California Community Colleges:Prerequisites and the Proposed Revisions to Title 5

Article By: 

Audrey Yamagata-Noji is the Vice President, Student Services, at Mt. San Antonio College, in Walnut, California. Serving as the Chief Student Services Officer since 1996, Audrey is principally responsible for all student-related services, activities, policies, and issues. She has held faculty and administrative roles in Counseling, EOPS, and Student Development. Audrey initiated a successful learning communities effort at Mt. San Antonio College that targets entering, at risk freshmen students.

Audrey previously served as the Dean, Student Development at Santa Ana College for over seven years. During that time, Audrey worked with Santa Ana College and the Santa Ana Unified School District staff to create many award-winning programs such as: College is in My Future (5th grader/parent college visitation effort), Juniors Day and Seniors Day (11th and 12th grade college visitation programs), Early Decision (graduating seniors matriculation assistance and early registration), Kinder-Caminata (kindergarten college and careers introduction program). These efforts have led to a marked increase in college enrollment for Santa Ana youth

Audrey received her Ph.D. in Education from Claremont Graduate University and her Master’s degree in Counseling and Bachelor’s degree in Psychology from California State University, Long Beach. She is a licensed marriage, family and child therapist.

Additionally Audrey Yamagata-Noji is presently serving her fifth term on the Board of Education for the Santa Ana Unified School District. First elected in 1987, Audrey served for three consecutive terms on the School Board through 2000. In 2002 and 2006, Audrey was again elected to the School Board.

As a resident of Santa Ana, in Orange County, California, Audrey has also served on many appointed committees and organizations such as: the City of Santa Ana Library Commission, Technology Chair for Santa Ana 2000, the City of Santa Ana Asian and Pacific Islander Advisory Committee, the Orange County Human Relations Commission, the National Conference for Community and Justice, the interim board for the Healthcare Foundation of Orange County, and the Presbyterian Congregational Development Committee for the Presbytery of Los Ranchos.

Audrey has also been active in the Pan Asian and Pacific American community, serving as: a trainer for Leadership Education for Asian Pacifics (LEAP), the program co-coordinator for the Leadership Development Program in Higher Education, the program founder for Building Communities Through Leadership (BCL), an advisor to the Asian Pacific Islander Heritage Council of Orange County, and a founding board member for Asian and Pacific Americans in Higher Education (APAHE).

Audrey has resided with her husband, Gene, in Santa Ana since 1980. Gene Noji is a retired teacher and coach from Woodbridge High School in Irvine. Audrey and Gene have one son, Randall.

The article was co-authored with Jim Ocampo, Mt. San Antonio College.

James Ocampo earned a Masters with Distinction in Educational Psychology from California State University, Northridge and is currently the Director of Assessment and Matriculation at Mt. San Antonio College. During the last 20 years at Mt. SAC, Jim has also served as Director of EOPS as well as Interim Director of Admissions. During that time, he has been directly involved in the college’s matriculation efforts. He has continuously worked with faculty in their efforts to develop and manage appropriate assessment instruments, as well as to establish fair and effective assessment practices. He has also been directly involved in the establishment and validation of the college’s course prerequisites.

Author Image: 
Audrey Yamagata-Noji, Vice President, Student Services, Mt. San Antonio College
James Ocampo, Director of Assessment and Matriculation, Mt. San Antonio College

In this article, the authors discuss the changing regulatory language related to prerequisites that has created a much needed dialog related to student success and access and equity.  The issues are complex, to be certain, but the solutions, as the authors suggest, that can be applied in a holistic context, can very well lead to comprehensive improvements for community college students and their educational success.



Focus on Student Success


Student success.  We all want the same thing, but we might have different perspectives on how best to get there. Clearly, the community colleges, as open access institutions, must constantly work toward finding that balance between welcoming all students, regardless of ethnicity, income, educational background or preparation, and establishing standards in order to best direct and support students' educational roadmaps.

Student Success is the agreed upon goal and outcome for our students. At the present time, there is growing frustration within many camps about how best to help our basic skills students reach collegiate success. Some have offered concepts such as "setting up our students to fail," "opening the door of access irresponsibly" and propose that stricter policies are put into place. Some will offer suggestions that include the words "mandatory", "required", "enforce", "deadlines" to gain greater control of the entrance, assessment, placement and enrollment processes.



Clarifying the Problem

The problem is not our students. The problem is not our faculty, staff or managers in the community colleges. The problem is not K-12 education. The problem is not access.


§   The problem is that we have very diverse students (language, age, educational background, disabilities, ethnicity, levels of preparation).

§   The problem is that we have a high demand for our courses and programs.

§   The problem is that we don't have a clear connection between our desire and obligation to educate our students and how best to organize that education.

§   The problem is that there is a great misunderstanding about regulations and policies related to assessment, placement, orientation, counseling and other related efforts.


There is clearly frustration about the process and requirements related to state regulations that guide assessment and placement functions as well as implementation of prerequisites in the community colleges. This frustration has led many to believe that the solution is to move away from the existing regulations and guidelines and to create a system that requires mandatory assessment and placement and allows the prerequisite approval process to change from required statistical validation studies to departmental content review.

The problem is that this recommendation is only part of the solution. The solution needs to be much broader, much more inclusive, and much more realistic. Recent proposals have suggested that current policies and procedures regarding the establishment of prerequisites, including conducting disproportionate impact studies, should be changed.  The required statistical validation, especially for prerequisites for non-sequential courses (e.g., reading level for philosophy, writing level for psychology) would be removed and the only remaining process would be content review.  Replacing our current policies and procedures, including the removal of the requirement to conduct disproportionate impact studies, and merely requiring a content review process to adopt prerequisites will NOT make a positive, desired impact.



Separation of Components

The proposed changes to the Title 5 regulations related to prerequisites address one component of a very complex process of matriculating students to the community college system. In addition to how we establish course and program prerequisites, we must also take into account the following:

·      Prerequisites for sequential courses (English writing, math, science)

·      Basic skills prerequisites (English writing, reading, math) as across-the-board prerequisites for entire groups of courses.

·      Validation of cut scores for actual placement

·      Use of multiple measures for assessment and course placement

·      Integration of Counseling /Advising and Orientation

·      Ongoing research studies that ensure prerequisites, cut scores, and other processes continue to be effective with no harm to any particular groups of students (disproportionate impact)



The Prerequisite "Problem"

What should a student know and be able to do in order to enter a particular course? How can we best predict what skills and knowledge students need to have in order to successfully pass a course? We cannot get confused between what preparation levels a student needs to have in order to enter a class with what a student has been able to master by the end of the course.

The Academic Senate initiated proposed changes to Title 5 section 55003 mainly because of their dissatisfaction with the current prerequisite validation process which relies on statistical research to establish mandatory placement procedures. Moving away from what some have called a "frustrating", "arcane", "overly complex," system of approval of prerequisites by the state Chancellor's Office to allowing local college faculty to utilize a process of "content review" to determine course prerequisites, must be viewed in the larger context of the assessment and placement process when determining student course readiness.

Faculty are content experts. They know the material that should be mastered in order to successfully complete particular courses. It is also a given that discipline specific sequential prerequisites have been established to assure that students have the skills needed to be successful in subsequent courses. Across-discipline prerequisite requirements (reading, writing, math) must be clearly determined to prove that a certain level of knowledge is required to enroll in a particular course. This concomitant requisite is based on whether the faculty know the particular basic skills preparation level that students should have in order to be successful in their classes. In other words, what skills and knowledge do students need to have in order to understand lectures, complete assignments, read and comprehend the textbook, and pass exams in particular courses? And how can you "prove" that these particular ski1l levels should be mandated in order for a student to enroll in the class?


For example, a student with a low reading level will more than likely not be successful in a philosophy course that is dependent on substantial amounts of reading. So, how should it be decided as to what requirements students should be required to meet based on the knowledge/skills we believe students should know/have, in order to enroll in this philosophy course? Faculty should be able to develop, with proven confidence, some rubric by which they recommend or require students to meet in order to enroll in a particular course, if in fact there is substantial proof that the requirements, skills and prior knowledge are indeed what is required. This requires the utilization of more research­ based methodology to supplement content review which in turn means that sufficient training and professional development must be provided as well.



Content Review Alone is Not the Answer

All research, as well as our practical experience as community college professionals, tells us that simply changing how prerequisites are established is clearly insufficient. Students must know what the requirements are for specific courses. Students must know and understand their appropriately assessed basic skills levels and the subsequent implications for their course enrollment.

Placement tests alone cannot predict student success in a course. California community colleges and higher education institutions in general have adopted a philosophy that decision making should be based on relevant research and data collection. This practice should be at the heart of making decisions that affect student access to courses as well as student progress and success.


The greatest temptation is to create and implement a mandatory system that will serve as a de facto screening device to improve the pass rates for certain courses.  In addition to their placement test scores and basic skills levels, we know that there are many other factors that impact community college students' success in c1ass:  work schedules, family emergencies, financial issues, health, transportation. 

What is absolutely critical is the complementary establishment of sufficient counseling services to assist students in understanding the assessment process, placement test results, and enrol1ment policies and restrictions. The majority of students will follow clear information provided to them about the successful steps to follow if, in fact, the policies and procedures appear fair and easily understood.  This is especially true if there are sufficient support services to guide students, the services are made known to students, and the services assure them of their rights as students.

The answer may appear complex, but in reality it can be summed up this way:

A holistic approach must be taken to fully assess, inform, guide and counsel students and faculty in understanding prerequisite knowledge and skills for particular courses and programs that will lead to enhanced student success. A clear procedure must be established so that both students and faculty understand what is being required and how policies are being implemented. In addition to assessment, sufficient and comprehensive support services must also be provided (orientation, counseling, advising) to ensure student success and educational equity.

There has been some discussion regarding the proposal to allow for content review alone to establish mandatory prerequisites.  Is this process biased, exclusionary or racist? In and of itself it isn't. However, this is where the integration of research and appropriate student services make the difference. There will always be concerns and cautions about whether students are being “appropriately placed." Many individuals have concerns that if content review alone is relied upon for placement, that certain groups of students will be negatively impacted.

Students of color, immigrant students, low income students, older students, and students with disabilities may score lower than others on placement tests. These initial test results may appear disproportionate but the college placement policies and cut scores alone don't necessarily lead to disparate treatment. If students of color fail to make progress by advancing to successive levels of basic skills courses, such that the majority of them are unable to enroll in courses required for their educational program, the impact of college policies and procedures can be seen as having a disproportionate impact. This is a fear of many:  That the students who need the most support, whose families depend on them to attain a college education and break the cycle of poverty, will be excluded or left behind -- especially if they are consistently placed into lower level courses and do not progress to the degree and transfer level.

Policies and procedures must be implemented that recognize the varying skills and preparation levels of our students. Adequate support services and successful learning strategies must be put in place in order to more fully meet the educational needs of our state’s most disadvantaged students – mostly for whom the community colleges are the only answer for a post-secondary education.  Our roles as community college educators must be reinforced to recognize our commitment to embrace the students who come to us and assist them in fully understanding the expectations and requirements of higher education while assuring them that sufficient support services will be provided to them to reach success. If requirements are put into place of a mandatory nature, the policies and procedures must be clear and sufficient support services must be in place to assure that students are not turned away.



Clearly, we can all bemoan the lack of resources. However, the importance of this issue is so great that we must all work to allocate resources so that we can successfully move in a direction of guaranteeing access and success for the equity of all students.


1.      Clarification of Content Review to Establish Prerequisites:  Per existing Title 5 Section 55003(b)(1), Content Review is already specified as a requirement for establishing course prerequisites.  Content Review is the starting point but alone is inadequate.  Content Review must be used in concert with other research methods in establishing course and program prerequisites (other than sequential course prerequisites) in order to establish validity of these requirements.  Due to the fact that assessment plays a key role in determining student eligibility for courses with prerequisites, current methods utilizing only consequential validity are also inadequate.  In addition, the required use of Multiple Measures when assessing students for course placement must be enforced in determining the student's course eligibility.


2.      Regulatory Clarification—Requiring Assessment and Orientation:  Many colleges believe, erroneously, that they are not able to mandate orientation, to mandate assessment and to mandate placement. There is a clear misunderstanding of the current regulations.  By clarifying the regulations or simply by clarifying the guidelines for implementing the regulations, colleges will know how they can better establish requirements related to matriculation components.  Colleges have the authority to mandate assessment and to mandate orientation and counseling (Title 5 Section 55520).  Colleges cannot mandate the enrollment of students into counseling classes unless students are not charged for the class.  Again, simply mandating assessment without establishing orientation and counseling services is insufficient.


Title 5 Section 55520 – Required Services

At a minimum, each community college district shall provide students, except as exempted pursuant to section 55532, with all of the following matriculation services:


(a) the processing of applications for admission;

(b) orientation and pre-orientation services designed to provide nonexempt students and                                         potential students, on a timely basis, information concerning college procedures and                                   course scheduling, academic expectations, financial assistance, and any other matters                                 the college or district finds appropriate;

            (c) assessment for all nonexempt students pursuant to section 55524;

            (d) counseling or advisement for nonexempt students pursuant to section 55523;

            (e) assistance in developing a student educational plan pursuant to section 55525, which                                         identifies the student's educational objectives and the courses, services, and programs to                             be used     to achieve them;

            (f) post enrollment evaluation, pursuant to section 55526, of each student's progress; and

            (g) referral of students to:

                        (1) support services which may be available, including, but not limited to, counseling,                                  financial aid, health services, campus employment placement services, Extended                                          Opportunity Programs and Services, campus child care services, tutorial services, and                                Disabled Students Programs and Services; and

                        (2) specialized curriculum offerings including but not limited to, pre-collegiate basic                                    skills courses and programs in English as a Second Language.


         Note: Authority cited: Sections 66700 and 70901, Education Code. Reference: Section 78212,         Education Code.


3.  Regulatory Clarification -- Sufficient Basic Skills Courses:  Currently, Title 5 Section 55003(i) provides language that directs colleges to have sufficient basic skills courses available if reading, writing and math skills requirements established as course prerequisites.  This section must remain to ensure that students have adequate access to the courses they are being required to take. 

 (i) If a prerequisite requires precollegiate skills in reading, written expression, or mathematics, the governing board of a district shall ensure that non-degree-applicable basic skills courses designed to teach the required skills are offered with reasonable frequency and that the number of sections available is reasonable given the number of students who are required to meet the associated skills prerequisites and who diligently seek enrollment in the prerequisite course.


4.  Technical Support from the Chancellor's Office: Colleges need a "place" to go to get          assistance in conducting necessary validation and content review studies in order to more fully           assess students' likelihood of success for various courses. The Chancellor's Office has not had the   staffing capability of performing this critically important function. For its entire life, the            assessment validation and approval process (for instruments and application of cut scores) has       been assigned to an external group of consultants from Kansas. This does not serve California       community colleges well.  If we believe that clarifying the assessment process and course             prerequisites is critical to improving student success, we must develop the technical support at the             statewide level in order to assist individual colleges and districts.


5.  Updated Models: Colleges need more updated models to follow related to validation, cut scores,      content review, and prerequisites in order to develop procedures and policies related to student   course placement. These models need to be developed in such a way that regulatory requirements             are embedded into clear methods and procedures that can be easily followed and implemented.


6.  Professional Development: Faculty, researchers, and Student Services professionals must be            able to receive ongoing and comprehensive training in order to implement current and proposed            course placement methods such as validating course prerequisites, establishing basic skills thresholds across disciplines, and utilizing content review as but one method in establishing prerequisites.


7.  Disproportionate Impact Studies: Disproportionate impact must be clearly defined. Students           of certain groups that are placed at lower course levels does not in itself determine that       disproportionate impact occurs.  However, lack of student progress and success among certain      student             groups does warrant the claim that disproportionate impact exists. Colleges should still be     required to regularly conduct disproportionate impact studies to both evaluate whether their        assessment and placement procedures are accurate and effective, and to evaluate the impact            that policies and procedures are having on specific groups of students' abilities to advance into          subsequent basic skills course levels and to make progress toward their educational goals.


The discussion of changing regulatory language related to prerequisites has created much needed discussion related to student success and access and equity.  We believe that continued dialog between numerous stakeholders is both a wise and an important investment.  The issues are complex, to be certain, but the solutions, applied in a holistic context, can very well lead to comprehensive improvements for community college students and their educational success.