Accessibility & Americans with Disabilities Act: ADA templates

Federal and state laws require that public entities publish certain accessibility information on municipal websites or in public facilities. State and local governments can follow the guidance below to develop a formal acknowledgement of obligations under Title II of the ADA.

Who must provide an ADA notice?

All public entities, regardless of size, must provide information about the rights and protections of Title II of the ADA to applicants, participants, beneficiaries, employees, and other interested persons [28 CFR Sec. 35.106]. The public entity must provide this information on an ongoing basis.

What information must be included in an ADA notice?

An effective ADA notice uses clear, concise language in standard font and sizes, without being too lengthy and complicated. An ADA notice must include brief statements about:

• Employment
• Effective communication
• Making reasonable modifications to policies and programs
• Not placing surcharges on modifications or auxiliary aids and services
• Filing complaints

The notice must include the identification of the employee serving as the ADA coordinator, if the public entity has a designated ADA coordinator (required for public entities with 50 or more employees). Learn more about the ADA coordinator role and how to designate one below.

How and where to provide an ADA notice

State and local governments should provide an ADA notice using the most effective methods to spread awareness to the general public. At a minimum, municipalities must display the ADA notice in their public facilities at an accessible location. This may be the same place that public meeting agendas are regularly posted, or another publicly accessible location. Under 65 ILCS 5/1-1-12, if municipalities maintain a website, they must publish the ADA notice on the website and ensure website accessibility is maintained.

In providing the notice, the municipality must comply with ADA Title II requirements for effective communication by offering alternative formats, where appropriate [28 CFR Sec. 35.160] Alternative formats may be ADA notices written in braille, large print, or announced over radio and audio tapes.

ADA notice template

Note the asterisks (*) in the template text below indicating best practices and additional considerations when using this template.

ADA notice under the Americans with Disabilities Act

In accordance with the requirements of Title II of the Americans with Disabilities Act of 1990 (ADA), the [agency name] will not discriminate against qualified individuals with disabilities on the basis of disability in its services, programs, or activities.

Employment:

[agency name] does not discriminate on the basis of disability in its hiring or employment practices and complies with all regulations overseen by the U.S. Equal Employment Opportunity Commission under Title I of the ADA.

Effective communication:

[agency name] will generally, upon request, provide appropriate aids and services to facilitate effective communication for individuals with disabilities so they can participate equally in [agency name] programs, services, and activities, including qualified sign language interpreters, documents in Braille, and other ways of making information and communications accessible to people who have speech, hearing, or vision impairments.*

Modifications to policies and procedures:**

[agency name] will make all reasonable modifications to policies and programs to ensure that people with disabilities have an equal opportunity to participate in its programs, services, and activities.

Anyone who requires an auxiliary aid or service*** for effective communication, or a modification of policies or procedures to participate in a program, service, or activity of [agency name] should contact [insert name and contact information for ADA coordinator] as soon as possible but no later than [5 business days****] prior to the scheduled event to ensure sufficient time for acquisition or modification of equipment or devices. Complaints that a program, service, or activity of [agency name] is not accessible to persons with disabilities should be directed to [insert name and contact information for ADA coordinator].

[agency name] will not place a surcharge on a particular individual with a disability or any group of individuals with disabilities to cover the cost of providing auxiliary aids/services, reasonable modifications of policy, barrier removal, or alternatives to barrier removal required to ensure individuals can participate in all services and programs.

[ADA coordinator name]
ADA coordinator [and other title if appropriate]
[Email address]
[Phone number]
[ADA coordinator’s mailing address]

Template notes

* Recommend identifying service providers for accessible communications (sign language, Braille, etc.) in advance

** § 35.130 requires public entities to make reasonable modifications in policies, practices, or procedures when the modifications are necessary to avoid discrimination on the basis of disability. For example, individuals with service animals are welcome in [agency name] offices, even where pets are generally prohibited.

*** Provide budget for these services

**** Although the ADA does not provide a legal timeframe requirement for the public to submit requests for policy or procedure modifications, 5 business days is recommended to ensure municipalities have sufficient time to prepare for requests and procure requested accommodations. Municipalities should ensure programs, services, programs are in accessible locations and formats far in advance of a scheduled event.

ADA notice examples

• City of Aurora
• City of Naperville
• Village of Skokie

Who must designate an ADA coordinator?

Public entities with 50 or more employees (either full-time or part-time) must designate at least one employee to coordinate compliance with the ADA.

What are an ADA coordinator’s responsibilities?

The ADA coordinator is responsible for ensuring municipal compliance with ADA Title II regulations, facilitating accessibility initiatives, and addressing grievances or concerns related to the ADA within municipal programs, activities, or services. Depending on the size of the community, this can be a full-time position or an additional role for an existing employee or employees.

Who is the right candidate to be an ADA coordinator?

Any employee can serve as an ADA coordinator so long as that person is knowledgeable about ADA regulations and has sufficient decision-making authority in the organization to make changes and actions necessary for compliance. Common positions that serve this role include deputy municipal administrator, municipal attorney, municipal engineer, human resources representative, or a dedicated full-time ADA coordinator. In many cases, it is best practice to fill this role in house rather than engaging a third party since the ADA coordinator will serve as a representative of the organization when addressing grievances, interacting with the public, and improving internal accessibility practices — all of which benefit from a high level of knowledge of the organization and community.

The ideal candidate for an ADA coordinator role is comfortable speaking with members of the public and coordinating with a variety of people, both internal and external. They may encounter frustrated members of the public, especially when addressing grievances, so the candidate needs  the ability to remain calm during tense conversations. The ADA coordinator will serve as the public entity’s liaison to any ADA-related concerns in the community.

ADA coordinator contact information template

ADA coordinator under the Americans with Disabilities Act

As required by Title II of the Americans with Disabilities Act (ADA), all public entities that employ 50 or persons must designate at least one employee, commonly referred to as an ADA coordinator, to coordinate its efforts to comply with and carry out its responsibilities under this act. The ADA coordinator is responsible for ensuring compliance with ADA Title II regulations, facilitating accessibility initiatives, and addressing concerns or grievances related to the ADA within municipal programs and services.

This role involves coordinating efforts to promote equal access and inclusivity for individuals with disabilities, as mandated by Title II of the ADA. The ADA coordinator acts as a liaison between the [agency name] and the public, fostering communication and collaboration to enhance accessibility. The appointment of an ADA coordinator underscores the [agency name]‘s commitment to upholding the principles of non-discrimination and accessibility outlined in the ADA. Contact information for the [agency name]’s ADA coordinator is listed below:

[ADA coordinator name]
ADA coordinator [and other title if appropriate]
[Email address]
[Phone number]
[ADA coordinator’s mailing address]

ADA coordinator contact information examples

• City of Aurora
• Cook County
• Village of Oswego

Who must establish an ADA grievance procedure?

Public entities with 50 or more employees (either full-time or part-time) must publish an ADA grievance procedure to resolve complaints alleging a violation of the ADA. Grievance procedures describe a system to address complaints related to accessibility and public facilities, services, programs, and activities.

What information should be included in an ADA grievance procedure?

A grievance procedure establishes a process for resolving complaints of disability discrimination in a timely and fair manner. Title II regulations do not include the specific points required to be included in a grievance procedure, however the Department of Justice provides a model grievance procedure.

According to the ADA Best Practices Tool Kit for State and Local Governments, an effective ADA grievance procedure includes:

• A description of how and where a complaint may be filed with the public entity
• If a written complaint is required, a statement notifying potential complainants that alternative means of filing will be available to people with disabilities who require such an alternative
• A description of the time frame and process to be followed by the complainant and the government entity
• Information on how to appeal an adverse decision
• A statement of how long complaint files will be retained

The following ADA grievance procedure flowchart provides recommended processes and time frames from the time a grievance is submitted to the municipality to final resolution of the grievance.

PDF Grievance procedure flowchart
Word (text only) Grievance procedure flowchart

How and where to provide an ADA grievance procedure

Public entities with 50 or more employees should provide an ADA grievance procedure using the most effective methods to spread awareness to the general public. At a minimum, municipalities must display the ADA grievance procedure in their public facilities at an accessible location. Under Illinois law, if a municipality maintains a website, they must publish the ADA grievance procedure on the website and maintain accessibility to the website.

In providing the grievance procedure, the municipality must comply with ADA Title II requirements for effective communication by offering alternative formats, where appropriate. Alternative formats may be ADA grievance procedures written in braille, large print, or announced over radio and audio tapes. All written complaints and correspondence received by an ADA coordinator or public entity must be retained for at least three years.

Grievance procedure template

Note the asterisks (*) in the template text below indicating best practices and additional considerations when using this template.

Grievance Procedure under the Americans with Disabilities Act

[Agency name] is committed to upholding the Americans with Disabilities Act of 1990 (ADA) and specifically the Title II regulations which prohibits discrimination against individuals with disabilities in accessing public services, programs, and activities. Recognizing the importance of ensuring equal access for all, this grievance procedure is established to address complaints related to accessibility and public facilities, services, programs, and activities.

Who may file an ADA grievance

Any person who believes that they have been excluded participation in, denied the benefits of, or otherwise subjected to discrimination because of a disability under any [agency name] facility, service, program, or activity, may file a grievance. A grievance may also be filed on behalf of another person.

How to file an ADA grievance

Grievances should be submitted in writing and contain information about the alleged discrimination such as name, address, phone number of complainant and location, date, and description of the issue.

Grievances can be submitted through the following options:*

• In-person: Grievances may be submitted in-person at the following address:
  [municipal building address]
• Email: Grievances may be submitted by filling out the ADA Accessibility Complaint Form and emailing to [email address]
• Phone: Grievances may be submitted by calling [phone number]
• Online form: Grievances may be submitted via online, fillable ADA Accessibility Complaint Form [descriptive link]
• Mail: Grievances may be submitted by filling out the ADA Accessibility Complaint Form and mailed to the following address:
  [municipal building mailing address]

Alternative means of filing complaints — such as someone filling on behalf of the complainant, personal interviews, or a tape recording of the complaint — will be made available upon request.

The grievance should be submitted by the complainant and/or by their designee as soon as possible, but no later than [60 days**] after the alleged violation to:

[ADA coordinator’s name]
ADA coordinator [and other title if appropriate]
[Email address]
[Phone number]
[ADA coordinator’s mailing address]

ADA grievance processing

Within 15 calendar days after receiving the complaint, [agency’s] ADA coordinator, or their designee, will meet with the complainant to discuss the grievance and possible resolution. Within 15 calendar days*** of the meeting, [agency’s] ADA coordinator, or their designee, will respond in writing, and where appropriate, in a format accessible to the complainant, such as large print, Braille, or audio tape. The response will explain the position of the [agency name] and offer options for substantive resolution of the complaint.

ADA grievance appeals

If the response by [agency name] does not satisfactorily resolve the issue, the complainant or their designee may appeal the decision within 15 calendar days after receipt of the response to the [city manager/county commissioner/other appropriate high-level official] or their designee.

Within 15 calendar days after receipt of the appeal, the [city manager/county commissioner/ other appropriate high-level official] or their designee will meet with the complainant to discuss the complaint and possible resolutions. Within 15 calendar days after the meeting, the [city manager/county commissioner/ other appropriate high-level official] will respond in writing, and, where appropriate, in a format accessible to the complainant, with a final resolution of the complaint.****

[Insert name of city manager/county commissioner/ other appropriate high-level official]
[Title]
[Email address]
[Phone number]
[Mailing address]

ADA compliant record retention

The ADA coordinator will keep a record of all complaints filed for non-compliance with the ADA and Section 504 of the Rehabilitation Act of 1973 for a minimum of three years following the date of case closure provided all audits have been completed and no litigation is pending or anticipated.

Template notes

* Providing a variety of grievance submission options is recommended to ease the burden of submission on the complainant. You may choose to add or substract from this list based on available submission options for your organization. You may also provide additional details for each option, such as listing a specific email address or phone number.

** §35.170 requires grievance submission no later than (180) days after alleged incident, unless the time for filing is extended by the designated agency for good cause shown. However, many public entities recommend grievance submission no later than 60 days after incident to ensure timely grievance processing and correction.

*** While the ADA does not explicitly state the number of days required between each grievance procedure step, public entities are required to specify the time period in which corrective actions will be taken to address grievances. Per recommendation from the Department of Justice, 15 calendar days in between each grievance procedure step is strongly recommended.

**** § 35.172 requires public entities to fully investigate each complete complaint and attempt informal resolution. If resolution is not achieved, public entities may issue a Letter of Findings that shall include — (1) Findings of fact and conclusions of law; (2) A description of a remedy for each violation found; and (3) Notice of the rights available under paragraph (b) of this section. (b) If the designated agency finds noncompliance, the procedures in §§ 35.173 and 35.174 shall be followed. At any time, the complainant may file a private suit pursuant to section 203 of the Act, whether or not the designated agency finds a violation.

ADA grievance procedure examples

• Illinois Department of Transportation
• Village of Oswego
• Sample grievance procedure (ADA Tool Kit for State and Local Governments)