What an OCR Resolution Agreement Requires for Your Website

Where these agreements come from

When the U.S. Department of Education's Office for Civil Rights investigates a website accessibility complaint, many cases end in a voluntary resolution agreement: the district commits to specific steps, and OCR monitors until they are done. Many of these agreements are published afterward, which is why their shape is well known. They have been signed by school districts, charter schools, colleges and universities. If a complaint has just arrived, start with our guide to what happens after an OCR complaint.

The commitments they have in common

1. A written policy for making new, added and changed content accessible, commonly including content from vendors and other outside sources.
2. An audit of existing online content and functionality by someone with real knowledge and experience in web accessibility, reaching past the home page to subordinate pages and outside content.
3. A corrective action plan that schedules the fixes the audit calls for, with completion commonly set 18 to 24 months after OCR approves the plan.
4. A public accessibility notice, typically a link from the home page explaining how to report inaccessible content, tied to a grievance procedure.
5. Staff training for the people who create content, run the website and buy technology, often starting within 30 to 60 days and repeating every year, with records of who attended and what was covered.
6. Regular reports to OCR, on a schedule such as every six months, until OCR closes its monitoring.

Some agreements also call for input from people with disabilities during the audit. The specifics, from deadlines to reporting frequency, vary from one agreement to the next.

Which standard applies?

Older agreements commonly named WCAG 2.0 AA. The Department of Justice's Title II rule now sets WCAG 2.1 AA as the standard for state and local government web content, so it is reasonable to plan around 2.1 AA. Your counsel will know what your agreement actually says. Our deadline guide covers the rule itself.

What tends to trip districts up

• The site keeps changing. The audit is a snapshot, but the policy covers everything posted afterward. New flyers and PDFs keep arriving while the old ones are being fixed.
• Outside content. Calendars, athletics schedules, forms and board platforms built by other companies are commonly in scope.
• Documents. Years of PDFs are often the largest single pile of work. See which old PDFs have to be accessible.
• Paperwork. Training records and progress reports are due on dates, and they need evidence behind them: what was found, what was fixed, and when.

The same list works as a readiness checklist

You do not need a complaint to adopt these practices. A district that already has a web accessibility policy, a named person responsible for it, a current audit, a schedule for fixes, an accessibility page with a way to report problems, trained content staff, and a dated record of what it has fixed is in a much better position if a complaint ever arrives.

Where a scan fits, and where it does not

An automated scan does not resolve a complaint, does not satisfy an agreement by itself, and is not a legal defense. Agreements typically expect review by someone with accessibility expertise, and whether any tool meets a particular agreement's audit requirement is a question for OCR and your counsel. What ongoing scanning does well is the evidence side: a dated record of what was found and when it was fixed, and an early warning when new content breaks something, which is exactly what progress reports ask for.