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Building a Sustainable A11y Program

1. Executive Summary: The Peer-Validated Solution

To move from our current "Launch" stage to the "Optimize" stage in the FY 24/25 Accessibility Maturity measurement, we must evolve beyond our "team of one." This is not just an internal opinion; new benchmarking data from peer institutions shows our current staffing is a critical outlier.

Our peers (Tulane, Georgetown, Princeton) have funded central Digital Accessibility teams of 2–3+ professionals, separate from their larger (7–8+) Disability Services offices. Rice has one.

The "Optimize" stage of the AMM can be achieved when the central accessibility office (the "Hub") enables the entire university to share responsibility (the "Spokes"). This is a proven model used by peers: Princeton's 3-person Hub has successfully trained and certified 100+ staff across campus.

This page outlines the peer-validated, "Hub-and-Spoke" model, starting with the minimal investment our peers have already made: funding and constructing a central "Hub" (Director, Specialist, Technologist).

2. Benchmarking: Our "Team of One" vs. Peer Institutions

The benchmark data comparing accessibility staffing and placement in peer organizations clearly shows that Rice is behind in our level of support.

Institution Accessibility Staff Disability Staff Total Staff
Rice 1 3 4
Tulane 2 7 9
Georgetown 2 8 10
Wash U 1* ( + staff in PubAffairs ) 8 9+
Princeton 3 7 10
Stanford 4 24 28
Harvard 14 9 23

Key Findings from Peer Data:

  • We Are an Outlier: Our "team of one" for digital accessibility is far below the peer standard of 2–3+ staff.
  • Our Proposal is Reasonable: Our plan to create a 3-person "Hub" (Director, Specialist, Technologist) is not an over-reach. It is the minimum standard set by peers like Princeton.
  • Housing the Hub: While housing varies, peers like Wash U and Harvard have accessibility staff embedded directly in OIT, validating our "Hub" placement. Others have the hub reporting through compliance and equity offices.

3. The "Hub": Central Accessibility Program Office (APO)

The centralized office houses roles that require deep technical knowledge, skills, and abilities, as well as strategic governance of the digital accessibility program. Reporting structure of the APO of peer programs are seen under the Provost, Compliance, Institutional Access and IT.

This is an example of the core positions that could make up the centralized team.

Director

Compliance & Service Management

  • 851 Policy monitoring & a11y program maturity
  • Communication, marketing, engagement planning
  • Team leadership
  • Develops and manages university accessibility training and champions programs
  • Leads the university-wide Accessibility Steering Committee
  • Builds connections & support among internal stakeholders driving campus accessibility

Web Accessibility Specialist

Expert-Level Technical Web Auditing & Remediation

  • Manual and functional testing of websites & applications
  • Assistive technologies (screen readers, text-to-speech, etc.)
  • Accessibility evaluation tools and frameworks
  • WCAG & WAI-ARIA application & code remediation
  • Training users to build, update & remediate web content

Universal Design Technologist

Pedagogical & Academic Expertise

  • Universal Design for Learning (UDL)
  • WCAG application to course creation
  • Accessible documents & media techniques
  • Assistive technologies for students with disabilities
  • Academic software (Canvas, Ally)
  • Accessible course content design
  • Trains & educates faculty & staff

Digital Accessibility Specialist

Focus on ICT testing & purchasing

  • Vendor communication & assessment of conformance
  • Supporting RFPs & RFIs, accessibility contract language
  • Manual and functional testing of ICT
  • Accessibility evaluation tools and frameworks
  • Investigation & resolution of reported barriers
  • Trains & educates faculty & staff

4. The "Spokes": Distributed KSAs Across the University

This is the key to reaching the "Optimize" stage. We must embed the following knowledge, skills and abilities into daily operations of these specific departments, just as our peers have done.

A. Executive Leadership (President, Provost, VPs)

  • Strategic Sponsorship: Champion accessibility as a core institutional value (the "Executive Statement" gap).
  • Resource Allocation: Fund the "Hub" and enforce accountability for the "Spokes."
  • Support Accessibility Champions: Provide executive level support, funding and incentives for employees to complete a11y training & certification.

B. Procurement & Finance

  • Accessible Sourcing: Include accessibility requirements in all RFPs and contracts.
  • Vendor Negotiation: Hold vendors accountable and halt non-compliant purchases.
  • Tier 1 A11y Evaluation: Gather and assess vendor accessibility data (VPATs, ACRs).

C. Human Resources

  • Inclusive Job Design: Write accessibility responsibilities into relevant JDs.
  • Inclusive Recruiting: Actively recruit and retain employees with disabilities.
  • Employee ADA Accommodations: Manage inclusive, interactive accommodation processes.
  • Require a11y training: specific training by role and function across departments for employees, establish goals and norms for peformance, encourage professional development in accessibility.

D. Technical Units (Public Affairs, Departmental IT & Web Developers)

  • UX/UI Designers: Design for accessibility before development begins, enforcing brand standards.
  • Developers: Write accessible code from the start; include accessibility as a release gate.
  • Communications: Create accessible templates for use across University, ensure comms & marketing staff follow a11y best practices.

E. Academic & Faculty Leadership (Provost, Deans, SDRC, CTE)

  • Curriculum Leadership: Require Universal Design for Learning (UDL).
  • Faculty Development: Partner with the hub to train/support accessible course design and accommodation understanding.
  • Require a11y training: specific training by role and function across departments, establish goals and norms for peformance.

F. Compliance & Ethics, Access (CCO, ADA Coordinator, AVP Access Excellence)

  • Compliance Oversight: Monitor ADA & Section 504 adherence.
  • Inclusive Culture: Foster beliefs/behaviors that create a culture of care and inclusion.

5. Recommended Housing: The Peer-Validated "Hub-and-Spoke" Model

This "Hub-and-Spoke" model is not theoretical; it is a best practice validated by our peer benchmark data.

The HUB

The Accessibility Program Office (APO)

Function: Governance, policy, university-wide strategy and compliance, high-risk procurement audits, vendor management, and "train-the-trainer" programs. They are the expert consultants.

Peer Validation:

  • This mirrors Princeton's model, which has a central "Hub" of 3 accessibility staff.

The SPOKES (Housed in Departments)

A distributed network of "Accessibility Liaisons or Champions" across campus.

Function: Existing staff in key units (Public Affairs, HR, Procurement, CTE) trained by the "Hub" and designated as their unit's accessibility point-person. They are the first line of defense.

Peer Validation:

  • Goal achieved by Princeton via its 3-person Hub training/certifying 100+ IAAP staff ("Spokes").
  • Model used by Wash U and Harvard.

This is the only way to scale our program. The central "Hub" provides deep expertise, while the "Spokes" embed the KSAs into every unit—making accessibility a shared, manageable responsibility.

6. Future-Proofing: KSAs from a Mature Peer Hub (Harvard)

Our 3-person "Hub" is the minimum standard, validated by peers like Princeton. Harvard's 14-person Digital Accessibility Services (DAS) team shows the KSAs required for a truly "Optimized" state. As we build our program, plan to develop these KSAs currently missing from our 3-person plan:

A. Dedicated Development & Remediation

  • Harvard's KSA: Multiple Digital Accessibility Developers and a Manager for proactive remediation and component building.
  • Rice's Gap: Senior Specialist expected to test, consult, and remediate—creates a bottleneck; dedicate development KSA long-term.

B. Dedicated Procurement & Vendor Management

  • Harvard's KSA: Digital Accessibility Support Analyst with procurement-to-contract expertise.
  • Rice's Gap: Work bundled into Senior Specialist; mature program needs a dedicated procurement KSA.

C. Dedicated Program & Operations Management

  • Harvard's KSA: Led by Senior Director and multiple Managers; deep ops layer to manage team/flow.
  • Rice's Gap: Director covers strategy, governance, and operations—unsustainable as scale grows.

D. Embedded, Full-Time "Spokes"

  • Harvard's KSA: Roles like Digital Accessibility Officer (FAS)—a full-time Spoke embedded in a school/unit.
  • Rice's Gap: Current spoke model relies on partial-role liaisons; mature model dedicates full-time positions in high-need areas.

Digital Accessibility AMM RACI Matrix Example

This RACI matrix outlines the operational roles for key university stakeholders, based on the seven dimensions of the W3C Accessibility Maturity Model (AMM).

This plan is built on a "Hub-and-Spoke" model:

  • The "Hub": Central team is Responsible (R) for executing governance, compliance, training.
  • The "Accountable" (Provost, Compliance): Executive leadership is Accountable (A) for policy, risk, and overall success.
  • The "Spokes" (HR, SDRC, etc.): Distributed units are Accountable (A) and Responsible (R) for their specific domains.
AMM Dimension Office of Compliance ADA Coordinator Student Disability Resource Center (SDRC) HR (Employee Accommodations) Office of Access & Inst. Excellence Provost APO (Accessibility "Hub")
1. Oversight & Culture
(Policy, attitudes, decision-making)
A C C C R A R
2. Personnel
(JDs, recruiting, employee resource groups)
I I I A, R C A C
3. Knowledge & Skills
(Training, education, filling gaps)
I C C C C A A, R
4. ICT Development Life Cycle
(Design, development, testing, ACRs)
I C I I I A A, R
5. Procurement
(Sourcing, negotiation, selection of accessible products)
C C I I I A R
6. Support
(Internal/external accessibility assistance)
I C A, R R I I R
7. Communications
(Accessibility of all internal/external comms)
I C C C R A R

Key / Legend

  • R = Responsible: The person/group doing the work. (e.g., OIT is Responsible for training).
  • A = Accountable: Ultimately answerable for success or failure. (e.g., Provost is Accountable for overall culture; HR for inclusive JDs).
  • C = Consulted: Input required (two-way). (e.g., ADA Coordinator is Consulted on policy).
  • I = Informed: Notified of action (one-way).