Self-evaluation and Transition Plan
General Overview
Evaluating your organization’s accessibility and creating a transition plan can be critical for identifying areas for growth and improvement. Under the 1990 Americans with Disabilities Act (ADA) and the 1973 Rehabilitation Act, certain entities (based on type and size) are required to assess their programs, policies, practices, services, and facilities to ensure they are accessible to people with disabilities. These entities are also required to identify barriers to access and to create a plan (including identifying responsible individuals, timeline, and budget) that addresses the removal of the identified barriers. The evaluation and planning process is typically led by the organization’s accessibility coordinator and is recommended every three years. By conducting a thorough self-evaluation and creating a comprehensive transition plan or accessibility plan for improvement, organizations can enhance inclusivity, mitigate legal risks, and demonstrate a proactive commitment to accessibility. Importantly, self-evaluation and transition planning are about continually identifying, addressing, and embedding accessibility into every aspect of operations. These can be critical to helping your organization meet evolving needs while setting a standard for inclusive leadership.
Key Terms
Implementation
To ensure an authentic and effective self-evaluation and transition planning process, your organization should follow these overall steps:
- Appoint a team leader for the process. This could be your accessibility coordinator if you have one.
- Determine who from your team will participate in the process and when. Prepare by familiarizing yourself with key terms and legal requirements specific to your organization.
- Involve people with disabilities in the assessment process to ensure that diverse perspectives are considered. Recognize that the disability community encompasses diverse identities, including race, gender identity, and socio-economic status.
- Foster trust by involving the disability community early in the process and by maintaining open communication about progress.
- Evaluate all aspects of organizational operations including policies, practices, procedures, physical spaces, communication methods, digital spaces, services and programming.
- Use existing tools such as the Arts and Culture Accessibility Self-Assessment Tool.
- Apply the findings of your self-evaluation to create an actionable transition plan (or accessibility plan) that prioritizes and establishes clear steps, timelines, and potential costs, and that also outlines team members responsible for implementation. (The “Assess & Plan” page of The Hub has helpful guidelines and templates for creating an accessibility plan).
- Share your evaluation findings and transition plans with stakeholders and the public when appropriate.
- Conduct self-evaluations regularly and update transition plans annually to reflect progress and new priorities.
- Consider engaging additional user/experts and consultants to better understand and address specific barriers.
- Refer to findings from your self-assessment during budgeting, creation of new policies or programs, and/or designs of new spaces.
Associated Legal Requirements or Obligations
Please note that, while this content was developed by people with expertise in the ADA and legal requirements related to access, it was created for informational purposes and should not be considered legal advice.
- Title II of the ADA or a Title II Entity
- Self-Evaluation Requirement (28 CFR § 35.105)
- Public entities with 50 or more employees must conduct a Self-Evaluation of their programs, services, and policies to ensure compliance with the ADA.
- The Self-Evaluation must be maintained on file and available to the public.
- Transition Plan Requirement (28 CFR § 35.150(d))
- A Transition Plan must be developed from the findings of the Self-Evaluation and outline:
- Barriers that need to be removed.
- The process and timeline for removal.
- Assigned personnel responsible for implementation.
- The estimated costs for modifications.
- The Transition Plan must be publicly available and regularly updated.
- A Transition Plan must be developed from the findings of the Self-Evaluation and outline:
- Self-Evaluation Requirement (28 CFR § 35.105)
- Title III of the ADA or a Title III Entity
Title III organizations (private businesses, nonprofits, and places of public accommodation) are not required to conduct a formal Self-Evaluation or Transition Plan. However, organizations are strongly encouraged to conduct periodic Self-Evaluations and maintain a Transition Plan to demonstrate proactive compliance with accessibility standards and barrier removal requirements.
- Section 504 of the Rehabilitation Act
Organizations receiving federal funding may be required to complete a Self-Evaluation and create a Transition Plan.
- For federally funded arts and cultural organizations:
- Organizations that receive direct or indirect funding from the National Endowment for the Arts (NEA) are required to maintain a 504 Self-Evaluation and Transition Plan that is no more than three years old.
- Self-Evaluation findings must be documented and publicly available upon request.
- For federally funded arts and cultural organizations:
See also:
- ADA (Americans with Disabilities Act)
- IDEA (Individuals with Disabilities in Education Act)
- Rehabilitation Act of 1973
- Section 504 of the Rehabilitation Act
- Title II of the ADA or a Title II Entity
- Title III of the ADA or a Title III Entity
- U.S. Access Board
- WCAG (Web Content Accessibility Guidelines)
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