Scope of Digital Accessibility for Affiliated Websites
UMB is required under Title II of the ADA to ensure that digital content providing access to University services, programs, or activities is accessible to people with disabilities.
This requirement applies regardless of where a website is hosted, what platform it uses, or whether it is built in the University’s content management system (CMS).
How UMB Determines Whether an Affiliated Website Is in Scope
A website is considered within UMB’s ADA Title II digital accessibility scope if any one of the criteria below is met. These criteria are alternative triggers, not cumulative requirements.
Access to UMB Services, Programs, or Activities
The website provides the public, students, applicants, employees, or participants with access to official UMB services, programs, or activities.
Examples include, but are not limited to:
- Applications, registration, or enrollment processes
- Academic, research, clinical, or training programs
- Employment, fellowships, or internships
- Events, services, or opportunities offered by UMB or a UMB school or unit
Required Pathway for Participation
Use of the website is required in order to apply for, register for, participate in, or obtain information necessary to engage in a UMB service, program, or activity.
This includes cases in which the website is presented as the official or primary access point and no equivalent alternative access method is provided.
UMB Operational or Content Control
The website is operated, managed, or content-controlled by UMB or by a UMB school, unit, center, or department.
Indicators may include:
- UMB staff create, approve, or update content
- The site exists to advance a UMB mission, initiative, or program
- UMB determines what content is published or removed
Operating on Behalf of UMB
The website is operated by a third party or affiliated entity on behalf of UMB for the purpose of delivering or supporting UMB services, programs, or activities.
This may include externally hosted sites that function as the official public-facing presence for a UMB program or initiative.
What Does Not Determine Title II Applicability
The following factors alone do not determine whether a website falls under UMB’s ADA Title II obligation:
- Hosting location or platform
- Branding differences or visual identity
- Presence of a University or school logo
- Historical affiliation or partnership
- Physical proximity to campus
Digital accessibility scope under ADA Title II is determined by functional responsibility — whether a website provides access to UMB services, programs, or activities or is operated by or on behalf of UMB.
This determination is separate from institutional hosting, branding, domain, certificate, and infrastructure requirements, which are governed by UMB’s security and compliance standards.
Websites Operated By Legally Separate Organizations
Websites operated by legally separate organizations (such as independent nonprofits or partner entities) that do not deliver, support, or provide access to UMB services, programs, or activities, and that are not operated by or on behalf of UMB, are outside the scope of UMB’s ADA Title II digital accessibility obligation.
Institutional Scope and Applicability
The criteria above are intended to determine whether an affiliated or externally operated website falls within UMB’s ADA Title II digital accessibility obligations.
All websites that are operated, managed, or content-controlled by UMB or a UMB school, unit, center, or department are subject to UMB’s digital accessibility requirements, including informational websites. Accessibility obligations are not limited to transactional or application-based sites.
For websites operated by legally separate organizations, applicability depends on whether the site delivers or provides access to UMB services, programs, or activities, or operates on behalf of UMB.
Relationship to Hosting and Security Requirements
Digital accessibility scope under ADA Title II is determined by functional responsibility — whether a website provides access to UMB services, programs, or activities or is operated by or on behalf of UMB.
This determination is separate from institutional hosting, branding, domain, certificate, and infrastructure requirements, which are governed by UMB’s security and compliance standards.
A website may:
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Be subject to ADA Title II accessibility requirements without being classified as an institutional site for hosting purposes; or
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Be classified as an institutional site for security and domain management purposes even if it does not independently trigger ADA Title II scope.
Both standards may apply depending on the circumstances.