Six things to settle before any of this reaches a student
These are the failure points that turn an accessibility gain into a compliance problem.
AI output is a draft, not an accommodation of record.
If an IEP specifies a qualified interpreter, live captions do not satisfy it. If it specifies braille instruction, a screen reader does not satisfy it. AI reduces the labor of producing accessible material. It does not change what the plan legally requires.
Auto-generated alt text and captions need a human pass.
Generated alt text describes what is in the picture. It does not know why you assigned the picture. The instructional point is the part a person has to add.
Student data needs an agreement before it goes anywhere.
IEPs, 504 plans, evaluation reports, behavior data, and health information are education records. Confirm a signed data privacy agreement covers the specific tool before any of it is pasted into a prompt. Every prompt here uses bracketed placeholders for that reason.
Never let AI issue a standalone label.
Risk flags, behavior classifications, disability predictions, and language proficiency calls stay with the team. AI can organize the evidence a team reviews. It does not get a vote.
WCAG conformance is the floor, not the goal.
A page can pass every automated check and still be unusable. Test with the people who rely on it, and budget for that testing the same way you budget for the license.
Translation quality varies sharply by language.
Machine translation performs well in high-resource languages and poorly in many of the languages Michigan families actually speak. Verify before relying on it for anything consequential.
Current federal deadline, as of September 2026
The ADA Title II digital accessibility rule still requires WCAG 2.1 Level AA for web content and mobile apps a public entity provides or makes available, including through vendors. On April 20, 2026, the Department of Justice issued an interim final rule extending the compliance dates by one year: April 26, 2027 for public entities serving a total population of 50,000 or more, and April 26, 2028 for smaller entities and special district governments.
The standard, the scope, and the exceptions did not change — only the dates. Existing Title II effective-communication obligations apply now, and private litigation is unaffected by the extension. Districts should confirm with counsel which date applies to them, since the threshold turns on the population of the jurisdiction served.
Show Columns by Role
Show Rows by Area of Eligibility
Special education eligibility categories13 areas
Populations served outside special education eligibility8 areas
Universal access layers8 areas
Special education eligibility categories
The thirteen categories defined by the Michigan Administrative Rules for Special Education. Federal IDEA uses different names for several of these; the Michigan term and rule number are given.
| Area of need | Student | Parent | Teacher | Administrator |
|---|---|---|---|---|
| Specific Learning DisabilitySLD · R 340.1713Dyslexia, dysgraphia, dyscalculia, processing disorders | ||||
| Speech and Language ImpairmentSLI · R 340.1710Articulation, fluency, voice, receptive and expressive language | ||||
| Other Health ImpairmentOHI · R 340.1709aADHD, asthma, epilepsy, diabetes, limited strength or alertness | ||||
| Autism Spectrum DisorderASD · R 340.1715Social communication, restricted interests, sensory response differences | ||||
| Emotional ImpairmentEI · R 340.1706Withdrawal, anxiety, depression, sustained behavior barriers to learning | ||||
| Cognitive ImpairmentCI · R 340.1705Federal IDEA term: intellectual disability | ||||
| Visual ImpairmentVI · R 340.1708Low vision through blindness; includes braille and large-print users | ||||
| Deaf or Hard of HearingDHH · R 340.1707Any degree of hearing loss that interferes with learning | ||||
| Deaf-BlindnessDB · R 340.1717Concurrent hearing and vision loss; intervener-supported | ||||
| Physical ImpairmentPI · R 340.1709Federal IDEA term: orthopedic impairment; motor access needs | ||||
| Traumatic Brain InjuryTBI · R 340.1716Acquired injury; needs change across recovery | ||||
| Severe Multiple ImpairmentSXI · R 340.1714Concurrent intellectual, physical, and functional needs | ||||
| Early Childhood Developmental DelayECDD · R 340.1711Through age seven, when no other category applies |
Populations served outside special education eligibility
Learners with real access barriers who are not covered by MARSE. Several are protected under other federal law; all of them show up in the same classrooms.
| Area of need | Student | Parent | Teacher | Administrator |
|---|---|---|---|---|
| English learners and multilingual studentsTitle IIINot a disability category — do not route through special education | ||||
| Section 504 only, no IEPSection 504Accommodations without specially designed instruction | ||||
| Gifted, talented, and twice-exceptionalState and local2e learners hold both giftedness and a disability | ||||
| Students experiencing homelessness or in foster careMcKinney-Vento · ESSAHigh mobility, interrupted enrollment, device instability | ||||
| Migrant and highly mobile studentsTitle I Part CRecords arrive late, incomplete, or in another language | ||||
| Medically fragile, homebound, and chronically absentLocal policyInstruction must reach the student, not the seat | ||||
| Rural and limited-connectivity learnersDigital equityAccess failure looks like disengagement in the data | ||||
| Trauma-affected learnersCross-cuttingOverlaps every category above; rarely labeled |
Universal access layers
These apply to every piece of content for every learner. Built in once, they remove the need for most individual retrofits. WCAG success criteria are noted where they apply.
| Area of need | Student | Parent | Teacher | Administrator |
|---|---|---|---|---|
| Captions and transcriptsWCAG 1.2.2 · 1.2.4Live and recorded | ||||
| Alt text and described visualsWCAG 1.1.1 · 1.2.3 · 1.2.5Images, charts, diagrams, video | ||||
| Reading level and plain languageCross-cuttingAdjusts demand without lowering the standard | ||||
| Keyboard, switch, and voice operationWCAG 2.1.1 · 2.1.2 · 2.5.1The most common motor-access failure point | ||||
| Color, contrast, and visual densityWCAG 1.4.3 · 1.4.11 · 1.4.12Low vision, color vision deficiency, visual fatigue | ||||
| Cognitive load and document structureWCAG 2.4.6 · 3.2 · 3.3Real headings, predictable order, one action per line | ||||
| Accessible assessmentIDEA · ESSAAccommodations must transfer to the testing platform | ||||
| Device, bandwidth, and offline accessDigital equityMobile-only households are the norm, not the exception |