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Disability Access and Inclusion Plan — 2017-2021

Introduction

Community College of Philadelphia is committed to fostering an educational and working environment that values the diverse backgrounds and experiences of all people. Inherent in the College’s strategic vision to serve as a transformative agent for the citizens of Philadelphia is the overarching dedication to celebrating diversity, promoting equity and advancing social justice. As the College commits to an uncompromising focus on student success, we must consider whether all individuals have equitable access to instruction, information, communication and services. This would include students who come to the College with varied abilities and experiences, visitors who contribute to the daily activities of the College, and employees who strive to support the mission and vision of the College.

The Disability Access and Inclusion plan was proposed and developed to articulate the College’s recognition of its compliance mandates and its vision to better serve all citizens of Philadelphia by creating a welcoming, responsive environment that supports individuals whose abilities exist on a continuum. The Plan was proposed and written to address the diverse needs of the community we serve, including its members with a disability. 

This Plan outlines priority areas for growth, the actions required to achieve our goals and activities designed to measure success. It aims to respond to the needs of our community, including those with a disability; to identify creative solutions and employ best practice approaches to eliminate barriers to access and inclusion; and to create a welcoming campus that values and respects every individual while providing them opportunities for success.

Statement of Commitment

As Community College of Philadelphia engages in transformative reorganization to address the evolving needs of the citizens of Philadelphia, we are reminded of the ongoing obligation to design our programs and services to address the needs of a diverse population. As noted in The City’s College: Impact 2025 (Generals, 2016, p. 1), “Opening the doors is a fraction of what it means to provide access.” Indeed, barriers imposed through physical design, digital inaccessibility or ineffective communication close doors to equitable participation in higher education for a substantial percentage of the population and contribute to poor postsecondary outcomes for far too many individuals.

According to the 2013 Annual Disability Status Report: Pennsylvania (Erickson & von Schrader, 2014), approximately 11.2% of Pennsylvanians ages 21-64 have a disability. In Philadelphia, where the prevalence rate for disabilities in this demographic rises to 17.3%, only 23.7% are employed and 35.3% live below the poverty line. We also know that individuals with disabilities are twice as likely as those without to attend a two-year college versus other postsecondary institutions (Van Noy, Heidkamp, and Kaltz, 2013). Taken together, this data tells us that disability is overrepresented in Philadelphia, unemployment and underemployment are overrepresented in the disability community, and  Community College of Philadelphia will more likely be the college to whom this population will turn for hope of a better future. When considering the College’s primary role in workforce development, readiness and economic innovation, we must champion a population that experiences the highest unemployment and underemployment rates by virtue of the inequality that exists in traditional work environments.

Through this Disability Access and Inclusion Plan, Community College of Philadelphia affirms its commitment to and ardent support of students, employees and visitors with disabilities, and embraces its responsibility in meeting their needs. The plan stands in alignment with The City’s College: Impact 2025 (Generals, 2016, p. 2), where it states, “Among its peers, Community College of Philadelphia will be recognized as an institution that levels the playing field, improves communities, retains and graduates its students, and fuels the local and regional economy.” By serving this sector of the population whose aspirations are compromised far too often by marginalization and lack of academic preparation, we will level the playing field to better serve all students, employees and visitors.    

As the College embraces substantive reorganization, it seeks to ensure that the campus experience of people with a disability—staff, students or visitors—is equitable to that experienced by the College community as a whole, and that staff and students with a disability enjoy success in the same measure as their peers.

The Plan calls for

  • a comprehensive audit of the College’s facilities, programs and services
  • development of policies that ensure access
  • provision of awareness, training and support to the College community in meeting its compliance mandates
  • establishment of sustainable resources to support inclusion and accessibility
  • employment of accountability measures to ensure compliance

Disability Compliance and Higher Education

Community College of Philadelphia’s commitment to fostering an educational and working environment that values the diverse backgrounds and experiences of all people is not only the right thing to do; in the case of disability, it is the law.  The key legislation ensuring that the rights of individuals living with disabilities are protected against acts of discrimination includes Sections 503, 504 and 508 of the Rehabilitation Act of 1973, the Americans With Disabilities Act of 1990 (ADA 1990), and the Americans With Disabilities Act as Amended (ADAAA of 2008).

The Rehabilitation Act of 1973 is generally viewed as the first civil rights law for people with disabilities at the national level. Section 503 requires affirmative action in hiring and other employment actions for individuals with disabilities. Section 504 states that “no qualified individual with a disability in the United States shall be excluded from, denied the benefits of, or be subjected to discrimination” for programs or services provided by entities that receive Federal financial assistance, such as in higher education. And Section 508 requires all Federal agencies to make their electronic and information technology accessible to people with disabilities.

The Americans with Disabilities Act (ADA) is a federal civil rights statute designed to remove barriers that prevent qualified individuals with disabilities from enjoying the opportunities available to persons without disabilities. The ADA protects qualified applicants and employees with disabilities from unlawful discrimination in recruitment, hiring, promotion, discharge, pay, training, fringe benefits, classification and related aspects of employment. The ADA does not replace Section 504 of the Rehabilitation Act of 1973, but in situations where the ADA provides more protection, the ADA standards apply. In 2008, the ADA Amendments Act (ADAAA) was passed to reestablish the broad definition of disability first envisioned by Congress when the ADA was passed.

Development of the Plan

The College recognizes its responsibility to create an inclusive and supportive culture, free from harassment or discrimination, for the entire college community. The College’s mission, vision, and core values underpin this commitment, necessitating the development of this Disability Access and Inclusion Plan. Through this plan, the College articulates its commitment to provide an accessible, inclusive work and learning environment where all students, staff, and visitors are treated with dignity and enjoy the benefits of education and employment.

The College began developing a Disability Access and Inclusion Plan early in 2015, shortly after forming the ADA Accessibility Committee in 2014 to serve in an advisory capacity and recommend to the President improved efforts for providing programs, activities, and facilities accessible by and inclusive of all individuals, including those with a disability. Early on, the Committee endeavored to develop a comprehensive disability plan for the College, initiating a consultation process designed to highlight issues, assess achievements, and revise directions and strategies. The process solicited involvement of employees and students at various levels within the College, and drew upon the services of professional practitioners in a variety of fields.

The developed plan supports the historical mission and the future of Community College of Philadelphia as articulated in The City’s College: Impact 2025 (Generals, 2016). Its intent is to ensure that individuals with a disability can access education and services in a way that facilitates equity, independence, and inclusion.

The goal in the development of this Plan is to be

  • Comprehensive in ensuring that provisions for people with disability cover all college activities and programs in recognition of their right to fully participate in the academic and social life of the College.
  • Inclusive in ensuring that core activities of the College are designed and implemented to accommodate the needs of all students, staff, and visitors with a disability.
  • Equitable in ensuring that the College responds to and recognizes the needs, rights, and responsibilities of all, while ensuring that solutions are equitable for everyone.
  • Respectful of all stakeholders, ensuring that interactions with individuals with a disability are characterized by respect for their right to dignity, privacy and confidentiality.

Implementation of the Plan will benefit the College by:

  • Ensuring compliance with relevant legislation
  • Striving to eliminate discrimination by promoting the basic human right to fully participate in society, including education and employment
  • Initiating appropriate action to overcome or eliminate identified barriers to full access for individuals with disability
  • Demonstrating our commitment to providing an inclusive and non-discriminatory community for all people

It is the College’s intent to periodically update this plan to reflect changes in laws and regulations, new policies or procedures, emerging technology, assessment outcomes, and organizational structure and responsibilities.

References

Erickson, W., Lee, C., & von Schrader, S. (2014). 2013 Disability Status Report: Pennsylvania. Ithaca, NY: Cornell University Employment and Disability Institute (EDI).
Van Noy, M., Heidkamp, M., & Kaltz, K. (2013). How are Community Colleges Serving the Needs of Older Students with Disabilities? New Brunswick, NJ: National Technical Assistance and Research (NTAR) Leadership Center.

ADA Accessibility Committee

Committee MemberDepartment
Simon Brown Diversity and Equity Office
Patrick Gorman Information Technology Services
Laura Harman* Planning and Finance
Lisa Hutcherson Human Resources
Albert Kristoff* Safety and Security
Wendy Kohler Center on Disability
Peter Margolis FLOAT
Eve Markman Marketing and Government Relations
Catherine Martin Counseling
Gregory Murphy Institutional Advancement
Anthony Palimore Architecture, Design and Construction
Lisa Papurt Center on Disability
Megan Rizzo Counseling
Denise Sanders Information Technology Services
Jason Stein Marketing and Government Relations
Lynne Sutherland

Dean of Students

*Denotes no longer with the College

Goals

GoalsStrategiesInitiativesMeasurement

Audit

Conduct an initial comprehensive audit and evaluation of the policies and procedures, information and communication technology, and physical facilities of Community College of Philadelphia to ensure compliance with the ADA and Rehabilitation Act. Develop strategies for ongoing assessment of College’s compliance.
1.  Identify and retain the services of an external auditor to evaluate accessibility compliance and inclusion throughout the institution, including: employment, academic and student services, Information and Communication Technologies (ICT), and physical facilities.
  1. Contact with external auditing organization.
  2. Analyze audit report.
  3. Develop and implement strategy with a timeline to remedy concerns and enhance accessibility.
  4. Develop auditing template(s).
  5. Develop auditing cycle.
  6. Reevaluate auditing efforts after one full cycle.
  1. Summary/overview report outlining changes and updates to current policies and procedures.
  2. Audit completed and remediation plan written within 6 months of approval.
  3. Auditing templates developed.
  4. Auditing calendar developed.
  5. Summary report of first cycle with recommendations for future cycles.

Policies Development

Develop policies that ensure persons with disabilities will not, on the basis of that disability, be denied equitable access to Information and Communication Technology, facilities and services.
Ensure that individuals with a disability are included in the process of policy development.  Identify ways in which individuals with disabilities are included in the process of policy development.

Survey committee members to ensure individuals with disabilities were considered in policy development.

Ensure accessibility throughout the procurement process.

  1. Create statement to include in   RFPs.
  2. Work with purchasing to include statement in RFPs.
  3. Create list of questions to ask potential vendors RE: accessibility.
RFPs have an accessibility statement and a list of qualifying questions to assess vendor’s accessibility features.
Create a policy to incorporate Universal Design Principles in accessible course materials facilities, and college information and Communication Technology (ICT).

Create policy.

Periodically sample ITC, course materials and physical environment for accessibility.

Awareness, Training and Support

Create a culture of intentional inclusion of all qualified individuals, including those with a disability, through publicity campaigns and comprehensive training efforts; ensure sustainability of initial effort by creating an infrastructure of ongoing support for designing accessible programs and services.

 

Raise awareness of shared responsibility for compliance with the ADA, as amended, and Rehabilitation Act.
  1.    Develop a marketing campaign for College community that establishes legal necessity of enhancing accessibility in all programs, services and facilities.
  2. Engage the community in promoting inclusion as an institutional value by infusing accessibility in current College initiatives.
  3. Develop request for accommodation statement to include on all publicity for College events.
  1. Pre/Post survey to measure effectiveness of campaign that assesses College community’s awareness of issues pertaining to inclusion.
  2.  Survey College committees to determine characteristics of committee members.
  3.  Evaluate a random sample of publicity announcements for inclusion of accessibility statement.
Institute mandatory training for College community regarding compliance mandates associated with ADAAA and the Rehabilitation Act.
  1. Survey College community regarding understanding of obligations under ADAAA and the Rehabilitation Act.
  2. Using information for survey, develop training plan and identify learning outcomes.
Pre/Post survey.
Educate College community regarding emergency egress procedures for individuals with a disability and those with temporary limitations. Identify and publicize areas of refuge during emergency evacuations.
  1. Ensure emergency plan addresses disabilities and delineates procedures.
  2. Ensure that proper signage is included.
  3. Education of the College community regarding all emergency egress procedures.
  1. Emergency plan has procedures that are clearly delineated for individuals with disabilities.
  2. Areas of refuge are identified with accessible signs.
  3. Random sample of faculty and staff can articulate emergency evacuation procedures as they pertain to individuals with disabilities.
Assist faculty in designing accessible courses.
  1. Include course accessibility in New Faculty Training modules.
  2. Develop course accessibility checklist.
  3. Develop mini-lessons to present during New Faculty Training.
  4. Provide faculty training to add closed captioning to videos.
  5. Provide faculty with training in creating accessible documents using mainstream tools within. Microsoft Office.
  6. Apply Quality Matters accessibility criteria to all online learning.
  7. Enforce accessibility review of third-party systems used in online courses as a condition of course approval.
  1. Review random samples of courses for accessible design each semester.
  2. Compare course evaluations from courses where faculty completed training with those where faculty did not participate in training.
  3. Collect data from course accessibility checklists and evaluate for increased accessibility.
  4. Include items pertaining to accessibility on course evaluations.
Develop training modules for web content authors, ensuring enhanced appreciation for and skill development in creating accessible online materials.

Create a mechanism for training all web content editors.

  1. Run JAWS software on randomly selected webpages.
  2. Run web auditing tool and create a schedule for regular scans.
Provide readily available support materials to the College community in creating and maintaining ICT that is user- friendly and accessible to a broad range of learners, including those with a disability.
  1. Identify third-party vendor (e.g. 3Play Media) to assist with large-scale captioning projects.
  2. Explore third-party vendor(s) to assist with conversion of print materials into alternate formats (SensusAccess, AMAC).
  3. Develop College web pages dedicated to accessibility topics and support materials.
  4. Distribute Quality Matters (TM) rubric and MSWord Accessibility document to all faculty.
  1. Track usage of support materials.
  2. Develop brief surveys regarding user experience in interfacing with training materials.

Funding Support

Develop and sustain adequate funding and resources to support inclusion and accessibility.
Establish a budget
  1. Itemize recommended purchases.
  2. Prioritize purchases according to a 3-year plan.

Conduct annual financial audit of expenses related to accessibility.

Identify and solicit external funding sources to support accessibility and inclusion activities.    
Create efficiencies in the current budget to support accessibility and inclusion activities.    

Accountability and Compliance

Establish a system of accountability, responsibility and compliance to create a more accessible and inclusive community.
Maintain compliance through Executive Leadership governance of the Disability Access and Inclusion Plan.
  1. Create a body to monitor, and inform the executive leader-ship on, noncompliance.
  2. Document evidence of inclusion and accessibility support through performance evaluation.
  3. Encourage management-level advocacy for increased resources to support inclusion and accessibility.
  4. Offer incentive opportunities for management to incorporate accessibility and inclusion into their divisional operations.
  5. Encourage management to integrate inclusion and accessibility into college-wide planning efforts.
  6. Encourage vice presidents to include disability accessibility and inclusion within Diversity Plan initiatives in their Diversity Plan year-end reports.
  1. Reports on non-compliance and recommendations for remediation.
  2. Periodic reviews of divisional plans and operations, including use of incentives.
  3. Removal of non-compliant material from all College locations (courses, websites, communications, etc.)
Proactively seek input and support from campus community individuals with disabilities concerning the College’s inclusion and accessibility activity and progress.
  1. Add individuals with disabilities to the Facilities Planning Committee and other key College-wide committees.
  2. Encourage student involvement in the work of inclusion and accessibility.
  3. Solicit input from identified employees and students with disabilities concerning effectiveness of services, programs, and activities regarding access and inclusion issues.

Survey of committees to check on inclusion.

Integrate Assistive/Adaptive Technology (AT) throughout the College.
  1.  Install K3000 on computers in the Library and Learning Labs/Learning Commons
  2. Continue to work with IT to develop a timeline for installation of other adaptive technology.
  3. Develop a process for installation of classroom technology.
Creation of a thorough list of where AT has been integrated.
Develop a process for compliance review for AD and UD (Universal Design).
  1. Create a compliance statement and coordinate with administration to include RFPs.
  2. Assess the effectiveness of all compliance measures.
Have governing body review compliance, holding parties accountable and providing steps for remediation.