In 1990, the Americans with Disabilities Act (ADA) was passed. It prohibits discrimination against individuals with disabilities. Institutions of higher education are included under Title III of the ADA,and as such are required to provide the same access to services and education to qualified individuals with disabilities as individuals without. A review of the literature of accessibility of online programs and courses in higher education shows that compliance to the ADA is sporadic due to several challenges. In Spring 2020, all institutions of higher education transitioned to some form of online instruction due to the COVID-19 pandemic. This created even more challenges in complying to the law. This paper reviews the challenges to compliance to the ADA in online courses both in normal operations and during the COVID-19 pandemic, and offers recommendations and resources for improving compliance.