Comment on FR Doc # 2026-07663

Docket No. DOJ-CRT-2026-0067 (RIN 1190-AA82) I am a Director of Disability Services at a public institution of higher education in Pennsylvania. I work directly with students with disabilities and support institutional accessibility implementation. I appreciate the opportunity to comment on the Interim Final Rule extending ADA Title II web accessibility compliance deadlines. The Department’s recognition of implementation challenges, particularly staffing, legacy content, and limits of automated remediation is consistent with what I observe in practice. The extension may provide needed flexibility for institutions. However, the rule places significant emphasis on institutional burden without equally centering the ongoing impact on individuals with disabilities. In higher education, inaccessible digital content directly affects students’ ability to participate in courses, complete assignments, and access essential services. Students are often required to request individual accommodations for content that could be proactively accessible, resulting in delays and inequitable access. While the extension may reduce short-term pressure, it risks reinforcing a reactive approach to accessibility rather than advancing systemic compliance. The Department suggests that additional time will lead to better outcomes; however, this is not guaranteed without clear expectations for progress. To better balance feasibility and access, I recommend: Establish interim expectations for progress during the extension period to prevent delays in implementation. Prioritize high-impact systems, including learning management systems, course materials, and core student-facing platforms (e.g., registration and financial aid). Expand practical guidance to help institutions translate WCAG standards into operational practice, particularly for large-scale content remediation and vendor accountability. Reinforce that ADA obligations remain in effect, including the requirement to provide equally effective communication, regardless of extended deadlines. Consider the impact on individuals with disabilities in cost-benefit analysis, including delayed access, increased administrative burden, and potential effects on academic outcomes. The extension reflects legitimate institutional challenges, but it should not unintentionally delay meaningful access. With clearer expectations and prioritization, the extended timeline can support effective implementation rather than postponing progress. Thank you for the opportunity to comment.