The 90-Day Hearing and the Unclaused LMS
A state university's 12,000-student portal runs on a vendor LMS plus 40 departmental WordPress sites. The board adopted WCAG 2.2 AA in policy last year, but the LMS contract, signed in 2019, has no accessibility clause. Disability services reports 14 complaints this term: 9 about PDFs, 3 about the LMS quiz timer, and 2 about missing video captions. The CIO must decide whether to issue a public conformance statement, replace the LMS, or fund a remediation sprint before a legislative hearing in 90 days. There is $150,000 and two developers available.
1. Given the 90-day hearing, $150,000, and two developers, how should the CIO sequence the response? Justify what you would defer.
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Sequence by legal exposure and user impact, not by complaint count alone. Immediate (0–30 days): fix or configure the LMS quiz timer so extra time and pause behavior work; this blocks assessment and creates high legal risk. Provide alternative-format PDFs through a documented request workflow while remediating the highest-traffic documents. For captions, identify the 2 affected videos, caption them, and add a caption requirement to new content. 30–60 days: publish an accessibility statement with scope, known barriers, alternatives, and a feedback contact-not a blanket conformance claim. 60–90 days: prepare hearing evidence: complaint log, remediation dates, testing results, and contract-renewal plan. Defer full LMS replacement: procurement alone exceeds the timeline and budget, and it does not fix current barriers. Use renewal leverage for a remediation clause and accessibility warranty.
2. Should the university publish a conformance statement now? What must be true before publishing?
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Do not publish a blanket “WCAG 2.2 AA compliant” claim. Third-party LMS content, 40 departmental sites, and unresolved complaints make that claim difficult to defend. Publish an accessibility statement instead, stating the scope, standards targeted, known barriers, alternative access routes, feedback mechanism, responsible owner, and dated remediation commitments. Before publishing, require: (1) manual and assistive-technology testing evidence for the scoped properties, not just automated scans; (2) a named owner for each known barrier; (3) a working feedback and escalation process; (4) legal review of the wording. A conformance claim should wait until all applicable success criteria in the stated scope are verified and third-party exceptions are clearly disclosed.
3. What procurement actions can reduce recurrence even though the current LMS clause is missing?
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Treat the missing clause as a current-contract problem and a future-contract opportunity. For the current LMS, negotiate at renewal: accessibility roadmap, remediation service levels, testing rights, and termination or credit remedies. For all new procurements, add mandatory accessibility requirements, require a current accessibility conformance report and evidence, test critical flows before award, and include contract language with remedies. Review departmental WordPress purchases through a central intake so shadow IT cannot bypass requirements. Document vendor claims and verify them, because a vendor self-assessment is not proof. These actions reduce recurrence without pretending the existing contract can be retroactively rewritten.