Report 2017-102 Recommendation 18 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 #18 To: Foothill-De Anza Community College District

To ensure that its website complies with accessibility standards, by June 2018, De Anza should develop procedures to monitor website accessibility and incorporate steps to prevent instructors from publishing inaccessible content on the college's website. These procedures should include a tracking mechanism to demonstrate how many accessibility errors the college identifies and how long it takes to fix those errors.

Annual Follow-Up Agency Response From October 2022

Evidence of full implementation of procedures to monitor accessibility and prevent the publication of inaccessible content:

- Three automated monthly website accessibility scans are performed by vendor RocketValidator. Reports are maintained by the vendor and the college web team is notified when scans are completed.

- Our content management system, OmniUpdate by ModernCampus, prevents any webpages from being published without passing an accessibility scan first.

Evidence of full implementation of tracking mechanism

- All accessibility scan reports are imported into an internal accessibility tracking database,

- Each reported error is tracked in the system. Staff can make comments and mark the issue as resolved.

- Reports are generated with statistics regarding average time to resolution, number of errors and affected pages, and false positive metrics.

For Reference: Monthly Compliance Procedures

- Three accessibility reports are generated monthly and imported to our database through an API.

- Each error is reviewed by staff and assigned to the appropriate staff member for resolution

- Staff makes the corrections, adds notes to the database and marks the issue as resolved

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

FHDA previously provided reports showing monthly accessibility checks its vendor performed on the school's website, but it did not provide documentation demonstrating that it is monitoring how long staff take to correct identified accessibility errors.

Annual Follow-Up Agency Response From October 2021

Evidence of full implementation of procedures to monitor accessibility and prevent the publication of inaccessible content:

- Three automated monthly website accessibility scans are performed by vendor RocketValidator. Reports are maintained by the vendor and the college web team is notified when scans are completed.

- The content management system, OmniUpdate by ModernCampus, contains a setting that prevents any webpages from being published without passing an accessibility scan.

Evidence of full implementation of tracking mechanism

- All accessibility scan reports are maintained by RocketValidator, and resolution information is contained within OmniUpdate. Both have dates associated with them and the amount of time to fix errors can be calculated by determining the difference between the two.

For Reference: Monthly Compliance Procedures

- Three accessibility reports are generated on a monthly basis and sent to the college web team.

- The web team collectively reviews the reports and determines the issues to be resolved and the personnel assigned to those issues.

- Personnel make corrections or improvements, and then check those against the report using the same tool (i.e. RocketValidator)

- Notes are made on the individual pages when corrected.

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

De Anza provided three reports showing monthly accessibility checks its vendor performed on the school's website. However, De Anza did not provide documentation demonstrating that it is monitoring how long staff take to correct identified accessibility errors.

Annual Follow-Up Agency Response From October 2019

From the Office of Communications:

As noted in previous responses, while website accessibility measures were in place prior to the audit, the De Anza College website has been redesigned and is now more systematically assessed, with the process, results and follow-up formally recorded for regular review and analysis.

The content management system (CMS) for the college's new website, launched May 1, 2018, has been intentionally configured to permit publication of webpage content -- developed by hundreds of decentralized users -- only if it is free of accessibility errors. Web accessibility requirements are presented in all trainings on the content management system (CMS), which approximately 200 faculty and staff members have taken to date. Additional trainings are currently scheduled.

As also noted in previous responses, the website undergoes an automated, monthly accessibility scan using a quality validation tool - RocketValidator, engineered specifically for large websites - with a second tool, tenon.io, utilized as required. The reports are generated, captured and reviewed by the web administrator, who follows up with all appropriate actions and records them in an ongoing, cumulative spreadsheet. According to RocketValidator's published rankings, De Anza College is always at or near the top in accessibility among college and universities nationwide, routinely ranking higher than Yale, Harvard, Princeton, Columbia, Brown, Cornell, Johns Hopkins, UC Berkeley, UC Irvine and UC Santa Barbara, among others. As of this response date, De Anza College remains number one, with an average accessibility error per page of 0.00 (https://rocketvalidator.com/leaderboards/united-states-education).

California State Auditor's Assessment of Annual Follow-Up Status: No Action Taken

De Anza did not provide documentation to support its claim of full implementation.

6-Month Agency Response

Although Foothill-De Anza Community College District submitted a 60-day response to this recommendation, it did not submit its 6-month response.

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

The district did not submit a response.

1-Year Agency Response

Although Foothill-De Anza Community College District submitted a 60-day response to this recommendation, it did not submit its 1-year response.

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

The district did not submit a response.

60-Day Agency Response

While accessibility measures were in place prior to the audit, the De Anza College website is now more systematically assessed, with the process, results and follow-up formally recorded for regular review and analysis.

The website undergoes an automated, monthly accessibility scan using a quality validation tool engineered specifically for large websites, with a second tool readily available as required. The reports are generated, captured and reviewed by the senior web coordinator, who follows up with all appropriate actions and records them in an ongoing, cumulative spreadsheet. Any notification to the web team about an accessibility issue would similarly be noted and promptly attended to, with follow-up recorded. Web accessibility requirements are presented in all trainings on the content management system (CMS), which more than 150 faculty and staff members have taken to date. The CMS setup for the college's new website, launched May 1, permits publication of webpage content -- developed by hundreds of decentralized users -- only if it is free of accessibility errors.

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

De Anza did not provide documentation to support its assertion of full implementation of this recommendation.

All Recommendations in 2017-102

Agency responses received are posted verbatim.