NSAA filed public comments to the Department of Justice regarding its decision to extend by one year the compliance dates for the web content and mobile application accessibility requirements adopted in April 2024 (“2024 Rule”). NSAA expressed appreciation for the delay, as the additional time will allow public school districts to devote resources to assessing compliance obligations and improving accessibility rather than immediately diverting educational resources to anticipated litigation and enforcement activity. In response to the Department's indication that it intends to consider future rulemaking regarding the substance of the 2024 Rule, NSAA urged the Department to reconsider how Subpart H applies specifically to public elementary and secondary schools. Unlike most public entities, we said, school districts operate within a comprehensive and longstanding statutory framework that already requires individualized accommodations, modifications, and educational services for students with disabilities. Any future revisions to the Title II web accessibility regulations should recognize these existing obligations and distinguish between public-facing information intended for the general public and educational services delivered to identified students and families through instructional platforms, learning management systems, student information systems, and other secured educational environments.
NSAA urged the Department to: