Comment on FR Doc # 2026-07663
Melody CarverOpposeIndividual
Summary: An instructional technologist argues that the current accessibility requirements are too technically demanding for instructors to meet consistently, leading some to remove materials entirely. They suggest a tiered approach where instructors meet a baseline of accessibility first and only address more complex requirements (like human-reviewed captions) as specific accommodations are requested.
I work as an instructional technologist and this is my personal opinion. I am supporting instructors creating courses, preparing them for accessibility, and providing trainings. The more departments I meet with the more I realize that the technical level of knowledge required by instructors to meed WCAG in their courses is not at the technical level of web developers to comply with WCAG 2.1 Level AA. Some instructors struggle to get digital materials put online initially. Adding the extra requirement to make them fully accesibile has caused some instructors to say they take materials down. This does not achieve the goal of equal access. My suggestion is to modify instructor requirements to support the availability of materials for all learners at a reasonable expectation, suggesting that in LMS courses, instructors are first required for their pages have tags, alt text, machine captions, and high contrast as a baseline prior to students joining their class. Then as accommodations are provided specifically as a necessity, instructors can take the additional time to add human reviewed video captions, video descriptions, and at that point seek for assistance to get documents to an acceptable accessibility requirement. This relieves partial pressure on the overwhelming parts of WCAG but still requires a starting point. Documents are the biggest hurdle in WCAG and software companies are still continually adding features. Currently, accessibility checks from Microsoft, Google and Adobe PDF produce all different outcomes. Therefore supporting instructors, even as an instructional technologist can still lead to many unanswered questions about self-made documents, slideshows, pictures of the white board, math equations, and more. STEM fields need more document and math support clarity when if comes to Accessibility because solutions from software and AI have not had time to evolve enough to become consistent.
Thank you for your consideration.