Report 2017-102 All Recommendation 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 #1 To: Community Colleges Chancellor's Office

To ensure that all community colleges are complying with timeliness requirements, by June 2018, the Chancellor's Office should establish guidance for the colleges on tracking and monitoring their effectiveness in responding to students' requests for instructional materials in alternate media in a timely manner. At a minimum, this guidance should provide direction to all community colleges on establishing a time-frame goal for completing students' requests. The guidance should also provide direction to colleges for establishing procedures to track and periodically monitor their performance in promptly responding to requests, identify reasons for delays in responding to requests, and take action as needed to improve their timeliness in completing future requests.

1-Year Agency Response

The Chancellor's Office has issued guidance to the community college system titled "Addendum to Guidelines for Producing Instructional and Other Printed Materials in Alternate Media for Persons with Disabilities". This guidance clarifies the timeliness of alternate media production, the student request process, and specifics on monitoring college performance related to this task.

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


6-Month Agency Response

A thorough analysis of the issues has been conducted. During a meeting with all college disability directors on 2/28/18, the three colleges who participated in the audit shared their experiences and passed on the guidance that they received from the auditors to all colleges. Also during the meeting, focus groups were convened to discuss what current policies exist with regard to producing alternate media and tracking complaints. The Chancellor's Office staff circulated amongst all participants to gather first-hand the issues the colleges are dealing with.

In addition, a short-term workgroup on alternate media met 3/27 in Cerritos. The group includes accessibility experts, alternate media providers and program directors so that multiple points of view and expertise are incorporated into the development of the policies and guidance on producing and tracking requests for alternate media. The group started by compiling all of the relevant literature, current guidance, and pertinent court cases on the subject. Then existing procedures in use at the colleges were evaluated and compared against the recommendations of the CSA report. Also noted were current legal precedents as listed in a UC Berkeley settlement (University of California, Berkeley campus and Disability Rights Advocates, 2013) and a Cal State Fullerton case (Docket Number 09-03-2166 US Department of Education, Office for Civil Rights v. California State University, Fullerton). There was a second meeting April 16th to further establish the timeliness aspect of the guidance. May 1st another meeting took place to tackle the complaint provisions required to be in the guidance. The draft was finalized and presented to the DSPS Regional Coordinators for comments on May 22. This guidance is scheduled to send out to the field in June.

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

At the time of its response, the Chancellor's Office indicates it expects to send out guidance to the colleges in June. See one-year response provided in late June 2018.


60-Day Agency Response

A thorough analysis of the issues has been conducted.

During a meeting with all college disability directors 2/28/18 the three colleges who participated in the audit will share their experiences and pass on the guidance that they received from the auditors.

Also during the meeting, focus groups will discuss what current policies exist with regard to producing alternate media and tracking complaints.

A short-term workgroup will convene to assist in the development of the guidance for the colleges so that they are consistent across the system and meet the objectives set forth by the auditors.

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


Recommendation #2 To: Community Colleges Chancellor's Office

To ensure that community colleges promptly address any complaints they receive related to alternate media requests and web accessibility, by June 2018, the Chancellor's Office should provide guidance to the community colleges on developing procedures to track and periodically review complaints received related to accessibility services, and to address any accessibility complaints in a timely fashion.

1-Year Agency Response

The Chancellor's Office has issued guidance to the community college system titled "Addendum to Guidelines for Producing Instructional and Other Printed Materials in Alternate Media for Persons with Disabilities". This guidance clarifies the timeliness of alternate media production, the student request process, and specifics on monitoring college performance related to this task.

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


6-Month Agency Response

A thorough analysis of the issues has been conducted. During a meeting with all college disability directors on 2/28/18, the three colleges who participated in the audit shared their experiences and passed on the guidance that they received from the auditors to all colleges. Also during the meeting, focus groups were convened to discuss what current policies exist with regard to producing alternate media and tracking complaints. The Chancellor's Office staff circulated amongst all participants to gather first-hand the issues the colleges are dealing with.

In addition, a short-term workgroup on alternate media met 3/27 in Cerritos. The group includes accessibility experts, alternate media providers and program directors so that multiple points of view and expertise are incorporated into the development of the policies and guidance on producing and tracking requests for alternate media. The group started by compiling all of the relevant literature, current guidance, and pertinent court cases on the subject. Then existing procedures in use at the colleges were evaluated and compared against the recommendations of the CSA report. Also noted were current legal precedents as listed in a UC Berkeley settlement (University of California, Berkeley campus and Disability Rights Advocates, 2013) and a Cal State Fullerton case (Docket Number 09-03-2166 US Department of Education, Office for Civil Rights v. California State University, Fullerton). There was a second meeting April 16th to further establish the timeliness aspect of the guidance. May 1st another meeting took place to tackle the complaint provisions required to be in the guidance. The draft was finalized and presented to the DSPS Regional Coordinators for comments on May 22. This guidance is scheduled to send out to the field in June.

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

At the time of its response, the Chancellor's Office indicates it expects to send out guidance to the colleges in June. See one-year response in late June 2018.


60-Day Agency Response

A thorough analysis of the issues has been conducted.

During a meeting with all college disability directors 2/28/18 the three colleges who participated in the audit will share their experiences and pass on the guidance that they received from the auditors.

Also during the meeting, focus groups will discuss what current policies exist with regard to producing alternate media and tracking complaints.

A short-term workgroup will convene to assist in the development of the guidance for the colleges so that they are consistent across the system and meet the objectives set forth by the auditors.

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


Recommendation #3 To: Community Colleges Chancellor's Office

To comply with statutory reporting requirements on its efforts to serve students with disabilities, by June 2018, the Chancellor's Office should establish and report on a system for evaluating state-funded programs and services for disabled students, including its gathering of outcome data, staff and student perceptions of program effectiveness, and data on the implementation of the program.

Annual Follow-Up Agency Response From October 2020

The Chancellor's Office, on June 15, 2020, submitted a legislative report on Disabled Student Program and Services (DSPS) in response to Education Code section 67132(b). The report reflects the 2017-18 and 2018-19 academic years and contains data on the four elements mandated by legislation, staff and student perception of program effectiveness, data on the implementation of the program, physical accessibility requirements and outcome data.

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


Annual Follow-Up Agency Response From December 2018

The Chancellor's Office has established a system for evaluating state-funded programs and services for disabled students. The "CCCCO DSPS Program Plan" establishes a survey that collects implementation and outcome data as well as faculty and staff perceptions of program effectiveness. This evaluation process was presented to the community college system at our annual conference, California Association for Post-secondary Education and Disability (CAPED) October 18-22.

The plan includes the following Each college will be required to complete the staff and student survey every two years and the entire evaluation plan will be completed for each college every five years as required by Section 67312. This will become the basis for the biennial legislative report.

After all initial survey data is received in June 2019, a group of experienced practitioners will review the reports and calibrate the results using a uniform scale. Those colleges that fall significantly below the mean will be identified for follow-up by means of counseling or direct on-site technical assistance as the circumstances warrant. Districts/colleges not selected for follow-up assistance will be deemed to have successfully completed the evaluation process for the current cycle. A summary of the data will be incorporated into the 2020 legislative report.

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

The Chancellor's Office has not yet fully implemented this recommendation. As it indicates in its response, the Chancellor's Office expects to receive initial survey data from the districts in June 2019, and further expects to report on that data to the Legislature in 2020.


1-Year Agency Response

The Chancellor's Office has established a system for evaluating state-funded programs and services for disabled students. The "CCCCO DSPS Program Plan" establishes a survey that collects implementation and outcome data as well as faculty and staff perceptions of program effectiveness. This evaluation process will be presented to the community college system at our annual conference, California Association for Post-secondary Education and Disability (CAPED) October 18-22.

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

The DSPS Program Plan provided to us by the Chancellor's Office shows the survey that the Chancellor's Office proposes to use to collect data on program effectiveness. However, the program plan does not address how it plans to report on the data it collects, as we recommended it should do.


6-Month Agency Response

A thorough analysis of the issues has been conducted. During a meeting with all college disability directors 2/28/18 the three colleges who participated in the audit shared their experiences and passed on the guidance that they received from the auditors to all colleges. Also during the meeting, focus groups were convened to discuss what current policies exist with regard to producing alternate media and tracking complaints. The Chancellor's Office staff circulated amongst all participants to gather first-hand the issues the colleges are dealing with. In addition:

- The plan to evaluate state-funded programs and services for disabled students is in progress. The findings from the meeting 2/28/18 were summarized and will be included in the next biennial report to capture staff perceptions of the program. We discovered that the majority of our colleges have an annual student survey so we will collect the student perceptions of the program that way.

- A survey used to gather data on what the colleges are already reporting on and the cycle of each college's reaccreditation visit, will form the basis of the plan that each college will follow to contribute to future biennial program reports.

- A task force was chosen to piece together the components being measured into a cohesive, sustainable plan that each college can execute regardless of fluctuations in funding. This task force met May 4th in Sacramento. The group consists of practitioners who have a research background as well as a student with disabilities. It also demonstrates a cross-section of colleges from the small, single college districts to large multiple college districts. There was a follow up meeting May 18th where the group discussed the options for program evaluation. The next meeting is June 6th where it is expected that a complete draft will be proposed. The final meeting is June 15th which will include the plan on how to disseminate the guidance to the field.

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


60-Day Agency Response

A thorough analysis of the issues has been conducted.

During a meeting with all college disability directors 2/28/18 the three colleges who participated in the audit will share their experiences and pass on the guidance that they received from the auditors.

A plan to evaluate state-funded programs and services for disabled students is underway. The findings from the meeting 2/28/18 will help inform the data gathering.

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


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.

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.


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.

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.


Annual Follow-Up Agency Response From October 2019

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.

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.

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.

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.


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.

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.


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.

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.

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


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.

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


Annual Follow-Up Agency Response From October 2019

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.

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.

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.

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.


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.

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.


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.'

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.

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.

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


Recommendation #6 To: Community Colleges Chancellor's Office

To assist all community college districts and colleges in ensuring that they have consistent, transparent, and continuous implementation of their processes for upgrading and replacing IT equipment, by September 2018, the Chancellor's Office should issue guidance to the districts and community colleges on establishing written procedures for those processes.

Annual Follow-Up Agency Response From December 2018

The Chancellor's Office 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 response to the request for Chancellor's Office guidance to be issued to the districts and community colleges, the Chancellor's Office requested the ASWG to develop guidance policies for an Information and Communication Technology and Instructional Material Accessibility Standard. This standard provides recommendations. Information and Communication Technology (ICT) encompasses electronic and information technology as well as telecommunications products. ICT products include computers, information kiosks, telecommunications equipment, multifunction office machines, software, websites, and electronic documents. The standard serves as the Chancellor's Office guidance to the districts. As of November 2018, the standard includes implementation guidance stating "The CCCCO recommends that districts establish written procedures for the compliance process."

The Chancellor's Office expects all California Community Colleges to comply with state and federal law and the ASWG provides a framework and reference as a guide to compliance.

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

Based on our follow-up request, the Chancellor's Office provided documentation showing that the guidance described in its response was distributed electronically to the community college system in January 2019.


1-Year Agency Response

The Board of Governors for the California Community Colleges Chancellor's Office allocates state funding and provides leadership and technical assistance to the 73 districts in the system. The districts, in turn, provide leadership to the 115 colleges and are responsible for establishing policies and procedures for the upgrading and replacing of IT equipment.

The Chancellor's Office 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 response to the request for Chancellor's Office guidance to be issued to the districts and community colleges, the Chancellor's Office requested the ASWG to develop guidance policies for an Information and Communication Technology and Instructional Material Accessibility Standard. This standard provides recommendations. Information and Communication Technology (ICT) encompasses electronic and information technology as well as telecommunications products. ICT products include computers, information kiosks, telecommunications equipment, multifunction office machines, software, websites, and electronic documents. The standard serves as the Chancellor's Office guidance to the districts.

The Chancellor's Office expects all California Community Colleges to comply with state and federal law and the ASWG provides a framework and reference as a guide to compliance.

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

Our review of the standards provided by the Chancellor's Office did not identify guidance to the districts for establishing written procedures, as we recommended. When we followed up on our concern, the Chancellor's Office indicated it would address this point in its one-year response.


6-Month Agency Response

The Chancellor's Office is developing guidance to the districts and community colleges on establishing written procedures for those processes.

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


60-Day Agency Response

A proposal is under development to bring before the Board of Governors to adopt the following STANDARDS, EVALUATION CRITERIA, and BEST PRACTICES from the Telecommunications and Technology Advisory Committee (TTAC) and Systemwide Architecture Committee (SAC). These include the following:

- Evaluation Criteria

o Feasibility Study

o Suitability for systemwide deployment

o Life cycle plan for components

o Goals versus functionality

o Adherence to published standards

o Exposure to risk

o Outsourcing

o Funding and resource support

- Standards

o A technology feasibility study must be conducted before significant project funds are committed.

o Data transfer

o System (Application, Hardware, Network Operating Systems, etc.)

o End user compatibility

o Databases and DBMS

o Query and Report Writing Tools

o Security

o System configuration and operating procedures

o Vendor provided systems and components

o Deviations

- Best Practices

o Components should be chosen which have a significant market share within industry and / or the community college system.

o Components should be available and supportable in the Community College System

o Components should be chosen in which the vendor has implemented an active product improvement program

o Project managers should solicit broad based input

o Components should be chosen that are not at the end of their natural life cycle

- Recommended Tools

o Databases

o Server Operating Systems

o Web Servers

o Report Writers / environments

o Programming Languages

o Programming Environments

o Web Development Tools

o Middleware

o Office Applications

o ADA Evaluations

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


Recommendation #7 To: Community Colleges Chancellor's Office

To assist all community colleges in increasing transparency of their shared governance decision-making processes, by September 2018, the Chancellor's Office should issue guidance to the community colleges on establishing procedures to document the attendees, input received, and agreements reached during department meetings, including those to consider technology equipment requests.

Annual Follow-Up Agency Response From October 2020

see response provided for June 2018 update.

California State Auditor's Assessment of Annual Follow-Up Status: Will Not Implement

As we previously stated in our response to the Chancellor's Office response from June 2018: We did not recommend that the Chancellor's Office dictate details of the local shared governance policies and procedures as the Chancellor's Office response states. Instead, our recommendation is for the Chancellor's Office to issue guidance to the community colleges on establishing procedures to document the attendees, input received, and agreements reached during department meetings, including those to consider technology equipment requests. We believe the guidance is important; as we state on page 39 of our report, because the community colleges 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 therefore stand behind our recommendation.


1-Year Agency Response

see response provided June 2018.

California State Auditor's Assessment of 1-Year Status: Will Not Implement

As we previously stated in our response to the Chancellor's Office response from June 2018: We did not recommend that the Chancellor's Office dictate details of the local shared governance policies and procedures as the Chancellor's Office response states. Instead, our recommendation is for the Chancellor's Office to issue guidance to the community colleges on establishing procedures to document the attendees, input received, and agreements reached during department meetings, including those to consider technology equipment requests. We believe the guidance is important; as we state on page 39 of our report, because the community colleges 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 therefore stand behind our recommendation.


6-Month Agency Response

The Board of Governors has established, by legislation, minimum standards for local shared-governance decision making processes consistent with Education Code Section 70901(b)(1)(E). The practical details of local shared governance processes, including procedures to document attendee input and agreements reached at department meetings, are a matter of local authority and control in the community college system. It would not be appropriate or practicable for the Chancellor's Office to dictate the details of the local shared governance policies and procedures. Accordingly, the Chancellor's Office declines the invitation to issue general guidance to the community colleges on the transparency of local shared governance decision-making processes.

California State Auditor's Assessment of 6-Month Status: Will Not Implement

We did not recommend that the Chancellor's Office dictate details of the local shared governance policies and procedures as the Chancellor's Office response states. Instead, our recommendation is for the Chancellor's Office to issue guidance to the community colleges on establishing procedures to document the attendees, input received, and agreements reached during department meetings, including those to consider technology equipment requests. We believe the guidance is important; as we state on page 39 of our report, because the community colleges 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 therefore stand behind our recommendation.


60-Day Agency Response

To implement this recommendation the Chancellor's Office will consider engaging an ad hoc workgroup comprised of Consultation Council members to develop a set of guidelines that would be adopted by the Board of Governors and distributed to colleges. These guidelines would explained in a series of webinars and conference presentations as well as being posted on the Chancellor's Office website. This recommendation needs to be vetted in the Chancellor's Cabinet and implemented at the executive level.

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


Recommendation #8 To: Cerritos Community College District

To ensure that it is fulfilling requests for alternate media services from students with disabilities in a timely manner, by June 2018, Cerritos should 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 it takes to complete requests. Additionally, Cerritos should calculate the number of days it takes to complete requests, and periodically evaluate its performance against its time-frame goals.

1-Year Agency Response

Cerritos College has developed standard operating procedures to ensure equal access to instructional materials for qualified students with disabilities. The procedures include college catalogs, course schedules, textbooks and other printed course materials in alternate formats. The Universal Access Taskforce is reviewing the alternate media procedures for finalization. The Taskforce has also developed an Equally Effective Alternative Access Plan which will ensure compliance with the California Government Code Section 11135 and Section 508. A copy of the procedure and plan will be provided. See attachments for supporting documents.

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

The operating procedures provided to us by Cerritos contain provisions for it to track the time to complete alternate media requests, to analyze the timeliness of addressing requests periodically, and to make programmatic changes to achieve necessary improvements.


6-Month Agency Response

Cerritos College has drafted standard operating procedures to ensure equal access to instructional materials for qualified students with disabilities. The procedures include college catalogs, course schedules, textbooks and other printed course materials in alternate formats. The Universal Access Taskforce is reviewing the alternate media procedures for finalization. The Taskforce has also drafted an Equally Effective Alternative Access Plan which will ensure compliance with the California Government Code Section 11135 and Section 508. A copy of the procedure and plan will be provided.

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


60-Day Agency Response

Meetings are begun to discuss the DSPS internal processes, and tools that we will use to develop and track timely delivery of alternate media. The Universal Access Task Force is meeting February 2, 2018 to develop a plan for implementation.

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


Recommendation #9 To: Cerritos Community College District

To ensure that it promptly addresses any complaints it receives related to web accessibility and alternate media requests, by June 2018, Cerritos should establish procedures for tracking and reviewing complaints received related to accessibility and addressing complaints in a timely fashion.

1-Year Agency Response

The Office of Public Affairs developed and implemented an operating procedure that maintains an accessible website for all users. The procedure ensures a web presence that is accessible, Cerritos College adheres to Web Content Accessibility Guidelines (WCAG) 2.0 level AA and Section 508 of the U.S. Rehabilitation Act. Additionally, Cerritos College implemented a new software program called "Omni Update Insights Module" that measures web effectiveness by using a proprietary scoring mechanism related to four key areas: 1. accessibility, 2 search engine optimization, 3. spelling, and 4. web links. A copy of the procedure will be provided.

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

The operating procedures provided to us by Cerritos contain provisions for it to record and track complaints, and identify the staff at Cerritos responsible for responding to and resolving the identified issues. Cerritos also provided documentation showing its progress in resolving accessibility issues identified on its website.


6-Month Agency Response

The Office of Public Affairs developed and implemented an operating procedure that maintains an accessible website for all users. The procedure ensures a web presence that is accessible, Cerritos College adheres to Web Content Accessibility Guidelines (WCAG) 2.0 level AA and Section 508 of the U.S. Rehabilitation Act. A copy of the procedure will be provided.

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

Cerritos indicated it would provide documentation to support its response to this recommendation with its one-year response. We will evaluate the status of its implementation at that time.


60-Day Agency Response

Cerritos is working on expanding existing student conduct, grievance, concern, or Title IX report submission and case management SaaS, Maxient, to include a category or categories for web accessibility- and alternate media request-related complaints. Cerritos is currently updating its website which will provide better web accessibility monitoring.

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


Recommendation #10 To: Cerritos Community College District

To ensure that students with disabilities have equal access to instructional materials, by June 2018, Cerritos should develop procedures to monitor and periodically review the accessibility of instructional materials. For example, Cerritos 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 that instructors completed the checklist and that the instructional materials comply with accessibility standards.

Annual Follow-Up Agency Response From October 2019

Cerritos College and Faculty Senate developed professional learning opportunities to all faculty while also providing a comprehensive information location of faculty resources through the Teaching Excellence (CTX) program. CTX is operated through Faculty Senate to provide new and current employees training on universal access. Trainings are provided to faculty regarding related areas such as accessibility, ensuring instructional materials are accessible and video captioning.

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

Cerritos provided its procedure describing its steps to periodically review the accessibility of instructional materials, as we recommended.


1-Year Agency Response

Cerritos College and Faculty Senate developed professional learning opportunities to all faculty while also providing a comprehensive information location of faculty resources through the Teaching Excellence (CTX) program. CTX is operated through Faculty Senate to provide new and current employees training on universal access.

CTX has provided trainings to faculty regarding related areas such as accessibility, ensuring instructional materials are accessible and video captioning. See supporting documents.

California State Auditor's Assessment of 1-Year Status: No Action Taken

Cerritos' one-year response does not address developing procedures to monitor and periodically review the accessibility of instructional materials. In its six-month response, the college indicated that it was working with the Faculty Senate on developing procedures to monitor and periodically review these materials. However, this response indicates the development of learning opportunities for faculty and for training, but does not include developing procedures to monitor and periodically review the accessibility of instructional materials as we recommended.


6-Month Agency Response

Cerritos College has been working with the Faculty Senate on developing procedures to monitor and periodically review the accessibility of instructional materials. No plan has been developed at this time.

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


60-Day Agency Response

Meeting have begun to discuss the need for accessible instructional materials. No plan has been developed at this time.

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


Recommendation #11 To: Cerritos Community College District

To ensure that all instructors are aware of the accessibility standards for instructional materials, Cerritos should include in its next collective bargaining negotiations a requirement for instructors to periodically attend accessibility trainings.

Annual Follow-Up Agency Response From November 2020

Cerritos College and Faculty Senate have developed professional learning opportunities to all faculty while also providing a comprehensive information location of faculty resources through the Teaching Excellence (CTX) program. CTX is operated through Faculty Senate to provide new and current employees training on universal access. CTX has provided trainings to faculty regarding related areas such as accessibility, ensuring instructional materials are accessible and video captioning.

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

Although Cerritos discusses developing learning opportunities for faculty and providing trainings on accessibility, its response does not describe requiring all instructors to attend trainings or including such a requirement as part of the collective bargaining agreement. As we state on page 23 of our report, 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. Thus, Cerritos' response does not address our recommendation.


Annual Follow-Up Agency Response From October 2019

Cerritos College and Faculty Senate worked on developing professional learning opportunities to all faculty while also providing a comprehensive information location of faculty resources through the Teaching Excellence (CTX) program. CTX is operated through Faculty Senate to provide new and current employees training on universal access. CTX has provided trainings to faculty regarding related areas such as accessibility, ensuring instructional materials are accessible and video captioning.

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

Although Cerritos discusses developing learning opportunities for faculty and providing trainings on accessibility, it's cover letter to us stated that it did not mandate trainings and did not include as part of the collective bargaining agreement. As we state on page 23 of our report, 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. Thus, Cerritos' response does not address our recommendation.


1-Year Agency Response

Cerritos College and Faculty Senate worked on developing professional learning opportunities to all faculty while also providing a comprehensive information location of faculty resources through the Teaching Excellence (CTX) program. CTX is operated through Faculty Senate to provide new and current employees training on universal access.

CTX has provided trainings to faculty regarding related areas such as accessibility, ensuring instructional materials are accessible and video captioning. See supporting documents.

California State Auditor's Assessment of 1-Year Status: No Action Taken

Although Cerritos discusses developing learning opportunities for faculty and provided trainings on accessibility, it does not indicate a requirement for instructors to periodically attend accessibility trainings. As we state on page 23 of our report, 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. Thus, Cerritos' response does not address our recommendation.


6-Month Agency Response

Cerritos College has met with representatives of the College's constituent groups and Faculty Senate to provide new and current employees training on universal access.

Cerritos College continues to 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.

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


60-Day Agency Response

Cerritos College has met with 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. Cerritos College is working 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.

However, it is unrealistic to include this in a collective bargaining agreement without negatively impacting the general operations budget.

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

We appreciate the efforts that Cerritos is taking to address our recommendation and look forward to reviewing documentation of its efforts in June 2018. However, as we state on page 23 of our report, 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. Therefore, we stand by our recommendation that Cerritos should include in its next collective bargaining negotiations a requirement for instructors to periodically attend accessibility trainings.


Recommendation #12 To: Cerritos Community College District

To ensure the consistent, transparent, and continuous implementation of processes for technology equipment upgrades and replacements, by June 2018, Cerritos should establish written procedures for those processes.

1-Year Agency Response

Cerritos College has developed a technology equipment replacement plan which includes written procedures that include equipment within the data center and classroom technology equipment. Cerritos College has also created a technology equipment database of equipment within the data center and other areas throughout the campus. A copy of the written procedure and database will be provided.

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


6-Month Agency Response

Cerritos College has developed a technology equipment replacement plan which includes written procedures that include equipment within the data center and classroom technology equipment. Cerritos College has also created a technology equipment database of equipment within the data center and other areas throughout the campus. A copy of the written procedure and database will be provided.

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

Cerritos indicated it would provide documentation to support its response to this recommendation with its one-year response. We will evaluate the status of its implementation at that time.


60-Day Agency Response

Cerritos College is working on updating and revising 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.

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


Recommendation #13 To: Cerritos Community College District

To ensure that its technology master plan supports the strategic goals of the district, Cerritos should update its master plan by June 2018, and should ensure that the plan includes detailed steps to accomplish its goals.

Annual Follow-Up Agency Response From November 2020

Cerritos College has updated its Facilities Master Plan as of June 2019 and the Technology Master Plan was completed as of April 2020. Cerritos College has developed a prioritization of the projects outline in the plan and is ready to begin. Work has already began but Cerritos College will be hiring a project management team to assist in the implementation of the plan. This is anticipated to be approved in January 2021.

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

Cerritos College has not provided documentation for our review that supports its assertion of full implementation of this recommendation.


Annual Follow-Up Agency Response From October 2019

Cerritos College has updated its Facilities Master Plan as of June 2019 and currently is under contract and currently working on updating the Technology Master Plan. This master plan will integrate into the Educational Master Plan and Facilities Master Plan. This master plan is will be completed by the end of January 2020.

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


1-Year Agency Response

Cerritos College is under contract and currently working on updating the Facilities Master Plan and Technology Master Plan that will integrate into the Educational Master Plan. As noted in the master plan timeline which I have will include as supporting documentation, the master plan is to be completed by the end of the 2018-19 academic term May 2019.

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


6-Month Agency Response

Cerritos College issued a Request for Qualifications (RFQ) to update the Facilities Master Plan and Technology Master Plan that will integrate into the Educational Master Plan. The RFQ responses were due May 22, 2018. Currently the committee is reviewing the proposals for interview and recommendation for approval to the Board of Trustees by July 2018. The master plans will take approximately 3 - 6 months to complete.

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


60-Day Agency Response

Cerritos College is finalizing its 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. The goal is to have the RFQ released in February 2018.

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


Recommendation #14 To: Cerritos Community College District

To increase the transparency of its annual review process, by June 2018, Cerritos should establish procedures requiring its departments to document attendees, input received, and agreements reached during meetings to consider instructional technology equipment requests.

Annual Follow-Up Agency Response From November 2020

The planning process is well defined written process starting with department chairs filling out annual Unit Plans. These plans are completed in our planning system called "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. Cerritos College believes its annual review process is open and transparency and well established. Annually during our shared governance meeting - "Planning and Budget Committee" we discuss ways in improving the process. Evaluate what works and what does not. Cerritos College has implemented the recommendation above.

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

Cerritos did not provide documentation showing it has established procedures requiring its departments to document attendees, the input received, and the agreements reached during meetings to consider instructional technology equipment requests.


Annual Follow-Up Agency Response From October 2019

The 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.

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

Cerritos did not provide documentation showing it has established procedures requiring its departments to document attendees, the input received, and the agreements reached during meetings to consider instructional technology equipment requests.


1-Year Agency Response

The annual planning process for 2018-19 is complete. The 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.

Supporting documentation will be submitted.

California State Auditor's Assessment of 1-Year Status: No Action Taken

The documentation provided by Cerritos College does not include procedures requiring its departments to document attendees, the input received, and the agreements reached during meetings to consider instructional technology requirement requests.


6-Month Agency Response

The annual planning process for 2018-19 is complete. The 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.

Supporting documentation will be submitted.

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

Cerritos indicated it would provide documentation to support its response to this recommendation with its one-year response. We will evaluate the status of its implementation at that time.


60-Day Agency Response

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.

Supporting documentation will be submitted to better show this process by June 30, 2018.

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


Recommendation #15 To: Foothill-De Anza Community College District

To ensure that it is fulfilling requests for alternate media services from students with disabilities in a timely manner, by June 2018, De Anza should establish procedures for monitoring its timeliness in responding to such requests so that it can periodically review its performance in completing the requests. Specifically, it should record and track sufficient information to be able to review how long it takes to complete requests. Additionally, De Anza should calculate the number of days it takes to complete requests, and periodically evaluate its performance against its time-frame goals. Further, to evaluate its performance, De Anza should establish a time-frame goal for completing alternate media requests.

Annual Follow-Up Agency Response From October 2022

A DSPS student requesting alternative media services accesses Clockwork through De Anza's MyPortal. Specifically, Clockwork sends an automated module to track alternative media requests from students. Once the request is submitted, they automatically receive a confirmation email that their request has been submitted, another for when it has been accepted, an additional email when their request is pending, and lastly when the request has been completed. This keeps students aware of the timeline of their request.

Specifically, Clockwork captures the exact time email notifications are sent out to students in response to their requests. The emails give details to the approximate turnaround time for alternative media accommodations. Processing requests through the alternative media student module in Clockwork tracks the time-frame goal, which can be exported as reports for evaluation. The Alternative Media Specialist and DSPS supervisor meet periodically to evaluate the performance of these requests and address any issues for improvement.

Regarding tracking timeliness, now that many students are back on campus, the Alt Media Specialist has instructed that they bring in their books to her so that she can scan in their books if the publisher does not respond within a timely manner during the first week of the quarter. She also maintains a spreadsheet of student requests in addition Clockwork to tracking this.

The "Instructions for Making an Alternative Media Requests" online guide https://www.deanza.edu/dsps/dss/alt_media.html addresses all alt media processes and procedures, along with step-by-step instructions for making a request through Clockwork. Additionally, DSPS students can access alt media information in Canvas. This Canvas shell is updated every quarter by Alternative Media Specialist.

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

De Anza's response does not fully address our recommendation. Although De Anza established time-frame goals for completing alternate media requests and procedures to fulfill students' alternate media requests, our recommendation was to establish procedures for monitoring its timeliness in responding to such requests so that it can periodically review its performance in completing the requests. De Anza also did not provide documentation demonstrating that it compared its timeliness in completing the requests to time-frame goals, as we recommended.


Annual Follow-Up Agency Response From October 2021

From De Anza College Disability Support Programs and Services (DSPS) Division (2021):

We continue to utilize Clockwork and have built an automated module to track alternative media requests from students, when they make a request via MyPortal. When a student submits a request, the automated email template triggers a confirmation email to the student when their request has been submitted, accepted, pending and completed.

For example, the Alternative Media Specialist receives the request, works with the student to meet their alternative media needs, and documents in Clockwork when the request is completed. By using Clockwork to monitor all alternative media requests and completions, we can accurately track request and completion times.

Clockwork captures the exact time of notifications sent out to students as their request is handled. The initial email sent out to student states the approximate turnaround time for alternative media accommodation. Processing requests through the alternative media student module in Clockwork tracks the time-frame goal, which can be exported as reports for evaluation. The Alternative Media Specialist and DSPS supervisor continue to meet periodically to evaluate the performance of these requests and address any issues for improvement.

The DSPS dean, counselors and staff collaboratively created a student guide to assist with the new alternative media procedures and requests, titled "Instructions for Making an Alternative Media Requests." This guide provides terminology that students should know and step-by-step instructions for making a request through Clockwork (instead of using direct email). Our Alternative Media Specialist has also developed a Canvas course shell that is provided to new students requesting alt media accommodations. The Instructional Guide has been added to this landing page with additional resources and information. https://www.deanza.edu/dsps/dss/alt_media.html

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

De Anza's response does not fully address our recommendation. Although De Anza established time-frame goals for completing alternate media requests and procedures to fulfill students' alternate media requests, our recommendation was to establish procedures for monitoring its timeliness in responding to such requests so that it can periodically review its performance in completing the requests. De Anza also did not provide documentation demonstrating it compared its timeliness in completing the requests against time-frame goals, as we recommended.


Annual Follow-Up Agency Response From October 2019

De Anza College has developed procedures to fulfill requests for alt media services from students with disabilities through the following:

De Anza had formed a task force for review and implementation of procedures to such items as course textbooks, college catalogs, course syllabi, and other printed course materials in alternate media format as needed.

The Alternate Media Specialist uses Clockwork to track all alternate media requests which includes showing the duration between the initial request and completion of the request. See attached "Alternative Media-DA Update".

The DSPS Supervisor meets with the Alternate Media Specialist monthly to evaluate the performance against the time frame goal for completing alternate media requests, and jointly works on alternative solutions should an issue arise. Note: These meetings met twice per month when the process was being improved, moving to once per month once implementation was completed. Supporting evidence with calendar appointments recorded in Clockwork (under appointments labeled "Touch base").

In addition, a goal to track students' alternative media requests via Clockwork against the length of time it takes for the student to receive completed alternative media materials. See attached document, "Fall 2018 Alt Media Completion"

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

De Anza's response does not address our recommendation. Although its response describes procedures to fulfill students' alternate media requests, our recommendation focused on establishing procedures for monitoring its timeliness in responding to such requests so that it can periodically review its performance in completing the requests. De Anza also did not provide documentation demonstrating it compared its timeliness in completing the requests against time-frame goals, as we recommended. In follow-up correspondence, De Anza stated that moving forward, it will work on getting procedures established.


1-Year Agency Response

Although the Foothill-De Anza Community College District submitted a 6-month response for this recommendation, it did not submit a 1-year response.

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

The district did not submit a response.


60-Day Agency Response

The Foothill-De Anza Community College District did not submit a 60-day response for this recommendation. It did, however, submit its 6-month response.

California State Auditor's Assessment of 60-Day Status: No Action Taken

The district did not submit a response.


6-Month Agency Response

The DSPS Division has established a procedure for monitoring the timeliness in responding to DSS student requests for alternate media. The Alternate Media Specialist uses Clockwork to track all alternate media requests that includes how the duration between the initial request and completion of the request. Periodically, the DSPS Supervisor meets with the Alternate Media Specialist to evaluate the performance against the time frame goal for completing alternate media requests.This started in September of 2017 and has continued to the present day.

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

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


Recommendation #16 To: Foothill-De Anza Community College District

To ensure that it promptly addresses any complaints it receives related to web accessibility and alternate media requests, De Anza should follow its new procedures for tracking and reviewing complaints related to accessibility.

Annual Follow-Up Agency Response From October 2022

The college still believes it has provided extensive evidence of its commitment to website accessibility and practices. Again, these are located on our Website Accessibility page at https://www.deanza.edu/communications/web_accessibility. To date, we have still not received an accessibility complaint about our website. Were a web accessibility issue reported, the listed procedure would be followed:

- A record would be created in the online database, the user's report would be acknowledged, and the web administrator would be notified.

- The web administrator would review the complaint and notify the technical support personnel to be attached to the issue.

- Personnel would review the complaint and correct the issue(s) found and test corrected page(s) with accessibility checking tools.

- Notes would be added to the database, and the user who reported the issue would be immediately notified of the correction.

The college considers it a hallmark of its own documented dedication to accessibility that no complaints have been lodged. Once again, should a complaint be registered, it would be immediately acknowledged and addressed as above. We wish to note, respectfully, that it is impossible to respond to an assertion that De Anza's process cannot be assessed if that assessment is predicated solely on the receiving of a complaint. It is the college's goal to ensure that the accessibility of the website continues at the highest possible level, at which no complaints would reasonably arise. Please advise how - with the continued absence of complaints -- we can respond to the item in a manner deemed satisfactory.

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

De Anza states that no website accessibility complaints have been received to date. Therefore, we cannot yet assess whether it is following its new procedures for tracking and reviewing complaints related to web accessibility and alternative media requests.


Annual Follow-Up Agency Response From October 2021

The college believes it has provided extensive evidence of its commitment to website accessibility and practices. Again, these are located on our Website Accessibility page at https://www.deanza.edu/communications/web_accessibility. Were a web accessibility issue reported, the listed procedure would be followed: A record would be created in the online database, the user's report would be acknowledged, and the web administrator would be notified. The web administrator would review the complaint and notify the technical support personnel to be attached to the issue. Personnel would review the complaint and correct the issue(s) found and test corrected page(s) with accessibility checking tools. Notes would be added to the database, and the user who reported the issue would be immediately notified of the correction.

The college considers it a hallmark of its own documented dedication to accessibility that no complaints have been lodged. Once again, should a complaint be registered, it would be immediately acknowledged and addressed as above. We wish to note, respectfully, that it is impossible to respond to an assertion that De Anza's process cannot be assessed if that assessment is predicated solely on the receiving of a complaint. It is the college's goal to ensure that the accessibility of the website continues at the highest possible level, at which no complaints would reasonably arise. Please advise how - with the continued absence of complaints -- we can respond to the item in a manner deemed satisfactory.

DSPS implemented a landing page that is accessible to all students for alternative media complaints. The website now includes an alternative media complaint form: https://www.deanza.edu/dsps/dss/alt_media_reportform.html. The Disability Information Student Handbook (DISH) has also been updated and redesigned, with a table of contents added, for a more user-friendly experience: https://www.deanza.edu/dsps/dss/dish_2020_2021/dish_welcome_3column.html

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

De Anza states that no website accessibility complaints have been received to date. Therefore, we cannot yet assess whether it is following its new procedures for tracking and reviewing complaints related to web accessibility and alternative media requests.


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).

As with the website accessibility scan reports, any complaint to the web team about an accessibility issue would similarly be noted and promptly attended to, with follow-up recorded. No website accessibility complaints have been received to date.

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

De Anza states that no website accessibility complaints have been received to date. Therefore, we cannot yet assess whether it is following its new procedures for tracking and reviewing complaints related to web accessibility and alternative media requests.


60-Day Agency Response

Foothill-De Anza Community College District did not submit a 60-day response for this recommendation.

California State Auditor's Assessment of 60-Day Status: No Action Taken

The district did not submit a response.


6-Month Agency Response

Foothill-De Anza Community College District did not submit a 6-month response for this recommendation.

California State Auditor's Assessment of 6-Month Status: No Action Taken

The district did not submit a response.


1-Year Agency Response

Foothill-De Anza Community College District did not submit a 1-year response for this recommendation.

California State Auditor's Assessment of 1-Year Status: No Action Taken

The district did not submit a response.


Recommendation #17 To: Foothill-De Anza Community College District

To ensure that students with disabilities have equal access to instructional materials, by June 2018, De Anza should develop procedures to monitor and periodically review the accessibility of instructional materials. For example, De Anza 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 that instructors completed the checklist and that the instructional materials comply with accessibility standards.

Annual Follow-Up Agency Response From October 2021

In spring 2020, all instruction was moved online due to the pandemic, and all faculty members were required to be Canvas certified, with training addressing accessibility. Even with the return of some instruction to a face-to-face modality, a significant majority of instructors still use Canvas as the main repository for all course materials.

Two formal processes are included in the Faculty Association contract to periodically review the practices that instructors follow to meet accessibility standards. The administrative evaluation process includes two accessibility-related criteria: "Works with student and/or student support services to provide reasonable accommodations for students with disabilities, and provides accessible materials where appropriate" and "Demonstrates sensitivity in working with students of diverse racial, ethnic, national origin, and ancestry background; color; sex, gender identity, and sexual orientation; physical and mental ability; medical condition; age; marital status; religious creed; and socioeconomic status." The required student evaluation process for faculty members also directly addresses accessibility: "Demonstrated sensitivity in working with students of diverse racial and ethnic backgrounds, sexual orientations, and physical and mental disabilities."

All faculty members undergoing the tenure process are evaluated regularly in order to advance to the next stage. Full-time instructors who are applying for Professional Achievement Awards, merit-based advancements in salary, must be evaluated every four years. Part-time faculty members are required to be evaluated within the first three quarters of employment and every nine quarters of employment subsequently. Administrative evaluators are provided access to the faculty member's course materials, whether digital or physical, and have the opportunity to review the accessibility of instructional materials.

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

We noted in our 2019 assessment that De Anza had established an accessibility checklist, which allows instructors to self-certify the degree to which instructional materials are accessible, and for a second individual to validate the self-certification. However, De Anza did not indicate how widespread the checklist is used for courses that are not online. Its statement that 2020 classes were held online is off-topic, as the school has resumed on-campus instruction for Fall 2021. De Anza did not provide procedures to monitor and periodically review the accessibility of instructional materials or documentation to demonstrate that it reviews instructional materials for courses not offered online. As we state on pages 18 and 19 of the report, without a process to periodically review the accessibility of instructional materials, the college cannot demonstrate that it complies with accessibility standards and meets the needs of students with disabilities.


Annual Follow-Up Agency Response From October 2019

We continue to have an accessibility checklist in place as previously noted for online courses. The checklist resides in our Learning Management System and is always available to faculty who utilize the LMS. Furthermore, accessibility information is located on our website so it is available to all faculty, regardless of modality.

Instructors have purview over their courses, however, faculty who participate in workshops and ongoing training opportunities for the online modality demonstrate how their instructional materials comply with accessibility standards during such trainings.

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

De Anza states that the accessibility checklist is for its online courses and also available to faculty who use the Learning Management System. The checklist allows instructors to self-certify the degree to which instructional materials are accessible, and for a second individual to validate the self-certification. However, De Anza did not indicate how widespread the checklist is used for courses that are not online. Further, it did not provide procedures to monitor and periodically review the accessibility of instructional materials or documentation to demonstrate that it reviews instructional materials for courses not offered online. As we state on pages 18 and 19 of the report, without a process to periodically review the accessibility of instructional materials, the college cannot demonstrate that it complies with accessibility standards and meets the needs of students with disabilities.


60-Day Agency Response

Foothill-De Anza Community College District did not submit a 60-day response for this recommendation. However, it did submit a 6-month response for this recommendation.

California State Auditor's Assessment of 60-Day Status: No Action Taken

The district did not submit a response.


1-Year Agency Response

Although it submitted a 6-month response to this recommendation, Foothill-De Anza Community College District did not submit its 1-year response.

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

The district did not submit a response.


6-Month Agency Response

De Anza College has adapted the Online Course Accessibility Checklist which has been used this past year on a voluntary, peer review basis when faculty seek compensation for transitioning an online or hybrid course to the new course management system. In Fall 2018, the Online Education Faculty Coordinator will work with selected shared governance groups to agendize the draft of the Accessibility Checklist and accompanying procedure for reviewing a random sample of online course content for accessibility. Once input is considered and the final version is complete, the process and Accessibility Checklist will be posted on the Online Education Center website and the procedure will be implemented.

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

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


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.


Recommendation #19 To: Foothill-De Anza Community College District

To ensure that all instructors are aware of the accessibility standards for instructional materials, De Anza should include in its next collective bargaining negotiations a requirement for instructors to periodically attend accessibility trainings.

Annual Follow-Up Agency Response From October 2021

De Anza offers extensive training that involves accessibility standards:

- All faculty members must be Canvas-certified to use Canvas, and because of the recent move to online teaching due to the COVID-19 pandemic, all faculty members who have taught in the past two years have been Canvas certified. The Canvas certification training directly addresses accessibility standards. More than 900 faculty members at De Anza are now Canvas certified, which demonstrates that accessibility training is widespread.

- All new full-time faculty members participate in a multi-day orientation training. Part of the training addresses accessibility standards.

- In addition, new full-time instructors participate in a first-year-experience program, and training for accessibility standards is repeated during this year-long training.

- New part-time faculty members also attend orientation training, which addresses accessibility standards.

De Anza also has a rigorous evaluation process required of all faculty members to advance in employment and salary increases that directly address accessibility standards in multiple criteria. As described in #17 above, there are two formal administrative and student evaluation processes in place to periodically review the practices that instructors follow to meet accessibility standards. These evaluation processes are included in the Faculty Association collective bargaining agreement.

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

De Anza has not demonstrated it has fully implemented this recommendation. Canvas certification only pertains to online instruction, and De Anza's campus is open for the Fall 2021 term. As such Canvas certification does not address our recommendation. Further, De Anza has not addressed our recommendation that all instructors periodically attend accessibility trainings.


Annual Follow-Up Agency Response From October 2019

Periodic mandatory accessibility trainings are not included in the collective bargaining agreement. However, Learning Management System (LMS) training IS required for those faculty who wish to teach in the online modality. The LMS training includes a section specifically on accessibility.

We will continue to offer accessibility information and training to instructors through the required LMS training. Optional workshops focused on accessibility. are available to a wider audience across campus as needed.

California State Auditor's Assessment of Annual Follow-Up Status: Will Not Implement

De Anza's training on accessibility is only required for its instructors teaching online courses. Although De Anza offers optional workshops to instructors, as we state on page 23 of our report, 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.


60-Day Agency Response

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

California State Auditor's Assessment of 60-Day Status: No Action Taken

The district did not submit a response.


1-Year Agency Response

Although Foothill-De Anza Community College District submitted a 6-month 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.


6-Month Agency Response

The FHDA Community College District, comprised of both De Anza College and Foothill College, and Faculty Association will discuss the requirement set forth in the recommendation during the active negotiations period.

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


Recommendation #20 To: Foothill-De Anza Community College District

To ensure the consistent, transparent, and continuous implementation of processes for technology equipment upgrades and replacements, by June 2018, the Foothill-De Anza district should establish written procedures for those processes.

1-Year Agency Response

Educational Technology Services has implemented three new processes/procedures to managing technology refresh projects from individual computer replacements to large-scale enterprise projects. These processes include:

ETS Project Process - Medium- and large-scale project management

FHDA Equipment Refresh Process - Small-scale project management

ETS Employee Guide - Individual computer replacement management

Copies of all of these documents will be forwarded via email as per the instructions below.

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


Recommendation #21 To: Foothill-De Anza Community College District

To increase the transparency of its annual review process, by June 2018, De Anza should establish procedures requiring its departments to document attendees, input received, and agreements reached during meetings to consider instructional technology equipment requests.

Annual Follow-Up Agency Response From October 2021

There are multiple methods for faculty members to provide input on instructional technology equipment requests. One is at the department level. While some departments might be small (sometimes with only one full-time faculty member) and department meetings are not held, larger departments often keep meeting notes of attendees. For example, the English Department takes notes at each meeting, noting the attendees and input that was given on various items including budgetary requests such as instructional technology equipment. It also holds meetings to review program review requests, which includes any instructional equipment requests. The department then posts the meeting notes on the department Canvas shell so that all members of the department can see what input was given or decisions made.

Another method for the faculty to provide input is through the Academic Senate. The Academic Senate keeps official meeting notes, including records of attendees and decisions made. The Academic Senate is closely tied to the campus's Instructional Planning and Budget Team, with faculty representatives serving on the team who help make decisions about resource allocation for instructional equipment requests. Relevant websites with documentation include https://www.deanza.edu/gov/academicsenate/ and https://www.deanza.edu/gov/ipbt/.

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

De Anza's response does not address the recommendation that it establish procedures requiring its departments to document attendees, input received, and agreements reached during meetings to consider instructional technology equipment requests.


Annual Follow-Up Agency Response From October 2019

The annual program review process includes directions for identifying instructional technology requests for consideration by the Instructional Planning and Budget Team (IPBT) composed of faculty, staff, administrators and students. Program review materials are submitted by departmental representatives to the dean after consulting among departmental members during established departmental meetings. As a secondary step, Deans review departmental requests and prepare a comprehensive division request list. Faculty representatives on IPBT are expected to communicate with their colleagues and encourage review of the requested items for accuracy prior to any allocation of funding for instructional technology requests. Finally, and before allocation begins, requests are posted to the public website. Requests are then vetted by the Instructional Planning and Budget Team based on agreements and funding guidelines.

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

De Anza did not provide procedures requiring its departments to document attendees, input received, and agreements reached during meetings to consider instructional technology equipment requests. Although it provided documentation of a meeting template to capture the information, the examples provided do not consistently show the attendees, input received, and agreements reached during meetings to consider instructional technology equipment requests.


60-Day Agency Response

Foothill/De Anza Community College District did not submit a 60-day response for this recommendation. It has, however, submitted responses for the 6-month and 1-year reporting periods.

California State Auditor's Assessment of 60-Day Status: No Action Taken

The district did not submit a response.


1-Year Agency Response

In addition to other processes developed by De Anza College leadership, the district's IT team (Educational Technology Services - ETS) has also developed a procedure for documenting the specific outcomes of regular equipment refresh prioritization meetings held between ETS and college leadership/staff. A copy of the meeting notes template along with samples of meetings notes using this template will be forwarded via email as per the instructions below.

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

De Anza did not provide documentation to support its assertion of full implementation of this recommendation. Although it provided documentation that its ETS unit has procedures and has begun to document attendees and agreements reached in its technology meetings, it did not provide documentation showing procedures for departments or that its departments were documenting department technology meetings as we recommended.


6-Month Agency Response

Procedures for documenting attendees, input and agreements reached were discussed with division deans in preparation for program review submission in the spring term. In Fall 2018, the Instructional Planning and Budget Team will request updated lists of instructional equipments needs based on program review submissions from the the spring term and request an explanation of how the instructional equipment requests were determined.

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

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


Recommendation #22 To: Los Rios Community College District

To ensure that it is fulfilling requests for alternate media services from students with disabilities in a timely manner, by June 2018, American River should establish procedures for monitoring its timeliness in responding to such requests so that it can periodically review its performance in completing the requests. Specifically, American River should calculate the number of days it take to complete requests, and periodically evaluate its performance against its time-frame goals.

1-Year Agency Response

The Alt Media Process will be added to the DSPS Unified Policies Manual, which is accessible and used by all DSPS staff and faculty. Additionally, pages 2-4 of the document are also available for DSPS students to download from the website. Copies of the written documentation will be submitted today.

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

American River's procedures include provisions for generating and reporting on the degree to which the college is meeting its time-frame goals for alternate media requests on a weekly and semester basis.


6-Month Agency Response

American River College has engaged in monitoring its timelines for completion and created a plan for regular review. That plan will be reduced to a formal memorandum by October 2018 and submitted. Generally, the plan is as follows:

1. Students requesting accessible materials from DSPS make their first contact with the staff when they submit their request. In order for DSPS to try to meet all requests in a timely manner, we have set up an automated notification-via-email process in SharePoint that will notify staff 3 days before the due date for all requests that have not been completed yet. If the request is still not completed by the due date, then a second automated notification email will be sent to notify staff as well as the DSPS Supervisor (1 day past the due date). During this process, the DSPS staff are constantly communicating with the student to update them on the status of their request. All communication is documented and can be retrieved.

2. Weekly reports are generated and reviewed by the Alternate Media/Assistive Technology staff and emailed to the DSPS Supervisor to evaluate performance against preferred time-frame for completion.

3. At the end of every semester, DSPS reviews and evaluates request completion against the 10-day completion goal, which is a standard that DSPS prefers to follow. Below is a report of Alternative Media request tickets for the spring 2018 semester.

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


60-Day Agency Response

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 that process. The documentation of that process has started, but has not been completed.

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

We look forward to reviewing American River's procedures for monitoring its timeliness in responding to requests for alternate media services from students with disabilities, as well as the documentation from its stated plan to engage in a periodic review of its performance against its goal.


Recommendation #23 To: Los Rios Community College District

To ensure that it promptly address any complaints it receives related to web accessibility and alternate media requests, by June 2018, American River should establish procedures for tracking and reviewing complaints received related to accessibility and addressing complaints in a timely fashion.

6-Month Agency Response

The process for addressing requests has been developed and distributed to those responsible for this obligation. A copy of the process is submitted with this report.

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


60-Day Agency Response

American River College is in the process of reducing this process to writing to satisfy this recommendation, but has not completed that project.

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


Recommendation #24 To: Los Rios Community College District

To ensure that students with disabilities have equal access to instructional materials, by June 2018, American River should develop procedures to monitor and periodically review the accessibility of instructional materials. For example, American River 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 that instructors completed the checklist and that the instructional materials comply with accessibility standards.

Annual Follow-Up Agency Response From October 2023

In 2019, the District's Technology Accessibility Task Force created an Information and Communication Technology Accessibility Program ("ICT Plan"). The attached plan contains an Accessibility Remediation Plan to monitor and track activities related to accessibility.

The ICT Plan outlines various procedures to ensure accessible instructional materials and websites. Specifically, the plan identifies responsibilities, how accessibility policies are communicated, trainings to ensure materials are accessible, support for staff, "accessibility checkers" to verify up-to-date content, automated website checks, and guidelines for any content that is posted.

The ICT Plan references several District policies and regulations regarding accessibility, including District Policy 8321, section 3.1.3 which references the need to "design, monitor, and uphold accessibility practices." Prior to the 2019 ICT Plan, the District also launched FastTrack, an effort to improve the quality and accessibility of online courses by aligning with state standard rubric, which sets the highest level of design standards to support online student success in the CA Community College system.

Recently, the District hired three full-time Online Course Developer Coordinators and four Universal Design for Learning/Accessibility Support Coordinators to assist faculty with online course development and accessibility. These positions assist all faculty with creating materials that follow principles of universal design, including online course materials. The job descriptions are attached.

Lastly, in connection with the District's ICT Plan, American River College created its 2019-2025 Distance Education Plan ("DE Plan") with a focus on policies and guidelines on how the college conducts and monitors its distance education (see attached). The DE Plan outlines how instructional materials, courses, programs, and websites are reviewed, and has action steps to ensure compliance.

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


Annual Follow-Up Agency Response From October 2022

Los Rios' previous response on October 25, 2019 indicated that the recommendation was fully implemented, but that the District would review existing procedures to monitor the District's accessibility program. Shortly after the response, the District entered remote operations due to the COVID-19 pandemic and adjusted all its programs and services to be accessible online (to the fullest extent possible).

The District will provide any changes to its policies and regulations that were created during the pandemic.

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

American River did not substantiate that it has developed a procedure to monitor and periodically review the accessibility of instructional materials.


Annual Follow-Up Agency Response From October 2019

American River College will use existing review procedures to monitor and periodically review the accessibility of instructional material and the District's comprehensive Information Communication Technology (ICT) Accessibility program.

The Los Rios Accessibility Task Force created a comprehensive Accessibility program that ensures access to ICT. The Accessibility Program includes a summary of practical guidelines for building and maintaining an accessible institution, policies and regulations, and explanations of the work and shared responsibilities necessary to implement and maintain accessible environments. The Board of Trustees approved the program and policies on October 16, 2019.

All ARC Faculty are evaluated through the college's performance review process on a cyclical basis. This is an effective procedure for monitoring and periodically reviewing the accessibility of instructional materials and includes classroom observations by the peer review team. Additionally, student review forms are collected. The Peer Review Team must cite specific examples and recommendations for improvement in writing on the Faculty Performance Review form which becomes a permanent part of the employee's personnel file. Improvement and remediation of inaccessible instructional materials will be documented on the review form and are further reinforced by Los Rios Policies 7136, Information and Communication Technology Accessibility and 7145, Distance Education..

Reviewing and monitoring instructional materials is only part of the solution to ensuring accessible instructional materials. In fact, instructors are already using Blackboard Ally which identifyies inaccessible content within the Learning Management System. American River College is committed to the ongoing training and education in accessibility to ensure that instructors will have the skills and knowledge to select, upload, and create accessible content.

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

American River did not substantiate that it has a developed a procedure to monitor and periodically review the accessibility of instructional materials. Our review of the Los Rios ICT Accessibility Program found that, while it provided guidance to instructors and other college personnel on purchasing and implementing accessible instructional materials, it did not include procedures for the college or district to periodically review that instructors and other personnel had done so appropriately. Further, although the classroom faculty performance review form has the reviewer rate the sufficiency of the instructor's classroom teaching methodologies for students with diverse and special needs, and different learning styles, the form does not have the reviewer rate whether the instructional materials comply with accessibility requirements.


Annual Follow-Up Agency Response From June 2019

The process below ensures the delivery of the accessibility of instructional materials through the use of the Canvas Learning Management System.

1. Instructors automatically receive a Canvas course shell for every course section they teach. Use of Canvas by instructors continues to grow with about 90% of course sections now using Canvas.

2. Instructors are guided to the Resources Section of the ARC Canvas template with their course which includes a topic on how to make course material accessible. This includes information on: the built-in Canvas accessibility tool; the Blackboard Ally tool; and Grackle.

3. Instructors can opt in to Blackboard Ally through the above template topic, from the Canvas help menu, or through the link sent in the weekly Instructional Technology Center newsletter. Ally makes digital course content more accessible by -

- Automatically checking for accessibility issues and generating alternative accessible formats for students.

- Providing an accessibility score for each piece of content, guiding the instructor on how to remediate that content to achieve full accessibility, and helping to alter future behavior.

The Ally Pilot will continue through fall 2019. Ongoing training sessions are provided throughout each semester. Full integration of Blackboard Ally into Canvas will occur in spring 2020.

4. Instructors who use external applications find that most major publishers have already been assessed for accessibility and are now integrated into Canvas. New requests must be vetted before integration into Canvas which includes LRCCD's accessibility requirements. This ongoing process helps to ensure accessibility of publisher content and external applications.

5. Some faculty use their websites to post instructional material. ARC's redesigned website launched in June 2019. Faculty with legacy websites are transitioning materials to an accessible Canvas profile page.

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

The process described by American River does not address development of procedures to monitor and periodically review the accessibility of instructional materials.


1-Year Agency Response

ARC uses the learning management system Canvas to ensure access to accessible digital instructional materials and will use this to ensure the review of the accessibility of instructional materials (documentation of this process will be submitted by June 2019):

1. Canvas learning management system usage for instruction materials:

Instructors automatically receive a Canvas course shell for every course section they teach. Use of Canvas by instructors will continue to grow and be universally encouraged.

2. Blackboard Ally Canvas integration for generating alternative formats and guiding creation/remediation of accessible content

The Ally Pilot began in fall 2018 with instructors opting in to use this tool. The pilot, which includes training in it use, will continue through spring 2019. Full integration into Canvas will occur in fall 2019. Ally makes digital course content more accessible by -

1. Automatically checking for accessibility issues and generating alternative accessible formats (Tagged PDF, html, ePub, eBraille, and audio/MP3) using advanced Machine Learning Algorithms.

2. Guiding instructors on how to improve the accessibility of their course content and alter future behavior.

3. Accessible publisher content in Canvas

External applications must go through a vetting process before integration into Canvas which includes LRCCD's accessibility requirements. Currently, several major publishers have met this requirement and are integrated into Canvas including Macmillan Higher Education, McGraw-Hill, Pearson, and Cengage. This process will continue.

4. Accessible faculty websites

Some faculty use their websites to post instructional material. ARC's redesigned website will launch in spring 2019. Faculty with legacy websites in the former version of Ingeniux will move to this accessible version. Other faculty have transitioned materials on their websites to an accessible Canvas profile page. This process will continue.

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


6-Month Agency Response

American River College has begun its analysis and use of Blackboard ALLY, a course content accessibility service that integrates with its Learning Management System (LMS), and has proposed a pilot program to address these issues at the LMS level. Additional work is required to address the instructional materials outside of the LMS. This procedure should be documented by the end of Fall 2018.

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


60-Day Agency Response

By June 2018, American River College will draft business practices to determine how American River College will monitor and periodically review the accessibility of instructional materials. That process has commenced, but not yet been completed.

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


Recommendation #25 To: Los Rios Community College District

To ensure that its website complies with accessibility standards, by June 2018, American River 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 2023

As mentioned in #24, the District's ICT Plan and ARC's DE Plan address procedures to address website accessibility (both Plans are attached).

In the District's ICT Plan, remediation activities are highlighted on page 34. The remediation section of the plan identifies issues such as broken links, browser compatibility issues, etc., and outlines a process to fix these issues. Page 39 of the ICT Plan creates a policy to track remediation process and activities by applying key performance indicators at periodic milestones.

The District also has a dedicated Technology Accessibility website where students and employees can request for reasonable accommodations and report accessibility issues with any website or content. The Technology Accessibility website serves as a resource for all students and staff, and can be found here: https://losrios.edu/about-los-rios/our-values/technology-accessibility. The link for reporting website accessibility is: https://losrios.edu/about-los-rios/our-values/technology-accessibility/report-accessibility-issue

In addition to the District's efforts, ARC's DE Plan specifically identifies website accessibility as a priority under Priority #2, with the goal of improving online communication and access to timely education. The DE Plan recommends to simplify website content across support services to increase accessibility (see page 29 of 39). With the support of the District, ARC and its staff can ensure that it is monitoring its websites for equitable access.

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


Annual Follow-Up Agency Response From October 2022

Shortly after Los Rios' last response on October 25, 2019, the district entered into remote operations due to the COVID-19 pandemic. In response to shifting all its operations online, the district adjusted its accessibility standards in the past three years.

As the pandemic ends and the district shifts to being fully on-ground again, the accessibility standards will be amended to reflect the current needs of students and employees. The district will finalize the formal documentation and forward it to you within a reasonable time.

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


Annual Follow-Up Agency Response From October 2019

The process is in place. The College is still working on the formal documentation. It should be ready by December 2019.

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


Annual Follow-Up Agency Response From June 2019

Below is the Site Improve procedure to ensure ADA compliance on our web site.

On the first of the month the Media Design Specialist runs the Site Improve accessibility Tool which generates a report. The Specialist can choose to run the accessibility tool more often if page construction in a given month requires it.

A report is created with issues found ranked A, AA, AAA.

The Los Rios Standard is to maintain a AA clearance rating (which means AA and AAA are priorities)

The Media Design Specialist fixes the issues.

This can require working with the CMS vendor (Ingeniux), or the page content owner but usually the issues can be solved by the Specialist

The Accessibility tool gives a percentage ranking for completeness of all rankings of issues. Currently ARC's site is running at a 98.3% of completeness.

Issues that will take longer than 2 weeks to solve are escalated to the IT Supervisor and PIO Supervisor for evaluation.

The American River College Website migration occurred in June 2019.

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

The procedure American River describes does not incorporate steps to prevent instructors from publishing inaccessible content or describe a tracking mechanism to demonstrate how many accessibility errors the college identifies or how long it takes to remedy those errors, but it does include procedures to monitor website accessibility.


1-Year Agency Response

By the end of Spring 2019, the IT Department will have documented the Site Improve Process. Migration to the new College Website is expected to be completed in Spring 2019.

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


6-Month Agency Response

The Website Design remains underway. American River College has also implemented the following, which will be documented by the Fall of 2018.

Through the Distance Education (DE) department, American River College now offers standardized Canvas faculty web pages. The College runs Siteimprove against the Canvas pages to ensure accessibility compliance. The goal is for the majority of faculty to use the new Canvas Faculty template for their individual site presence since the template is compliant.

Also, the work the DE department is doing on Recommendation 24 to ensure that the LMS content created by faculty remain ADA compliant assists in this work.

The main site is monitored with Siteimprove by the Education Web and Media Design Specialist regularly and a monitoring system has been established.

1. Specialist runs Siteimprove once a month and saves report results in an archive.

a. Specialist fixes issues maintaining Double A compliance or better for entire site and then re-runs report and saves that to archive

b. Specialist documents issues that take more than a week to fix by entering them into the Helpdesk system

i. Specialist fixes issues or escalates them up to web team after two weeks for resolution.

2. Student reported accessibility issue

a. American River College is implementing the Los Rios Procedure for Accessibility Issue Requests

i. Campus Help Desk staff will act as the Intake staff and the Specialist and Web Programmer will act as the resolution staff

3. The most common accessibility issue for students is the ability to log into website resources and the Los Rios wireless network.

a. American River College has implemented a Student Technology Center designed to help students with those issues. A student can request help by phone, email and in person.

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


60-Day Agency Response

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.

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


Recommendation #26 To: Los Rios Community College District

To ensure that all instructors are aware of the accessibility standards for instructional materials, American River should include in its next collective bargaining negotiations a requirement for instructors to periodically attend accessibility trainings.

Annual Follow-Up Agency Response From October 2023

The District will not be fully implementing with this recommendation. However, the District and the faculty union are committed to ensuring that instructors have the opportunity to attend accessibility trainings. This commitment is evidenced by the fact that in the most recent negotiations cycle, the District and its faculty union negotiated compensation for all faculty to attend accessibility training and receive some sort of compensation. Faculty can receive training and be compensated, or receive flex credit or college service hours.

This recent development is new, as the District fully intends to incentivize faculty for attending accessibility trainings to ensure proper compliance and make instructional materials accessible. A dedicated website for accessibility support services, including how to request support and information on compensation can be found here: https://employees.losrios.edu/training/professional-development/faculty-professional-development/accessibility-support

The District is currently offering a course called Foundations, an asynchronous training course that faculty can complete in approximately fifteen (15) hours over a two-week period. It is facilitated by a colleague faculty member with extensive online teaching experience. The Foundations course meets the district's new minimum standard for distance education preparation referenced in section 4.4.4 of the 2020-2023 Contract.

California State Auditor's Assessment of Annual Follow-Up Status: Will Not Implement

Although American River College offers training in implementing accessible materials as a resource to instructors, it has not required all instructors to take this training. As we state on page 23 of our report, 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.


Annual Follow-Up Agency Response From October 2022

Los Rios Community College District response is unchanged for this recommendation. It indicated in its last response that it would not implement the recommendation.

California State Auditor's Assessment of Annual Follow-Up Status: Will Not Implement

As noted in our comments to its original response, although American River College offers training in implementing accessible materials as a resource to instructors, it has not required all instructors to take this training. As we state on page 23 of our report, 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.


6-Month Agency Response

Los Rios Community College District did not submit a 6-month response for this recommendation. It indicated in its 60-day response that it would not implement the recommendation.

California State Auditor's Assessment of 6-Month Status: Will Not Implement

The district did not submit a response.


1-Year Agency Response

Los Rios Community College District did not submit a 1-year response for this recommendation. It indicated in its 60-day response that it would not implement the recommendation.

California State Auditor's Assessment of 1-Year Status: Will Not Implement

The district did not submit a response.


60-Day Agency Response

As noted in its original response, American River College objects to this recommendation and will take no further steps to move this recommendation forward.

California State Auditor's Assessment of 60-Day Status: Will Not Implement

As noted in our comments to its original response, although American River College offers training in implementing accessible materials as a resource to instructors, it has not required all instructors to take this training. As we state on page 23 of our report, 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.


Recommendation #27 To: Los Rios Community College District

To ensure the consistent, transparent, and continuous implementation of processes for technology equipment upgrades and replacements, by June 2018, the Los Rios district and American River should each establish written procedures for those processes.

Annual Follow-Up Agency Response From June 2019

This recommendation has been implemented in the addition of Appendix C to the District's 2017-2020 District Technology Plan.

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

Los Rios provided the district's plan for technology equipment upgrades and replacements, which includes plans for American River's upgrades and replacements.


1-Year Agency Response

A fully compliant process has been developed by the IT department. It is currently undergoing vetting through the Vice President consultation groups and will be finalized and submitted by June 2018.

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

In a follow-up conversation with the district, Los Rios indicated that the June 2018 date it references in its response should have read June 2019, which corresponds with the date of implementation that it provided. We will review Los Rios' process when the district submits it to us.


6-Month Agency Response

District IT research into the scope of procurement procedures has been completed. The next step is to consult with the College, General Services, and Purchasing to bring all the necessary parties together to draft a procedure for the District. This should be completed by Fall 2018.

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


60-Day Agency Response

District IT is researching the scope of the recommendation and will in consultation with the four colleges establish standards and work with purchasing and general services to develop the procedures for procurement. That project is not yet complete.

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


Recommendation #28 To: Los Rios Community College District

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 accomplished. Further, it should develop an implementation plan in conjunction with the development of its future technology master plan.

Annual Follow-Up Agency Response From October 2023

As indicated in Recommendations 24 and 25, the District's ICT Plan and ARC's DE Plan lists goals and plans to increase remediation efforts across the District. The two plans serve as implementation plans for the District and for ARC as a college, with the intention of the plans to outline the training and support needed to accomplish its goals. Additionally, the two plans set forth designated actions along with timelines to ensure that its priorities regarding accessibilities are addressed and implemented within a timely manner (both plans are attached).

Page 40 of the ICT Plan and page 11 of ARC's DE Plan list specific tasks and targets, along with timelines on when remediation tasks would be performed.

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

As we describe on pages 32 to 35 of our report, American River lacked detailed steps to implement its technology master plan. Technology master plans identify technology goals and planned replacements and upgrades of infrastructure technology equipment at colleges. These plans identify what technology projects are important, provide a framework for implementing those projects, and articulate how the technology plan can support the strategic plan of the district and its colleges. The district's Information and Communication Technology Accessibility Program and American River's Distance Education Plan, referenced in the district's response to our recommendation, do not address the infrastructure technology equipment replacements and upgrades contained within the technology master plan.


Annual Follow-Up Agency Response From October 2022

As indicated in its response to Recommendation 25, the district's goals in its technology master plan changed as the district entered remote operations because of the COVID-19 pandemic. Accordingly, this recommendation has not been fully implemented but its technology plans will be re-evaluated as the district scales back on remote operations and fully integrates back to offering on-ground services.

A new technology master plan will take into consideration how the district operated remotely during the pandemic and how technology will play a role moving forward. A new implementation plan will be drafted with this in mind and will be shared as soon as reasonably possible.

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


Annual Follow-Up Agency Response From October 2019

The College is still working on this plan. It should be ready by December 2019.

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


Annual Follow-Up Agency Response From June 2019

The College is working on this implementation plan and schedule.

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


1-Year Agency Response

American River College remains on target for the June 2019 implementation plan/schedule.

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


6-Month Agency Response

American River College remains on target for the June 2019 implementation plan/schedule.

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


60-Day Agency Response

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. That Process is not yet complete.

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


Recommendation #29 To: Los Rios Community College District

To increase the transparency of its annual review processes, by June 2018, American River should establish procedures requiring its departments to document attendees, input received, and agreements reached during meetings to consider instructional technology equipment requests.

Annual Follow-Up Agency Response From November 2023

In February of 2020, the District amended Board Regulation 3412 to create an Educational Technology Committee (see section 2.1.3 of R-3412 attached). The Committee was created to discuss and make recommendations related to educational technology, classroom multi-media, distance education, etc., including classroom/lab and distance education software and equipment.

The Committee promotes transparency and collaboration on technology tools and needs across the District. The Committee holds regular meetings and its minutes are publicly available here: https://employees.losrios.edu/our-organization/committees/education-and-technology-committee

The Committee meets once a month and the minutes lists the attendees, topics discussed, and informational items. The Committee is composed of faculty members from each college, District IT staff, distance education coordinators, and various technology representatives. The Committee hears updates from the colleges and its IT leads, discusses future district-wide technological purchases, and suggests recommendations to policies or regulations.

Each college also has a local committee focused on technology that works with each department. Requests for technology equipment can be made at the local committee level or at the District level. The District has developed a central location within the employee self-service hub for technology or software requests, and an assistive technology software hub for help with various software such as screen readers and document conversions. A screenshot of all the employee self-service resources is attached.

The self-service hub documents and tracks individual equipment or software requests to ensure that requests are fulfilled (see screenshot of fulfillment stages). With a centralized hub, District IT has made it easier for employees to make requests and track requests until they are fulfilled.

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

On pages 35 to 39 of our report, we describe concerns related to the transparency in the decision-making process for the selection of instructional technology equipment by departments at several colleges, including American River. We address this concern by recommending that American River establish procedures to document certain elements within its department meetings when considering instructional technology equipment requests. Los Rios Community College District's amendment of Board Regulation 3412 does not address our concern. Although the amendment created a district-level committee to evaluate district-wide technology purchases, it did not establish procedures requiring American River's departments to document attendees, input received, and agreements reached during meetings to consider instructional technology equipment requests.


Annual Follow-Up Agency Response From October 2022

In the district's previous response on October 25, 2019, the response outlines the procedure that American River College is following to increase transparency of its annual review process. The documentation and training slides for users were also provided.

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

As we described in our 2019 assessment, the annual unit plan and training slides submitted by American River do not include procedures requiring its departments to document attendees of the annual review process meetings to consider instructional technology equipment requests, input received in the meetings, and agreements reached during meetings.


Annual Follow-Up Agency Response From June 2019

The new Annual Unit Planning component of the Integrated Planning Portal was implemented in February 2019. Documentation of the process is here: https://apps.arc.losrios.edu/ProgramReview/Home/AnnualUnitPlanning

Training slides for users are here: https://apps.arc.losrios.edu/ProgramReview/Docs/Annual%20Unit%20Planning%202019.pdf

When a unit plan author (e.g. faculty department chair) indicates that instructional technology is being requested in support of a particular Action Step, the author is prompted with a message indicating that a follow-up process will occur in the fall for the author to provide future detail regarding the instructional technology needs (see screen capture image below). Included in this request for follow up is documentation of all faculty involved in the decision-making process for instructional technology requests.

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

The annual unit plan and training slides submitted by American River do not include procedures requiring its departments to document attendees of the annual review process meetings to consider instructional technology equipment requests, input received in the meetings, and agreements reached during meetings.


1-Year Agency Response

As a component of the annual unit planning process, the College's new Integrated Planning Portal will require developers to provide a list of all faculty involved in the decision-making process for instructional technology requests. This system will be implemented in February 2019, which is the start of the annual unit planning process. Documentation of this process will be submitted in June 2019.

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


6-Month Agency Response

American River College has created procedures to increase the transparency as noted. Those procedures will be reduced to a formal memorandum by October 2018 and submitted. Generally, the procedure is as follows:

1. The EMP system for the annual unit planning process has been modified to include a checkbox for instructional technology equipment requests where instructional faculty demonstrate verification that "all faculty were provided the opportunity for input when making this request."

2. In fall 2018 the EMP (unit planning) system will be replaced by an integrated planning system, which will include annual unit planning at its core. Within the new planning system, unit planning objectives that are accompanied with requests for instructional technology equipment will require that all instructional faculty involved in the decision-making process be listed as part of the request.

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


60-Day Agency Response

American River College has identified a process whereby the Chair and the Dean are able to certify that all faculty were provided the opportunity for input. Reducing that process to writing has not yet been completed.

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


All Recommendations in 2017-102

Agency responses received are posted verbatim.