Digital Accessibility - Determining Inventory, Risk, and Priority

Summary

Stepwise models VCCS can ensure that high-risk, high-priority items are addressed first, while also managing workload efficiently across faculty, staff, and administrative units.

Body

Inventory, Risk, & Priority

Before remediation or compliance efforts can succeed, we must first understand what materials exist, who owns them, and which carry the highest risk. An inventory without prioritization can overwhelm; prioritization without an inventory creates blind spots.


The accessibility framework provides a structured approach to:

  • Inventory: Individual responsibility for identifying and cataloguing all materials, systems, and content.
  • Risk: Determining which items could create the most legal, or operational exposure if inaccessible
  • Priority: Sequencing remediation work against compliance deadlines and resource capacity.
  • Disposition: Deciding which materials to remediate, archive, or delete (“offload”).


By applying this stepwise model, VCCS can ensure that high-risk, high-priority items are addressed first, while also managing workload efficiently across faculty, staff, and administrative units.

 

Image of stepwise model of inventory plus risk plus priority equals action plan

 

 

 

 

 

 

Applying the Risk Scoring Model (High/Med/Low) 

The scoring model translates qualitative judgments into consistent, trackable numbers.

Risk Question

Yes

No

Is this public-facing?

+3 (High)

0

Will this impact students?

+3 (High)

0

Will this impact faculty?

+3 (High)

0

Available upon request (FOIA, protest)?

+2 (Medium)

0

Does this impact operations?

+2 (Medium)

0

Could the College appear inactive if challenged?

+2 (Medium)

0

Internal only (staff)?

+2 (Medium)

1

 

Establishing Criteria for Archiving vs Deletion ('offloading')

Remediate

  • Actively used in instruction or operations.
  • Public-facing or student-facing.
  • Required by compliance (e.g., syllabi, catalogue, forms).

Archive

  • Not actively used but must be retained for records (e.g., accreditation evidence, compliance history, faculty senate minutes).
  • Clearly labelled “Archived – Not in Use” and stored in a way that avoids confusion with live content.
  • Accessibility remediation may be deferred, unless specifically requested (e.g., FOIA)

Delete (Offload)

  • Redundant, outdated, or trivial materials.
  • Drafts superseded by newer versions.
  • Content that has no instructional, operational, or compliance value.
  • Must follow College records retention schedules and legal counsel guidance.

 

Graphic of disposition workflow

Details

Details

Article ID: 160297
Created
Mon 2/9/26 12:14 PM
Modified
Tue 2/17/26 10:29 AM

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If you are supporting students, creating online content, or communicating electronically, the finalized DOJ rule requires public colleges and universities to make their digital content accessible to people with disabilities. This rule goes into effect April 24, 2026 and applies to all public institutions, including community colleges. That includes adjunct faculty, full-time faculty, and VCCS staff. This requirement is part of Title II of the ADA and is legally enforceable.