Building the Record: Complaints, Training, and Your Residents

Dated, structured, boring. And the most valuable thing you'll ever build.

I've said a version of this in every piece in this series, so let me finally say it straight: the question you're actually being asked, whenever this job gets tested, is never "were you perfect." Nobody's perfect, and everybody with any sense already knows that, including whoever's asking. The real question is whether you knew, whether you had a plan, whether you prioritized reasonably, and whether you actually did something about it. A dated record is the only thing that answers that question. Nothing else does — not your intentions, not the program you meant to build, not the training you were planning to schedule. The record.

Here's how to actually build one, without it eating your whole job.

Log the complaint the day it arrives

Whatever channel it comes in on — email, phone, someone at the front desk, a comment on social media — log it that day. An unlogged complaint is the worst fact that can exist in any file you'll ever have to produce, because it means the record shows you didn't know, when the truth is you did and just didn't write it down. There's no version of that gap that helps you later.

Acknowledge within two business days, in whatever channel the person used to reach you. Then solve their actual access problem first, by whatever means you've got, while the underlying fix gets scheduled separately. Access now, defect later — those are two different tracks, and conflating them is how people end up waiting weeks for a workaround that should've taken an email.

Once you've handled the person, reproduce the issue and ask one question: is this isolated, or is it systemic? A broken template outranks a broken page, because fixing the template fixes every page built from it. Fix it or schedule it with an actual date, tell the person which one happened, close the entry, and review the whole log quarterly for patterns. And here's the part that gets skipped more than any other: close the loop. An entry that ends with the fix but never tells the person what changed is a complaint that's answered in your paperwork and still unanswered in the world they actually live in.

Twelve columns, filled in every time

The discipline of an intake log beats whatever software you're tempted to buy for it. Date received. Channel. Person and contact, or "anonymous" if that's what they gave you. Item affected. The barrier, described in the person's own words — not your summary of it. Assistive technology involved, if you know. Access provided now, and the date. Systemic or isolated. Corrective action and who owns it. Target date. Resolution date. And what the person was actually told.

That last column is the one people skip and the one that matters most.

Training that people actually finish

Short, role-specific, repeated. Never one long annual course that everybody clicks through at 1.5x speed the week it's due. Content authors need headings, alt text, link text, and how to use the document checker — measured against WCAG 2.1 AA (opens in new window), not a vibe. Whoever does your buying needs to know how to demand and actually read an ACR (opens in new window) — which is the whole reason the last piece in this series exists. Communications needs captions and the rule about never locking information inside an image of text.

Tie publishing rights to completed training. I know that sounds heavy-handed, but it's the only enforcement mechanism I've ever seen actually work — not because people resent it, but because it's the only version of "please do this training" that has a consequence attached. And record every completion, because in your first year, reported training numbers are one of the only metrics you'll actually have. You won't have a year of complaint trends yet. You'll have this.

You don't need to build your own materials from scratch, either — several state programs publish full, free, role-based training sets. Link to what already exists. Writing your own is a use of your time that helps nobody.

The people this is actually for

Everything above is process. This part is the reason the process exists.

Find your local disability organization. Not personas in a slide deck — an actual organization, actual people, in your county, who've probably been trying to get somebody's attention for a while already. Offer them a standing invitation and pay them for structured testing time, the same way you'd pay any other consultant, because their expertise is exactly that: expertise, not a favor. Bring them your top tasks before you launch something, not after a complaint tells you what you missed.

Two rules make this real instead of performative. Pay people for their time. And report back to them what actually changed because of what they found — not as a courtesy, but because it's the whole point. One genuine working relationship like this will surface more real barriers than any scanner you'll ever run, and it changes what your program actually is. Not a compliance exercise you're managing around a legal deadline. A service, for people who are still here whether or not they ever file a complaint about it.

That's the whole record, really — not just the twelve columns in a spreadsheet, but the fact that somewhere in it, you can point to a relationship with actual people, not just a log of actual paperwork.

This isn't legal advice on what your specific grievance procedure needs to contain — verify the details against DOJ's guidance (opens in new window) and your counsel. And when a complaint names a specific page or document, ask Luke to take a first pass at it while you're logging the entry — it won't replace the manual test in your intake process, but it's a fast way to see what you're dealing with. Our accessibility statement and methodology show what this looks like applied to our own site.

Previous: how to read a VPAT · Next: reporting up, your maturity roadmap, and the budget ask

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Sources: DOJ guidance on web accessibility and the ADA (opens in new window) · Web Content Accessibility Guidelines (WCAG) 2.1 (opens in new window) · Accessibility Conformance Report (ACR) overview (opens in new window) · DOJ Disability Rights Section (opens in new window)