LEVEL ACCESS - BUSINESS JUSTIFICATION.docx

iTech 118 College Drive #5181 | Hattiesburg, MS 39406-0001 Phone: 601.266. 4357 | david.sliman@usm.edu | www.usm.edu

BACKGROUND

In 2018, The University of Southern Mississippi (USM) received a complaint from the Office of Civil Rights (OCR) advising that the following four domains had inaccessible content posted: usm.edu; southernmiss.com; online.southernmiss.com; and lib.usm.edu (“Subject Domains”). In response to the OCR complaint, stakeholders and vendors from each of the Subject Domains met to resolve the issues identified in the complaint and determined that the University needed to secure a platform for analyzing web accessibility issues.

Over the last 2 years we have been working with Level Access to comply with the Office of Civil Rights (OCR) Resolution Agreement (See Exhibit “A”) requiring that USM address accessibility across each of the primary core domains through the creation of an Accessibility Plan addressing each of the following components:

· maintaining accessibility of the services, programs and activities communicated or facilitated online through: Updating testing and remediation protocols

· Manual testing by certified physically challenged individuals

· Revising procurement protocols and language

· Including training of procurement personnel to review documentation (such as VPAT) aimed at effectively understanding how digital accessibility is evaluated and addressed in vendor selection, purchasing and contracts.

· Ongoing training for

· web developers

· procurement officials, and

· content creators

· Designating areas of responsibility

· Identifying appropriate levels and sources of funding for ongoing efforts.

CURRENT LANDSCAPE

· As USM continues to work with Level Access to refine its long-term accessibility strategy, the focus must expand beyond the initial websites named in the OCR Complaint. This expansion requires accessibility monitoring of all USM sites not yet included in focused testing. Meeting that need requires the expertise and proprietary platform that only Level Access can provide.

· The scope of the challenge

· A preliminary inventory shows USM has more than 100 distinct domains and subdomains in addition to the four core domains (usm.edu, lib.usm.edu, southernmiss.com, and online.usm.edu).

· No USM department oversees accessibility across all domains and subdomains.

· Only the four core domains are monitored, and only on a weekly basis. No single tool currently exists that can determine whether content across all domains and subdomains is accessible.

· Other web properties rely on varying methods. Lighthouse, for example, captures only about 30% of accessibility issues and, as a recent article notes, is helpful but falls short of the level OCR requires [See article].

· Domain administrators assess their sites only sporadically, at most once a semester.

GAPS IN GOVERNANCE AND CONTENT

· USM's digital environment is decentralized, so content owners in each area can publish inaccessible webpages and upload images, audio, video, and documents without understanding the accessibility requirements or the legal impact of posting inaccessible content.

· No standardized testing or remediation protocols confirm that only accessible content is uploaded across all domains.

· USM has made measurable progress on addressing PDF documents with the support of Level Access: it has built an inventory of content needing remediation and reduced the number of PDFs from the initial count of 5,690. However, content owners still need ongoing training and support to convert PDF content into accessible web pages and to remediate critically needed PDFs. Sustained support is essential to preserve this progress and to keep new inaccessible documents from being posted.

· Procedures and standardized language are being developed to ensure that purchased technology is accessible, and training documentation exists, but participation must increase.

· No one person at USM has expertise across all areas of accessibility, including web page accessibility, document remediation, and social media accessibility.

What Is Needed Closing these gaps requires both specialized expertise and the infrastructure to apply it at scale. USM cannot build either internally due to cost as well as skill-level constraints. A significant level of expertise across the areas of web, document, and social media accessibility is needed as is large scale monitoring, testing, and remediation tracking across all institutional assets. Moreover, any such solution must be capable of monitoring all domains and subdomains, moving from sporadic, inconsistent self-assessment to comprehensive, defensible compliance.

New Federal Regulation Changes In April 2024, the U.S. Department of Justice issued a final rule under Title II of the Americans with Disabilities Act (ADA) (ADA.gov summary) requiring state and local government entities, including public institutions of higher education, to make their web content and mobile applications conform to the Web Content Accessibility Guidelines (WCAG), currently version 2.1 Level AA. On April 20, 2026, DOJ extended the compliance deadline for entities serving populations of 50,000 or more to April 26, 2027, while the substantive requirements of the rule remain unchanged, and DOJ stated that it fully anticipates implementing the regulation at the new deadline. Because population is calculated at the state level, this deadline effectively applies to nearly all public universities, including USM. ADA Title IIIUPCEA The rule applies to web pages, online documents, video, audio, social media content, and mobile applications, whether created by USM or by vendors under contract with USM. Limited exceptions apply, including archived content that is not in active use, certain preexisting documents and social media posts, individualized password-protected content, and third-party content not posted as a result of a contractual or other arrangement with USM.

This rule expands USM's obligations well beyond the scope of the OCR Resolution Agreement, which addressed only the four core domains. Meeting these obligations will require a long-term compliance plan and a Unified Digital Accessibility Platform (UDAP) capable of scanning all USM domains and subdomains.

Accessibility across USM's digital environment is currently fragmented. No consistent, institution-wide approach exists, and domain administrators lack the experience, training, and tools needed for comprehensive accessibility analysis. Without these resources, USM cannot ensure compliance by the April 26, 2027 deadline.

UNIQUE NATURE OF LEVEL ACCESS SOLUTIONS

Level Access: A Unified Solution Level Access offers USM a unique combination of its Unified Digital Accessibility Platform (UDAP) and Digital Accessibility Maturity Model (DAMM), delivered by a single provider.

UDAP: Proprietary technology and processes delivered as one integrated solution:

· Oversight and tracking: Governance and monitoring dashboards let USM assess its accessibility status at any time and receive health-score alerts aligned with the DAMM. A centralized tracking log records status and remediation across every digital property. This creates a system of record that USM can use to respond to complaints, report to OCR and leadership, demonstrate good-faith effort, and support long-term funding.

· Manual testing: Certified testers with disabilities evaluate USM sites through user flows, capturing the lived experience of users, and identifying business-critical barriers.

· Automated scanning and testing: Testing spans every stage of the content lifecycle, from design through production, and includes on-demand testing through a proprietary browser extension. Because the license is not seat-based, USM can test as many properties and users as needed.

· Automated remediation and personalization widget: Users can adjust content to their individual needs, and the widget logs every adjustment so developers can correct issues over time. Non-coding administrators can apply on-demand code fixes for most web issues with the push of a button, and more complex fixes escalate to Level Access.

· Granular Accessibility Tracking Log: Creates a centralized record of accessibility status and remediation across every digital property, allowing USM to monitor adherence to the ADA and measure progress toward digital accessibility maturity.

· Generates data reports for OCR and USM leadership as needed, demonstrating good-faith effort and supporting long-term institutional funding.

· 24/7 Monitoring and Notifications: Sends alerts when health scores drop, based on thresholds USM sets and aligned with the DAMM.

· Continuously tracks critical issues, trends, and progress over time, and prioritizes key pages so teams can focus on the issues with the greatest impact on user experience.

· Training: Role-specific online training is available 24/7 with knowledge testing, supplemented by two live sessions to raise institutional awareness and prepare future content administrators.

· Support: Unlimited live and email consultation is available for issues from basic to complex.

· Security: Level Access holds SOC 2 Type II, FedRAMP, and ISO 27001 designations, and is the only accessibility provider to hold all three. This matters given the security risks facing higher education.

DAMM: A recognized, cross-industry framework that benchmarks USM's program across five levels, from initial to optimized. Each level defines proven actions for advancing accessibility, and Level Access provides consultative support at every stage to build a strong, resilient program. Level Access has deployed the DAMM for 25 years across many sectors, with depth in higher education.

Unique Company Experience Founded in 1999 by early innovators in digital accessibility, Level Access has helped shape the field since its beginnings, including through work that laid the groundwork for the WCAG standards. It has since taken part in accessibility governance and policymaking efforts and has guided institutions across higher education, such as the University of Cincinnati, as well as professional and healthcare organizations, including the American Counseling Association and Counselors for Social Justice. Its growth through acquisition has added to that depth of experience. Today, Level Access is the largest provider of unified digital accessibility platforms in the world, supported by a team with more than fifty years of combined experience.

LEVEL ACCESS UDAP AND DAMM COST

The chart below illustrates the cost of purchasing services from Level Access for a two-year period Within this two-year period, USM will continue to address the requirements of the OCR Resolution Agreement. The second phase will involve bringing all USM digital content up to the WCAG standards by April 2027 as required by the Americans with Disabilities Act.

CONCLUSION

To meet its obligations under the Resolution Agreement and the ADA Title II regulation taking effect April 26, 2027, USM must make accessibility a priority across all domains and subdomains. That means ensuring that only accessible content is posted going forward while also remediating content posted since July 2024. Doing so requires three things: visibility across all domains, a strategic implementation plan, and in-depth WCAG expertise to guide USM toward compliance.

USM currently has no solution that provides visibility across all domains and subdomains, and without it, comprehensive and consistent accessibility is impossible. Level Access provides a platform that offers the granular insight USM needs to address existing content, prepare future content, and track all remediation through auditable records.

Sustaining accessible content also requires two kinds of knowledge: general and role-specific resources for everyone who works with digital content, and experience implementing accessibility standards in higher education. A culture of accessibility depends on both, along with on-demand support when content owners need help.

Building an accessibility culture at USM requires experience in developing accessibility-focused processes and procedures, including holding content owners responsible for posting accessible content. It also requires safeguards that systematically reinforce accessibility, grounded in deep knowledge of accessibility principles, and experience applying them in higher education. USM does not currently have this experience in-house, nor does it have the expertise to develop effective policies and procedures or to implement them within its decentralized environment.

Level Access is uniquely positioned to fill this gap. Its Unified Digital Accessibility Platform (UDAP) provides general and role-based accessibility training, along with the identification and tracking needed to resolve existing issues and understand ongoing concerns. Its Digital Accessibility Maturity Model (DAMM) is a proven framework for benchmarking an organization's progress and guiding it toward accessibility maturity. Level Access also brings a highly experienced team, with a track record of using the DAMM to lead institutions across many sectors toward accessibility maturity.

Submitted Respectfully for review by: 

Chief Information Officer (CIO) 2 | Page BUSINESS CASE FOR PURCHASING LEVEL ACCESS UDAP AND DAMM

TO ADDRESS INSTITUTIONAL ACCESSIBILITY

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