UNITED STATES DEPARTMENT OF EDUCATION
OFFICE FOR CIVIL RIGHTS
SUMMARY REPORT

DATE: January 22, 1998

SUBJECT: Review of California Community Colleges: Access of Visually Impaired Students to Print and Computer based Information

On September 18, 1996, the U.S. Department of Education, Office for Civil Rights (OCR), mailed to all 106 California Community Colleges a letter stating the applicable legal standards regarding the obligation of community colleges to provide students with visual impairments access to print and computer-based information. Attached to this letter was an eleven item survey to be returned to OCR by November 15, 1996. The OCR letter/survey was introduced by a cover letter from the Chancellor's Office. Followup telephone calls to nonresponding colleges secured a 100% survey return rate from 106 colleges. The results of this survey were analyzed by researchers Jamie Dote-Kwan (CSU LA), and Jeff Senge (CSU Fullerton) in their report "Information Access for Students with Visual Impairments: Analysis and Final Report of the California Community Colleges' Survey and Self-Evaluation."

During Spring 1997, OCR conducted fifteen onsite visits at California Community Colleges throughout the state. With a few exceptions, each onsite visit lasted a complete day and consisted of six components:

First, at the High Tech Centers in the Disabled Student Program and Services (DSPS) Offices, OCR observed demonstrations of adaptive technology for the visually impaired. OCR also spoke with DSPS staff regarding the availability of alternative format for printed materials such as textbooks, examinations, class handouts, and campus publications.

Second, OCR visited outlying computer labs used by nondisabled students, both within departments (e.g., education, mathematics, business) and general "open" labs used by students to prepare course assignments. The purpose of visiting department labs and open labs was to determine the degree to which such mainstream computer labs are prepared to integrate blind students by providing adaptive technology, or whether the only means of accommodating blind students wanting access to computers is to refer them to the Hi Tech Center operated by the DSPS Office.

Third, on campuses that had already developed a system for promoting campuswide standardization of computer technology, OCR discussed the cost effectiveness of the campus' master technology committee/administrator addressing the issue of accessibility as early as possible when purchasing computer technology.

Fourth, at the campus library OCR shared resources available to librarians seeking to ensure accessibility to blind and low vision patrons, and inquired about the manner in which books, as well as newly computerized information such as card catalogues and CD ROM resources, were being made accessible.

Fifth, with respect to distance learning and computer networks, such as the campus LAN and the Internet, OCR spoke with pertinent campus administrators and technicians to determine what adaptive technology was being used to provide access for the visually impaired.

Sixth, at almost every campus OCR spoke directly with blind students regarding their experiences in accessing computer-based information and printed materials.

Because the purpose of this Compliance Review was not to determine compliance with respect to any individual campus, this report does not identify particular colleges when discussing OCR findings. For the record, on these dates OCR visited the following colleges (Region indicated within parenthesis):

Sacramento City College (II) February 7, 1997 San Jose City College (IV) March 11, 1997 DeAnza College (IV) March 11, 1997 Los Angeles City College (VII) March 17, 1997 El Camino College (VII) March 18, 1997 Saddleback College (VIII) April 16, 1997 San Monica College (VI) April 17, 1997 Santa Barbara City College (VI) April 21, 1997 San Diego City College (X) May 6, 1997 Palomar College (X) May 7, 1997 San Joaquin Delta College (V) May 13, 1997 Diablo Valley College (III) May 14, 1997 Contra Costa College (III) May 14, 1997 City College of San Francisco (III) May 22, 1997 San Rosa Junior College (III) June 24, 1997

In addition to the foregoing onsite visits, on October 16, 1997, OCR met onsite with the President of Ventura College Larry Calderon (Region VI), as well as his staff, to discuss the Braille Transcription Center that High Tech Specialist Dee Konzcal is attempting to establish for the purpose of serving the Braille transcription needs of California Community Colleges.

In summarizing OCR findings with respect to the status of California Community Colleges, please note that in general the above colleges were not randomly selected and were not expected to be representative of California Community Colleges as a whole. Approximately two thirds of the foregoing were selected because of their reputation for having at least one or more features that were especially noteworthy in serving the technology needs of blind students. OCR wished to see first hand some of the most advanced programs within the community college system so as to collect best practices for effectively serving blind students at community colleges. Therefore, in the following discussion regarding the situation of "most" California Community Colleges, OCR is relying not only on its onsite visits to the above named colleges, but also on results from the written OCR survey returned by each of the 106 colleges, on OCR telephone conversations with numerous college staff and students, and on individual complaints filed with OCR.

OCR is also drawing from information available from research gathered by components of the California Community College system. For example, the results of four relevant surveys/reviews of California Community Colleges were disseminated this last year:

(1) DeAnza High Tech Center Training Unit "Internet Access in the DSP&S Programs of California Community Colleges: An initial study of the availability and location of e-mail and Web access for staff and students of DSP&S programs in the California Community Colleges." The survey was sent in late May 1997, and a followup duplicate survey to nonresponders was sent in mid-June. Seventy-five (65%) of the 106 colleges responded. This study was presented October 14, 1997, at the Conference of CAPED (California Association of Post-Secondary Educators of the Disabled).

(2) The Assistive Computer Technology CIG (CAPED Interest Group), primarily composed of DSPS staff throughout California, conducted a statewide 1996 survey identifying access technology used by California Community Colleges. A total of 32 colleges responded to the survey identifying 110 different hardware/software products in use.

(3) "Disabled Students Programs and Services 1996-1997 Program Reviews" submitted by Gwyneth Tracy, July 1997. Eight program reviews of DSPS offices were conducted from September 1996 through May 1997 by Vocational & Educational Services in the Chancellor's Office. These reviews included a pre-onsite survey completed by the college, and an onsite visit by a review team. Campuses visited and described in this program review were Mira Costa College, San Diego Miramar College, Allan Hancock College, San Diego Mesa College, Chaffey College, Citrus College, and Santa Monica College.

(4) "High Tech Center Training Unit (HTCTU) Performance Review Report" issued November 17, 1997, by the Vice Chancellor, Student Services Division of the Chancellor's Office.

Number of California Community College Students with Visual Impairments

According to the results of the OCR survey, a substantial number of students registered with the DSPS Office as visually impaired are not requesting the college to provide printed materials in an alternative format. In the OCR survey, although the colleges reported a total of almost 1600 students with visual impairments who were registered with the DSPS office, less than 600 were identified as needing print enlargement, while less than 500 were identified as needing translation of printed materials into a nonvisual format (e.g., spoken voice, audiotape, Braille, etext). The fact that one third of students with visual impairments registered with DSPS Offices do not request translation of information into an alternative format may be because their visual impairment is such that an alternative format is not needed, or it may be because such students are not clear that alternative format is available as an accommodation.

In addition to the almost 1600 students with visual impairments who have registered with DSPS offices for some type of accommodation (one third of which were seeking an accommodation other than an alternative format), many DSPS Coordinators indicated to OCR that it was their experience that several students with visual impairments, including blindness, do not even register with the DSPS Office (and thus were not counted in the OCR survey). Instead, many students with visual impairments directly arrange with their course instructors to have examinations read aloud and take care of all other needs on their own.

Available data suggests that students with visual impairments may constitute as much as one fifth of students with disabilities, and that students with disabilities are approximately ten percent of the almost 1,400,000 California Community College students.

In conclusion, the foregoing discussion indicates that the number of students with visual impairments reported in the OCR survey as requesting accommodation from the DSPS Offices is probably significantly lower than the actual number of students with visual impairments attending California Community Colleges. Available evidence further indicates that there is an even greater number of students with visual impairments who have graduated from California high schools and who might enroll in California Community Colleges if assured access to the academic information needed for success.

Student Proficiencies (Braille/computer)

Of the 106 California Community Colleges, 56 campuses have one or more students needing a nonvisual format who are known to be Braille proficient (statewide total of 163 students identified as Braille proficient). Some colleges stated in the OCR survey that they did not know whether their visually impaired students were Braille proficient. This indicates that colleges may not be interacting with visually impaired students to discuss the full range of alternative formats available, and further indicates there may be unidentified Braille proficient students not requesting Braille translations because they are unaware that Braille is an option. In short, evidence available to OCR suggests that the actual number of Braille proficient students attending California Community Colleges may be higher than the OCR survey reflects.

Of the 106 California Community Colleges, 67 campuses have one or more students needing a nonvisual format who are known to be proficient in accessing electronic computer text (statewide total of 347 students identified as proficient in accessing electronic text). The foregoing numbers do not reflect the additional number of visually impaired students who wish to become proficient in using the computer but who have not been provided the opportunity to learn. When interviewing students with visual impairments OCR encountered many students who realized the importance of becoming proficient in accessing computer-based information but who felt, despite the numerous computer courses available to nondisabled students in the general course catalogue, that there was a lack of critical adaptive technology and training.

Access to Examinations

In general, due in large part to the strong position of instructors that course exams be administered to all students at the same time, course examinations are usually administered to blind students close in time to when the examination is given to nondisabled classmates. Although examinations are more likely than other types of printed course materials to be made available in Braille or digital text (see below), an audiotranslation provided by a "live" reader is by far the prevailing alternative format for examinations to students with visual impairments.

Specifically, the most common method is for the exam proctor to read the test aloud and record the blind student's answers. Rarely is a tape recording of this interchange made to serve as a backup for verifying what was spoken aloud by the proctor and for ensuring that the student's answers were correctly understood and recorded by the proctor. In OCR interviews with blind students they consistently described the disadvantages in taking examinations in this manner, e.g., there is minimal opportunity for reflective thinking and self-review of answers. In some cases, the person reading the test aloud is unfamiliar with the subject matter, thus increasing the likelihood of mispronunciation when reading the test aloud, and of misrecording when writing down the student's spoken response. Recognizing the risks inherent in using a proctor/reader to verbally administer examinations, some colleges have instructors personally conduct the examination and a relatively few colleges provide the student a copy of the examination in an alternative format such as Braille or audiocassette (and then translate the student's alternative format answers back into print for the instructor's grading convenience).

There is a small but important trend to provide examinations in digital text or Braille for blind students who are computer/Braille proficient. Students preferring to take examinations on a computer are more likely to be granted their preference than those students preferring Braille. One fourth of the colleges (28) stated that they had provided at least one student one or more examinations in Braille in the last year and a half, whereas during that same time period almost half (42) had provided at least one student one or more examinations in electronic text. Eighteen (18) colleges indicated they had provided at least one student one or more examinations on an audiocassette.

Access to Classroom Materials

The most common method for blind and low vision students to obtain a translation of class handouts is by personal reader. It appears that about half the campuses own optical character recognition scanners/readers which have the capacity to enable the student or staff to translate (after-class) the printed hardcopy (which was distributed in class to all classmates) into synthesized speech and/or electronic text (see below). As a practical matter it is usually one or more days after class distribution before an alternative format version becomes available to the blind student.

Access to Textbooks

With few exceptions, community colleges' method for providing alternate format for course assigned textbooks is limited to two approaches. The textbook is provided on audiocassette when available from a pre-recorded source such as Recording for the Blind and Dyslexic (RFBD), or a personal reader is available for a limited number of hours per week to cover any reading aloud needed by the student with the visual impairment.

Aside from a few colleges that have developed a significant budget for paying work-study students or a systematic method of utilizing outside community volunteers, most colleges reported difficulty in securing an adequate number of reliable qualified readers so as to be able to successfully match the "free" hours in the blind student's schedule and cover the amount of printed material necessary for the blind student to keep up with all textbook and other printed material required by course assignments. Frequent problems arose regarding scheduling conflicts, the quality of the reader's voice (difficult to listen to for long periods of time, difficult to understand due to accents or subject matter unfamiliarity resulting in mispronunciation, etc.), or simply failure to show up for appointments. These difficulties had an especially adverse impact when occurring shortly before an examination or course assignment deadline when the student was wholly dependent on a reader for access to critical information.

In general, while helpful as a backup or "fill-in-the-gap" measure, personal readers were wholly inadequate for translating anything more than limited quantities of relatively simple narrative text. Even when personal readers were taped while reading aloud onto audiocassette, such recordings lack internal document flexibility (listener ability to directly move between topical headings and among chapters) making use of such recordings for later review cumbersome and timeconsuming. Traditional audiotapes supplied by Recording for Blind and Dyslexic usually have beep tones placed throughout audio-reading of textbook to allow quick forward/back movement between chapters/sections. Recognizing this feature's importance, RFBD is currently perfecting newer techniques to facilitate internal document flexibility on its audiotapes (see ).

Whenever the text contained mathematical symbols/equations, scientific formulas, underscoring, accents, or other unusual punctuation, or even content specific dense information (e.g., precise dates, detailed instruction, etc.), according to students with visual impairments an auditory translation by audiocassette or personal reader was generally insufficient to provide meaningful access to the textbook (see ). Nevertheless, as was true for narrative text, math/science/foreign language textbooks were usually translated auditorily rather than into electronic text or Braille.

OCR found that California Community Colleges reliance upon adaptive technology to assist in providing alternative format for printed textbooks is still in the earliest stages of development. See below on High Tech Centers: Computerized Access to Print-Based Information.

While frequently expressing appreciation for efforts by the DSPS staff, the majority of blind students described themselves as largely on their own when it came to accessing most of the information contained in textbooks not available on audiocassette. A substantial number of the blind students successfully taking academic courses relied upon parents, personal assistants, or personally owned equipment (e.g., scanner) to fill in the gap between their alternative format needs and what the college provided.

High Tech Centers: Access to Computer-Based Information

Blind students wanting to maximize their opportunity for successful graduation from a four-year university and/or future employment are increasingly requesting instruction on how to use computers. While nondisabled students are offered a plethora of computer courses in the community college's mainstream curriculum, blind students are almost entirely shut out of these courses for a variety of reasons.

First, the adaptive technology needed to translate information that is presented visually to sighted students is frequently not available to blind students. Second, blind students are not adequately trained in how to use the adaptive technology that is available. Third, mainstream computer course instructors are not familiar with how to effectively assist blind students who are using adaptive technology to access standard computer software programs, thus blind students are precluded from acquiring literacy in standard computer programs in settings alongside their nondisabled classmates in mainstream computer courses. Fourth, because DSPS staff serve a wide variety of students with differing disabilities and needs, DSPS staff are rarely able to bridge the foregoing gap by becoming experts in both adaptive technology and mainstream computer programs. Even when a DSPS Office has a part-time high tech specialist, s/he must work closely with mainstream computer technicians/instructors on the rest of campus if blind students are to become computer literate to the same degree as nondisabled students. Unfortunately, DSPS high tech specialists usually feel they are performing at full capacity to simply serve their students at the high tech center. There is little time left over, and few organizational supports, for them to seek out computer technicians/instructors scattered around campus.

As one step toward addressing the foregoing gap between the needs of students with disabilities and what community colleges were able to provide, state funds were provided through the Chancellor's Office several years ago to the majority of community colleges for the purpose of establishing high tech centers. These high tech centers were intended to enable recipient colleges to acquire a basic foundation from which to begin serving the adaptive technology needs of disabled students.

However, many developments have occurred since the distribution of those initial funds to community colleges for establishing high tech centers. For example, computer based information in all fields (e.g., educational software) including the Internet, has increasingly become available primarily through "windows-based" systems rather than the older DOS/text-based systems that are user-friendly to screen readers (the adaptive technology which converts computer based information into synthesized speech). This means that at this time the majority of community colleges are struggling to acquire screen reading programs that work effectively in a windows environment. Without such screen readers, blind students are shut out of accessing the educational software programs used in the mainstream curriculum. They are also not able to effectively research assignments that increasingly reward, if not require, use of the Internet.

The Assistive Computer Technology (ACT) CIG (CAPED Interest Group), primarily composed of DSPS staff throughout California, conducted a statewide 1996 survey identifying access technology products used by California Community Colleges. A total of 32 colleges responded to the survey identifying 110 different hardware/software products in use. While the 31 colleges for which data was made available constitute only about one third of all California Community Colleges, several interesting observations may be made. First, only 8 of the campuses reported having a Braille printer, which means only about one fourth of the campuses had even the potential to produce hardcopy Braille onsite. Only eleven of the 31 campuses reported having the speech synthesizer DECTalk (the most commonly used hardware for producing synthesized speech). As an indicator of how many colleges have equipped blind students to access computer-based information that is packaged in a Windows environment, of the 31 colleges only six had the most popular windows screen reading program JAWS (two of the six also owned WindowEyes). With regard to windows screen reading products other than JAWS, another 5 colleges had only WindowEyes, 3 had only OutSPOKEN, while 3 owned both WindowEyes and OutSPOKEN.

A greater number of the 31 colleges responding in the ACT CIG survey were better equipped to serve students accessing information in a DOS environment, e.g., 16 colleges had the most popular Vocal-Eyes, while some of those 16 owned other DOS screen readers such as LP DOS, Artic, ASAP. Because educational programs as well as Internet information is rapidly becoming available primarily through a Windows environment, blind students may still be able to use the DOS environment to do course assignments in computer text, but blind students limited to a DOS environment are barred from accessing much of the research and educational information used in mainstream curriculum, and from participating in the more advanced educational computer tasks.

OCR experience, which is supported by the ACT CIG survey, is that colleges are more likely to own the computer software needed to accommodate students with low vision or mobility impairments, than they are to own the screen reading software needed by blind students to translate information into an auditory medium (synthesized speech). According to the ACT CIG survey, with regard to enlargement screen software for students with low vision to access computer based information, two-thirds (20) of the 31 colleges responding to the ACT CIG survey owned the highly regarded screen enlargement software Zoomtext (three of these owned additional enlargement software programs such as InLarge and/or Magic), while one college did not have Zoomtext but did have both InLarge and Magic). Two-thirds (19) of the 31 colleges owned the well-known Dragon Dictate, a program to assist persons with mobility impairments in accessing computer information.

Even those colleges which have acquired windows-based screen readers are unlikely to have paid staff who are really proficient in their use and maintenance. Insofar as almost all community colleges are now relying upon a part-time staff person (high tech specialist) to serve the adaptive technology needs of all disabled students, blind students (usually uncompensated) comprise a critical resource used to educate staff and other students about adaptive technology for the visually impaired. The difficulty in relying upon students for this function is that blind students are ordinarily juggling an academic load that is already timeconsuming due to the difficulties posed by the disability, they have little authority within the college system to mandate that needed purchases/repairs be attended to, and there is relatively high turnover as students depart when their academic goals have been achieved.

On most campuses OCR visited, a full-time adaptive technology specialist was desperately needed. In addition to training disabled students on how to use adaptive technology equipment at the DSPS high tech center, and assisting students thereafter in using such equipment, the expertise of the DSPS high tech specialist is increasingly being used as the primary resource for assisting the campus as a whole (such as the library and academic departments) to make computer-based information accessible.

The DSPS high tech centers were especially noted in the narrative summary for the 1996-1997 Program Reviews of the DSPS Program Evaluation Project conducted by the Vocational and Educational Services division of the Chancellor's Office. In OCR experience at least two of the eight sites selected for the 1996-1997 Program Reviews are known statewide as having model high tech centers. The Chancellor's Office 1996-1997 Program Reviews summary stated that "Most campuses now have adapted computers and software in various computer labs, and some even have additional lab staff trained in the specialized equipment. This mainstreaming of adapted computers is a very positive trend. The DSPS High Tech Centers have also provided a good place to train other computer lab specialists throughout the campus and staff are frequently viewed as computer experts for the entire campus." Note that this comment refers to adaptive technology in general, and does not track adaptive technology for students with visual impairments, especially blind students needing adaptive technology to translate information into an alternative format such as synthesized speech.

OCR notes that the Guidelines for Evaluation Form used by the Chancellor's Office program review team when conducting DSPS onsite visits does not list the Americans with Disabilities Act as one of the statutes governing the reviews, and the eight page Guidelines for Evaluation Form makes no reference to adaptive technology when listing items the review team is to consider. Thus, the narrative comments made by the program review team regarding generic adaptive technology does not provide much information as to the extent to which adaptive technology is available to blind students. It is usually less difficult to provide computer access for low vision and mobility impaired users who, unlike blind users, do not need presented information to be converted into an auditory mode.

High Tech Centers: Translating Limited Print into Speech/Etext

The high tech center at each community college not only serves as a primary source for enabling blind students to access computer-based information, but in many instances has the capacity to translate a limited amount of print-based information into digital text, Braille, or synthesized speech. The central piece of adaptive technology used by the high tech centers for translating printed text into any kind of alternative format is an optical character recognition scanner.

The most low-cost stand-alone scanner simply reads aloud the printed words when the print is laid face down on its glass surface (somewhat comparable to xeroxing), thereby providing a one time translation into synthesized speech without the intermediary step of translating the print into a computerized digital text. If the listener wishes to record the synthesized speech output, on many scanners this can be accomplished by simply plugging in a standard audiocassette taperecorder. When attempting to record a substantial amount of printed text so translated, such informal recordings are subject to most of the same problems, e.g., lack of internal document flexibility, that plague informal recordings of personal readers (see above).

However, the more expensive optical character recognition scanner is connected to a computer (external or internal) which converts the print into digital text (computer-based information). Conversion into digital text not only provides the maximum number of alternative format output options (e.g., synthesized speech, Braille, electronic disk) but digital text has the tremendous advantage of creating highly organized stored information that can be used again. While libraries were more likely to have "stand-alone" optical character recognition scanners, the scanners at most high tech centers had the capacity to translate into digital computer text.

An increasing number of blind students are becoming computer proficient and prefer to complete academic tasks and examinations on the computer. This usually means converting some printed text into electronic digital text. Thus, even when the blind student is not requesting hardcopy Braille or synthesized speech, a good quality optical character recognition scanner is a critical tool in accommodating a blind student.

High Tech Centers: Capacity to Translate Large Volumes of Print

DSPS Offices committed to providing the blind student an accurate translation reported that, when using scanners to translate printed text, a significant amount of proofreading time was required. Moreover, apart from copyediting, the mere act of feeding printed text into the scanner usually constituted a sufficiently significant amount of stafftime as to make reliance upon scanners undesirable for translating the large amount of printed material contained in textbooks. Although there are colleges outside the California Community College system that own an "industrial strength" scanner (which is used by mainstream business and has the ability to self-feed and self-collate the loose sheet double-sided pages of a printed book whose binding has been removed), OCR is not aware of any California Community College that owns, or has made arrangements to access, such a scanner which has been used successfully by other entities to efficiently translate entire printed &Ndigital text.

The amount of time spent by DSPS/high tech center staff translating printed text into digital text is especially troublesome in light of the fact that most printed text today was originally composed on the computer, e.g., publishers hold the electronic disk version of textbooks prior to outputting into hardcopy print. Even course examinations and class handouts, which are with increasing regularity created by the course instructor on computer, are nevertheless frequently delivered to the DSPS Office in a print format, necessitating use of DSPS staff and equipment to convert the print into digital text (and then, in some cases, on into Braille). However, although converting the printed hardcopy back into digital text was admittedly cost/labor inefficient, DSPS staff repeatedly expressed a concern that pressuring instructors to provide examinations/handouts on electronic disk might create one more barrier to the blind student timely accessing course examinations/handouts.

High Tech Centers: Translating Print into Braille

OCR found that those colleges which offered blind students the option of taking examinations in Braille, or of translating class handouts or portions of textbooks into Braille, usually were able to do so because the DSPS high tech center possessed certain key equipment, specifically, an optical character recognition scanner (for translating printed characters into digital text), Braille software (for translating digital text into electronic Braille codes), and a Braille printer (for translating electronic Braille codes onto embossed Braille hardcopy paper). OCR found few colleges were staffed and equipped to accurately translate on an ongoing weekly basis more than 10 printed pages into Braille (which usually met the average examination/class handout needs of one Braille proficient student, with no translation of textbooks). The majority of community colleges were not prepared to do even this. As noted above, the ACT CIG survey found only one fourth of the responding campuses reported having a Braille printer, which is essential for producing hardcopy Braille onsite.

Access to Mainstream Computer Labs

Adaptive technology for the blind has been installed in very few "mainstream" computer labs, "mainstream" meaning either department labs set up for students taking courses within that specific department (e.g., education, mathematics, business) or "open" computer labs for general use by the student body when completing academic assignments. There is an ideological division among various colleges as to whether to "push" disabled students out of the DSPS high tech center "nest" into the outlying mainstream computer labs or, instead, to build up the DSPS high tech center so that it serves as a centralized location that can centrally serve the full spectrum of needs of students with disabilities for educational computer technology.

In general, those colleges with the highest level of proficiency in meeting the needs of blind students favor establishing highly interactive relationships between the DSPS High Tech Center and the computer technicians at outlying computer labs so that the student with the disability has the benefit of working in an environment where onsite staff is familiar with the educational software used by the student. In other words, it is easier for the computer technicians serving the academic departments to acquire a working knowledge of the pertinent adaptive technology than it is to install on the DSPS High Tech Center the multitude of educational software programs used throughout campus and require the DSPS high tech specialist to become proficient in all these educational software programs. OCR found that "mainstream" computer technicians, once invited to the DSPS high tech center to observe demonstrations of adaptive technology, often were open and interested in how to incorporate adaptive technology into the mainstream computer labs they served.

OCR notes that both the local DSPS offices and the DeAnza High Tech Center were highly restricted by limited funding in the extent to which they could provide adaptive technology training for computer technicians in outlying mainstream computer labs. This is one of many examples where colleges for the most part unrealistically continue to rely exclusively on the DSPS Office to solve the technology needs of students with disabilities in the same way (and often with the same budget!) as the DSPS Office did back when access might mean merely providing a notetaker or reader.

One reason given by some colleges for concentrating all adaptive technology services in the DSPS high tech center is that it is cost efficient. Specifically, permanent installation of adaptive technology in outlying mainstream computer labs is assumed to require multiple purchases of hardware and software products/licenses. However, some campuses are exploring the feasibility of making adaptive technology software available on the campus LAN network so that it can be downloaded from any computer on campus. In this arrangement, a site license for "five" does not limit the college to five predetermined locations on campus, but rather limits the number of campus computers (anywhere) running the particular software to five at one time. As for hardware, some campuses already keep the speech synthesizer at a reference desk for hourly check out (or assigned to the student for the semester) to be installed at whatever computer is not in use at the time the blind student needs access. Moreover, if screen reader software programs begin to utilize the sound board in multimedia computers, the amount of specialized computer hardware needed to accommodate blind students should diminish.

Considering Accessibility When Purchasing Mainstream Technology

Several community colleges have already established at least a skeletal structure whose purpose is to facilitate communication, if not compatibility, among all the various computer technology purchasing being done by various departments at the same college. Such structures range from a campus technology committee that meets a few times a year and has no approval/disapproval authority regarding department technology purchases, to a central master technology committee/administrator whose approval/disapproval is required prior to any departmental technology purchases. OCR is not aware of any California Community College at which departments proposing to purchase new technology hardware and/or software are routinely asked whether they have considered how students with disabilities will access the particular proposed purchases.

A few community colleges (which already have a campuswide system for coordinating technology purchases) have taken steps to secure funds, above routine DSPS funds, to contribute to the cost of making technology accessible. At least one college takes a percentage off the top (prior to distribution through grants) of all monies available for campuswide mainstream technology expenditures. Several campuses allow the DSPS Office, above its routine budget, to seek additional funds for adaptive technology by submitting grant proposals in competition with grant proposals submitted by other campus departments requesting funds for technology purchases.

For the most part, however, colleges have not taken institutional responsibility for ensuring that the multitude of new purchases of technology designed for use by nondisabled students, will be accessible to students with disabilities. Instead, in the main community colleges are operating on the assumption that the DSPS Office will somehow "fix the problem" when a disabled student requests access to a course or other campus service that includes computer technology. Having made the assumption that accommodations for students with disabilities lie exclusively with the DSPS Office, most community colleges go on to assume (erroneously) that the routine DSPS Office budget can be made to stretch to cover the cost of all adaptive technology needs. Even with months of advance notice that a blind student intends to enroll in a course that uses computer technology, OCR found it common practice for the necessary adaptive technology not to be installed and operative when the student arrived for the first day of class. In a few cases DSPS Offices have suggested to disabled students that the appropriate method for obtaining major adaptive technology was for the student himself/herself to raise the funds through donations. Such suggestions clearly violate the college's obligation to provide reasonable accommodation.

To colleges which have already established a centralized mechanism to coordinate campuswide technology expenditures, OCR makes the following suggestions:

(1) written forms used to submit departmental grant proposals for mainstream technology purchases should contain a check-off box indicating that the applicant has investigated the issue of access as to at least the following disabilities: blindness, deafness, lack of physical dexterity. With respect to each of the foregoing disabilities that would be a barrier to use of the proposed computer technology purchase, the applicant should attach a sheet specifying by what method the proposed technology purchase may be made accessible (e.g., the type of adaptive technology that will need to be purchased) and what resources are available to cover the cost of rendering the new technology fully accessible,

(2) refer departments purchasing hardware and/or educational software programs to a list of resources for assistance in determining whether proposed technology purchases will be accessible to persons with various types of disabilities, and (3) develop a long term comprehensive strategy regarding equitable feasible distribution of the campuswide costs for adaptive technology. This strategy should realistically assess the cost of anticipated adaptive technology needs (keeping in mind that students with disabilities constitute as much as 10 percent of the student body), and determine the most appropriate time for addressing issue of access to ensure cost effectiveness and timeliness (when proposal for mainstream technology is being developed, when such technology is actually purchased, when student enrolls in course, etc.).

A final thought regarding methods by which the California Community Colleges may be able, as a group, to more effectively serve students with visual impairments. At this time there is essentially no method for the experiences acquired by the department of one college (e.g., a specific math software product is found to be impossible to access by screen reader) to benefit counterpart departments in other colleges when those counterpart departments at other colleges make similar future purchases of educational software. A central "bulletin board" could be an important resource for department staff selecting software products and for master technology committees reviewing proposals by departments to purchase new mainstream technology. In short, similar to a Better Business Bureau, tracking the accessibility of frequently used computer products would strengthen the consumer clout of all California Community Colleges.

Access to Library

During its onsite visits, OCR shared with librarians several ideas implemented at other colleges who successfully enable blind students to directly access, while remaining at the library, computer-based information and print-based information. In general, OCR found librarians eager for information on how to make their resources more available to patrons with disabilities, especially those with print-impairments. With few exceptions, community college librarians were unaware of numerous existing alternative format (e.g., audiotape, electronic text disk) lending resources which already possess duplicate copies of some of the books stocked in print on community college library shelves.

Many California community colleges already had at least some experience in providing onsite accommodation to persons with low vision. Specifically, a significant number of libraries possessed a CCTV unit, albeit often very old, that enlarges print placed under the magnifying lens. (A CCTV does not translate the print into digital text nor create an enlarged printout that the patron may take with him/her.) Librarians consistently mentioned they observed a wide range of patrons who regularly used low vision adaptive technology such as CCTV equipment and computer screen enlargement software. In other words, many library patrons who did not think of themselves as disabled found it convenient to be able to enlarge small print in books/computer programs. (This is sometimes referred to as the "curb cut" phenomena, where members of the general public find measures taken to accommodate persons with disabilities are useful for multiple purposes.) However, beyond a CCTV which exclusively benefits low vision (not blind) patrons and does not assist with access to computer-based information, libraries had minimal experience with providing direct onsite accommodation to patrons with visual impairments.

The OCR onsite visit was frequently the first substantial interfacing of the DSPS staff and the library staff, whose past practice has often been to simply refer blind patrons to the DSPS office for accommodation rather than attempt to directly serve such students at the library site. In addition to the issue of timeliness (contrast referral to the DSPS Office with the quick convenience of onsite service enjoyed by nondisabled patrons), a library's practice of relying exclusively on the DSPS Office to handle accommodation requests creates a funding conflict. The DSPS Office is only funded to serve students enrolled at that campus, not members of the public, whereas all California Community College libraries are required to serve the larger public beyond that of students enrolled at the local campus. No community college library of which OCR is aware has tackled the issue of how to establish whether a patron requesting accommodation has a qualifying disability when the patron is not a student and thus not registered at the college's DSPS Office.

In the last five years libraries at community colleges have been actively computerizing much of their reference materials. Almost every college has its card catalogue online, and most can access the card catalogue of other libraries via computer. Although new major expenditures by libraries tend toward acquisition of computer-based information resources, the bulk of information owned by colleges libraries today is still encoded in hardcopy print (books). An increasing number of libraries find that placement in a public area of an optical character recognition scanner, to convert hardcopy print into synthesized speech and/or digital text, is essential if the library is to provide timely, effective service to blind patrons. A scanner operated by the blind patron enables librarians to usually dispense with arranging for personal readers to assist patrons with visual impairments. Comparable in many ways to xerox machines, most scanners installed in a user friendly manner can be successfully operated by blind patrons with minimal instruction.

Shortage of space and inability to safely secure expensive equipment seemed uppermost in the minds of librarians contemplating onsite installation of adaptive technology. With regard to accessing computer-based information (e.g., card catalogues, educational software programs, campus LAN, Internet), libraries which were already highly computerized did not report special security problems when adaptive technology software was simply installed on a computer set among several other mainstream computers. On the other hand, when the library set aside a specially purchased high quality computer that stood on its own or was significantly superior to any other computer in the vicinity, librarians generally felt the need to take particular security precautions especially during off-hours when the library was less populated.

With regard to the noise factor from synthesized speech generated by computer screen reader software, a few libraries created a separate room to set up adaptive technology, but the vast majority provided blind patrons with ear/headphones to prevent the sound of synthesized speech interrupting the quiet needed by other library patrons. Headphones and synthesized speech hardware were often kept at the reference desk for checkout by patrons with disabilities.

Several librarians mentioned that, once adaptive technology was installed, coordination with the DSPS Office became important to ensure that library patrons had already been trained in the use of adaptive technology prior to attempting to use the library's equipment. A few DSPS Offices provide qualifying students with disabilities a small identification card to indicate to other campus departments, such as the library, on what adaptive technology the cardholder has been trained.

Finally, it must be noted that a disturbing number of community college libraries have a practice of informing students with visual impairments that accommodations are only available for reading materials assigned in a course in which the student is currently enrolled. Such practice clearly constitutes disparate treatment when nondisabled patrons are free to use the library's full resources for non-course related purposes.

Many community college libraries are already cooperatively working with other libraries (especially at four year universities) to dramatically enlarge the books available to patrons through book lending arrangements. However, virtually no community college library has begun a dialogue with nearby city/county public libraries or university libraries to determine the extent to which coordination around accessibility issues might be useful (e.g., regional/state card showing its holder has a print-impairment disability, regional/state system for locating a requested book in alternative format).

Access to Distance Learning and Computer Networks (LAN/Internet)

The movement of California Community Colleges to embrace distance learning as a cost-effective convenient method of meeting the needs of the larger community has literally exploded in recent years. This explosion carries special potential for persons with disabilities. At the same time, because distance learning to a high degree eliminates the highly auditory portion of the course (the classroom lecture and in person student discussions) and instead relies almost entirely upon visual presentation of information, blind students are placed at particular peril.

Community college administrators with whom OCR spoke were for the most part struggling to overcome the conceptual difficulties of attempting to ensure that even nondisabled students would continue to obtain the core of the educational experience in such an entirely new format. There has been minimal attention invested to date on how persons whose disability precludes receipt of information in a visual medium will be able to access a program that is almost exclusively visual in nature.

The DeAnza High Tech Center Training Unit presented at the October 1997 CAPED Conference the results of its survey taken six months earlier. The paper was entitled "Internet Access in the DSP&S Programs of California Community Colleges: An initial study of the availability and location of e-mail and Web access for staff and students of DSP&S programs in the California Community Colleges." Most of the report focuses on whether DSPS administrators and staff (most of whom are not disabled) have any method (including home computers) for accessing various types of computer-based information. However, the DeAnza study provided some information regarding access by DSPS students (who have a range of disabilities, not just visual impairments). As noted above, it is usually less difficult to provide computer access for low vision and mobility impaired users who, unlike blind users, do not need visually presented information to be converted into an auditory mode. Thus, it may be expected that a higher number of colleges will state that DSPS students (as a whole) have access to a particular technology service than would be true if the colleges were specifically asked whether blind students have access to that same service. This difference in focus (access of disabled students as a whole versus access of students with visual impairments) should be kept in mind when interpreting data from various surveys.

With respect to access to email, the OCR survey found that about one third (34) of the California Community Colleges were offering email service to nondisabled students, but only 10 campuses reported making this service available to students with visual impairments. Of further interest is the DeAnza study, although it did not track students with visual impairments independently of DSPS students as a whole. The DeAnza study indicated that of the colleges responding, 23 campuses stated that DSPS students had email access and 52 colleges stated that DSPS students did not have email access. Specifically, 12 colleges stated DSPS students (of unidentified disability types) had email access through computers in the high tech centers, 20 stated DSPS students had email access through computers on campus, and 11 stated DSPS students had access to email through computers at home or other off-campus location. Note that in the DeAnza study, the same college may be counted two or more times depending on the number of locations from where the service can be accessed.

With respect to Internet access, OCR found that about half (51) of the California Community Colleges provide Internet services to nondisabled students, but only one fifth (22) of the colleges provide Internet access to students with visual impairments. It is interesting to note that the DeAnza study found that of the colleges responding to the survey, 52 colleges stated DSPS students (of unidentified disability types) had World Wide Web access from some location including home, whereas 23 colleges stated DSPS students did not have access to the World Wide Web from any location. Specifically, according to the DeAnza study 30 colleges provided World Wide Web access through the high tech center, 40 colleges provided access through computers on campus, and DSPS students at 13 campuses had access from home or other off-campus location.

DeAnza High Tech Center Training Unit: Technical Assistance

In discussing the local high tech centers at community colleges, it is essential to refer to the DeAnza High Tech Center Training Unit, directed by Carl Brown and primarily funded by the Chancellor's Office of California Community Colleges. An outstanding reliable source of advisory support for all community colleges regarding their adaptive technology needs, this centralized resource was initially developed to offer statewide training and technical advice to DSPS coordinators who had little or no adaptive technology background. It still does an excellent job in providing introductory training and technical advice to DSPS staff.

However, as the range of adaptive technology has become more complex and specialized, the Center's limited funding has not enabled it to adequately serve the increased needs of the community colleges. In particular, more advanced training is needed for the high tech specialists working at many DSPS offices, and the opportunity to obtain introductory adaptive technology training should be extended to non-DSPS staff (e.g., librarians, academic departmental staff/technicians). OCR found that the already overextended high tech specialists at the local High Tech Centers are in a limited position to develop indepth training to meet highly specialized departmental needs (e.g., library access or educational software access needs of the math department).

Non-DSPS staff might be most economically trained at their own campuses in large groups rather than transported to De Anza. In an effort to respond to the increased number of staff at one locale that would like adaptive technology training, the DeAnza Center is increasingly open to traveling to the college site to provide training, rather than requiring staff to travel to the DeAnza Center. Training at the college location should allow a wider cross-section of college staff/technicians to benefit. This is an example of the DeAnza High Tech Center changing to meet the changing adaptive technology training needs of the community colleges. It is clear that this is an appropriate time to revisit and review the stated purpose and funding mandates under which the DeAnza Center operates to ensure that they are aligned with the needs of the California Community Colleges.

In the main OCR observations were similar to the "High Tech Center Training Unit (HTCTU) Performance Review Report" issued November 17, 1997, by the Vice Chancellor, Student Services Division of the Chancellor's Office. This document contains nine specific recommendations regarding the DeAnza High Tech Center Training Unit, including a recommendation for a statewide needs assessment of the colleges, and a report on the desirability and feasibility of bi-annual site visits to every college's high tech center.

Another role that the DeAnza High Tech Center has successfully fulfilled in the past, and which would be useful again, is that of identifying recommended adaptive technology products so that the Chancellor's Office can negotiate on behalf of all California Community Colleges to obtain the best price on various popular adaptive technology hardware and software. Several vendors have indicated a willingness to offer certain discounts and to explore the possibility of comprehensive service arrangements (e.g., a statewide hotline which could be accessed twelve hours a day by college staff and/or students).

Finally, the DeAnza Center currently maintains a Website that keeps California Community Colleges up-to-date not only on upcoming trainings, but also on adaptive technology developments and other related matters (see .

Caveat

Over a year has elapsed since OCR collected some of its data. Because this is a period of rapid technological growth by California Community Colleges, OCR anticipates that during this time the DSPS high tech centers have continued to expand their adaptive technology acquisitions. Also, active technical assistance by committed DSPS staff, by OCR, and by the DeAnza High Tech Center Training Unit, have already impacted community colleges' understanding of the importance of some of the issues covered in the OCR Compliance Review.

Report Submitted By:

______________________________________ Paul Grossman, Chief Regional Attorney

______________________________________ Sarah Hawthorne, Attorney



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