Report 2017-102 Recommendation 4 Responses

Report 2017-102: California Community Colleges: The Colleges Reviewed Are Not Adequately Monitoring Services for Technology Accessibility, and Districts and Colleges Should Formalize Procedures for Upgrading Technology (Release Date: December 2017)

Recommendation #4 To: Community Colleges Chancellor's Office

To ensure that students with disabilities have equal access to instructional materials, by June 2018, the Chancellor's Office should develop guidance for the community colleges on periodically monitoring the accessibility of instructional materials and on providing training to all instructors in making their materials accessible to students with disabilities.

Annual Follow-Up Agency Response From November 2020

The Chancellor's Office has provided opportunities for training for all instructors in making their material accessible to students with disabilities through a grant to the CCC Tech Center at the Butte-Glenn Community College District for the Shared Infrastructure Program. This grant has established the CCC Accessibility Center (CCCAC) which provides technical expertise, policy guidance, training, and solution specific to the information and communication technology accessibility, alternate media, and assistive technology for students with disabilities. In alignment with the 2019 statewide Accessibility Standard, the CCCAC assists colleges in identifying and implementing relevant accessibility solutions to improve access to campus-wide applications, website, documents, and instructional materials.

The CCCAC program continued to provide the applicable trainings, workshops, and online events, as well as continue to technical assistance on emerging assistive technology and alternate media solutions. Face-to-face training was conducted at regional and college locations based on institutional needs and demands, exceeding the total number of trainings planned for FY 2019-20. The CCCAC conducted a successful pilot of providing training via facilitated Zoom meetings, allowing the CCCCAC to be highly responsive during the COVID-19 pandemic. This included 12 live, interactive, Canvas Accessibility training sessions. The CCCAC engaged with other CCC technology initiatives to ensure a consistent and coordinated message regarding accessibility best practices. Working with CCCCO and Accessibility Standards Workgroup, the CCCAC continued building out an institutional evaluation matrix to inform districts what types of training and solutions to consider to address technology access campus-wide.

Completion Date: June 2020

California State Auditor's Assessment of Annual Follow-Up Status: Partially Implemented

Although the Chancellor's Office provides opportunities for training for all instructors, its provision of that training does not address our recommendation. The Chancellor's Office has not demonstrated that it has developed guidance for the community colleges on providing training to all instructors in making their materials accessible to students with disabilities.

Auditee did not address all aspects of the recommendation

Annual Follow-Up Agency Response From October 2020

The California Community College's Chancellor's Office (CCCCO) is fully committed to making Information and Communication Technology (ICT) and instructional technology accessible. ICT includes computers, telecommunications equipment, software, website, and electronic documents. Instructional materials include electronic materials such as syllabi, textbooks, presentations, handouts, e-learning courses, instructional videos, online collaborative writing, web conferencing, blogging, and any other instructional materials as technology evolves.

As such, the CCCCO has established an Accessibility Standard (Standard) to affirm accessibility expectations of all CCC districts. The standard recommends that districts establish written procedures for the compliance process. Furthermore, the standard communicates the CCCCO's expectations that all districts comply with state and federal law by using and maintaining accessible instructional materials and accessible ICT. The Standard also recommends that districts periodically monitor accessibility of both instructional materials and websites.

The Accessibility Standard is available on the California Community Colleges' Accessibility Center website which also publishes information about developing accessibility related board policies and specific guidance for meeting institutional accessibility obligations. The Institutional Guidance Matrix document emphasizes that implementation of the Standard is a continuous process and includes a maturity matrix as a guide for implementation. The maturity matrix specifies that for all goals and objective of implementing the Standard, the highest level of maturity calls for the college to regularly evaluate and assess the efficacy of implementation activities.

Completion Date: January 2020

California State Auditor's Assessment of Annual Follow-Up Status: Partially Implemented

The Chancellor's Office's new standards identify district and Chancellor's Office responsibilities for implementing these standards. Among the Chancellor's Office's responsibilities are providing guidance for the community colleges on developing guidance and coordinating any system-wide activities. Although its new standards include guidance for periodically monitoring the accessibility of instructional materials, it does not provide guidance on providing training to all instructors in making their materials accessible to students with disabilities, as we recommended.

Auditee did not address all aspects of the recommendation

Annual Follow-Up Agency Response From October 2019

CCCCO views accessibility of such material as foundational to the community colleges mission and a cornerstone of high-quality pedagogy. As such, the CCCCO has established an Accessibility Standard (Standard) to affirm accessibility expectations of all CCC districts. The standard specifically recommends that districts establish written procedures for the compliance process. Furthermore, the standard addresses the need to periodically monitor instructional materials accessibility by communicating the CCCCO's expectations that all districts comply with state and federal law by using and maintaining accessible instructional materials and accessible ICT.

Completion Date: January 2019

California State Auditor's Assessment of Annual Follow-Up Status: Pending

The Chancellor's Office's accessibility standard identifies district and Chancellor's Office responsibilities for compliance. As part of its responsibilities the Chancellor's Office's will develop guidance for districts and coordinate any system-wide activities. Although the Chancellor's Office has provided some guidance to the colleges, it did not provide any guidance which specifies that colleges should periodically monitor the accessibility of instructional materials.

Auditee did not substantiate its claim of full implementation

1-Year Agency Response

On June 19, 2018, Chancellor Eloy Oakley provided guidance to the community college system emphasizing the importance of meeting institutional accessibility obligations and announced the new Information and Communication Technology and Instructional Material Accessibility Standard. The Standard reinforces the requirement that colleges within the system create, purchase, and utilize instructional materials that comply with the accessibility requirements of Section 508 of the Federal Rehabilitation Act of 1973, in accordance with California Government Code sections 7405, 11135, and 11546.7. The Chancellor's guidance also included information on additional resources available on the Professional Learning Network at: http://prolearningnetwork.cccco.edu/ask/topic/accessibility.

Completion Date: June 2018
Response Date: June 2018

California State Auditor's Assessment of 1-Year Status: Pending

Chancellor Oloy Oakley's email to the district administrators indicated that the Chancellor's Office had developed new standards, which identify district and Chancellor's Office responsibilities for implementing these standards. Among the Chancellor's Office's responsibilities are providing guidance for the community colleges on developing guidance and coordinating any system-wide activities. However, the Chancellor's Office did not provide us with any guidance it had provided to the community colleges related to periodically monitoring the accessibility of instructional materials, or on providing training to all instructors in making their materials accessible to students with disabilities, as we recommended.

Auditee did not substantiate its claim of full implementation
Auditee did not address all aspects of the recommendation

6-Month Agency Response

Ensuring all students with disabilities have equal access to instructional materials is a top priority for the Chancellor's Office. As such, the CO has constituted an Accessibility Standard Working Group (ASWG) comprised of representative stakeholders from across the system and charged with developing standards, developing resources, and providing guidance for the CCC system. In the Spring of 2018, the ASWG developed a draft Information and Communication Technology and Instructional Material Accessibility Standard. The Standard clearly states that the CO and CCC will comply with the accessibility requirements of CA Government Code section 7405, Government Code section 11135, Government Code section 11546.7 and Section 508 of the Federal Rehabilitation Act of 1973. The ASWG is currently developing resources, instructional materials and guidance to assist colleges in complying with the standard. The Standard will be disseminated to the system from Chancellor Eloy Ortiz-Oakley by June 30, 2018.

Estimated Completion Date: June 30, 2018
Response Date: June 2018

California State Auditor's Assessment of 6-Month Status: Pending

60-Day Agency Response

On January 24, 2018, the Chancellor's Office conducted an online training webinar for college faculty, administrators, and staff that included a three-hour Instructional Materials Accessibility Track with three one-hour workshops in the following areas: Accessibility in Distance Education, Bringing our "A" Game: Lessons Learned in the Pursuit of Accessibility, and Universal Design Online Content Inspection Tool: UDOIT. There were 87, 105, and 107 participants respectively in the 3 workshops. The total headcount for the three workshops was 299 participants.

At its January 31, 2018, meeting the Distance Education and Educational Technology Advisory Committee (DEETAC) discussed updating and revising the distance education guidelines related to the accessibility of instructional materials for colleges. The DEETAC discussed how it would contribute to the distribution of guidelines when completed. Distribution plans include conducting an online webinar that is recorded and archived for later viewing for participants unable to attend in person. The guidelines will be posted to the Chancellor's Office web page in several locations. Chancellor's Office staff will also conduct live presentations of the guidelines at various conferences throughout the year. Information regarding the instructional materials accessibility guidelines will also be included in an addendum to the sixth Edition of the "Program and Course Approval Handbook" which provides guidance to colleges in the development and submission of courses and programs to the Chancellor's Office for review and approval.

Estimated Completion Date: June 2018
Response Date: February 2018

California State Auditor's Assessment of 60-Day Status: Pending

All Recommendations in 2017-102

Agency responses received are posted verbatim.