Responses to the Audit
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California Community Colleges Chancellor's Office
November 9, 2017
Ms. Elaine M. Howle, State Auditor
California State Auditor
621 Capitol Mall, Suite 1200
Sacramento, CA 95814
Dear Ms. Howle:
The California Community Colleges Chancellor’s Office (CCCCO) appreciates the opportunity to review and comment on your report titled, “California Community Colleges: Districts and Colleges are not Adequately Monitoring Services for Technology Accessibility and Should Formalize Procedures for Upgrading Technology”. In general, your report recommends the CCCCO provide community colleges guidance to:
- Strengthen the respond time to student’s requests for instruction materials.
- Expand the access of instructional materials to students with disabilities.
- Improve the processes for upgrading and replacing information technology equipment.
- Increase transparency of participatory governance decision-making processes, including those to consider technology equipment requests.
The CCCCO is working to implement the seven recommendations by the established timeframes. We thank the State Auditor staff for its work and we embrace the opportunity to improve our leadership role in these important policy areas.
If you have any questions, please contact Frances Parmelee at (916) 445-0540.
Sincerely,
Erik E. Skinner
Deputy Chancellor
Cerritos Community College District
November 9, 2017
Elaine M. Howle, CPA
State Auditor
621 Capitol Mall, Suite 1200
Sacramento, CA 95814
Dear Ms. Howle:
Enclosed you will find our responses to the recommendations identified from your report. We have provided our responses in PDF and Word format.
If you have any further questions, please contact me at (562) 860-2451 ext. 2242.
Sincerely,
Felipe R Lopez, MBA
Vice President of Business Services/Assistant Superintendent
Cerritos Community College District
cc: Dr. Jose Fierro, President/Superintendent, Cerritos College
Enclosures
Recommendations
Community Colleges
To ensure that they are fulfilling requests for alternate media services from students with disabilities in a timely manner, by June 2018, Cerritos should each establish procedures for monitoring its timeliness in responding to such requests so that it can periodically review its performance in completing the requests. Specifically, Cerritos should record and track sufficient information to be able to review how long they take to complete requests.
Response to the recommendation
To the existing official DSPS Excel spreadsheet, titled “Alternate Media Tracking Spreadsheet” currently documenting the date student request was received and the date alternate media conversion was completed and material ready for student pick-up, a column will be added delineating:
- type of alternate format of the final production format (Braille, MP3, enlarged print, PDF or other type needed for accessibility);
- length of class (9-week/other short-term, semester-length, summer intersession); and,
- the number, mean, median, and mode of days elapsed between receipt of student request and completion of student request, including for tiered requests wherein a student may, in effect, have two or more request dates for a class, time will be calculated as specified (number, mean, median, mode of elapsed days) .
A Performance Review Team will meet at least each primary term and intersession to review the performance data. Based on the data, the team will identify improvements as needed. The Team will be comprised of the Senior Accessibility Compliance Specialist, a DSPS staff member handling alternate media production, a DSPS faculty member, and the Team convener and chair will be the Dean of Disabled Student Programs and Services.
Recommendation
To ensure that they promptly address any complaints they receive related to web accessibility and alternate media requests, by June 2018, Cerritos should each establish procedures for tracking and reviewing complaints received related to accessibility and addressing complaints in a timely fashion.
Response to the recommendation
The college’s existing student conduct, grievance, concern, or Title IX report submission and case management SaaS, Maxient, will be expanded to include a category or categories for web accessibility- and alternate media request-related complaints. This will include (a) customized form(s), confidential electronic routing to appropriate personnel (Dean of DSPS for student concerns not against DSPS) or the Director, Diversity, Compliance, and Title IX Coordinator who will, as applicable, review, track, and manage or refer the matter to the responsible personnel (e.g., for web accessibility, to the Director, College Relations, Public Affairs, and Government Relations). Complaints related to personnel or confidential employee information will be routed to a separate database maintained by Human Resources. The rerouting of these complaints will be noted in the Maxient file. Maxient provides a robust complaint tracking solution that will be employed and it supports effective, confidential review for ensuring timely addressing of complaints.
Recommendation
To ensure that students with disabilities have equal access to instructional materials, by June 2018, Cerritos should each develop procedures to monitor and periodically review the accessibility of instructional materials. For example, the college could develop an accessibility checklist for instructors to complete when developing or selecting instructional materials, from which the college could periodically review a sample of course content to ensure instructors completed the checklist and that the instructional materials comply with accessibility standards.
Response to the recommendation
Cerritos College will work with faculty senate in order to develop an accessibility checklist for instructors to complete when developing or selecting instructional materials. This checklist will include:
1) Visual materials are accessible? Provide alternative text for images. Alternative text (or alt text) ensures that images are still accessible for people who are blind because their screen reader will read the alt text aloud for any images.
2) Audio materials accessible? Provide a text transcript for audio files. Text transcripts make audio information accessible to people who are deaf or hard of hearing. Closed captioning will allow learners to read the audio portion of videos.
3) Course software must allow for keyboard input? Allow all functionality via a keyboard. Providing the option for complete keyboard control gives learners who cannot use a mouse the opportunity to use assistive technologies that mimic the keyboard, such as speech input.
4) Does my authoring tool support accessibility? Choose an authoring tool that supports accessibility. This will make it easier for you, as a faculty, to make your course accessible to all your learners.
5) What feedback have I received? Incorporate user testing into your development process. Getting frequent feedback as you’re creating your course will allow you to fix any areas that aren’t accessible.
Periodic random monitoring will be facilitated by the Universal Access Committee to ensure instructional materials comply with accessibility standards.
Recommendation
To ensure that all instructors are aware of the accessibility standards for instructional materials, Cerritos should each include in their next collective bargaining negotiations a requirement for instructors to periodically attend accessibility trainings.
Response to the recommendation
Cerritos College will work collaboratively with the official representatives of the College’s constituent groups to provide new and current employees training on universal access. This includes, but is not limited to awareness of Board Policy and Administrative Procedure 3411, embedded training during the onboarding process and periodically offer universal access training for flex credit.
Furthermore, Cerritos College will work with the Universal Access Task Force to make available tools, tips, tutorials, and guidelines to all employees to ensure that accessibility is considered at the time of adoption of instructional materials and purchase of information technology products.
Recommendations
Districts and Community Colleges
To ensure the consistent, transparent, and continuous implementation of processes for technology equipment upgrades and replacements, by June 2018, Cerritos should each establish written procedures for these processes.
Response to the recommendation
Cerritos College will update and revise its current technology equipment replacement plan to include written procedures and expand the plan to include equipment within the data center and classroom technology equipment.
Recommendation
To ensure that its technology master plan supports the strategic goals of the district, by June 2018, Cerritos should continue its efforts to update its master plan and should ensure that the plan includes detailed steps to accomplish its goals.
Response to the recommendation
Cerritos College has recently completed and approved its Educational Master Plan (2017-2023). The College is currently working on a request for qualifications (RFQ) in order to update both its Facilities Master Plan and Technology Master with the hopes of integrating both of these plans.
Recommendation
To increase transparency in their annual review processes, by June 2018, Cerritos should each establish procedures requiring their departments to document attendees, input received, and the agreements reaching during meetings to consider instructional technology equipment requests.
Response to the recommendation
In order to increase transparency in the annual planning/review process, Cerritos College will establish a process that will necessitate meeting minutes at both the department and division level where agreements were reached regarding instructional technology equipment.
The annual planning process is well defined starting with department chairs filling out annual Unit Plans. These plans are completed in Program Review Plus, locally developed software. Unit plans are developed by first reviewing program review evidence/data in order to identify Strengths, Weaknesses, Opportunities, or Threats (SWOT). After the department completes the SWOT analysis, the unit sets goals. Activities are then determined by the department to accomplish the goals, which may require resources for personnel, software, equipment, etc. Department meeting minutes will be provided to the division office documenting these discussions. The next several steps in the resource allocation process reinforce the importance of dialogue in decision-making processes at Cerritos College.
Unit plans are submitted to the responsible administrator for the Division (Dean/ Director). This begins the development of the Division Plan. The division manager will review the Unit Plans submitted and build the Division plan from the contents submitted from the Units; and add Division needs identified through the program review process for non-instructional/administrative offices. Deans will be able to reference this discussion by documenting division level dialogue during their monthly division meeting. Division meeting minutes, along with department meeting minutes, will be available for review by the Vice President(s) of the area.
Comments
CALIFORNIA STATE AUDITOR’S COMMENTS ON THE RESPONSE FROM
CERRITOS COMMUNITY COLLEGE DISTRICT
To provide clarity and perspective, we are commenting on the response to our audit from Cerritos. The number below corresponds to the number we have placed in the margin of Cerritos’ response.
Although Cerritos indicates some actions it plans to take to address our recommendation, its response does not specify whether it intends to establish the procedures we recommended. We look forward to reviewing the documentation it provides with its future responses that report on its progress in implementing this recommendation.
Foothill–De Anza Community College District
November 9, 2017
Elaine M. Howle, State Auditor
California State Auditor
621 Capitol Mall, Suite 1200
Sacramento, CA 95814
RE: California State Auditor’s Report No. 2017-102
Dear Ms. Howle,
Attached is the response from Foothill-De Anza Community College District
(De Anza College), to the California State Auditor’s Report No. 2017-102
draft report. We sincerely appreciate the work of the CSA audit team
members in their development of the audit findings
and recommendations.
Foothill-De Anza Community College District would like to thank the
California State Auditor for the opportunity to respond to the draft
report.
Sincerely,
Kevin McElroy
Vice Chancellor, Business Services
Foothill-De Anza Community College District 12345 El Monte Road
Los Altos Hills, CA 94022
650-949-6201
Attachment
Cc: Judy C. Miner, Chancellor, Foothill-De Anza Community College District
Brian Murphy, President, De Anza College
Joe Moreau, Vice Chancellor, Technology
Lorrie Ranck, Associate Vice President, Instruction
Marisa Spatafore, Associate Vice President, Communication and External
Relations
Susan Cheu, Vice President, Finance and College Operations
Rob Mieso, Associate Vice President, Student Services
Stacey Shears, Division Dean, Disabled Student Programs and Services (DSPS)
Recommendations
Community Colleges
Foothill-De Anza Community College District Response:
Foothill-De Anza is in agreement with this recommendation and will take steps necessary to implement the recommendation by June 2018.
To ensure that they promptly address any complaints they receive related to web accessibility and alternate media requests, by June 2018, REDACTED REDACTED REDACTED REDACTED REDACTED REDACTED REDACTED REDACTED REDACTED REDACTED REDACTED REDACTED. Additionally, De Anza should follow its new procedures for tracking and reviewing complaints related to accessibility.Foothill-De Anza Community College District Response:
Foothill-De Anza is in agreement with this recommendation and will take steps necessary to implement the recommendation by June 2018.
To ensure that students with disabilities have equal access to instructional materials, by June 2018, REDACTED De Anza should each develop procedures to monitor and periodically review the accessibility of instructional materials. For example, the college could develop an accessibility checklist for instructors to complete when developing or settling instructional materials, from which the college could periodically review a sample of course content to ensure instructors completed the checklist and that the instructional materials comply with accessibility standards.Foothill-De Anza Community College District Response:
De Anza College has an accessibility checklist in place for use in peer review of online courses. In response to this recommendation, we will revise this checklist for broader instructional use and work in collaboration with Academic Senate on a process to periodically review a sample of courses in various modalities for accessibility of instructional materials.
To ensure that their websites comply with accessibility standards, by June 2018, REDACTED De Anza should each develop procedures to monitor website accessibility and incorporate steps to prevent instructors from publishing inaccessible content on their respective websites. These procedures should include a tracking mechanism to demonstrate how many accessibility errors each college identifies and how long it takes to fix those errors.Foothill-De Anza Community College District Response:
The new website, to be launched in early 2018 with the upgraded CMS, will obviate most of the website accessibility concerns. The college will require the approximately 300 decentralized users to ensure compliance before pages and edits are published.
Additional training opportunities will also assist in preventing instructors from posting inaccessible material, as will encouraging instructors to fully utilize the Canvas LMS, as is being done by the Online Education Center. The new website search tool, Funnelback, can search for errors in binary documents such as PDFs.
All other auditor concerns have already been addressed, as follows:
- The following policy statement regarding accessibility has been added to the Office of Communications website at http://www.deanza.edu/communications/web-accessibility:
De Anza College serves a diverse community that values varied experiences and perspectives and strives to fully include everyone. De Anza College strives to ensure that people with disabilities have access to the same services and content available to people without disabilities, including services and content made available through the college’s website.
The Office of Communications provides Accessibility Guidelines for website content providers collegewide. The college also ensures accessibility is a featured topic in trainings on the content management system (CMS). Accessibility experts are members of the college Technology Committee, for which accessibility is a standing agenda item. You may also read the Office of Communication's procedures for managing accessibility-related website improvements.
If you have a concern or question regarding accessibility of De Anza College website content, please email the Web Team at webteam@deanza.edu.
- The above-mentioned Office of Communications' procedures for ensuring website accessibility are:
In fulfilling standard Web Team work
- Prior to webpage publication, performing a check, using Tenon or a similar tool, and making any remaining changes.Monthly
- Performing a monthly, automated accessibility scan on the website, recording results into a spreadsheet, evaluating the concerns, and providing and recording corrective action. Month-to-month results analyses are also performed.
- Accessibility-related emails, phone calls or other contacts are recorded on a spreadsheet for action by the Web Team.
Other
- In working with vendors, ensuring that products meet accessibility standards. A spreadsheet to be maintained by the senior web coordinator now tracks errors noted by the multiple accessibility tools he uses, way(s) addressed, and speed of response.
To ensure that all instructors are aware of the accessibility standards for instructional materials, REDACTED De Anza, REDACTED should each include in their next collective bargaining negotiations a requirement for instructors to periodically attend accessibility trainingsFoothill-De Anza Community College District Response:
Per the recommendation, the college will discuss required accessibility training for faculty during contractual negotiations.
Recommendations
District and Community Colleges
To ensure the consistent, transparent, and continuous implementation of processes for technology equipment and replacements, by June 2018, REDACTED Foothill-De Anza REDACTED REDACTED should each establish written procedures for these processes.Foothill-De Anza Community College District Response:
Foothill-De Anza is in agreement with this recommendation and will take steps necessary to implement the recommendation by June 2018.
To increase transparency in their annual review processes, by June 2018, REDACTED REDACTED De Anza should each establish procedures requiring their departments to document attendees, input received, and the agreements reached during meetings to consider instructional technology requests.Foothill-De Anza Community College District Response:
Foothill-De Anza is in agreement with this recommendation and will take steps necessary to implement the recommendation by June 2018.
Comments
CALIFORNIA STATE AUDITOR’S COMMENTS ON THE RESPONSE FROM
FOOTHILL–DE ANZA COMMUNITY COLLEGE DISTRICT
To provide clarity and perspective, we are commenting on the response to our audit from Foothill–De Anza. The numbers below correspond to the numbers we have placed in the margin of Foothill–De Anza’s response.
We appreciate Foothill–De Anza’s outlining its planned procedures for ensuring website accessibility for its decentralized content management system users and its standard web team work. We look forward to reviewing formal documentation that these procedures have been established and implemented in its future responses that report on its progress in implementing this recommendation.
Los Rios Community College District
November 9, 2017
Elaine M. Howle, CPA State Auditor
621 Capitol Mall, Suite 1200
Sacramento, CA 95814
Re: Technology Audit Draft
Dear Ms. Howle,
The District is in receipt of your office's report on its audit of technology at the Los Rios Community College District and American River College. We appreciate your exhaustive and careful review of our technology practices. The report notes some of our best practices; it also presents a few recommendations for our review. We acknowledge, as an institution of higher education committed to engaging in continuous improvement, that there is always room for improvement and we will endeavor to take your recommendations to heart as we move forward. Enclosed is our response to the recommendations of the report as they relate to Los Rios and American River College.
Sincerely,
Theresa Matista
Vice Chancellor,
Finance & Administration
RESPONSES TO RECOMMENDATIONS ON PAGE 20
Recommendation No. 1: To ensure that they are fulfilling requests for alternative media services from students with disabilities in a timely manner, by June 2018, American River College should establish procedures for monitoring its timeliness in responding to such requests so that it can periodically review its performance in completing the requests. Additionally, American River College should calculate the number of days it takes to complete request, and periodically evaluate its performance against its time frame goal.
Response No. 1: As noted in the report, American River College completed requests for alternate media within its stated goal of two weeks 95% of the time. The data required to make the recommended calculation is readily available and already collected.
As a result, American River College believes it has procedures for monitoring its timeliness and will engage in a periodic review of its performance against its goal and document process.
Recommendation No. 2: To ensure that they promptly address any complaints they receive related to web accessibility and alternate media requests, by June 2018, American River College should establish procedures for tracking and reviewing complaints received related to accessibility and addressing complaints in a timely fashion.
Response No. 2: The Los Rios Community College District identified the need to focus on, and began work on, assuring the accessibility of electronic information technology across the District and its four colleges prior to the Audit. American River College previously added a link on each page of its website that asks if the user has any accessibility issues. While American River College has not received a single complaint about the accessibility of its website through that link, it remains ready, willing, and able to timely respond to any complaint to ensure access to the website materials. American River College will write down this procedure to satisfy this recommendation.
Recommendation No. 3: To ensure that students with disabilities have equal access to instructional materials, by June 2018, American River College should develop procedures to monitor and periodically review the accessibility of instructional materials. For example, the College could develop an accessibility checklist for instructors to complete when developing or selecting instructional materials, from which the College could periodically review a sample of course content to ensure instructors completed the checklist and that the instructional materials comply with accessibility standards.
Response No. 3: The District will undertake the creation of business practices to determine how American River College will monitor and periodically review the accessibility of instructional materials.
Recommendation No. 4: To ensure that their websites comply with accessibility standards, by June 2018, American River College should develop procedures to monitor website accessibility
and incorporate steps to prevent instructors from publishing inaccessible content on their respective websites. These procedures should include a tracking mechanism to demonstrate how many accessibility errors each college identifies and how long it takes to fix those errors.
Response No. 4: American River College currently has software that tracks the accessibility of its website and identifies issues that need correcting and is also in the process of redesigning the website with the goal of addressing these issues. The College will document its practices as suggested by the recommendation.
Recommendation No. 5: To ensure all instructors are aware of the accessibility standards for instructional materials, American River College should include in its next collective bargaining negotiations a requirement for instructors to periodically attend accessibility trainings.
Response No. 5: American River College objects to this recommendation and is not inclined to follow it. First, the method by which colleges engage in instruction is a matter almost exclusively in the purview of institutions of higher education, like American River College, not the Auditor’s office. There are numerous ways of getting this information to the faculty short of requiring forced attendance at mandatory accessibility trainings. For instance, information campaigns can provide this information to all faculty. Furthermore, collective bargaining is an area that is in the purview of the College and the District and the District should not be placed at a disadvantage in the collective bargaining process based on an unfunded mandate of the Auditor’s office that it must include a particular item in its collective bargaining negotiations.
RESPONSES TO RECOMMENDATIONS ON PAGE 40
Recommendation No. 6: To ensure the consistent, transparent, and continuous implementation of processes for technology equipment upgrades and replacements, by June 2018, Los Rios district, and American River, should each establish written procedures for these processes.
Response No. 6: We agree that having guidelines for standard equipment specifications that correlate with certain activities is helpful as well as documenting the communication protocol used by the IT department.
Recommendation No. 7: To ensure that it fully implements its technology master plan, by June 2018, American River should establish an implementation plan with detailed steps for achieving the goals in its technology master plan that it has not yet accomplish. Further, it should develop an implementation plan in conjunction with the development of its future technology master plan.
Response No. 7: American River College agrees that establishing detailed steps for implementing the goals within both its current and future Technology Master Plans would assist the college in achieving these goals. By June 2019, The College will develop an implementation plan/schedule for its current Technology Master Plan as well as incorporate said process into future technology master planning.
Recommendation No. 8: To increase transparency in their annual review processes, by June 2018, American River, should each establish procedures requiring their departments to document attendees, input received, and the agreements reached during meetings to consider instructional technology equipment requests.
Response No. 8: The process faculty use in documenting conversations occurring in department meetings is generally left to each department to determine. Technology needs are just one aspect of what is discussed and reviewed in the development of program and unit plans, let alone the many other items that are the subject of discussion in department meetings so culling just one aspect of those discussions may be viewed as intrusive. In regard to equipment needs, some departments may choose not to attribute a specific request to an individual because the recommendation forwarded is the department’s based upon the consensus of those who participated and/or reviewed. However, the college will work to develop a process whereby the Chair and the Dean are able to verify that all faculty were provided the opportunity for input.
Comments
CALIFORNIA STATE AUDITOR’S COMMENTS ON THE RESPONSE FROM
LOS RIOS COMMUNITY COLLEGE DISTRICT
We provided Los Rios with a redacted draft report that contained only those portions relevant to Los Rios. Therefore, the page numbers Los Rios cites in its response do not correspond to the page numbers in our final report.
Los Rios states that American River believes it has procedures for monitoring its timeliness and will engage in a periodic review of its performance. Here, we acknowledged American River’s plans to have procedures and a reporting tool implemented by October 2017, which was subsequent to the end of our field work. Therefore, we look forward to reviewing the procedures and reporting tool when Los Rios submits its 60-day response in February 2018.
Unfortunately, we cannot verify American River’s claim that it has not received a single complaint about the accessibility of its website. As we state here, American River does not have a process for tracking accessibility complaints submitted by website users or for documenting their resolution. Without a process for tracking and reviewing the resolution of accessibility complaints submitted through its website, American River cannot demonstrate that it is prepared to promptly address and monitor complaints related to website accessibility.
As we state here, although American River offers training in implementing accessible materials as a resource to instructors, it has not required all instructors to take this training. American River’s dean of planning, research, and technology noted that such a requirement would be a collective bargaining issue. We recognize that these negotiations are within the purview of the college and the district. However, as we also state here, without requiring faculty to attend accessibility training, colleges cannot ensure that faculty are aware of their responsibility to comply with accessibility requirements for the instructional materials they use. Moreover, our recommendation does not address the method by which American River engages in instruction, only the accessibility of the materials used, which is a legally mandated requirement.Although Los Rios states that American River will work to develop a process whereby the chair and the dean are able to verify that all faculty were provided the opportunity for input, its response is unclear how it will address the lack of consistent transparency in its annual review process. As we state here, because the community colleges—including American River—have not established procedures for instructional department staff to follow to consistently document the input received, the colleges cannot always demonstrate to stakeholders that their processes are transparent. We look forward to its future responses to better understand American River’s new process for the chair and dean to verify that all faculty were provided the opportunity for input and how this increases the transparency of the input received.