Seen From Outside

The afternoon test: eight checks anyone can run on a college website with a browser.

What a student, a parent or a lawyer can learn about a college's accommodations office in one afternoon with a browser, why the same eight things keep failing, and the staff training that keeps them fixed.

Start the afternoon test

The afternoon test is the audit anyone can run. It needs no login and no expertise. What it finds is rarely a missing policy. It is the right information in the wrong place, and documents built by habit rather than by design.

We built this test from outside-in reviews of public college websites. In the reviews we have run, the policy usually existed. The coordinator had been named and the complaints procedure written. What failed was placement, authoring habit and upkeep, and those three things fail for the same reason: the people who publish the pages and build the forms were never shown what an accessible version looks like, and nobody owns keeping it that way after they leave.

This guide is written to be handed to any college. Nothing in it names an institution. It has four parts: the test itself, so a college can run it on its own site before anyone else does; why the same things keep failing; what the federal rule actually asks, with the dates; and the curriculum, a core module for everyone and a short module for each department whose habits show up in the findings.

Part one

The afternoon test

Eight questions anyone can answer from the public site

Eight questions, each answerable from the public site. Next to each: what to look for, why it fails, the fix, and who owns it. Most of these are labor a college already employs rather than anything that needs buying; the exceptions are called out where they arise. All of them need a named owner.

Placementstart on the disability-services page

Can a student reach the responsible officer from the page they are actually on?

The coordinator usually exists, with a room, a phone number and a written procedure. The question is where that information lives. Often it sits on an equal-opportunity or human-resources page with no path from the disability-services page. Some colleges publish a complete designation in a site-wide notice reached through a footer link, but a student in difficulty does not read a link labeled for a legal notice as the place to go. Start on the disability-services page and look for the coordinator's name and the complaints route. If you have to search the whole site to find them, so does the student, and a student has less patience than an auditor.

One linkAdd the coordinator and the complaints route to the disability-services page. It is already written; it is in the wrong place.Owner: disability services + web
Formsrequest, documentation and appeal forms

Can the request form be completed on a screen?

Open every document that asks a student to supply something and try to type into it. If it has no fillable fields, the published route is print, handwrite, scan or carry back. A student who cannot use a printer or cannot write by hand has to ask for help in order to ask for help. Watch for forms titled as though they were fillable that contain no fields at all, and request forms authored in software never meant to produce one.

TemplateOne tagged, fillable form set: request, documentation guidelines, appeal. The defects repeat because the authoring habit repeats.Owner: disability services
Complaintsthe grievance procedure

Does the complaint procedure say a student may go outside the college?

Read the complaint procedure and check whether it tells a student, in writing, that they may take a complaint to the federal government regardless of how the college resolves it. Some procedures describe a process that ends with the college. This matters less as exposure than as trust: an institution confident in its process loses nothing by naming the external one, and a student who discovers the route later, on their own, tends to arrive already adversarial.

One sentenceStandard text, one legal review, same wording everywhere the procedure appears.Owner: legal + disability services
Timelinescatalog, office page, syllabus

Do the timelines agree with each other?

Compare what the catalog, the office page and the syllabus template say about when to request accommodations. When they disagree, each was usually true when written. Nobody owns the set. A student who follows the wrong one and is refused has a grievance that the college wrote for them.

One sourceOne page holds every deadline and timeline; every other page links to it instead of restating it.Owner: disability services + registrar
DocumentsPDFs and the links to them

Do the documents open as text, and do the links still work?

A scanned PDF is a photograph. Open it with a screen reader and you hear nothing. Some screen readers can run text recognition on demand, but the result is guesswork with no headings or structure, and it does not make the document conform. A document can also be real text and still fail: exported without tags, it gives a screen reader no headings to move through. Broken links are the same failure one step earlier: the document moved, the link did not.

SweepReplace scans with the source file exported as a tagged PDF; delete or redirect dead links. Note that tagging and fillability are separate acts: a correctly tagged export still has no form fields, which is a different job with a different tool.Owner: web + each publishing office
Structurethe page itself

Is the disability-services page itself built well?

Check the basics on the disability-services page: a declared page language, a real title, one main heading, and headings in order. Each is a small fix, yet a missing page language still turns up on about one in seven of the top million home pages (WebAIM Million 2026). When a college's disability-services page gets these right, it is often better built than the homepage that links to it, and worth saying so to the people who built it.

TemplateOnce the disability-services page passes, use it as the house template for every other student-facing page.Owner: web
Socialposts made after the deadline

Do the social media posts carry alt text and captions?

The rule covers what a public entity posts on social media once the deadline passes. Posts made before that date are exempt; posts made after are not. In practice this is content often produced by students, interns and the newest staff, with the least training and the fastest turnover. Every image needs a description; every video needs captions.

HabitTwo-line checklist pinned to the posting workflow, taught in the communications module below.Owner: marketing + communications
Governancethe board's deadline decision

Has the board decided which deadline the college is working to?

The rule sets two dates a year apart, and which one applies turns on whether the college counts as a special district government under 28 CFR 35.104. That definition requires enough administrative and fiscal autonomy to qualify as a separate government. A New Jersey county college does not have it: its county must appropriate the certified budget and capital costs and issues bonds for them (N.J.S.A. 18A:64A-17 through 18A:64A-19), and the 2022 Census of Governments lists county colleges among public school systems dependent on county governments. A college with no Census population of its own takes the combined population of the governments it is an instrumentality of, so a college shared by two counties takes both. Every New Jersey county is over 50,000. The answer is reachable in an afternoon. The question to ask is whether anyone has written it down and dated it.

Board minuteWork the definition through with counsel, then have the board record the standard and the duty, dated. Adopting a standard rather than a bare date survives any change to the deadline itself.Owner: president + counsel

Part two

Why the same things keep failing

Three causes, one of them the root

Placement

The information exists, written by the office that owns the policy, on that office's page. The student is on a different page. Nobody is responsible for the path between them.

Authoring habit

Forms are built in whatever the author knows: a word processor, a spreadsheet, a scanner. The output looks like a form. It is not one. The defect repeats from college to college because the habit does.

Nobody installs the skill

The person who fixed it last was never trained, and neither is whoever replaces them. Higher ed turnover runs about 13% a year across faculty and staff, and about 25% for part-time staff (CUPA-HR, 2024), so more than one person in eight leaves every year. The skill is not in any job description, not in any induction, and concentrated in the roles that turn over fastest: part-time communications staff, grant-funded coordinators, interns and adjuncts. This is the root cause, and it is the one that training addresses.

The arithmetic is simple. A fixed page decays at the rate of staff turnover. A trained office does not, because the habit moves with the role rather than the person. Remediation without training lasts until the people who did it move on; training without remediation leaves the current defects live. Do both, in that order, and the second one is what makes the first one stick.

Part three

What the rule actually asks

Title II web and mobile rule, 28 CFR part 35 subpart H

The federal rule requires state and local government web content and mobile apps, including those of public colleges, to meet WCAG 2.1 Level AA. It applies to content the college provides directly and to content it provides through a vendor under a contract, license or other arrangement. It sets two compliance dates, based on the population of the entity served.

April 26, 2027

Entities serving 50,000 or more people, which includes a college treated as an arm of a county over that threshold.

April 26, 2028

Entities under 50,000, and special-district governments regardless of population.

Be exact about who moved the deadline, because it is commonly misdescribed: the Department of Justice did, by interim final rule published April 20, 2026. Not Congress. It changed only the dates. The Department did not take public comment before the rule took effect; it took comments only afterward. The National Federation of the Blind is challenging the extension in federal court (filed May 21, 2026, District of Maryland, still pending), so treat the new date as the outside limit rather than the target.

The duties with no April date attached are already due, and they are the ones worth citing: effective communication (28 CFR 35.160) and, for public entities with 50 or more employees, a designated responsible employee whose name, office address and telephone number are made available to anyone who asks, plus a published grievance procedure (28 CFR 35.107). A college receiving federal financial assistance has also been bound by Section 504 since 1977: 34 CFR 104.7 and 104.8 for recipients with fifteen or more employees, and 104.44(d) on auxiliary aids for students. And a college with health programs answers to a second regulator on a different clock: HHS extended its own Section 504 web rule, by interim final rule published May 11, 2026, to May 11, 2027 for recipients with fifteen or more employees. The same lawsuit challenges that extension, so treat both new dates the same way.

Covered

  • Every page of the public website and any mobile app
  • Documents posted for current use: forms, handbooks, syllabi, catalogs
  • Social media posts made after the compliance date
  • Content behind a login: the learning platform, the portal, registration
  • Vendor-provided content the college makes available under a contract, license or other arrangement

Exempt, with conditions

  • Archived content, and all four elements must hold: created before the compliance date, kept only for reference, never changed since, and stored in a clearly identified archive area. The first element is the one that matters: you cannot archive your way out of a future obligation.
  • Documents posted before the compliance date, unless they are still used to apply for, gain access to, or take part in a service
  • Third-party content, unless the third party posts it under a contract, license or other arrangement with the college
  • Individualized documents (PDF, word processing, presentation or spreadsheet files) that are both about a specific person, their property or their account and password-protected or otherwise secured
  • Social media posts published before the compliance date. Posts after it are covered.
  • No exception cancels a college's older duty under Title II. When a student needs excepted content to use a service, the college must still give that student effective access, such as an accessible version, on request. And a 2019 form still in use is not archived; it is live.
  • Two narrow provisions exist and are worth knowing rather than relying on: 28 CFR 35.204 (fundamental alteration or undue financial and administrative burden, a determination the head of the entity must make in writing) and 35.205 (minimal impact). Neither is a general escape.

Part four

The curriculum

One core module for everyone, then one short module per role

Core module: the afternoon test, run live

Everyone who publishes anything. Ninety minutes. The group runs the eight questions on their own college's site, in the room, and writes down what they find. Nothing is abstract: the scanned PDF on the screen is one they recognize, the broken link is on a page someone present owns. The module ends with each person naming one item they will fix by Friday and one habit they will change.

On the size of this. Core plus one role module is about three hours per person. Required awareness courses elsewhere take under an hour, and foundational programs run roughly five to twenty hours, so treat this as an entry tier that changes what people do on Monday, not as a certification. It is deliberately short because a program people finish beats a program people are enrolled in.

Learning outcomes: recognize the five failure types on sight (placement, untagged document, unfillable form, dead link, missing alt text); know the one page that holds every timeline; know the coordinator's name and the two complaint routes; know which deadline the college has decided it is working to.

Role moduleThe habit that shows up in the findingsWhat they learnWhat they leave with
Leadership and board60 min Assuming the later deadline, and treating accessibility as an IT project rather than an institutional practice. The two dates and the legal question between them. What is live today regardless. The cost arithmetic of fix-once versus fix-annually. What they are accountable for under the rule. A written deadline determination for board adoption, and a one-page accessibility policy naming the standard and the accountable office.
Disability services2 hours Forms built in a word processor or scanned; timelines restated on several pages; the coordinator listed elsewhere. Building a tagged, fillable form from a template and testing it with a screen reader. Maintaining the single timeline page. Writing the standard contact-and-complaints block and placing it. Their own three forms rebuilt and tested; the contact block live on their page; ownership of the timeline page.
Web, communications, marketing2 hours Publishing what they are sent; social posts without descriptions or captions; image-only announcements. Checking a document before it goes up, and sending it back when it fails. Alt text that describes function, not appearance. Captioning video. Declaring page language and heading order. A two-line pre-post checklist pinned to the workflow; a "we will not publish this until" standard agreed with the offices that send them content.
Faculty75 min Syllabi as scanned PDFs; accommodation letters handled in email threads and personal notes; students referred late or not at all. What an accommodation letter obliges them to do and by when. Exporting a syllabus as a tagged document. Recognizing when to refer and how. Where the information lives once it reaches them. One accessible syllabus template they actually use; the referral path in three sentences they can say to a student.
Front-line offices60 min Advising, admissions, registrar, financial aid: the first people a student meets, and the most likely to give a different answer than the office page. The coordinator's name, the single timeline page, the request route. What "effective communication" means at a counter: an interpreter, a printed version, more time. What to say when they do not know. A one-card answer sheet matching the office page word for word, so every door gives the same answer.
IT and procurement75 min Buying platforms on features and price; accepting a vendor's accessibility claim without testing it; renewing without asking. Reading a vendor accessibility report and knowing what it leaves out. Contract language that puts the obligation on the vendor. Testing a login page and a form before signing. Standard accessibility terms for every purchase and renewal, and a test script for the three screens students use most.

The part that outlasts everyone in the room

Training the current staff fixes the current staff. It installs nothing that catches the next hire, which is the exact failure this guide diagnoses, so the program has to end with a rule rather than an event. The workable version is already in use: Texas A&M University-Corpus Christi requires every employee to complete digital accessibility training within 30 days of hire and every year after that, and IT can disable computer access for anyone who does not. Write the same rule into the job description for every role that publishes.

Attach it to what already exists rather than building something new: the onboarding checklist HR already runs, and the annual compliance module the college already requires for other purposes. If it is not in a job description and not in an induction, it is a project, and projects end.

The customized layer. The core module and the role modules are the same at every college; the habits are the same. What changes is the appendix: each department's module ends with the findings from that college's own afternoon test, by office, so a group never fixes a hypothetical. The disability-services office rebuilds its own forms. The communications team reviews its own last thirty posts. The board sees its own deadline question. General best practice teaches the pattern; the appendix makes it theirs.
Sequence by who you can actually convene, not by who matters most. Front-line offices (advising, admissions, registrar, financial aid) usually have standing weekly meetings, so their module can often run this term at no marginal cost by adding an item to a meeting that already happens. Faculty development days are calendared a year out and at many colleges are a bargained item, so faculty training belongs at the next in-service day rather than mid-semester. Do not assume which group sits where: at some colleges counselors and advisors hold ten-month appointments inside the faculty bargaining unit, which puts them on the faculty timetable rather than the staff one. Two questions decide the whole schedule and are worth asking before promising any of it: which bargaining units cover which staff, and does the college have a compensated obligation for required training.

90 days

How a college uses this

Ninety days, fixes first, training second

  • Days 1 to 30
    • Run the afternoon test on your own site. Write down the eight answers.
    • Place the contact-and-complaints block on the disability-services page. One link.
    • Name the single timeline page and point every other page at it.
    • Confirm the compliance date with counsel and put it on the board's agenda as a standard and a duty, not a date.
  • Days 31 to 60
    • Rebuild the three core forms as tagged, fillable documents. Test one with a screen reader.
    • Sweep scanned PDFs and dead links on every student-facing path.
    • Run the core module for the front-line offices, inside meetings that already exist. Fix lists come out of the room.
  • Days 61 to 90
    • Run the remaining role modules, each with its own appendix. Book faculty into the next in-service day rather than mid-semester.
    • Adopt the pre-post checklist and the procurement terms.
    • Re-run the afternoon test. Compare the eight answers to day one.
    • Put the test on the calendar to repeat each semester, with a named owner.
    • Write the training into induction and into the job descriptions that publish.

Measured honestly: a college that does the first thirty days has fixed the items a student is most likely to hit, and will need to do it again. A college that does all ninety and writes the training into induction has changed who fixes them next year, and the year after. That last clause is the whole difference, and it is one line in a job description rather than a budget.

Method and limits. The eight checks come from outside-in reviews of public college websites, run with a browser and no login. This guide reports no sector statistics. Not covered by the test: screen reader, keyboard or magnification behavior; color contrast; anything behind a student login. No institution is named. Rule text is from 28 CFR part 35 subpart H as amended by the Department of Justice interim final rule of April 20, 2026 (91 FR 20902), current as of October 2026; that extension is the subject of a pending federal lawsuit, National Federation of the Blind v. Department of Justice (D. Md.). HHS dates are from its interim final rule of May 11, 2026 (91 FR 25496). The county college classification is from the U.S. Census Bureau's 2022 Census of Governments, Individual State Descriptions. Turnover figures are from CUPA-HR; page-language figures are from the WebAIM Million 2026 report. This guide is not legal advice.