Report 2017-102 Recommendation 24 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 #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

All Recommendations in 2017-102

Agency responses received are posted verbatim.