Who Must Designate an ADA Coordinator?
Every state or local government entity with 50 or more employees must designate at least one person as its ADA Coordinator. This includes cities, counties, school districts, transit authorities, public universities, courts, and every other public entity that meets the threshold.
There is no specific job title required — the person may be called "ADA Coordinator," "Disability Services Director," "Civil Rights Compliance Officer," or something else entirely. What matters is that someone is designated and empowered to do the work.
Smaller entities (under 50 employees) are not required to designate a coordinator, but they still must comply with every other Title II requirement. Many smaller entities voluntarily designate a coordinator because it makes compliance easier.
Official Standard
28 CFR §35.107(a)
"A public entity that employs 50 or more persons shall designate at least one employee to coordinate its efforts to comply with and carry out its responsibilities under this part, including any investigation of any complaint communicated to it alleging its noncompliance with this part or alleging any actions that would be prohibited by this part."
Coordinator Responsibilities
While the regulation doesn't list every specific duty, the ADA Coordinator's role typically includes:
Making Coordinator Information Public
The entire purpose of having an ADA Coordinator is defeated if no one knows who they are. The entity must make the coordinator's information readily available:
- Name (or at minimum, the title of the position)
- Office address
- Phone number (and TTY or relay service number)
- Email address
This information should be posted on the entity's website, included on public notices, and available at service locations. Many entities also include it on meeting agendas, application forms, and building signage.
DOJ Guidance
The DOJ recommends that public entities "provide the ADA coordinator's name, office address, and telephone number to all interested individuals" and that this information be "included in public notices describing the entity's obligations under the ADA."
Grievance Procedures
Entities with 50+ employees must have a formal grievance procedure — a clear process for people to file ADA complaints and have them resolved. An effective procedure includes:
- Simple filing process: A complaint form (in accessible formats) or the ability to file by email, phone, or in person. The process should be easy enough that anyone can use it.
- Clear timelines: The entity should specify how quickly it will acknowledge the complaint, investigate, and respond. "Prompt" typically means weeks, not months.
- Investigation process: An impartial review of the facts. The complainant should have the opportunity to present evidence and be kept informed of progress.
- Appeals: If the complainant disagrees with the resolution, there should be a way to appeal to a higher authority within the entity.
- No retaliation: The procedure must make clear that retaliation against anyone who files a complaint is prohibited.
Important: Filing a grievance with the entity is not a prerequisite for filing a complaint with the DOJ or a federal court. People can file externally at any time.
Official Standard
28 CFR §35.107(b)
"A public entity that employs 50 or more persons shall adopt and publish grievance procedures providing for prompt and equitable resolution of complaints alleging any action that would be prohibited by this part."
Self-Evaluation
A self-evaluation is a comprehensive review of everything the entity does — all programs, services, policies, and practices — to determine if they discriminate against people with disabilities:
- Scope: Review every program, service, and activity — parks, libraries, licensing, public meetings, websites, emergency services, hiring, everything
- Involve the community: People with disabilities and disability organizations must have the opportunity to participate in the self-evaluation process
- Document findings: Entities with 50+ employees must keep the self-evaluation on file for at least 3 years
- Take action: Where barriers are found, the entity must modify its services, policies, and practices
Although the original deadline for completing the self-evaluation was 1993, many entities never completed one — and the DOJ continues to require it in enforcement actions and settlement agreements.
Official Standard
28 CFR §35.105(a)
"A public entity shall, within one year of the effective date of this part, evaluate its current services, policies, and practices, and the effects thereof, that do not or may not meet the requirements of this part and, to the extent modification of any such services, policies, and practices is required, the public entity shall proceed to make the necessary modifications."
28 CFR §35.105(c)
"Interested persons, including individuals with disabilities or organizations representing individuals with disabilities, shall be provided an opportunity to participate in the self-evaluation process."
Transition Plans
If the self-evaluation identifies physical barriersin facilities that require structural changes for program access, the entity must develop a transition plan:
- Identify obstacles: List every physical barrier in every facility — steps, narrow doorways, inaccessible restrooms, lack of signage, etc.
- Describe solutions: For each barrier, explain how it will be fixed (install a ramp, widen a doorway, add an elevator, etc.)
- Set a schedule: Specific completion dates for each modification, with priority given to the most critical programs
- Designate responsibility: Name the official responsible for overseeing the plan's implementation
- Public review: The transition plan must be available for public inspection and comment
28 CFR §35.150(d)(1)
"The plan shall, at a minimum — (i) Identify physical obstacles in the public entity's facilities that limit the accessibility of its programs, activities, or services to individuals with disabilities; (ii) Describe in detail the methods that will be used to make the facilities accessible; (iii) Specify the schedule for taking the steps necessary to achieve compliance; and (iv) Indicate the official responsible for implementation of the plan."
Important Note
This guide provides general information about ADA Coordinator requirements and related obligations. For legal advice about your entity's specific obligations or your rights as a person with a disability, connect with an experienced ADA attorney.
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What Does ADA Coordinator Requirements Mean in Practice
If you're asking about ADA coordinator requirements, the short answer is this: under Title II, a state or local government with 50 or more employees generally must name at least one ADA Coordinator. The job title can vary. What counts is that someone is actually designated, reachable, and responsible for the work.
This page lays out who has to designate a coordinator, what the role generally covers, and how the grievance process fits in. For the exact regulatory language, see the standard quoted above and the glossary if a term is unfamiliar.
Posting Coordinator Contact Information
A public entity that must designate a coordinator generally also has to make that person's name, office, address, and phone number available to anyone who asks, and often publishes it on the entity's own website or in public materials. If you cannot find this information for an entity you're dealing with, that itself can be worth asking about directly.
Grievance Procedures, in Plain Words
Entities with 50 or more employees generally must also adopt grievance procedures that provide for prompt and fair resolution of complaints alleging disability discrimination. This typically means a written process: how to file a complaint, who reviews it, and roughly how long it takes to get a response. The ADA Coordinator usually oversees this process, though the regulation does not spell out every detail of what it must contain.
If you've filed a complaint with a coordinator and heard nothing back, or the process itself seems to have no clear steps, that's a fact worth noting. It does not tell you whether the entity is breaking the law. It depends on the specifics.
What This Page Does Not Tell You
This guide explains what the regulation generally requires. It cannot tell you whether a specific entity you're dealing with is meeting those requirements, and it is not legal advice. If you've run into a wall with an ADA Coordinator, or a public entity near you doesn't seem to have one, the next step is usually to ask directly or look at your options.
If you're trying to sort out whether a situation you experienced involves a Title II issue like this one, read the rest of the Standards Guide for related topics on complaints and the legal process.