How to Approach an OCR Audit: Helpful Tips from Someone Who’s Been There 

By: Sarah Roberts
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When Foothill College received a letter from the Office of Civil Rights (OCR) informing it that the school had been selected for an audit of its online courses, word spread quickly throughout the campus community.  

A proactive audit of university online course accessibility was a new approach by OCR, meaning that leaders at the group of 23 selected colleges had to navigate uncharted waters. As the Dean of Instructional Technology, Lene Whitley-Putz was on the front lines as Foothill started working to put together a task force to handle the audit. While the process appeared intimidating, Whitley-Putz ultimately found the experience helpful and productive. 

At a recent webinar, Whitley-Putz shared her experiences with Verbit’s Lindsay Cisar, Senior Customer Success Manager, and offered useful insights for leaders at any school that finds itself on the next OCR audit list. Here are some key takeaways from that event.  

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How Foothill Ended Up One of the Selected Institutions 

OCR accessibility audits aren’t based on a report of wrongdoing like a student complaint. Instead, they are supposed to be random, proactive audits that assess how well educational institutions are accommodating their students. According to Whitley-Putz, in her conversations with the OCR, she learned that they were interested in taking a sample that included a wide range of institutions – community colleges, four-year universities, private and public. Still, she had some suspicions about why Foothill might have ended up on the list.  

“Foothill routinely comes to the top of search lists when you’re looking at community colleges,” said Whitley-Putz. “We have a fairly large online program with many online certificates.”  

While there is no way to know for sure, she believes that if people were searching for schools, they might’ve appeared right at the top – especially since their online programs date back to the 1990s. The same history might explain why someone would have intentionally selected them. However, all of this is guesswork, and the real takeaway is that any university or college could face an OCR audit, so all institutions should learn what to expect.  

How to Choose Courses for the Audit 

Whitley-Putz explained that OCR shared instructions about the types of courses they wanted to review. Mainly, they were looking for large, high-impact courses that many students take. For instance, courses like English 1, in which most students who attend Foothill enroll. 

Ultimately, Whitley-Putz and her team looked for the courses with the highest online enrollment and the most students and made their selections from there. Once they chose the courses, they needed to inform the relevant faculty members that they would be a part of the audit.  

Quelling Faculty Fears about the OCR Audit 

Faculty members can’t be expected to express enthusiasm over being chosen to undergo close government scrutiny of their courses. To ease their concerns, Whitley-Putz said that they carefully crafted emails notifying instructors. The email informed them that the audit was not something they should fear, that they were not in trouble and that her team would work with them to fix any issues that they uncovered. After all, accessibility can be extremely technical, and instructors don’t always have the knowledge they’d need to remedy issues in their courses.  

“Being an expert in one field doesn’t mean that you’re an expert in another,” said Whitley-Putz. “We try really hard to partner with faculty and let them know that we don’t expect them to be experts in accessibility, that’s what we’re here for.” 

Foothill also put together a webinar to give faculty members more information and a chance to ask questions. After that, Whitley-Putz said it seemed that the instructors didn’t have any more ongoing angst about the audit.  

Why Attention – Even an Audit – is Good for Accessibility 

Foothill established itself as a leader in online learning by getting started long before the trend became popular. As a result, Whitley-Putz said they might seem like they would be better off than other universities when it comes to accessible online courses. However, she pointed out that being an “early adopter” doesn’t always equate to being the best.  

“I think attention is good because when you’ve been doing something for a long time, you might fall into a pattern, and that pattern may not be as cutting edge as it needs to be,” she said.  

Whitley-Putz pointed out that accessibility “is not a static field where the standard was set 20 years ago.” 

The standard for accessibility is constantly evolving, and with AI, these changes are happening faster than ever.  

Another benefit of the audit, according to Whitley-Putz, is that, especially when budgets are tight, administrators might not make accessibility the priority that it should be. However, being selected for the OCR audit can change the perspective of administrators and help mobilize support for improvement efforts.  

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Dispelling the Illusion of Accessibility 

Whitley-Putz highlighted another common issue that she’s noticed surrounding accessibility on campus. Many instructors rely on tools like automatic accessibility checkers

“If you run the accessibility checker and it find no errors it gives you balloons and says ‘congratulations!’” she said.  

Unfortunately, those results can be misleading and give faculty members a false sense of security as they don’t really check everything.  

“It certainly doesn’t check for things that have to be done manually, like captions on a video,” said Whitley-Putz.  

Additionally, an automated checker can’t determine if the alt-text on images are relevant to the given context. With so many issues that these checkers can’t adequately review, the results can be highly misleading and prevent faculty from identifying accessibility barriers.  

The OCR audit ultimately gave momentum to Whitley-Putz’s efforts to genuinely boost accessibility for Foothill’s students. Viewing the audit through that lens helped turn what might otherwise seem like an intimidating ordeal into something positive for the campus community.  

Partnering with Verbit for Accessible Media 

Whitely-Putz pointed out that accessibility involves many technical complexities. Crafting fully accessible online courses requires specialized expertise that not everyone possesses. Fortunately, Verbit’s team has the experience and knowledge to simplify that challenge, particularly with live captioning, video captions, transcription and audio description. Connect with us to learn more about enhancing accessibility for courses, events and beyond.