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EDUCAUSE has sent out a request that members fill out a DOJ survey seeking conceptual thoughts (not formal notice and comment) on the implementation of standards for web accessibility under the Americans with Disabilities Act.  Such development has been expected for some time. W3C 2.0 AA standards apply under Title I of the ADA, which affects the federal government. The Department of Justice is making its way now through the subsequent Titles which affect higher education, both public and private.

This moment is an opportunity that higher education should not miss. Through EDUCAUSE’s leadership, a special committee should be formed, working with experts, stakeholders, and representative member institutions from different Carnegie class schools to accomplish at least three goals. 

First, EDUCAUSE should create a road map explaining in a clear, step-by-step fashion, a time line of next steps and what to expect from the administrative law process of notice and comment on this matter.  That information should be highlighted as available on its website and/or in electronic copy through relevant list serves (CIO, Policy and Web Access, for example). 

Second, the special committee should begin to formulate positions proactively staking out higher education’s stand on this matter. The fact that web sites must be made accessible is not open to question; case law has already established that point. What is being asked is, essentially, what standards and upon what time line for implementation? Special sessions at EDUCAUSE, online forums, and other means of voicing thoughts and concerns among members and to help inform the special committee should be organized throughout this process. 

Third, at such time that the DOJ does engage in formal notice and comment, our community should be prepared with all of this activity to submit formal comment in the belief that the issue has been comprehensively addressed and consolidated in a comment that represents community interests. 

Opportunities to exercise the quality of leadership that this moment offers for our community do not arise often enough. We have one now and it is for an issue that we can all agree is important to advance. For the sake of our missions and a positive reputation that we can establish globally as well as in the United States, let’s endeavor to do it right. 

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