Industry Guide · Schools & Education
ADA Compliance for Schools & Education
Public schools sit under Title II; private schools under Title III; both layer with Section 504 and IDEA. Where each applies and how accessibility audits differ for each.
Which title applies to my school?
Public K–12, public colleges, and publicly funded programs: Title II. Private schools, private colleges, and test-prep or tutoring companies: Title III. Religious schools are generally exempt from Title III but still subject to Section 504 if they accept federal funds.
Public schools — Title II
Title II requires program access — that is, the program as a whole must be accessible, not necessarily every facility. A district with two high schools does not have to make every building accessible; it must make the program accessible.
Key obligations:
- Self-evaluation and transition plan. Every public entity was required to produce one. Many are outdated — refreshing them is a common CIAC engagement.
- Effective communication. Sign-language interpreters, CART transcription, accessible materials — the "primary consideration" standard means the student's preferred auxiliary aid is generally used unless it creates an undue burden.
- Physical accessibility of school buildings to the extent needed for program access.
- Digital accessibility of the district website and LMS under the new DOJ Title II rule — WCAG 2.1 AA is the binding standard.
Private schools — Title III
Same physical-accessibility and auxiliary-aid rules as any public accommodation, measured against the 2010 ADA Standards. Plus:
- Learning management systems (Canvas, Schoology, Google Classroom, Moodle). Your LMS is your "course materials" online — it has to meet WCAG 2.1 AA.
- Admissions testing. Title III covers testing entities; modifications to the testing environment are required for disability-related needs.
- Course materials. PDFs, videos, and third-party tools must be accessible or have accessible alternatives.
Section 504 & IDEA — the law stack
- Section 504 of the Rehabilitation Act applies to any school receiving federal funds (most K–12). Similar obligations to Title II.
- IDEA (Individuals with Disabilities Education Act) covers K–12 special education with IEPs. More specific than Section 504 for students with qualifying disabilities.
- Section 1557 of the ACA layers on for school-based health centers.
- State laws add damages on top in several states.
Common violations
- Outdated or missing Title II transition plan
- District website with PDFs that are image-only (not tagged)
- LMS videos without captions
- Parent-portal login forms with unlabeled inputs
- Locker rooms not accessible on field-trip or athletic-event days
- Assembly seating with accessible spots only in the back row
- Classroom doors with pull-force exceeding spec
- School-vendor contracts (e.g. online testing, tutoring SaaS) without WCAG warranty
Cost benchmarks
- CIAC Title II transition-plan refresh (small district): $4,000 – $12,000
- CIAC private-school physical audit: $2,000 – $6,000
- District website + LMS WCAG audit: $5,000 – $20,000
- LMS captioning for existing video library: highly variable; budget $10/minute as a starting estimate