Miami University DOJ Settlement: What Every College Must Do Before April 2026

On March 3, 2026, the Department of Justice published a consent decree resolving a 12-year lawsuit against Miami University. It's the first comprehensive DOJ enforcement action targeting higher ed digital infrastructure — and it sets a precedent every college needs to understand before the April 24, 2026 ADA Title II deadline (just 49 days away).

What Happened: 12-Year Lawsuit Finally Resolved

In 2014, the National Federation of the Blind (NFB) sued Miami University (Ohio) for inaccessible digital content. The case dragged through courts for over a decade.

On March 3, 2026, the parties signed a consent decree — essentially a court-enforceable settlement laying out exactly what Miami must do to comply with the ADA. The DOJ published the decree as public guidance for other universities.

Why This Settlement Matters

• •First comprehensive DOJ settlement targeting higher ed digital infrastructure — not just websites, but LMS, third-party tools, course materials, textbooks, and administrative systems
• •Explicit WCAG 2.0 AA requirement — provides clarity that the April 24 Title II rule applies to universities
• •Staffing mandates — requires dedicated accessibility coordinators and cross-departmental committees
• •Training requirements — all faculty, TAs, content publishers, procurement staff must receive role-specific training
• •Precedent for enforcement — DOJ can use this as a template for other universities that fail to comply

What Miami University Must Do: Complete Requirements Breakdown

1. Web Content Accessibility — WCAG 2.0 AA for Everything

The decree requires WCAG 2.0 Level AA conformance for:

• ✓All university websites (admissions, course registration, student portals, faculty sites, departmental sites)
• ✓Third-party platforms (learning management systems, registration systems, student information systems)
• ✓Mobile apps (official university apps must meet WCAG 2.0 AA adapted for mobile)
• ✓Digital course materials (syllabi, assignments, lecture slides, readings, assessments)
• ✓Multimedia content (videos must have captions and audio descriptions; audio-only content must have transcripts)
• ✓PDFs and documents (all documents must be tagged, structured, and screen-reader accessible)

Timeline: Most web content must be compliant within 6 months. Complex third-party systems get 12-18 months depending on remediation complexity.

2. Canvas LMS Migration and Third-Party Tool Requirements

Miami University must:

• 1.Migrate all course content to Canvas LMS within 6 months (Canvas is pre-approved as accessible)
• 2.Ensure all Canvas content meets WCAG 2.0 AA within 12 months (migration doesn't automatically mean accessible content)
• 3.Audit all third-party integrations (Turnitin, Respondus LockDown Browser, Zoom, Kaltura, etc.) and require VPAT documentation proving WCAG conformance
• 4.Discontinue or remediate non-compliant tools — if a vendor can't provide accessibility, the university must find an alternative

This is massive for universities that rely on dozens of third-party tools. Each integration needs to be vetted, and vendors must provide accessibility documentation (VPATs or ACRs).

3. Staffing Requirements: Three Mandatory Roles

The decree mandates three dedicated positions:

4. Training Requirements for Faculty, Staff, and Procurement

The decree requires role-specific training for:

• 👨‍🏫All faculty and teaching assistants — must complete training before creating digital course content (covering accessible document creation, video captioning, alternative text, Canvas accessibility features)
• 🖥️Web content publishers (communications, marketing, departmental web editors) — HTML accessibility, WCAG basics, testing with screen readers
• 🛒Procurement staff — must require VPAT/ACR documentation from vendors before purchasing software or platforms
• ⚙️IT personnel — developers and sysadmins managing university platforms must understand WCAG 2.0 AA requirements

Timeline: Initial training must be completed within 6 months. Ongoing annual refresher training required. New hires must complete training within 90 days of start date.

5. Textbook and Course Material Accessibility

One of the most challenging requirements:

• •All required textbooks and course materials must be available in accessible formats (e.g., EPUB with proper structure, PDFs tagged for screen readers, Braille when requested)
• •Faculty must select accessible textbooks when available — bookstore must provide accessibility information at time of selection
• •If accessible versions don't exist, the university must remediate materials (OCR scanned pages, add alt text, structure headings, etc.)

This overlaps with the $20 million PDF remediation crisis at Ohio State University — large universities have tens of thousands of legacy documents that require manual remediation.

6. Monitoring, Reporting, and Enforcement

Miami University must:

• 1.Conduct quarterly accessibility audits of web content, LMS, and third-party tools
• 2.Submit biannual compliance reports to the DOJ showing progress toward WCAG 2.0 AA conformance
• 3.Maintain a public accessibility statement listing known issues, remediation timelines, and contact information for accessibility requests
• 4.Establish a complaint process for students and faculty to report accessibility barriers (with mandatory response timelines)

Timeline Analysis: How Long Does Miami Have?

Miami has 6 months to complete most major milestones — and that clock started on March 3, 2026. Other universities facing the April 24 ADA Title II deadline have even less time.

Cost Implications: What Will This Cost Your University?

Based on Ohio State University's $20 million PDF remediation budget and NASCIO state government data, here's a realistic cost breakdown:

Staffing Costs (Annual, Ongoing)

• •Accessible Technology Coordinator: $80,000-$120,000/year
• •Web Accessibility Coordinator: $65,000-$95,000/year
• •Committee consulting/support: $20,000-$50,000/year
• •Total staffing: $165,000-$265,000/year

Remediation Costs (One-Time)

• •Web content audit and remediation: $200,000-$1,000,000 (depending on site complexity and number of pages)
• •PDF remediation: $25-$500 per document (Ohio State: $12-20M for tens of thousands of documents)
• •Video captioning backlog: $1-$10 per minute (thousands of hours of legacy video content)
• •LMS migration and integration remediation: $200,000-$1,000,000+
• •Total remediation: $12,000,000-$20,000,000+ (large universities)

Training Costs (Annual)

• •Faculty training development and delivery: $50,000-$150,000/year
• •Staff training (procurement, IT, web editors): $20,000-$50,000/year
• •External training subscriptions (Deque University, WebAIM, etc.): $10,000-$30,000/year
• •Total training: $80,000-$230,000/year

Tooling and Software (Annual)

• •Automated testing tools (axe DevTools, WAVE, Lighthouse): $5,000-$20,000/year
• •PDF remediation software (CommonLook, Adobe Acrobat Pro licenses): $10,000-$50,000/year
• •Captioning services (3Play Media, Rev, Verbit): $20,000-$100,000/year
• •Continuous monitoring platforms (Siteimprove, Level Access, AudioEye): $30,000-$150,000/year
• •Total tooling: $65,000-$320,000/year

How This Connects to the ADA Title II Rule (April 24, 2026)

The Miami University consent decree is essentially a preview of DOJ enforcement under the ADA Title II rule, which becomes mandatory on April 24, 2026 (49 days away).

Key Parallels

• ✓Same accessibility standard: WCAG 2.0 Level AA (the Title II rule references WCAG 2.0 AA as the technical standard)
• ✓Same enforcement authority: DOJ can investigate complaints, require remediation, and pursue legal action
• ✓Same scope: All web content, mobile apps, and third-party platforms operated by public entities (including universities)
• ✓Same staffing expectations: Title II doesn't explicitly mandate coordinators, but the consent decree shows what DOJ expects universities to have in place

If your public university hasn't started preparing for April 24, the Miami University settlement shows exactly what "compliance" looks like — and how much work is involved.

Does This Apply to Private Colleges?

The ADA Title II rule applies only to state and local government entities — meaning public universities, community colleges, and state university systems.

Private colleges fall under ADA Title III, which currently has no explicit WCAG standard. However:

• •Private institutions that receive federal funding (nearly all do via student loans/grants) are covered by Section 504 of the Rehabilitation Act, which requires "comparable accessibility"
• •DOJ Title III settlements increasingly reference WCAG 2.1 AA as the expected standard (even though it's not codified)
• •Private colleges face lawsuits too — Harvard, MIT, Stanford, and dozens of others have been sued under Title III

Bottom line: Private colleges should follow the same WCAG 2.0/2.1 AA standard. The Miami University settlement provides a roadmap even for institutions not directly covered by Title II.

What Happens If a University Doesn't Comply?

Consequences for non-compliance include:

• 1.DOJ enforcement actions — investigations, consent decrees, court-ordered remediation (like Miami University)
• 2.Federal funding termination — under Section 504, OCR can revoke federal funding for non-compliance (though this is rare, it's a powerful threat)
• 3.Civil lawsuits from students — disabled students can sue for injunctive relief and attorney's fees under the ADA
• 4.OCR complaints and investigations — Office for Civil Rights handles Section 504 complaints and can mandate corrective action
• 5.Accreditation risk — regional accreditors increasingly include accessibility as a compliance standard
• 6.Reputational damage — public lawsuits, media coverage, and student advocacy can harm enrollment and donor relationships

Compliance Roadmap: What Your University Should Do Before April 24

With 49 days until the April 24 ADA Title II deadline, here's a triage plan based on the Miami University requirements:

Week 1-2: Immediate Actions (March 2026)

• 1.Audit current accessibility status — run automated scans (axe DevTools, WAVE, Lighthouse) on key pages (homepage, admissions, registration, student portal)
• 2.Identify critical gaps — prioritize high-traffic pages and student-facing systems
• 3.Begin hiring process for Accessible Technology Coordinator (this takes 60-90 days minimum)
• 4.Draft accessibility policy and publish interim accessibility statement acknowledging known issues and commitment to remediation

Month 1-3: Foundation Building (April-June 2026)

• 5.Hire accessibility staff — Accessible Technology Coordinator and Web Accessibility Coordinator (consider interim consultants while hiring)
• 6.Form Digital Accessibility Committee with cross-departmental representation
• 7.Begin faculty training — at minimum, provide accessible document creation guides and Canvas accessibility resources
• 8.Audit third-party tools — request VPATs from all LMS integrations, student information systems, and critical platforms
• 9.Fix highest-impact issues — focus on course registration, student portals, and admissions (areas with immediate student impact)

Month 4-12: Systematic Remediation (July 2026-March 2027)

• 10.Complete comprehensive web audit — all university websites, departmental sites, and faculty pages
• 11.Remediate or replace non-compliant third-party tools — discontinue tools that can't meet WCAG standards
• 12.Implement continuous monitoring — set up automated scanning and manual testing schedules
• 13.Begin PDF and video remediation — prioritize current semester materials, then work backward through archives
• 14.Establish procurement requirements — all new software purchases must include VPAT review and accessibility clause in contracts

Related Compliance Resources

• •Universities Are Scrambling: The $20 Million Accessibility Crisis Before April 2026 — Ohio State's PDF remediation budget breakdown
• •ADA Title II April 2026 Deadline Countdown — comprehensive compliance guide for public entities
• •State Government ADA Compliance: NASCIO Report Key Takeaways — state agency compliance data and challenges
• •Section 508 Compliance: The Complete Guide for 2026 — federal accessibility requirements for institutions receiving federal funding
• •VPAT Guide: How to Create an Accessibility Conformance Report 2026 — vendor documentation requirements
• •PDF Accessibility: How to Make ADA-Compliant PDFs (2026 Guide) — complete PDF remediation process and cost breakdown
• •Best Accessibility Testing Tools Compared (2026) — automated and manual testing tool reviews
• •IAAP Accessibility Certification Guide 2026: CPACC, WAS & CPWA Compared — professional certification for accessibility coordinators
• •Free Website Accessibility Checker — scan your university homepage or student portal in 60 seconds

Final Thoughts: This Is Just the Beginning

The Miami University consent decree is precedent-setting — but it won't be the last. DOJ has hundreds of open ADA investigations into public universities, and the April 24 Title II deadline will likely trigger a wave of enforcement actions.

Universities that wait until the last minute will face the same fate as Miami: multi-year lawsuits, court-ordered remediation, and millions in compliance costs.

The good news? You still have time — 49 days until April 24 — to start building the foundation. Hire the right people, audit your systems, train your faculty, and start fixing the highest-impact issues. The Miami settlement shows exactly what DOJ expects. Now it's up to you to deliver.