Higher education has a long and well-documented habit of doing the first half of hard things very well and quietly abandoning the second half. Strategic plans get written. Committees get formed. Policies get adopted. And then, somewhere between the announcement and the expected change in behavior, nothing much happens.
Digital accessibility is the current, high-stakes version of this pattern — and the April 24, 2026federal deadline for WCAG 2.1 Level AA compliance under ADA Title II has made theconsequences undeniable (U.S. Department of Justice, 2024).
Two Very Different Things
The Accelerating Implementation Methodology (AIM), developed by Don Harrison at Implementation Management Associates through more than four decades of organizational research, draws a foundational distinction that most institutions have never applied to their accessibility work: the difference between installation and implementation (Harrison &Implementation Management Associates, 2024).
Installation is deploying the change — writing the policy, launching the LMS, scheduling the training, announcing the initiative. Installation is measurable, fast, and satisfying. It produces artifacts that look very much like progress.
Implementation is something else entirely. It is the point at which people who were not previously behaving a certain way begin consistently behaving that way. It is slower, harder to see, and almost impossible to manufacture through announcements alone. According to Harrison, it is where the overwhelming majority of organizational change initiatives fail.
The distinction matters acutely in higher education, where governance structures are distributed, faculty have high autonomy, and the people most responsible for creating accessible digital content — instructors — are often the last to know that a policy expecting it from them exists.
The Data Are Not Subtle
Anthology’s 2025 Faculty Survey of 2,508 actively teaching instructors across US colleges and universities found that only 22% consistently consider accessibility when designing course materials, just 11% said they had the right tools and training to do so, and 81% said they needed more information on the ADA Title II requirement — with 36% unaware of it entirely (Anthology, 2025a).
These numbers describe an installation-only outcome. Policies exist at most of these institutions. Compliance offices exist. Training calendars have accessibility workshops on them. The installation work has been done. The implementation work — the part that results in faculty actually changing how they create and share digital content — has not.
Meanwhile, 40% of institutions have just one or two staff members dedicated to technology accessibility (Educause, 2023), and full compliance by all institutions by the April deadline is “just not going to happen,” according to Jonathan Thurston of the Global Initiative for Inclusive Information and Communication Technologies (as cited in Palmer, 2026).
Why the Gap Persists
AIM methodology identifies several structural reasons why installation routinely substitutes for implementation — and each maps directly onto the accessibility challenge in higher education.
- No clear definition of the desired end state.
One of AIM’s first requirements is that organizations define the change with enough specificity that people know exactly what behavior is expected of them. Most institutional accessibility policies fail this test. They state objectives at the level of WCAG compliance without translating that into concrete, role-specific expectations: what does an accessible syllabus look like? What is a faculty member supposed to do with a 10-year-old lecture video? When compliance requirements are vague, people cannot comply — even if they want to.
Jamie Axelrod, director of disability resources at Northern Arizona University, described what this gap looks like in practice: “I’m sure every institution has a math faculty member who likes to handwrite and scan all of the homework that they give to students. That’s going to be a big change and cultural shift” (as cited in EdTech Magazine, 2025). - No active sponsorship.
AIM is unambiguous that change requires sponsors — leaders who visibly and continuously advocate, resource, and reinforce the change, not merely approve it (Harrison & Implementation Management Associates, 2024). In most higher education accessibility initiatives, the sponsor is whoever signed off on the policy. That person has moved on to their next priority. The absence of active, sustained sponsorship is, according to Prosci’s global research cited in higher education change management literature, the single biggest predictor of initiative failure (Collegis Education, 2025). - No reinforcement.
Harrison quantifies a critical asymmetry: organizations typically invest heavily in communication — roughly one unit of effort — while investing almost nothing in reinforcement, which should receive approximately three units of effort. Telling people about a change once, or even many times, is not the same as creating the conditions under which the new behavior becomes habitual. Reinforcement means embedding accessibility expectations into tenure review, course design processes, annual reviews, procurement contracts, and promotion criteria. Almost no institution has done this.
Implementation is Not an Easy Task
At Binghamton University, part of the SUNY system, the accessibility team has led 30 trainings, conducted as many digital inventories, audited nearly 250 websites, and scanned and stored more than 60,000 files in their LMS (GovTech, 2025). The senior director there is clear-eyed about what the work involves: “Our expectation is not going to be 100 percent compliance, although we’re going to strive to do that, but the reality is, we don’t have unlimited time and money, and we have a lot of work to do. But you’ve got to start somewhere” (as cited in GovTech, 2025).
What Binghamton has done is treat accessibility as implementation work, not installation work— integrating it into faculty orientations, new staff onboarding, professional development, and software training, and building it into the workflows that shape actual behavior rather than merely announcing it from above (GovTech, 2025). That is the AIM model in practice.
The Compliance Deadline as a Starting Line
The framing of April 24 as a finish line is understandable but analytically wrong. As CarnegieHigher Education (2026) observed, “April 24, 2026, is a compliance deadline, but it’s also acultural marker for digital accessibility in higher education.”
Institutions that sprint to the deadline, declare compliance, and reduce investment will find themselves cycling through this same pattern — partial installation, thin adoption, persistent gaps — every time the legal or regulatory environment shifts. The institutions that will reach genuine, durable implementation are the ones that stop treating their policy as the deliverable and start treating it as the starting condition for the real work: defining what changed behavior looks like at every role level, building active sponsorship at the level of provost and president, and creating the reinforcement structures that make accessibility the path of least resistance rather than an additional burden.
That work does not end on April 24. It begins.
References
- Anthology. (2025a). The accessibility gap: Why faculty struggle and how institutions can help [White paper].
https://backstage.anthology.com/sites/default/files/2025-10/Accessibility_Gap_WhitePaper_v2.pdf - Association of Governing Boards of Universities and Colleges. (2025, August 15). AGB policyalert: ADA digital accessibility rule requires full compliance by April 2026.
https://agb.org/news/agb-alerts/agb-policy-alert-ada-digital-accessibility-rule-requires-full-compliance-by-april-2026/ - Carnegie Higher Education. (2026, February 11). ADA Title II final rule for higher education.
https://www.carnegiehighered.com/ada-title-ii-final-rule-higher-education/ - Collegis Education. (2025, July 9). Change management in higher ed isn’t a one-off, it’s a leadership discipline.
https://collegiseducation.com/insights/change-management-in-higher-ed/ - EdTech Magazine. (2025, June 17). A guide to the ADA Title II accessibility rule.
https://edtechmagazine.com/higher/article/2025/06/guide-ada-title-ii-accessibility-rule-perfcon - Educause. (2023). Educause QuickPoll results: Risks and opportunities in higher education accessibility.
https://er.educause.edu/articles/2023/8/educause-quickpoll-results-risks-and-opportunities-in-higher-education-accessibility - GovTech. (2025, November 7). EDUCAUSE ’25: Preparing higher ed for new digital accessibility rules.
https://www.govtech.com/education/higher-ed/educause-25-preparing-higher-ed-for-new-digital-accessibility-rules - Harrison, D., & Implementation Management Associates. (2024).
Accelerating ImplementationMethodology (AIM). IMA Worldwide.
https://imaworldwide.com/what-is-aim/ - Palmer, K. (2026, January 21). Higher ed prepares for new era of accessibility. Inside Higher Ed.
https://www.insidehighered.com/news/government/colleges-localities/2026/01/21/higher-ed-prepares-new-era-ada - U.S. Department of Justice. (2024, April 24). Nondiscrimination on the basis of disability; accessibility of web information and services of state and local government entities [Final rule]. Federal Register, 89(80).
https://www.federalregister.gov/documents/2024/04/24/2024-07758/nondiscrimination-on-the-basis-of-disability-accessibility-of-web-information-and-services-of-state
