Report 2017-102 Recommendation 5 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 #5 To: Community Colleges Chancellor's Office

To ensure that community colleges' websites comply with accessibility guidelines, by September 2018, the Chancellor's Office should provide guidance to colleges on establishing policies and procedures to monitor the accessibility of their websites. Additionally, by September 2018, the Chancellor's Office should provide guidance on best practices for colleges to use in preventing their websites from containing inaccessible information.

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: Fully Implemented

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: Partially Implemented

Although the Chancellor's Office demonstrated that it provided guidance on best practices for colleges to use in preventing their websites from containing inaccessible information, it did not provide sufficient guidance to colleges on establishing policies and procedures to monitor the accessibility of their websites. The Chancellor's Office's accessibility standard establishes the expectation that all community colleges use and maintain instructional materials consistent with its accessibility standard, and indicated to us that monitoring is an implicit requirement of maintaining materials and ensuring compliance with the law. However, as we discuss on page 20 or our report, two of the three community colleges we reviewed did not have adequate processes to ensure that their websites were accessible to users with disabilities. Therefore, we believe that the monitoring requirement should be made explicitly in guidance, as we recommended.

Auditee did not substantiate its claim of full implementation

Annual Follow-Up Agency Response From October 2019

The Chancellor's Office has provided guidance to the community college system on establishing policies and procedures to monitor the accessibility of their websites. This guidance is included in the CCCCO Information and Communication Technology and Instructional Material Accessibility Standard (Standard) in the Implementation/Responsibilities section. The Standard was introduced to the community college system via a June 19, 2018 memo from Chancellor Eloy Ortiz Oakley.

The Chancellor's Office has also provided guidance on best practices for colleges to use for maintain website accessibility. The California Community Colleges (CCC) Technology Center has developed a CCC Accessibility Center that houses tools designed to support testing and evaluation of website for accessibility issues and promote compliance with Accessibility Standards. A library of training materials and tools has been developed to assist in scaling accessibility education across the system. Full day IT Accessibility workshops are held twice annually. Online self-paced accessibility courses are available on demand and campus trainings are available upon request.

Completion Date: January 2019

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

Although the Chancellor's Office demonstrated that it provided guidance on best practices for colleges to use in preventing their websites from containing inaccessible information, it did not provide sufficient guidance to colleges on establishing policies and procedures to monitor the accessibility of their websites. The Chancellor's Office's accessibility standard establishes the expectation that all community colleges use and maintain instructional materials consistent with its accessibility standard, and indicated to us that monitoring is an implicit requirement of maintaining materials and ensuring compliance with the law. However, because two of the three community colleges we reviewed did not have adequate processes to ensure that their websites were accessible to users with disabilities, as we indicated on page 20 of our report, we believe that the monitoring requirement should be made explicitly in guidance, as we recommended.

Auditee did not substantiate its claim of full implementation

1-Year Agency Response

The California Community Colleges Technology Center has developed a CCC Accessibility Center that houses tools designed to support testing and evaluation of websites for accessibility issues and promotes compliance with Accessibility Standards. The Accessibility Center is working to increase adoption of the CCC Accessibility Standard and expand the usage of accessibility tools by the colleges. Additionally, a library of training materials is being developed to assist in scaling accessibility education across the system. A new training and monitoring program is also being developed that will teach college IT staff how to best perform self assessments in accessibility. The CCC IT Accessibility Workshop is scheduled for the system on January 8, 2019, which includes a featured session for 'Scanning & Monitoring Websites for Accessibility.'

Estimated Completion Date: January 2019
Response Date: December 2018

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

6-Month Agency Response

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. Within the 18/19 school year, the ASWG will be in the process of creating guidance for colleges on establishing policies and procedures to monitor the accessibility of their websites. The ASWG has aggregated resources internal and external to the CCC system and developed guidance for faculty to develop and/or select instructional materials that are accessible to all their students.

Estimated Completion Date: September 2018
Response Date: June 2018

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

60-Day Agency Response

The Butte Community College District's Technology Center has an Accessibility Team responsible for managing website accessibility resources.

Guidance in this area is currently under development.

Estimated Completion Date: September 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.