The Office for Civil Rights’ Processing of Web Accessibility Complaints

The report presents the results of our review of the Office for Civil Rights (OCR) process for resolving web accessibility complaints that were previously dismissed and subsequently reopened as directed investigations and OCR’s approach to evaluating web accessibility complaints submitted after the November 2018 revision of its Case Processing Manual. Among our findings, we determined that OCR’s resolution of web accessibility complaints previously dismissed under section 108(t) and subsequently reopened as directed investigations differed from how these reviews were resolved in the past, specifically with regard to whether or not a compliance determination was made, and that determinations made were inappropriate based on the level of testing performed. As a result of OCR’s changes to its procedures and the unclear way these changes were implemented, it could be difficult for people unfamiliar with OCR’s process to understand OCR’s procedures for processing these complaints.