1. Purpose

Ensure a clear process for instructors and academic units to request exceptions to the UW Minimum Digital Accessibility Technical Standard, that:

• Aligns with ADA rule exceptions
• Sets clear expectations and timelines
• Includes appropriate documentation

2. Scope   

This procedure applies to digital course content acquired, developed, distributed, used, purchased, or implemented by or for the University and used to provide University services, programs, or activities regardless of the source of funding.

3. References

• UW APS 9.0 Digital Accessibility
• DOJ Final Rule on Web Accessibility under Title II (2024)
• WaTech USER-01 Digital Accessibility Policy

4. Definitions

Web Content

Web content means the information and sensory experience to be communicated to the user by means of a user agent, including code or markup that defines the content's structure, presentation, and interactions. Examples of web content include text, images, sounds, videos, controls, animations, and conventional electronic documents. (ADA Title II Rule)

Web content may be published on a variety of platforms such as websites, learning management systems, or other applications.

Conventional electronic documents

Conventional electronic documents means web content or content in mobile apps that is in the following electronic file formats: portable document formats (“PDF”), word processor file formats, presentation file formats, and spreadsheet file formats. (Department of Justice’s regulations 28 CFR Part 35)

Digital Course Content

Digital course content is web content, including conventional electronic documents accessed through online platforms, that is used for instructional purposes in courses offered to students by the university.

Provisional Approval

Provisional approval means a product which does not fully meet the Minimum Digital Accessibility Technical Standards is approved for use within defined requirements. Provisional approval must include an expiration date, by which time the product must either be submitted for a new scope and risk review or stop being used.

5. Roles and Responsibilities;

Role	Responsibility
Instructor or Delegate	Submits exception request that includes all the required information using the digital course content accessibility exception request form. Works collaboratively with Civil Rights Compliance Office, Review Panel, Vice Provost and other exception process partners to ensure a smooth and effective process. E.g., provide timely feedback on questions. If granted provisional approval, ensures that the digital course content meets provisional requirements.
Civil Rights Compliance Office (CRC)	Provides scope and risk assessment findings. Determines if low-risk digital course content qualifies to be used with provisional approval. Determines provisional requirements and expiration dates for low-risk digital course content with provisional approval. Escalates medium and high-risk digital course content for review by subject-matter experts and/or a Review Panel. Tracks outcomes of all exception requests and re-engages with instructor/delegates when provisional approvals expire.
Subject-matter Experts (a sub-set of the Review Panel comprised of faculty and staff with extensive accessibility expertise)	Review medium- and high-risk digital course content requests. Determine if there is a known solution. If so, recommend actions to make digital course content accessible in lieu of provisional approval. If not, escalate the request to the Review Panel.
Digital Course Content Accessibility Exception Review Panel (Review Panel)	Determines if medium- or high-risk digital course content qualifies to be used with provisional approval. Determines provisional requirements and expiration dates for medium- or high-risk digital course content with provisional approval. Recommends whether to approve or deny a request to the Vice Provost.
Vice Provost	Approves or rejects the Review Panel’s recommendations. Determines whether to elicit additional input from the Provost before making a final determination.

6. Procedure Steps 

A. Initiation  

1. Instructor/Delegate submits a Digital Course Content Accessibility Exceptions Process request via a UW Connect web form to CRC.

B. Scope and Risk Assessment 

1. CRC evaluates the request for scope and risk and either replies to the Instructors/Delegate or escalates to the Review Panel.
   • If digital course content is considered low risk, CRC grants the Instructor/Delegate provisional approval to continue to use the course content without further review.
   • If digital course content is medium- or high-risk, CRC will forward the request to Subject-matter Experts for further review.

C. Subject-matter Expert Review

1. The Subject-matter Experts evaluate the exception requests escalated to them by CRC.

• • If there is a clear solution that would make the inaccessible digital course content accessible, the Subject-matter Experts recommend actions the Instructor or Delegate should take to make the digital course content accessible.
  • If there is no clear solution that would make the inaccessible digital course content accessible, the Subject-matter Experts forward the request to the Review Panel.
  • Review Panel evaluates the request and makes a recommendation to the Vice Provost as to whether to deny the request or grant provisional approval.

D. Exceptions

1. Vice Provost grants provisional approval or rejects the request.

• • If approved, the Instructor or Delegate may continue to use the digital course content during the timeframe granted for their provisional approval. The Instructor or Delegate will still need to respond to accommodation requests as per usual, including those related to the course content for which they have an exception.
  • If an exception is not approved, the digital course content may not be used.

E. Documentation

1. Vice Provost informs the Instructor or Delegate of the decision related to their request.
2. CRC confirms documentation of decisions, outcomes, and expiration dates.

7. Compliance and Enforcement

• Digital course content granted provisional approval must have an expiration date to prompt a reassessment of whether circumstances have changed and the content is able to reach compliance.
• Digital course content that is not granted provisional approval cannot be used to deliver UW programs or services.
• Digital course content that is not granted provisional approval may be resubmitted if the circumstances have substantially changed.&

8. Revision History

Version	Date	Author	Description
1.0	6/10/2026	Marisa Nickel and Marcus Hirsch	Initial release

Related Policies

• APS 9.0 Digital Accessibility  

Related Standard

• UW Minimum Digital Accessibility Technical Standard  

Related Procedures

• Procedure for Digital Product Accessibility Reviews 
• Exceptions to the Minimum Digital Accessibility Technical Standard for Web Applications and Mobile Apps