Decentralized systems often suffer from gaps in oversight. Departments can be reluctant to pay for accommodations because they did not adequately plan for access costs in their departmental budgets.

On campuses with decentralized systems, the staff at individual departments typically don’t have adequate knowledge of how to appropriately coordinate access services. Staff may not have enough familiarity with the ADA or Section 504 requirements to provide effective accommodations, or even to realize that providing effective accommodations is their responsibility.

While institutions may try to resolve this issue by providing training, it’s a challenge to do this in such a way that all staff have the knowledge they need. Even if this sort of all-campus training is accomplished one time, turnover creates a need to retrain staff, and whenever there are updates to existing policies and procedures, these must be distributed both widely and effectively.

Additionally, a lack of streamlined procedures, policies, and practices can lead to misunderstandings around issues like who is ultimately responsible for which parts of providing access, and unnecessary delays. A scattershot approach can also mean that deaf students receive different levels of access even within the same institution. 

In a decentralized system, deaf students are sometimes forced to carry additional labor as they negotiate for timely and effective access and educate others about the accommodation and funding process. This burden can be significant enough to cause students to give up, and just go without access.

When a system fails to provide equal opportunity, this may result in lawsuits and Office of Civil Rights investigations. Previous case law and legal requirements make it clear that regardless of whether an organization is public or private, their programs and services must be accessible to deaf people.