Digital Accessibility Plan for CU Denver


This digital accessibility plan outlines CU Denver's commitment and ongoing efforts towards ensuring digital accessibility in compliance with Colorado House Bill 21-1110 and the rules established by the Colorado Governor's Office of Information Technology (OIT). This plan demonstrates good faith in progress in removing accessibility barriers. In alignment with CU’s Administrative Policy Statement 6011: Digital Accessibility, which establishes minimum accessibility standards for all university digital content and technology, this plan reinforces the university’s obligation to provide equitable access to digital resources.

Compliance with the Rules

CU Denver aims to be in compliance with technology accessibility rules by:

  1. Providing reasonable accommodations or modifications as stipulated by the Americans with Disabilities Act (ADA).
  2. Maintaining a published accessibility statement.
  3. Demonstrating good faith progress on its plan to remove digital accessibility barriers, as outlined in this document.


Accessibility Standards Applied

CU Denver is committed to adhering to the accessibility technical standards developed by the Governor’s Office of Information Technology (OIT), which include:

  • World Wide Web Consortium (W3C) Web Content Accessibility Guidelines (WCAG) 2.1 Level AA or higher. The Web Subcommittee is actively assessing CU Denver’s compliance with these standards by using automated testing with Siteimprove and by manually testing new code releases.
  • Section 508 of the U.S. Rehabilitation Act of 1973, including Chapters 3, 4, 6.
  • Following C.R.S. 24-85-101 to 24-85-104, ARTICLE 85.


CU Denver’s Efforts

CU Denver embodies a culture of commitment and understanding when it comes to digital accessibility, recognizing that all individuals should be able to access digital content. The university actively promotes inclusivity and accessibility for all members of our community, including current employees and students as well as prospective employees and students. Each department, school, and college is responsible for making their content accessible. CU Denver has a strategic initiative led by the Accessibility Steering Committee (ASC) to ensure comprehensive compliance with Colorado House Bill 21-1110.To that end, CU Denver has a plan to prioritize, evaluate, remediate, and continuously improve every digital touchpoint within our services, programs, and activities. Below, you’ll find some of the measures that the university is undertaking in that plan.


Accessibility Maturity (for 2024)

Accessibility Maturity Stages
StageCriteria
LaunchRecognized need organization-wide. Planning initiated but activities not well organized.

Why are we at this stage?

CU Denver has recognized the need for digital accessibility compliance, particularly with the passage of HB21-1110. Various initiatives and subcommittees have been formed under the Accessibility Steering Committee to address different aspects of accessibility. While planning is underway and activities have begun, a fully integrated and optimized approach is still in development. 


Organizational Measures

CU Denver is undertaking the following organizational measures to remove technology accessibility barriers:

Governance, Roles, and Responsibilities 

  • CU Denver has established an Accessibility Steering Committee (ASC) to lead the strategic initiative for compliance. This aligns with the State of Colorado’s governance criterion, which ensures that IT accessibility is positioned appropriately within the organization, and that accountability is clearly defined.
  • Various subcommittees, such as the Digital Software Compliance Subcommittee, the Procurement Subcommittee, the Report + Response Subcommittee, Web Subcommittee, and the Training Subcommittee have defined roles and responsibilities for specific areas of accessibility. These roles reflect the state’s recommendation to designate point people responsible for maintaining accessibility compliance within their domains, including procurement, development, and training. 

Evaluation and Remediation

  • The Web Subcommittee utilizes Siteimprove to automatically check CU Denver websites for accessibility problems and provides reports to web editors for remediation.
  • Manual accessibility testing is also emphasized for developers when releasing new digital tools.
  • The Digital Software Compliance Subcommittee aims to create a centralized inventory of software applications to facilitate auditing and tracking accessibility compliance.
  • The Report + Response Subcommittee aims to evaluate existing barrier reporting channels and create a process for the resolution of digital accessibility barrier reports.
  • Anthology Ally was procured in 2018 as a tool to assist in identifying digital content that needed remediation. In January 2024, Anthology Ally was installed in all Canvas courses and faculty have access to a course accessibility report which identifies content that needs remediation.
  • Anthology Ally provides a course accessibility report to instructors within Canvas which identifies content that needs remediation and provides just in time training on a variety of digital accessibility issues to improve the course experience for students.
  • Anthology Ally has been implemented in the LMS as a student facing tool for students to self-service alternative formats of content and documents within Canvas.
  • SensusAccess was procured in August 2024 as a pilot tool to assist in remediating PDFs.  A review of the pilot data and funding availability will determine whether or not this product is renewed in August 2025.

Skills and Training

  • The Web and Training Subcommittees recognize the need for regular training for web editors on digital accessibility.
  • The CU Denver Division for Teaching Innovation and Program Strategy (TIPS) offers workshops and events for faculty and staff on digital accessibility.
  • Anthology Ally has been implemented in all courses within Canvas to provide faculty with awareness and support for improving the accessibility of their courses.
  • The Web Subcommittee plans to collaborate with other subcommittees to promote digital accessibility updates and training.
  • Due to our faculty being on 9-month contracts, the Training Subcommittee plans to begin meeting consistently in Fall 2025 to build time for meaningful collaboration and planning. 

Communication and Support Process

  • The Report + Response Subcommittee is actively working on identifying multiple formats for users to report on digital accessibility barriers, such as calling or emailing the OIT helpdesk or submitting an online form.
  • This subcommittee is also developing a process for the resolution of reported digital accessibility barriers, including a centralized tracking system and defined response timelines.
  • The Web Subcommittee is working on creating a user-friendly central webpage for digital accessibility information and resources, including how to report a problem and how to make digital content accessible.
  • State websites need to include the state's accessibility statement and contact information. CU Denver's accessibility webpage aims to fulfill this requirement.

Procurement and Vendor Management

  • The Digital Software Compliance and Procurement Subcommittees are focused on documenting the current IT procurement process to ensure it includes accessibility considerations.
  • CU Denver aims to ensure that the procurement process includes a centralized inventory for all software applications to track accessibility status.
  • The Digital Software Compliance Subcommittee action plan focuses on working with Anschutz Information Strategy and Services (ISS) and Information Security and IT Compliance (ISIC) to test and refine current procurement processes, including centrally collecting and documenting VPATs and accessibility data.

Software Development Lifecycle (SDLC)

  • While not explicitly detailed as a separate initiative yet, the emphasis on incorporating accessibility into software procurement and the focus on training developers on manual accessibility testing are initial steps toward integrating accessibility into the SDLC. The university recognizes the importance of ensuring that IT accessibility requirements are consistently incorporated.

CU Denver will continue to define an accessibility roadmap including timelines, goals, roles, responsibilities, and policies as needed. The university is committed to conducting and maintaining an inventory of technology and then prioritizing, validating through testing, and addressing accessibility issues found. CU Denver aims to create and implement a plan for providing reasonable accommodation and modification until technology can be made accessible. Contact information and support for receiving accessibility feedback, and accommodation requests are being established through the work of the Report + Response Subcommittee. CU Denver will continue to hire people with accessibility skills and train current employees on providing accessible services and technology. The goal is to incorporate accessibility requirements into technology development stages including design, development, user experience, and quality assurance. CU Denver is also working on creating and posting a progress-to-date report that is updated quarterly and demonstrates concrete and specific efforts toward compliance with the OIT rules.  


Appendix A:
Accessibility Standards and Legal References

1. World Wide Web Consortium (W3C)

The World Wide Web Consortium (W3C) is the main international standards organization for the World Wide Web. It develops protocols and guidelines to ensure the long-term growth of the web. W3C is responsible for creating the Web Content Accessibility Guidelines (WCAG), which are widely adopted standards for digital accessibility.

2. Web Content Accessibility Guidelines (WCAG) 2.1

WCAG 2.1 is a set of guidelines developed by W3C to make web content more accessible to people with disabilities, including visual, auditory, physical, speech, cognitive, language, learning, and neurological disabilities.

  • Level AA is the standard most commonly adopted by governments and institutions, including CU Denver and the State of Colorado.
  • WCAG 2.1 builds on WCAG 2.0 and includes additional success criteria to improve accessibility for users with cognitive and mobile accessibility needs.

3. Section 508 of the U.S. Rehabilitation Act of 1973

Section 508 requires federal agencies to make their electronic and information technology accessible to people with disabilities.

  • It includes technical standards for software, websites, multimedia, and hardware.
  • Chapters 3, 4, and 6 of the Section 508 Refresh (2017) are particularly relevant:
    • Chapter 3: Functional Performance Criteria
    • Chapter 4: Hardware
    • Chapter 6: Support Documentation and Services

4. Colorado Revised Statutes (C.R.S.) Sections 24-85-101 through 24-85-104 – Article 85

Article 85, titled "Information Technology Access for Individuals Who Are Blind or Visually Impaired", is part of Colorado’s accessibility legislation.

  • It was strengthened by House Bill 21-1110 and Senate Bill 23-244, which mandate that all state agencies and public entities (including higher education institutions) conform to WCAG 2.1 Level AA or provide reasonable accommodations.
  • The Governor’s Office of Information Technology (OIT) is responsible for rulemaking and enforcement under this statute. 

Publish Date: June 2025

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