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The Americans with Disabilities Act (ADA) requires that public institutions provide and ensure an equal opportunity learning environment for all students. An audit of online courses at a mid-sized accredited university demonstrated that a large majority are not compliant with ADA regulations. A front-end analysis was conducted to determine the causes of the problem. A Systems Approach was adopted to analyze the problem within the context of the operating system in order to identify the causes of the problem and determine the best solution. A proposal was developed for the design, development, implementation and evaluation of the system-wide learning solution.