An ADA Coordinator is the employee a state or local government designates to run its compliance with the Americans with Disabilities Act, and the responsibilities of an ADA Coordinator span complaint intake, facility and program audits, arranging sign language interpreters and other communication aids, reviewing policies that create barriers, and now overseeing website and mobile app accessibility under a federal rule with deadlines starting in 2027. Any public entity with 50 or more employees is required to appoint at least one.1eCFR. 28 CFR 35.107 – Designation of Responsible Employee and Adoption of Grievance Procedures
Who Must Appoint One
Title II of the ADA requires every public entity with 50 or more employees to designate at least one person to coordinate compliance and investigate complaints.1eCFR. 28 CFR 35.107 – Designation of Responsible Employee and Adoption of Grievance Procedures The count is government-wide and covers every department and division. Full-time and part-time staff both count; contractors do not.2ADA.gov. ADA Best Practices Tool Kit for State and Local Governments – Chapter 2 The rule pulls in most city and county governments, state agencies, public universities, and school districts of any meaningful size.
A separate obligation runs through Section 504 of the Rehabilitation Act. Any organization receiving federal financial assistance that has 15 or more employees must also designate a coordinator and adopt grievance procedures, even if it never reaches the ADA’s 50-employee threshold.3U.S. Department of Health and Human Services. Section 504 of the Rehabilitation Act of 1973 Final Rule Fact Sheet Community health centers, housing authorities, and federally funded nonprofits often fall in this group.
Private businesses covered by Title III of the ADA face no legal requirement to appoint someone with this title.4ADA National Network. Role of an ADA Coordinator Many larger companies do so anyway to keep accessibility practices consistent across locations.
Handling Discrimination Complaints
Every public entity with 50 or more employees must adopt and publish a formal grievance procedure to resolve disability discrimination complaints.1eCFR. 28 CFR 35.107 – Designation of Responsible Employee and Adoption of Grievance Procedures The regulation requires the process to be “prompt and equitable” without prescribing exact timelines, so the coordinator generally designs the intake system, investigates complaints, and works toward resolution.
The DOJ’s model grievance procedure recommends giving the coordinator 15 calendar days to respond in writing after a complaint is filed, followed by an appeal path to a higher-level official such as a city manager or county commissioner.5ADA.gov. ADA Best Practices Tool Kit for State and Local Governments – Chapter 2 The model also calls for retaining all written complaints, appeals, and responses for at least three years. That paper trail becomes the entity’s primary evidence of good-faith compliance if the DOJ later investigates.
Auditing Facilities and Programs
Public entities must evaluate their own services, policies, and practices and correct anything that falls short of federal requirements.6eCFR. 28 CFR 35.105 – Self-Evaluation Entities with 50 or more employees have to keep the self-evaluation on file for at least three years and make it available for public inspection. The file must list the people and organizations consulted, describe the areas reviewed and problems identified, and document what the entity changed as a result.
When the self-evaluation surfaces physical barriers, the entity needs a transition plan. The regulation specifies the contents: an inventory of the obstacles that limit access, a description of the methods for removing them, a schedule for completing the work, and the name of the official responsible for carrying it out.7eCFR. 28 CFR 35.150 – Existing Facilities The coordinator is usually the named official and in practice drives the process, prioritizing high-traffic areas like entrances and restrooms, getting cost estimates, and tracking progress.8ADA.gov. ADA Update: A Primer for State and Local Governments
The audit reaches internal policies as well. A blanket “no animals” rule is the standard example: the ADA requires public entities to modify policies to allow service animals, and staff can ask only two questions, whether the animal is needed because of a disability and what task it has been trained to perform.9eCFR. 28 CFR 35.136 – Service Animals Coordinators also review emergency evacuation protocols, public meeting procedures, and program registration processes. If the coordinator concludes a requested modification would cause an undue burden or fundamentally alter the service, the reasoning has to be documented in writing.10U.S. Department of Justice. Settlement Agreement Between The United States of America and The City of Hudson, New York Under the Americans with Disabilities Act That documentation requirement shows up repeatedly in DOJ settlement agreements.
Effective Communication
Public entities must make their communications with people who have disabilities as effective as their communications with everyone else.11eCFR. 28 CFR 35.160 – General The coordinator is the person who fields requests and arranges the appropriate aid: qualified sign language interpreters for meetings, Braille or large print, video captioning, or screen-reader-compatible files.
The regulation gives the individual’s preference real weight. The entity must give “primary consideration” to the type of aid or service the person with a disability requests, and the appropriate aid depends on the nature and complexity of the communication.11eCFR. 28 CFR 35.160 – General A brief exchange at a service counter might be handled with pen and paper; a court hearing or medical consultation calls for a qualified interpreter. The DOJ’s model notice suggests asking people to submit requests at least 48 hours ahead of a scheduled event.5ADA.gov. ADA Best Practices Tool Kit for State and Local Governments – Chapter 2
Digital Accessibility Under the 2024 Rule
The newest and largest addition to the job comes from a DOJ final rule published in April 2024 requiring state and local government websites and mobile apps to meet Web Content Accessibility Guidelines Version 2.1, Level AA (WCAG 2.1 AA), a technical standard for making digital content usable with screen readers, keyboard-only navigation, and other assistive technologies.12ADA.gov. Fact Sheet: New Rule on the Accessibility of Web Content and Mobile Apps Provided by State and Local Governments
In April 2026, the DOJ extended the compliance deadlines. Entities serving populations of 50,000 or more now have until April 26, 2027. Smaller entities and special district governments have until April 26, 2028.13Federal Register. Extension of Compliance Dates for Accessibility of Web Information and Services of State and Local Government Entities
DOJ guidance places the following tasks squarely on the coordinator:
- Inventorying every website, web app, and mobile app the entity owns or provides, including content hosted by third-party vendors.
- Sorting content into what must meet WCAG 2.1 AA and what falls under an exception, such as archived pages, pre-existing documents, third-party posts, and password-protected individualized documents.
- Prioritizing fixes on content that enables high-value tasks like paying bills, submitting forms, or registering for programs.
- Overseeing vendors, because the public entity remains responsible for accessibility even when a vendor built or hosts the site.
- Training web developers, content creators, and procurement staff on the requirements.14ADA.gov. State and Local Governments: First Steps Toward Complying with the ADA Title II Web and Mobile Application Accessibility Rule
Making the Coordinator Findable
Appointing a coordinator does not satisfy the regulation on its own. The entity must publicize the coordinator’s name, office address, and telephone number to all interested individuals.15ADA.gov. ADA Best Practices Tool Kit for State and Local Governments – Chapter 2 Addendum Most entities post the information on a dedicated accessibility page on the official website and repeat it in employee handbooks, job postings, and lobby notices. The DOJ’s model notice recommends explaining what the ADA generally requires alongside the contact details, so people understand their rights before filing a complaint.5ADA.gov. ADA Best Practices Tool Kit for State and Local Governments – Chapter 2
Training and Qualifications
Federal regulations do not prescribe specific credentials. No particular degree or certification is required. What the law does require is that the entity give the coordinator enough training, resources, and authority to do the job. DOJ settlement agreements commonly require a newly appointed coordinator to complete training within 90 days covering program access, barrier removal, effective communication, and reasonable modifications.10U.S. Department of Justice. Settlement Agreement Between The United States of America and The City of Hudson, New York Under the Americans with Disabilities Act
The most recognized voluntary credential is the ADA Coordinator Training Certification Program (ACTCP), administered through the ADA National Network and the University of Missouri. Certification requires an ADA Basics prerequisite, 12 credits of foundation training covering the coordinator’s role, self-evaluations and transition plans, the 2010 design standards, and Title I employment guidelines, plus 6 additional credits in areas like effective communication or emergency preparedness, and 22 credits of electives drawn from at least five specialty areas.16ADA Coordinator Training Certification Program. Certification Requirements National and regional training programs typically cost between $250 and $900. The 2010 ADA Standards for Accessible Design remain the technical reference the coordinator advises departments on when renovations come up.17ADA.gov. 2010 ADA Standards for Accessible Design
What Happens When Entities Fall Short
Enforcement for Title II runs through designated federal agencies and the Attorney General. When an agency receives a complaint and finds a violation it cannot resolve informally, it issues a letter of findings that describes a remedy for each violation, which can include compensatory damages. If negotiations fail, the matter is referred to the Attorney General for a federal enforcement action, and courts can award attorney’s fees to the prevailing party. States cannot invoke sovereign immunity to avoid these remedies.18ADA.gov. Americans with Disabilities Act Title II Regulations
DOJ settlement agreements give a concrete picture of remediation. A typical agreement requires the entity to appoint a coordinator within 30 days, provide training within 90 days, publish the coordinator’s contact information on its website, and keep written documentation of any decision that a requested modification would create an undue burden.10U.S. Department of Justice. Settlement Agreement Between The United States of America and The City of Hudson, New York Under the Americans with Disabilities Act Those same steps, taken proactively, are what the coordinator role was designed to make routine.