Undue Burden

Estes Park Schools utilize various third-party software, services, and government-issued resources to support educational and operational needs. These platforms, documents, and tools are often governed by the accessibility practices of external entities, including state and federal agencies. While the district is committed to advocating for accessible materials, it does not have the authority to directly modify or remediate content created and hosted by outside organizations.

Some required enrollment or compliance documents—such as those issued by the Colorado Department of Education—may not meet WCAG 2.1 AA accessibility standards at the time of publication. Due to limited staffing and technical resources, Estes Park Schools may not be able to fully remediate or recreate such documents in accessible formats. As such, the district claims an undue burden exemption under HB 21-1110 for the accessibility of these externally created, mandated resources.

Visitors to the Estes Park Schools website who click on links directing them to third-party or government-hosted content will see a message indicating that they are leaving the district’s website. This message will also state that Estes Park Schools cannot ensure the accessibility compliance of the destination content.

Whenever feasible, the district will offer alternative formats or direct support to individuals who are unable to access required materials. Additionally, as vendor and agency partnerships evolve or expire, the district will evaluate whether alternative providers or solutions can meet both service and accessibility standards.

Materials such as blueprints, architectural drawings, technical maps, handwritten documents, and other complex or historical records often cannot be fully adapted to meet accessibility standards. Estes Park Schools will label these materials appropriately, indicating their accessibility limitations. When possible, metadata and tags will be included to improve compatibility with assistive technologies.

Agendas and meeting materials created before July 1, 2025, may not meet accessibility requirements. During the grace period outlined in the bill July 1, 2024 and July 1, 2025, the district is focusing its limited staff and resources on developing processes and training to guarantee that all newly created electronic documents meet accessibility standards. These items will remain available in the public repository but will include clear disclaimers noting their potential inaccessibility. Upon request, staff will remediate such documents into accessible formats on a case-by-case basis.

The district currently lacks a dedicated position specializing in digital accessibility and IT content management. While partnerships with vendors like Allyant provide some remediation support, additional staffing for accessibility would require significant budgetary adjustments. At present, document and web content remediation will be incorporated into existing staff duties as time allows. Efforts to integrate accessibility training and resources into staff workflows will continue.

Estes Park Schools recognize the value of publicly sharing digital student generated work with families and our community. Students will be encouraged to apply digital accessibility principles whenever reasonable, it is not reasonable to expect full compliance for every piece of student-created content due to the developmental and educational nature of their work. Based on our district’s resources, it is not feasible to ensure that all student-generated work will meet full accessibility standards.

The following measures will be taken to address student-generated content:

• Clear Labeling: When student-generated content is shared publicly (e.g., on school websites or during events), staff will include disclaimers indicating that the content may not meet full accessibility standards.
• Ensuring Accessibility for Publicly Showcased Work: All student work displayed on the district’s website or other digital platforms will be reviewed for accessibility compliance and, when appropriate, remediated in a manner that preserves the original intent and integrity of the student’s work.

Estes Park Schools use specialized third-party software to manage financial operations, including budgeting, payroll, tax reporting, and document distribution (e.g., 1099s and W-2 forms). These systems are typically vendor-provided and often lack customization options to fully meet accessibility standards. Retrofitting financial and tax documents generated by these systems, such as detailed budget summaries, audits, or tax forms, would require significant technical resources and expense, creating a financial and administrative burden for the district.

Planned Actions:

• Advocate for accessibility improvements with third-party software providers to enhance future updates and consider alternative vendors with more compliant accessibility functionality at contract renewal.
• Provide alternative formats or accommodations, such as verbal explanations, simplified summaries, or accessible document formats, upon request.
• Attach boilerplate language to all outgoing financial and tax documents with information on how to contact the accessibility team to request assistance in making materials accessible. 

Exterior digital signage used by Estes Park Schools (e.g., marquees displaying announcements or events) is inherently visual and cannot provide audio descriptions for individuals with visual impairments. The technology to integrate audio output for these signs is currently unavailable or cost-prohibitive, making compliance an undue burden.

Planned Actions:

• Post equivalent announcements on the district's accessible website, school newsletters, or social media channels.

Fuel usage reports and related data are managed using specialized software designed for logistical tracking and export. These systems are often proprietary and lack features to ensure accessibility compliance, such as screen reader compatibility. Adapting exported reports for accessibility involves significant technical and financial challenges.

Planned Actions:

• Advocate for accessibility improvements with third-party software providers to enhance future updates and consider alternative vendors with more compliant accessibility functionality at contract renewal.
• Provide individualized explanations or summaries of fuel data upon request.

Report cards and student transcripts are generated through district software systems, which often have limited accessibility features. Retrofitting these documents to ensure compatibility with assistive technologies, such as screen readers, requires significant time and resources.

Planned Actions:

• Advocate for accessibility improvements with third-party software providers to enhance future updates and consider alternative vendors with more compliant accessibility functionality at contract renewal.
• Continue working with software providers to enhance accessibility features in their platforms.
• Offer alternative formats or direct assistance for students and families requesting accessible versions of these documents.
• We will follow state rules interpretation guidance to password protect outgoing transcripts. 

Estes Park Schools utilize BoardDocs and Community, third-party platforms through Diligent, to host and manage all school board policies, agendas, minutes, and related documentation. The district has limited control over the accessibility features of these platforms. Ensuring full compliance for all hosted content would require changes to the proprietary platform that are outside the district’s control and could present a significant financial or contractual burden.

Planned Actions:

• Advocate for accessibility improvements with third-party software providers to enhance future updates and consider alternative vendors with more compliant accessibility functionality at contract renewal.
• Work with Diligent to advocate for accessibility improvements and monitor updates to their platforms.
• Clearly indicate on the website that BoardDocs and Community are provided through a third-party and may not fully meet accessibility standards.
• Provide alternative formats or accommodations, such as direct assistance or copies of policies in accessible formats, upon request.

Estes Park Schools utilize the Frontline platform to manage critical student documentation, including Individualized Education Programs (IEPs), 504 Plans, Multi-Lingual (ML) Plans, Advanced Learning Plans (ALPs), and READ Plans. These documents are typically generated in PDF format by the platform, and while they are essential for educational planning, the PDFs are not inherently accessible without manual remediation. Adapting these files to meet accessibility standards requires significant technical and staff resources, presenting an undue burden.

Planned Actions:

• Advocate for accessibility improvements with this third-party software provider to enhance future updates and consider alternative vendors with more compliant accessibility functionality at contract renewal.
• District staff will work with individuals to provide accessible formats of these plans upon request, ensuring that stakeholders can access the necessary information without delay.
• We will follow state rules interpretation guidance to password protect outgoing plan documentation. 

Estes Park Schools utilize LearnPlatform to manage the vetting, approval, and tracking of digital instructional tools in alignment with curricular goals, data privacy standards, and overall instructional efficacy. As a centralized platform for evaluating educational technology, LearnPlatform generates reports and documentation that inform key instructional and compliance decisions.

Regarding accessibility, LearnPlatform does not currently have a Voluntary Product Accessibility Template (VPAT) available. However, the vendor has confirmed that a third-party accessibility audit is scheduled for later in 2025, with a completed VPAT expected by April 2026. This delay presents a challenge in verifying conformance with WCAG 2.1 AA standards, especially for stakeholders who require accessible versions of vendor-related documentation.

Without a VPAT or confirmed conformance, any remediation of LearnPlatform-generated documentation (often in PDF or online formats) must be handled manually. This process demands significant time, technical knowledge, and staff capacity. As such, full accessibility compliance for all LearnPlatform documentation currently represents an undue burden on the district.

Planned Actions:

• Continue engaging with LearnPlatform to ensure that the scheduled third-party accessibility audit proceeds as planned, and to monitor progress toward the April 2026 VPAT completion.
• Provide accessible alternatives for LearnPlatform-generated materials upon request, especially for documents critical to parents, students, and staff.
• Prioritize internal training for staff on accessible documentation practices relevant to third-party platform outputs.
• Reassess undue burden status after the completion of the audit and publication of the VPAT to determine necessary adjustments in practice.