• Mt. Hood Community College Accessibility Corrective Action Plan

  • January 26, 2015

    As part of MHCC’s commitment to maintain the highest standard of serving all of our community, the College recently conducted a comprehensive internal audit of our online services to evaluate their accessibility to those with disabilities. The results of this audit led us to adopting the Corrective Action Plan that follows. This plan will help ensure MHCC is in full compliance with the federal Americans with Disabilities Act (ADA), as amended, while simultaneously incorporating current best practices in this arena. You are welcome to review the plan to learn how MHCC is making significant progress in meeting the needs of the diverse community that we serve. For more information about the federal ADA, as amended, please visit http://www.ada.gov/ada_intro.htm. For more information about MHCC’s work in this area, please contact the MHCC Disabilities Services Office at (503) 491-6923 or Email to dso.web@mhcc.edu.

    The content of this report includes a plan to correct all items identified in the audit of MHCC electronic processes and systems.  We are anticipating that this plan will ensure that the accessibility of the college’s electronic materials, systems, courses, programs, services and activities are readily available to individuals with disabilities. The college completed a comprehensive audit in November 2014 and the results of this audit have been used to develop this corrective action plan as stated in the MHCC Agreement with the Office of Civil Rights.

    MHCC has determined that the college will adhere to the WCAG 2.0 – AA standard of accessibility.  This standard was used during the audit process.

    Many individuals throughout campus participated in this audit and determined priorities from the results of the comprehensive audit with projected deadlines for completion.  These priorities are not necessarily listed by order of importance as many of these priorities are of equal importance and each area will be working on these simultaneously. The identified actions include the following:

    • Internet/Intranet Website - Several issues were identified with our current website.  The website is in the process of a complete overhaul, the result of a new vendor.  The vendor has assured MHCC that accessibility WCAG 2.0 Standard AA is being adhered to in the development of this site.   The target date for completion of this website is October 30, 2015.
    • MHCC Portal (MyMHCC) – The portal system used by the college is a Jenzabar product and is fully ADA compliant as specified on a document obtained from the vendor.  Issues were identified with a program the Portal utilizes called CX Web.  This product is no longer supported by the vendor.  Jenzabar has released a Student CRM that is expected to fix all issues with CX Web and will make all functionality within the portal ADA compliant.  The other accessibility issue of posting inaccessible materials to the portal will be addressed through training of all faculty and staff.  The target date for completion of the CX Web functionality is July 30, 2015 and the completion of training is October 30, 2015.
    • Learning Management Systems – MHCC uses the LMS systems of eLearning and Blackboard which are ADA compliant.  The two primary compliance issues are posting of inaccessible materials with links to inaccessible information and lack of captioning on audio/video presented lectures.  This issue will be addressed through a request of funding to complete the uncaptioned lecture materials and training with all faculty and staff on preparing accessible documents and hyperlinks. The target date of completion is October 30, 2015.
    • Faculty and Staff Training – It was identified that all FT and PT Faculty and Staff require training on the development of accessible formatted materials.  Training materials are being developed and training sessions will be scheduled throughout campus by the Disability Services Coordinator/Counselor and Disability Services Assistive Technology Specialist.  Faculty have always been required to complete an Online Academy before developing an online course.  Accessibility and the creation of materials in accessible formats have been covered in this training.  This requirement will continue.  The Online program has scheduled many additional training sessions fall 2014 and winter 2015 terms on developing materials in accessible formats for all faculty.  These trainings will also be continued.  The target date for completion of trainings is October 30, 2015 although MHCC will continue offering these trainings throughout every future term.  The Disability Services Office is also establishing a resource page on their website for all of the resources and training materials so they will be readily available for faculty and staff. 
    • Documents Posted to Website, Portal, and Blackboard – MHCC has established a board policy that all materials need to be accessible to students and employees with disabilities.  Information will not be posted on the website if it is not WCAG 2.0 – Standard AA compliant.  The target date for completion is October 2015.
    • Registration Process – There were a number of issues identified while working with a blind student using JAWS during the audit.  Content was identified that was incompatible with the web-based formatting, ineffective course and section search functions for screen readers. MHCC is working with the Jenzabar vendor to resolve the issues with registration.  A new Constituent Resource Module (CRM) has been designed and will be installed.  This will be tested to insure that our online registration process is compatible with WCAG2 - Standard AA.  The target date for completion is August 30, 2015.
    • Applications for Admission – The applications for admission have been reviewed and revised regarding content.  The PDF’s will be formatted in accessible formats after staff have received training.  The target date for completion is October 30, 2015.
    • Budget Request for Assistive Technology Specialist Imbedded in IT – It has been proposed for approval to hire a full time Assistive Technology Specialist imbedded in IT.  This individual can work on ensuring that accessibility is researched for all software and new processes established at the college.  In addition, this individual will serve as a liaison between IT, DSO, HR, and the college community to insure that any accessibility issues concerning electronic accessibility are resolved.  Target date for completion is July 30, 2015.
    • Budget Request for Funding of Captioning for OL Courses – It has been proposed that funding be approved to caption the online audio/video presented lectures.  Target date for completion is August 30, 2016.  
    • Graphics/Online Catalog – The current software used by the college is not accessible to individuals using screen readers.  Options for accessibility are being explored and an accessible online catalog will be available for students by August 30, 2016. 
    • Human Resources - HR uses NEOGOV as a vendor and they were contacted on 11/24/14 regarding accessibility of the college’s online applicant tracking service. NEOGOV reported “near-compliance”.  MHCC is working with the vendor to remedy any accessibility issues and will require the vendor to complete corrective actions by August 26, 2015. 
    • Testing Center – The Testing Center needs an updated computer and the updated version of JAWS.  Target date for completion is February 15, 2015.
    • Library – The library has a total of 83 scholarly research databases with three primary vendors.  All of the vendors are committed to making resources, including captioned videos, compliant with accessibility standards and they have no corrective action plan other than to maintain their current compliance.  
    • Bookstore – The MHCC Bookstore utilizes a website from an outside vendor, Nebraska Book Company (NBC).  MHCC received confirmation from NBC on 11/19/14 that their website is compliant with WCAG2 – Standard AA.  MHCC had made some minor changes to the bookstore site that weren’t compliant but corrections have been made.  There are no further issues needing resolved at this time.
    • Purchasing - The College has established systems for procurement, acquisitions, and contracts that will help ensure ADA compliance.  An audit of the college’s current requisition and purchasing systems was conducted in January, 2015. The findings confirmed that these systems include appropriate steps to ensure the accessibility of all procurements, acquisitions and contracts. The college’s Chief Information Officer, or designee, is accountable to ensure that all IT-related purchases meet ADA compliance and products are accessible. Occasionally, purchasing is done through contracts, which are routed for approval prior to a requisition being processed through the system. Contracts require a cover form to authorize a contract, called a Contract Approval Form, or CAF. The CAF will be revised to include approval by IT to ensure WCAG compliance if contracts include the purchase or use of any technology-related product or service. This will be in place for direct purchases as well as for any products or services from third-party vendors. The target date of completion is February 28, 2015.

    MHCC is committed to the establishment of systems that will ensure continued compliance and maintenance of the accessibility of college programs, services, and activities delivered on-line.  The following initiatives will insure ADA/504 and WCAG compliance are followed by employees. The following steps will be taken to ensure continuity of accessibility compliance:

    • MHCC has developed a new board policy and administrative regulation ensuring accessibility for all individuals with disabilities. Ongoing.
    •  A new grievance procedure has been approved to allow individuals with disabilities an improved process for rectifying any accessibility issue.  This procedure defines a clear role for HR to investigate allegations for employees and/or students involved in a complaint situation concerning accessibility due to disability.  Ongoing.
    • Full-time and part-time staff and faculty will be required to complete trainings on the ADA, accessibility, creation of accessible formatted materials, videos, courses, etc.  Annually.
    • Information that is not in an accessible format will not be posted on the new web-site.  Departments are now in the process of updating the departmental websites.  Target date for completion is August 30, 2016. 
    • A request for the creation of a new full-time Assistive Technology Specialist position has been submitted.  This position will be imbedded in the IT department and will be responsible for insuring that MHCC maintains WCAG compliance with electronic processes.  In addition, this person will be responsible for training and serving as a liaison between DSO and HR. Target date of new hire is August, 2015, pending budget approval.
    • The ADA Sub-Committee of the Technology Council and the Technology Council will continue to work on issues of accessibility as they arise throughout the college.  If issues of inaccessibility arise, this committee and council will work on resolution within compliance standards. Ongoing.
    • Prior to completion of this corrective action plan, a test will be conducted by current MHCC blind students using JAWS to ensure that all systems are accessible.  This practice will be continued on an annual basis to identify any issues needing resolution.  Target date for completion is November 30, 2015.
    • A request for funding has been submitted to caption the video/audio lectures and resources in the online and portal courses.  Target date for completion is August 30, 2016.

    During this corrective action phase, MHCC has established an interim plan for any individuals with disabilities to request assistance with inaccessible programs, services, and activities delivered on-line.  On the Accessibility Tab at the bottom of the MHCC.edu Home Page, individuals with disabilities are directed to contact the Coordinator of Disability Services or the ADA/504 Compliance Officer.  They will prioritize any inquiries and lead an assisted resolution process during this interim period.