Extension of Compliance Dates for Nondiscrimination on the Basis of Disability; Accessibility of Web Information and Services of State and Local Government Entities

The National School Attorneys Association (NSAA) supports the Department of Justice's decision to extend the compliance deadline for web accessibility requirements for public schools. They argue that school districts face unique operational challenges and urge the Department to distinguish between public-facing content and secured educational content, which should remain governed by existing individualized accommodation frameworks under IDEA and Section 504.

Netsmart Technologies, Inc., a health IT software provider, supports the goal of the rule but argues that the proposed one-year extension is insufficient for complex healthcare systems and requests a two-year extension. They also seek specific guidance on clinical workflow exceptions for reflow requirements and clarification on whether the rule applies to internally-used clinical applications.

The School Superintendents Association (AASA) supports the one-year delay in implementing Web Content Accessibility Guidelines (WCAG) 2.1 AA Standards but urges the Department of Justice to further revise the regulations to exempt password-protected educational content. They argue that the current requirements impose an unrealistic financial and administrative burden on school districts, which already have individualized obligations under IDEA and Section 504 to provide accommodations.

A representative of a public entity supports the Department of Justice's decision to extend the Title II compliance deadlines due to resource and staffing limitations. The commenter requests that the DOJ provide concrete operational playbooks, procurement standards, and clear guidance on legacy content and third-party software to help public entities meet these mandates.

A web developer at a small municipality expresses support for the initiative to establish digital accessibility standards for public entities. While the commenter notes concerns about their specific municipality's overreaction and the lack of guidance for legal counsel, they ultimately advocate for the continued progress of the rule.

The County of San Diego supports the extension of compliance deadlines for the DOJ ADA Title II Web and Mobile App Accessibility Rule. They argue that more time is necessary to manage the significant economic and technical burdens of remediation, secure funding, and leverage evolving technologies like AI-driven accessibility tools.

The commenter is seeking clarification on legal liability and compliance standards for municipal airports regarding third-party mobile applications and web accessibility. They are asking specific questions about responsibility for vendor compliance and the sufficiency of self-auditing for ongoing monitoring.

The Mayor of Nashua, New Hampshire, supports the ADA Final Rule deadline extension but requests further revisions and additional time to address the technical and financial burdens of compliance. The commenter argues that the current requirements for third-party content and complex maps are impractical for mid-sized municipalities and suggests that the Department of Justice provide funding or tools to prevent the removal of public information from websites.

The commenter argues that local governments will be unable to meet the WCAG 2.1 AA requirements because major technology vendors, such as Granicus, do not yet have the necessary technology to support them. They support extending the compliance dates to avoid a wave of lawsuits against government entities caused by these vendor limitations.