Report 2017-102 Recommendation 17 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 #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.

All Recommendations in 2017-102

Agency responses received are posted verbatim.