REVISED DATE: 05/06/2026
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Purpose:
To establish procedures for ensuring all documents posted to the Reynolds website comply with the Americans with Disabilities Act (ADA) Title II, Section 504, Section 508, and Web Content Accessibility Guidelines (WCAG) 2.1 Level AA standards.
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Procedure and/or Process Definitions:
Document: A file submitted for posting to the Reynolds website, including but not limited to PDF, Microsoft Word, Microsoft Excel and Microsoft PowerPoint formats.
Document Creator: Individual(s) who produced the original document content.
Document Owner: Department, division, office or individual responsible for a document's accuracy and ongoing maintenance.
Marketing and Communications Web Team: The team responsible for accessibility review and publishing of documents to the Reynolds website.
WCAG 2.1 Level AA: The Web Content Accessibility Guidelines technical standard required under ADA Title II federal regulations.
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Procedures:
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Scope
These procedures apply to all documents submitted for posting to the Reynolds website created by Reynolds Community College employees. All submissions are routed through the Marketing and Communications Web Team regardless of content management system (CMS) access level.
Documents created by external parties may not be hosted on the Reynolds website. Where an external document must be referenced, a link to the original source is preferred. Exceptions apply when federal, state or accreditation requirements mandate direct hosting.
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Submission
All documents intended for the Reynolds website must be submitted to the Marketing and Communications Web Team along with the document creator's contact information, the document owner (if different) and a brief description of the document's purpose and intended audience.
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Accessibility Review
The Marketing and Communications Web Team reviews all submitted documents for WCAG 2.1 Level AA conformance prior to publication using the Document Accessibility Review Checklist and approved accessibility checking tools. Current tools, criteria and review procedures are maintained in the Document Accessibility Guide, which serves as the operational companion to this procedure.
A record of each review is maintained in the college's document accessibility audit log.
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Compliant Documents
Documents that pass accessibility review are published to the Reynolds website. The submitter is notified of publication.
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Noncompliant Documents
Documents that do not pass accessibility review are held and not published. The Marketing and Communications Web Team notifies the document creator or owner of the failure and provides available remediation options. The document may be resubmitted for review after remediation is complete.
Remediation options and current timelines are described in the Document Accessibility Guide.
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Emergency Exception
A document that does not meet WCAG 2.1 Level AA may be published without prior remediation only when a specific federal, state or accreditation requirement mandates publication by a deadline that cannot be met through the standard review process, and when failure to publish creates greater legal liability than the accessibility non-compliance risk.
Exception requests must be submitted to the relevant vice president, who reviews and approves or denies the request. If approved, the vice president notifies the Marketing and Communications Web Team. The document is published with an accessibility disclaimer and sent for remediation. Where remediation cannot be completed immediately, an accessible alternative version may be provided in the interim. A compliant version must be posted as soon as practicable. All exceptions are documented in the audit log.
No other exceptions apply. Documents that do not meet the emergency exception criteria will not be published until compliant, regardless of internal deadlines, departmental preferences or past practices.
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Federal Regulatory Exceptions
Certain document categories are exempt from WCAG 2.1 Level AA requirements under ADA Title II regulations. These exceptions are narrow. The primary categories are:
Archived content: Documents created before the college's compliance date, kept only for reference or recordkeeping, stored in a designated archive section and not modified since archiving.
Preexisting conventional electronic documents: Word, PDF, PowerPoint or spreadsheet files posted before the compliance date, unless the document is currently used to apply for, access or participate in college services, programs or activities, in which case the exception does not apply.
Even when a federal exception applies, the college must still provide effective communication and reasonable accommodations to individuals with disabilities who request access to excepted content.
Guidance on applying these exceptions is maintained in the Document Accessibility Guide.
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Other Information:
Document Accessibility Guide and Review Checklist
VCCS Training Resources:
First-hand experience: Digital accessibility does matter