OCR Letter: California Community Colleges

Thomas J. Nussbaum, Chancellor
California Community Colleges
1107 Ninth Street
Sacramento, California 95814

(In reply, please reference Case Docket No. 09-97-6001)

Dear Chancellor Nussbaum:

On March 26, 1996, the U.S. Department of Education, Office for Civil Rights (OCR) met with you and your staff to notify you that OCR was beginning its college onsite visits in the statewide compliance review under Title II of the Americans with Disabilities Act of 1990 (Title II) and Section 504 of the Rehabilitation Act of 1973 (Section 504). This compliance review focuses on the status of community colleges in meeting their obligation under Title II and Section 504 to provide students with visual impairments access to print and computer-based information. The review examines whether students with visual impairments, particularly blind students, are accorded an equal educational opportunity by California Community Colleges, or whether they are being discriminated against on the basis of their disability [34 C.F.R. ' 104.4(a); 28 C.F.R. ' 35.130]. Specifically, OCR is considering whether the Chancellor's Office employs methods of administration that have the effect of substantially impairing accomplishment of the objectives of the California Community College Community Colleges educational program with respect to students with visual impairments [34 C.F.R. 104.4(b) (4)].

This letter contains four parts: (1) highlights from OCR Summary Report, (2) nine suggestions on how areas of OCR concern may be addressed by the Chancellor's Office, (3) a request that meetings be set up in the next month between OCR and appropriate members of the Chancellors's Office, and (4) a description of other items enclosed in the packet attached to this letter.

The OCR Summary Report (enclosed) is base on OCR survey results, onsite visits, complaint resolution experience, and reports from various components of the California Community College system. Some highlights from the OCR Summary Report are:

  • Access to technology is recognized by California Community Colleges as a high priority for all students. Yet students with visual impairments currently face overwhelming barriers to such access.
  • It is extremely expensive for community colleges to meet their legal obligation to provide communication as effective as that provided to nondisabled students when each college attempts to individually serve a handful of students whose disability requires print and computer-based information to be translated into alternative medium. Consequently, students with visual impairments, particularly blind students, who are scattered throughout the community college system, are drastically underserved by Disabled Student Programs and Services (DSPS) Offices whose budgets are stretched thin.
  • Braille proficient students are under-identified by colleges, the majority of whom are not prepared to provide timely Braille translations for examinations and classroom handouts, much less textbooks.
  • Adaptive technology is available to eliminate most barriers facing students with visual impairments. However, use of adaptive technology requires an upfront capital outlay and specialized staff training. In contrast, the cost of personal readers is usually borne by the California Department of rehabilitation when the student with a visual impairment is a client, and in other cases personal readers may be obtain from a pool of volunteers. Yet in many situations adaptive technology not only removes barriers to information/technology access that personal readers do not, but adaptive technology offers long term savings over labor-intensive methods of accommodation. For example, once translated into the proper electronic digital text, information can be cost-effectively output multiple times into a variety of alternative formats (e.g., synthesized speech, Braille, screen magnification) that will benefit not only underserved students with visual impairments but students with other types of disabilities (e.g, learning disabilities, acquired brain injury).
  • Acquisition of technology and expansion into distance education, including the Internet, is occurring at an explosive rate among California Community Colleges. Failure at this time to take into account the needs of students with visual impairments will foreseeably result in substantial investment in inaccessible products and program structures, thus unnecessarily raising the subsequent cost of accommodating students with visual impairments, and in some cases precluding such accommodation altogether.
  • Present >method of administration by the Chancellor's Office are failing to effectively respond to the above.

Listed below are nine strategies by which the Chancellor's Office may wish to address areas of OCR concern:

I. Cost-Effective Approach to Purchasing Adaptive Technology

With respect to obtaining group discounts for mainstream computer products, OCR notes that the Chancellor's Office is in the process of negotiating with manufacturers (e.g., Sun Microsystems) and has also established an advisory committee to create a systemwide master offering list to facilitate cooperative purchase of computer products at substantial discounts to participating colleges. The Chancellor's Office and/or its components (i.e., the DeAnza High Tech Center Training Unit) has the expertise to identify which adaptive technology hardware/software products, if acquired pursuant to a group purchasing arrangement, would most benefit community colleges in need of such products to ensure that students with visual impairments have access to libraries, departmental computer laboratories, and DSPS/high tech centers. The Chancellor's Office would then be in a position to negotiate opportunities for optional group purchasing arrangements.

Consider for inclusion in the list of hardware/software products: large screen monitor, optical character recognition scanner, screen reader software, speech synthesizer, screen enlargement software, CCTV, Braille conversion/editing software, Braille printer. Colleges purchasing products pursuant to this agreement will need appropriate staff training.

II. Adaptive Technology Training

The DeAnza High Tech Center Training Unit currently provides excellent statewide training and technical assistance to California Community Colleges. However, the needs of the colleges for adaptive technology training have grown beyond the purposes for which the Center was originally established. When the Center was originally established ten years ago many colleges were in the initial stages of acquiring adaptive technology. Now most colleges have at least part-time high tech specialist who have indicated that they need more advanced training in order to do their job (e.g., explicit training on interfacing screen reading software with commonly used complex computer programs, e.g., LOTUS, MCAD).

In addition to advanced training for DSPS/high tech specialist, as students with disabilities have exercised heir right to access the mainstream educational program, libraries and department computer labs are becoming aware of the need to acquire onsite adaptive technology rather than merely refer students to the DSPS/high tech center, which does not have the capacity and is not funded to make all technology/information on campus accessible. Thus, college staff outside DSPS/high tech center are requesting adaptive technology training, preferably focussed on their unique needs.

III. Access Guidelines for Distance Learning and Campus WebPages

California Community Colleges, individually and collectively as part of the California Virtual University, are rapidly developing their capacity to deliver educational programs to offsite students through technology. Little attention is being given to ensure that these distance learning programs are accessible to students with disabilities, especially students with visual impairments. Moreover, colleges are placing more and more information on the Internet and campus LAN, yet the WebPages through which this information is to be accessed have not been designed to facilitate access by persons with visual impairments.

The need for guidelines regarding distance learning has been recognized by several different entities in the California Community College system, including the Academic Senate which in Fall 1997 adopted Guidelines for Good Practice: Technology Mediated Instruction. It is OCR understanding that four regional distance learning centers to assist in development of program and course materials will be set up in 1998-1999. The concept of accessibility should be firmly integrated into such development.

If guidelines to ensure access are made available to colleges now, such information on how to structure distance learning programs and campus WebPages will not only ensure that colleges meet their legal obligations but will also enable colleges to save significant expense over the later cost of retrofitting these programs after substantial investment has been made in inaccessible structures. The Chancellor's Office may wish to draw on distance education and webpages access guidelines developed by others.

IV. Distribution of Standard Technology Grants/Funds

Each year the Chancellor's Office offers colleges opportunities to apply for technology grants or otherwise establish eligibility for technology funds. The process for applying/establishing eligibility should require a college to describe the method by which it will meet its obligation under Title II of the Americans with Disabilities Act of 1990 and Section 504 of the Rehabilitation Act of 1973 to ensure this particular technology is made accessible to persons with disabilities, including persons whose disability requires a nonvisual format. Technology access, like architectural access, must be addressed institutionally as an integral part of the planning process.

V. Printed Materials Translated into Electronic Text/Braille

Recent federal legislation has removed one of the major obstacles to providing print in an alternative format by eliminating the copyright barriers to reproduction when the purpose is to provide access for person with disabilities. One of the remaining obstacles is the time-consuming labor-intensive process of converting hardcopy print into electronic text so that it can be output in the appropriate alternative format (e.g, Braille, synthesized speech).

One method of dramatically reducing the conversation time/labor is through use of an industrial optical character recognition scanner now on the mainstream business market. Unlike the scanners (estimated cost $5,000) used by DSPS offices which usually require that staff handfeed each side of every printed sheet, such industrial scanners (estimated cost less than $90,000) are able to read/collate/translate into electronic text an entire doublesided textbook (after binding removal). Thus one or two high efficiency Alternative Format Centers could be established in California, and electronic text returned by modem to the requesting college. Finally, it should be noted that certain types of print information do not lend themselves to scanning (special punctuation, graphs, charts, mathematical symbols, subscripts). It is much easier for an Alternative Format Center, specializing in translating print to develop solutions to these conversion difficulties.

The Braille Transcription Center (CSU Fullerton) serving California State University campuses has found as a practical matter that, not only conversion from print to electronic text, but also translation from electronic text to Braille, is most effectively and reliably done at a centralized location. Nevertheless, another option is for each college to use its own Braille printer to output the electronic text. Not only textbooks, but even small Brailling tasks such as examinations and class handouts are sometimes most efficiently handled at an offsite centralized location rather than at a DSPS/high tech center that serves one or two blind students.

VI. Central Registry of Textbooks in Alternative Format

At the present time there is not method for DSPS offices to easily exchange information about what textbooks they currently possess in alternative formats. Audiocassettes obtained from the national Recording for the Blind and Dyslexic (RFBD) are centrally catalogued by RFBD. However, textbook translations created by individual colleges (ranging from audiotapes made by personal readers, to hardcopy Braille translations, to enlarged print, to electronic text input by DSPS staff) may be stockpiled on the shelf after one time use. On the other hand, some colleges are under the missimpression that they are not entitled to reclaim the alternative format textbooks from the students after the semester is completed. Thus, again there is no opportunity for other students with visual impairments to benefit from a prior translation.

If a central registry, perhaps on the Internet, were established so that DSPS Offices could simply post the title/publisher/alternative format of unused textbooks within their possession, not only would this reduce duplication of translation efforts, but when DSPS is assisting students with print impairments in making last minute course selections, it would be useful to know that certain textbooks are immediately available in an alternative format.

VII. Library Access

As a result of the Telecommunication and Technology Infrastructure Program (TTIP) and other recent initiatives, California Community College libraries are investing significant funds in technology hardware/software acquisition. OCR notes that the Chancellor's Office has been charged with developing standards and funding recommendations in the area of library technology initiatives and electronic resources and technology human resources training fund.

Traditionally, community college libraries have relied upon referring students to DSPS as the exclusive method by which patrons with disabilities are served. On many campuses such referrals constitute the library's sole contact with the DSPS/high tech center. However, there are many ways in which DSPS Offices are not equipped to handle the broader access issues on the library, e.g., DSPS funding is restricted to expenditures directly related to the instructional/curriculum needs of enrolled students (a narrower purpose than would cover the general services provided by the community college library). A concerted effort needs to be made both to alert community college libraries to their print/computer access responsibilities, and to acquaint them with resources available to assist in better serving patrons with disabilities.

VIII. Followup to OCR Survey

The survey of all colleges initiated by OCR on September 18, 1996 was a useful tool for obtaining some information about the extent to which print and computer based information is being made available to students with visual impairments. However, within the last tow years community colleges have made unprecedented movement toward "technologizing" their campuses. It would therefore be appropriate for the Chancellor's Office to conduct its own followup survey to determine the extent to which progress has been made since the initial OCR survey. The DeAnza High Tech Center Training Unit has expressed an interest, if requested by the Chancellor's Office, in conducting more indepth research into many of the areas covered by the OCR survey with respect to a smaller number of the campuses (e.g., a randomly selected twenty percent).

IX. Annual DSPS Program Reviews

's Office (Vocational and Educational Services) conducts program reviews of DSPS offices at about ten California Community Colleges. The Guidelines for Evaluation for these program reviews does not direct the reviewer to give substantive attention to the issue of adaptive technology (as contrasted with the page and a half devoted to architectural barrier removal). In particular, the question of access by students with visual impairments to print/computer based information is not raised. This program review mechanism would be an ideal method for alerting colleges on an ongoing basis that the Chancellor's Office values a college's commitment to ensuring that students with disabilities have equal access to print and computer-based information. Also, when listing the federal statutes that govern the program reviews, the Guidelines for Evaluation lists the Rehabilitation Act of 1973 (Section 504), but no mention is made of the Americans with Disabilities Act of 1990, which contains numerous references to the important role of technology in ensuring persons with disabilities equal access. The Guidelines for Evaluation used when conducting program reviews of DSPS offices should be revised to reflect more recent legal and technological developments.

Anticipated Process for Resolving Compliance Review Issues

At this time OCR is requesting that the Chancellor's Office provide OCR an opportunity to meet with staff and/or other appropriate individuals who have a working knowledge in fields affected by the above proposed nine strategies. Because many strategies are within the purview of different staff and because it is desirable to offer adequate time to thoroughly discuss the practical aspects of each strategy. Please feel free to set meetings for different times/dates to accommodate multiple scheduling needs. OCR is interested in hearing from the Chancellor's Office as to whether the proposed strategies are consistent with California Community Colleges goals and objectives, and if so, what next steps might be appropriate. It is not expected that any formal commitments will be made during these initial meeting(s). If possible, please schedule the meeting(s) prior to March 1, 1998.

The standard OCR process for resolving compliance review issues is for OCR and the public institution/recipient to reach a mutual understanding on what steps will be taken to address existing problems, and for OCR too monitor implementation of those steps through the institution/recipient submission of a specified number of annual progress reports to OCR.

Attachments

Attached to this OCR letter are several documents. The first are two OCR letters, issued since we last met with you, resolving specific individual complaints filed with OCR. These two letters describe the applicable legal standards regarding a public college's duty to provide students with visual impairments access to research resources (e.g., library books, Internet) and to provide textbooks in an appropriate alternative format. As a practical matter, neither of these duties can be accomplished in a timely efficient manner without use of specialized technology.

For further reference, attached is a copy of U.S. Department of Education (Department) "Requirements for Accessible Software Design" issued March 6, 1997, describing standards utilized by the Department when selecting computer hardware and software applications for use within the Department's computing environment to ensure the accessibility of its programs and activities to individuals with disabilities.

Also attached is a copy of the "Information Access for Students with Visual Impairments: Analysis and Final Report of the California Community College: Survey and Self-Evaluation" completed by researchers Jamie Dote-Kwan (California State University at Los Angeles) and Jeffrey Senge (California State University at Fullerton). This report analyzes data collected from surveys returned to OCR from all 106 community colleges in response to the OCR questionnaire sent by the Chancellor's Office on September 18, 1996.

Finally, attached is an OCR Summary Report drawn from OCR onsite visits during Spring 1997 to 16 community college campuses, from the OCR survey results, from OCR experience in processing complaints and responding to requests for technical assistance, and from information available from California Community College entities.

For further information you may contact Paul Grossman, Chief Regional Attorney, qt (415) 437-7816, or Sarah Hawthorne, Staff Attorney, at (415) 437-7719. To schedule the requested meetings, please contact Sarah Hawthorne.

Sincerely,

Stefan Rosenzweig
Regional Director

cc: Ralph Black
Thelma Scott-Skillman
Rita Cepeda
Larry Toy
Kaylene Hallberg
Katherine Campisi
Carolyn Norton

 

Response

March 13, 1998

Stefan Rosenzweig, Regional Director U.S. Department of Education
Office for Civil Rights, Region IX
Old Federal Building
50 United Nations Plaza, Room 230
San Francisco, California 94102

Case Docket No. 09-97-6001

Dear Mr. Rosenzweig:

We received the Office for Civil Rights (OCR) summary report, suggestions for addressing areas of concern to OCR, and the supplemental materials regarding access to technology for students with disabilities in the California Community Colleges. We are also apprised of OCR's request to meet with Chancellor's Office staff to monitor our progress in addressing these issues. After review and analysis by various members of my staff, I would like to summarize our response to each of your nine suggestions as well as to the issue of access to technology for persons with disabilities in general.

First, let me assure you that the California Community Colleges is deeply committed to ensuring access to its educational activities to all students, including students with disabilities. The California Community Colleges have been a national leader in providing services to students with disabilities. We are fully aware of the positive relationship between a student with a disability's education level and likelihood of entering the workforce. We also realize that under the Americans with Disabilities Act (ADA) as well as Section 504 of the 1973 Rehabilitation Act the colleges have a significant responsibility to assure that all of their programs and services are usable by and accessible to persons with disabilities. Therefore, while we realize that providing equal access to technology for persons with disabilities will involve a comprehensive, systemwide commitment over an extended period of time, we are committed to this outcome.

Second, let me address each of the nine suggestions/strategies you offer for addressing the various access issues before us.

1. Cost-effective Approach to Purchase Adaptive Technology

We have utilized the strategy of group purchasing of adaptive equipment in the past through the High Tech Center Training Unit (HTCTU) at De Anza College. Since we are now expanding this effort to include general computer technology, I will direct my lead staffperson, Dr. XXXXXX, to study this possibility further and to coordinate efforts with the HTCTU. We are supportive of group purchasing discounts as long as the colleges still have the option to purchase other equipment if they have unique needs. In addition, we are aware that the California Assistive Technology System (CATS) disseminated specifications for basic computer access and adaptability to all of the 106 community colleges last year. These specifications were developed by Missouri as part of their grant under the Technology Related Assistance to Individuals with Disabilities Act (Tech Act). We are seeking to collaborate more closely with CATS (which is California's version of the Tech Act) to ensure that their work and that of other Tech Act projects can be effectively utilized in our system. To that end, Dr. XXXXX, DSP&S Coordinator at the Chancellor's Office serves as a member of the CATS Advisory Council.

2. Adaptive Technology Training

We concur with the suggestions and strategies related to training. In fact, we are in the process of issuing a Request for Application (RFA) for the High Tech Center Training Unit for the next five year cycle of operation. We have incorporated many of the concepts you put forth regarding adaptive technology training into the RFA. These include: advanced training on interfacing screen readers with complex computer programs; and annual needs assessment of the colleges to determine their training needs which will form the basis for the subsequent year grant work plan; training offered more frequently at diverse locations throughout the state; and training of librarians, learning center, and campus computer center staff on access issues related to persons with disabilities. In addition to this effort, I will ask the librarians, learning center, and campus computer lab staff to include training modules on access issues for persons with disabilities into their general inservice programs.

3. Access Guidelines for Distance Learning and Campus Web Page

We concur with the strategies related to this issues. I will immediately direct that the Chancellor's Office task Forces related to distance learning as will as California Virtual University have persons on them to specifically address access issues for persons with disabilities. In fact, we have already begun this process. XXXXX, who oversees California Virtual University (CVU) efforts for the Community Colleges, has laid the foundation for a work group of persons with expertise in disability issues to address CVU related access issues. In addition, the distance learning work group has invited disability experts to participate in their meetings. To assure that the necessary guidance to college is available, I will specifically ask Vice Chancellor of Educational Services and Economic Development, XXXXX, whose staff oversees the distance learning issues, to develop, in cooperation with the DSP&S Unit and the HTCTU, guidelines for distance learning to assure it is accessible to and useable by persons with disabilities. In addition, I will send a letter to the Chief Executive Officers of the colleges and districts asking them to include someone with expertise in disability access issues on all campus/district committees which involve planning for new technology on campus.

4. Distribution of Standard Technology Grants/Funds

We also agree with the strategy to ask colleges to address how they will meet their Section 504 and ADA requirements in grant proposals for technology related projects. Accordingly, I will direct my staff to include this language, along with scoring points for this item, to future Requests for Application (RFAs) for technology grants.

5. Printed Materials Translated into Electronic Text/Braille

The identification of the most effective strategies and methods for converting the various instructional ans educationally related materials which are provided in print to all students into accessible, alternate formats of large print, disk, and/or Braille for students with disabilities will be a substantial task which requires time, thought, analysis, and consensus of various constituent groups in the Community College system. As you know, any solutions must fit with our governance structure which affords considerable autonomy and independence to the 71 community college districts in the state. Currently, we have been and will continue to affirm, the responsibility of each college under Section 504 and the ADA to make its print materials available in alternate formats to students/persons with a disability. In addition. Our DSP&S unit has begun discussions with the DSP&S Regional Coordinators about regional approaches to the provision of alternate media. We are familiar with the program at California State University Fullerton as well as efforts at Ventura College to a regional center to provide information in alternate media. Our preliminary discussions reveal that some translation of materials such as test, class syllabi, and other materials into alternate format may well be done at the campus level by some colleges. However, textbooks, college schedules, and other lengthy; complex materials are difficult to produce in a timely manner at the local level. This issue involves various campus and Chancellor's Office stakeholders including, bit not limits to: DSP&S, general faculty, bookstore and library staff, and persons responsible for printing the college catalog and schedule. Therefore, the issue, and any regional or systemwide solution, needs to be addressed in an inte-divisional manner. Accordingly, I will direct XXXXX, General Counsel for the Community Colleges, to lead a work group of persons from the above stakeholder groups, which will address this issue and propose solutions to me. I will also ask Dr. XXXXX, Vice Chancellor of the Student Services Division to direct staff to assist with the work related to this effort. These solutions will be shared with the Chancellor's Office Consultation Councils before a final decision is made. While I will ask Mr. XXXXX to convene the work group as soon as possible, it is likely to take six months before any final action plan can be agreed to on this issue. Rest assured, that we will remind the colleges of their individual obligations to provide alternate media as required under Section 504 and the ADA, regardless of the presence of any regional or systemwide resources.

6. Central Registry of Textbooks in Alternate Format

We agree that a centralized resource of textbooks available in alternate format would be a significant resource to the colleges. Therefore, we will be adding this activity as one to be undertaken by the HTCTU as part of its activities. The registry would become part of the HTCTU Web Page. Colleges would voluntarily submit information about textbooks available on disk or in Braille so that colleges could more effectively utilize their limited resources. In addition, I will ask the DSP&S unit, in cooperation with the HTCTU, to put out an advisory to the colleges on this resource as well as the fact that colleges can reclaim alternative format textbooks from students when they have completed the class for which it was provided.

7. Library Access

We are aware that campus libraries need to assure that their programs and services, including print materials and information on-line needs to be accessible to and usable by persons with disabilities as required by Section 504 and the ADA. We will undertake several actions to assure this information is known. First, we will include in the RFA for the HTCTU for the next five year cycle the option for training of librarian, learning center, and other campus lab staff on access issues for persons with disabilities. Second, I will direct that Ms. XXXXX, the leadperson for libraries in the Instructional Resources and Technology unit here in the Chancellor's Office is included in the work group described above to explore the development of centralized or regional alternate media centers/resources. Third, I will ask Ms. XXXXX to explore avenues for additional staff development opportunities for librarians on access issues for persons with disabilities.

8. Follow-up to OCR Survey

While we recognize the need to periodically gather data to monitor the progress of the colleges in providing access to print materials for students with disabilities, we do have workload issues related to this activity. The Chancellor's Office DSP&S unit staff is very limited at this time. We will be asking the HTCTU to take on several new activities to assist in capacity building related to the provision of materials in alternate format. They, too, have workload limitations which must be considered. Accordingly, we plan to defer a follow-up survey until we have undertaken more direct activities to support the colleges in their provision of alternate materials.

9. Annual DSP&S Program Reviews

The DSP&S program reviews have already been revised to include issues related to adaptive technology and the role of the campus HTC as well as library and computer lab access for students with disabilities. A team member is now selected who has expertise in adaptive technology. In addition, the review does examine the college self evaluation required under the ADA. I will ask the DSP&S unit to take steps to update all of the program review materials to reflect the current practices of the review, which do include an assessment of and technical assistance related to adaptive technology on the campus.

Anticipated Process for Resolving Compliance Issues

I would suggest the following process related to a meeting with Chancellor's Office staff to discuss your letter, proposed strategies, and our plans to address the issues. I will ask XXXXX to convene a meeting to be attended by the parties whom have been identified in this report as having a lead role in addressing these issues, and your designee(s). I will be sure to be available to open the meeting and convey the importance of an effective team effort to address the issues involved. The purpose of the meeting will be to review the actions I have outlined for our undertaking and to discuss any issues related to these actions. Subsequently, I would ask that you contact XXXXX for periodic updates on our progress in addressing this issues. I am sure that you will understand that I would like to have our limited staff put the highest priority on direct capacity building and technical assistance to the colleges regarding the issues involved.

In summary, I will look forward to meeting with you to discuss your concerns and our plans to address these concerns. Once again, I assure you that we are committed to full and equal access for all of our students, including students with disabilities, to all of the programs and services offered by the California Community Colleges. For further information, you may contact XXXXX, General Counsel, at (916) 327-5692 or XXXXX, Dean, Student Services at (16) 324-2348. We look forward to talking with you about these issues in the near future.

Sincerely,

Thomas Nussbaum
Chancellor

cc:

June 12, 1998

TO: Superintendents and Presidents
Chief Instructional Officers
Chief Student Services Officers
Disabled Student Programs and Services Coordinators
Distance Education Coordinators
Librarians

FROM: Thomas J. Nussbaum
Chancellor

Subject: Office for Civil Rights (OCR) Review of Information Access for Visually Impaired Students

Synopsis: As you recall, in September 1996, the Chancellor's Office distributed to all colleges a survey prepared by the Office for Civil Rights of the U.S. Department of Education (OCR) concerning access to print and electronic information for students with visual impairments. During 1997, the results of that survey were compiled and OCR staff visited a number of campuses to gather hand information about services to students with visual impairments. In January 1998, OCR issued a report of its investigation which contained a number of findings and recommendations for ways our system can improve access to print and electronic information for visually impaired students.

On March 13, 1998, I provided OCR with our preliminary response to their report and outlined a number of steps the Chancellor's Office and districts can take to address the concerns they have raised. Since districts will need to play a significant role in this effort, I have listed below a brief a summary of the steps we plan to take.

1. As part of our cooperative purchasing initiative, we will be exploring the possibility of establishing a process whereby colleges can voluntarily participate in a systemwide purchase of adaptive equipment to be used by visually impaired students throughout the campus ( in libraries, computer labs, etc.).

7. The Chancellor's Office will monitor progress in these areas through the DSP&S program reviews and contracted civil rights reviews of vocational educational programs.

8. Finally, the Chancellor's Office will apprise OCR of our process in addressing the concerns they raised. We hope to work collaboratively with them the resolve these issues as expeditiously as possible.

Some of the steps discussed above are fairly straightforward and can be implemented quickly while others will take more time. Some can be carried out by Chancellor's Office staff while others will require cooperation and coordination at both the state and local levels. We will update you as we move forward with the implementation of these plans, where necessary we may call upon you and your staff to provide further assistance in the effort. If you have specific question questions about the OCR investigation or the system response, you may call General Counsel.

Action/Date Requested: Please review and distribute as necessary.

Contact:

cc: Cabinet
President Foundation for the California Community Colleges
OCR Chief Regional Attorney
OCR Staff Counsel