System Procedure 1B.4.2 Inclusive and Accessible Learning and Work Environments

System Procedures
 Chapter 1B - System Organization and Administration / Equal Education and Employment Opportunity

for Board Policy 1B.4

Part 1. Purpose

  • To define and govern the accessibility compliance process required by each institution to ensure inclusive and accessible learning and work environments.
  • To support colleges and universities in achieving and maintaining institutional and programmatic compliance with state and federal accessibility regulations.

Part 2. Scheduled Accessibility Reviews using Functional Performance Criteria (FPC)

Subpart A. Purpose
Functional Performance Criteria is the practice of periodically evaluating how well digital products or services meet accessibility standards by testing their functionality against the criteria outlined in Section 508 of the Rehabilitation Act of 1973. Functional Performance Criteria involves checking for issues manually, such as keyboard navigation and screen reader compatibility, that automated tools might miss. Functional Performance Criteria details how users with different disabilities should be able to interact with the technology effectively. Performing regular assessments of college and university courses, services, and facilities promote compliance with applicable accessibility requirements and standards, thereby promoting inclusive and accessible learning and work environments for all students and employees, including those with disabilities.

Subpart B. Sampling
Accessibility compliance assessments are conducted and maintained by each institution as approved through the appropriate college or university process. These assessments are based on established accessibility standards and guidelines, such as the Web Content Accessibility Guidelines (WCAG) and the Americans with Disabilities Act (ADA). Areas to be sampled include, but are not limited to, the following:

  • Websites and Content, Online Portals, Social Media and Faculty & Student Portals
  • Course Materials
  • Software & Applications
  • Online Forms, Surveys
  • Library Resources

The following items are exempt and do not have to be sampled:

  1. Archived web content as defined in C.F.R. § 35.104 (2025).
  2. Preexisting conventional electronic documents that are available as part of the college, university, or system office web content or mobile apps before the date the public entity is required to comply with this subpart, unless such documents are currently used to apply for, gain access to, or participate in the public entity's services, programs, or activities.
  3. Content posted by a third party, unless the third party is posting due to contractual, licensing, or other arrangements with the public entity.
  4. Individualized, password-protected or otherwise secured conventional electronic documents. Conventional electronic documents that are:
    1. About a specific individual, their property, or their account; and
    2. Password-protected or otherwise secured.
  5. Preexisting social media posts that were posted before the date the public entity is required to comply with this subpart.

Subpart C. Annual Report
Presidents shall submit an annual report by Oct 1st to the chancellor on the progress made in addressing any outstanding findings or concerns on the current accessibility status of their college or university as identified in the accessibility compliance assessment.

Subpart D. Content
An accessibility compliance assessment must contain the applicable elements of the course or service being evaluated, and may include the subject, course number, course title, course description, credits, lecture hours, lab hours, prerequisites, co-requisites, accessibility standards referenced, assessment findings, recommended improvements, the effective date, revision history, and other elements determined by the college or university.

Subpart E. Uses
For college and university purposes, accessibility compliance assessments are used to ensure equitable access for students, to communicate accessibility status with external parties, to ensure compliance with legal requirements, to communicate the essential accessibility elements of a course or service to faculty and staff, for program and course reviews, and for grant applications. Faculty members use these assessments to develop accessible course materials, communicate accessibility requirements to other faculty members, and for program and course review.

Subpart F. Ownership
Pursuant to Board Policy 3.26 Intellectual Property, accessibility compliance assessments are considered institutional works owned by the colleges and universities.

Subpart G. Record Keeping
Colleges and universities shall enter accessibility compliance assessments into their designated record-keeping systems.

Related Documents:

To view related federal statutes, go to the U.S. Government Publishing Office site. You can conduct a search from this site by typing in the statute number.
  • 28 CFR 35.104 (2025) Definitions

System Procedure History:

Date of Adoption: 01/14/26
Date of Implementation: 01/14/26
Date of Last Review:

Date & Subject of Amendments:


No additional HISTORY

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