
    Who does the work
    Program managers make the changes. The practice tracks each one and keeps the record.

    28 CFR 35.130(b)(7), 35.150(b), 35.160 and 35.163

  5. Stage 5: Kept current

    What it looks like
    The self-evaluation comes back when programs move or the rules change. Every request, grievance and change sits in a dated record.
    Who does the work
    Programs and procurement share it. The coordinator holds the record, and the practice keeps it current.

    28 CFR 35.105 and 35.107

A row describes how the work runs. It isn't a finding that the law is met.

The full page for public entities

Government vendorsSection 508, and Title II and Section 504 through the contract

When a city, a state agency or a federally funded program provides your product to the public, its obligation travels through the contract to you. Title II's web rule covers content a public entity provides directly or through contractual, licensing or other arrangements, and the HHS Section 504 rule says the same of its recipients. Federal agencies buy against Section 508, which uses WCAG 2.0 AA. State and local buyers need WCAG 2.1 AA, starting April 26, 2027 for the largest.

  1. Stage 1: No evidence

    What it looks like
    No conformance report, or one filled in from a checklist without testing. Accessibility questions in a bid get a yes.
    Who does the work
    Nobody owns it, so sales answers.

    29 U.S.C. 794d(a)(1)(A)

  2. Stage 2: A report on file

    What it looks like
    An Accessibility Conformance Report exists, but it's old, it says Supports where testing would say Partially Supports, and nobody can show the test behind it.
    Who does the work
    A product manager, on top of the roadmap.

    36 CFR Part 1194, Appendix A, E205.4

  3. Stage 3: Tested and reported

    What it looks like
    The product is tested by hand against WCAG 2.1 AA, the level state and local buyers need under Title II, and the report says what was found, criterion by criterion, with the date of the test.
    Who does the work
    The practice performs the test and writes the report remotely. Your team fixes.

    28 CFR 35.200(b)

  4. Stage 4: Fixed on a schedule

    What it looks like
    Failures go on the roadmap with dates, each release is retested, and the report is reissued when the product changes. Contracts say what conforms, what doesn't yet and when it will.
    Who does the work
    Product and engineering own the fixes. The practice retests and reissues the report.

    28 CFR 35.200(a); 45 CFR 84.84(a)

  5. Stage 5: Built in

    What it looks like
    Accessibility is a release criterion, designers and developers work from a short checklist, and every version a buyer runs has a current report.
    Who does the work
    Product, design and engineering share it. The practice tests each major release.

    W3C Accessibility Maturity Model, as the benchmark

A row describes how the work runs. It isn't a finding that a product conforms.

The full page for government vendors

DigitalWebsites, apps and documents, tested by hand

Websites, apps and documents are one channel of the obligation, and they draw a growing share of lawsuits. An automated scan finds some problems. A person with a keyboard and a screen reader finds the rest. Public entities, and organizations whose programs get HHS money even through a city or state, have fixed dates in 2027 and 2028. Every covered organization owes effective communication now.

  1. Stage 1: Untested

    What it looks like
    No one has tested the site. An overlay may be installed. Problems surface as complaints or a demand letter.
    Who does the work
    Nobody, or the web vendor when asked.

    28 CFR 35.160 and 36.303(c)

  2. Stage 2: Scanned

    What it looks like
    An automated scan runs and the error count drops, but nobody has tried the site with a keyboard or a screen reader, and the forms and PDFs people need haven't been checked.
    Who does the work
    Marketing or IT, with a scanning tool.

    WCAG 2.1 Level AA

  3. Stage 3: Tested by hand

    What it looks like
    The pages and tasks people use most are tested against WCAG 2.1 AA by a person, using the Department of Homeland Security Trusted Tester process with assistive technology, and every finding is dated.
    Who does the work
    The practice performs the test remotely. Your developers or vendor fix.

    WCAG 2.1 Level AA

  4. Stage 4: Fixed and retested

    What it looks like
    Findings are fixed in order of impact, each fix is retested by hand, documents are remediated, and an accessibility statement tells people how to report a barrier.
    Who does the work
    Developers and content staff fix. The practice retests and keeps the record.

    28 CFR 35.200(b); 45 CFR 84.84(b)

  5. Stage 5: Built in

    What it looks like
    Accessibility is checked before release, editors and designers work from a short checklist, vendor contracts carry accessibility terms, and the program is measured against the W3C Accessibility Maturity Model.
    Who does the work
    Design, development, content and procurement share it. The practice audits on a schedule.

    W3C Accessibility Maturity Model, as the benchmark

A row describes how the work runs. It isn't a finding that a site conforms.

The full page on websites and apps

Who does the work

No one has to hire an accessibility team. The work splits three ways.

On site, by your people

Program, front-desk and box office staff deliver each accommodation on the day, and facilities staff keep routes and features working.

Your sites, your staff

Remote, by the practice

Intake and the conversation with the person by phone, email and video, the policies and the request path, the self-evaluation, testing by hand, the record and the yearly review.

Performed by the practice

Referred out

Design and sealed drawings to licensed architects, construction to your contractors, and legal questions to your counsel.

Named in writing at the start

Passes the check. Fails the program.

Each of these would pass a checklist. The person who came to use the program is still turned away.

The sign-up page passes. The medical form doesn't.

Registration works with a screen reader. The medical form every camper has to return is a scanned PDF, to be printed, filled in by hand and uploaded. Auxiliary aids and services have to be provided in accessible formats, in a timely manner, and in a way that protects the person's privacy and independence. A blind parent who needs someone else to fill in a child's medical form has neither.

28 CFR 36.303(c)(1)(ii)

The grievance procedure is posted. Nobody receives the complaint.

The procedure is published, and the contact on it left in March. The coordinator's name, office address and telephone number have to be available to anyone who asks, and complaints need prompt and equitable resolution.

28 CFR 35.107(a) and (b)

The report says Supports. The checkout doesn't.

The vendor's conformance report marks every criterion Supports. A screen reader user can't get past the payment step. Title II's web rule covers content a public entity provides through contracts, so for a city of 50,000 or more the gap is the city's to answer for from April 26, 2027, and the contract decides who fixes it.

28 CFR 35.200(a) and (b)(1)

The scan passes. The form can't be finished.

An automated scan reports zero errors. A keyboard user can't reach the submit button, and error messages aren't announced to a screen reader. A scan checks part of the success criteria. The rest takes a person.

WCAG 2.1 success criteria 2.1.1, 3.3.1 and 4.1.3

In force nowADA Titles II and III, Section 504 and Section 508: program access, effective communication and accessible technology
April 26, 2027ADA Title II web and mobile rule for public entities of 50,000 or more, including content they provide through contracts
May 11, 2027Section 504 web and mobile rule under 45 CFR 84.84, for organizations with fifteen or more employees whose programs get HHS money, even through a city or state

How an engagement runs

The work is finite and it has an order. Every engagement moves through the same four steps, and each one ends in something you keep.

STEP 01

Know where you stand

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. Every finding carries the date it was observed and one of three results: meets the requirement, doesn't meet it, or not tested. Not tested is reported as a result, never left blank.

STEP 02

Hold the documents

The documents your rule requires, written for your organization: a coordinator designation and grievance procedure where the rule calls for them, an accommodation policy and a way to ask, and an accessibility statement.

You keepA document set that answers an inquiry without rework.

STEP 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.

STEP 04

Keep the record

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.

Credentials, and how to confirm them

Two of these can be checked directly: the NYC certification in the City's public directory, and the federal identifier on SAM.gov with a free account. For the two certifications, a copy of each certificate comes with any written inquiry. How to confirm each one.

  • ADA Coordinator Cert. (ADACC)55147918-4622
  • Department of Homeland Security Trusted TesterTT-2604-08987
  • NYC Minority Business EnterpriseMWCERT2025-1083
  • Federal UEI, SAM.govE2Q7D9LYPM54
  • NYC Vendor, PASSPortVS00099772
  • NAICS541611 · 541519

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.

On the record in the rulemaking behind these dates

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.

SECTION 504 RULEMAKING

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 a 30-minute call

A 30-minute call establishes which rule binds you, which row you're on, and what it would take to reach the next one. No obligation, and no prepared pitch.

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