Comments on DOL Digital Literacy and Resilience, Request for Information (RFI)

February 6, 2023

Yufanyi Nshom

Office of Workforce Investment

U.S. Department of Labor

200 Constitution Ave, NW

Suite C-4510

Washington, DC 20210

RE: Digital Literacy and Resilience, Request for Information (RFI)

Thank you for thanking the time to collect feedback on improving digital literacy and resilience through the lens of digital equity. The American Foundation for the Blind (AFB) is a national nonprofit that advocates for a world of no limits for people who are blind or have low vision by mobilizing leaders, advancing understanding, and championing impactful policies and practices using research and data. At AFB, we believe that digital equity is an expansive issue that is vitally important for people with disabilities and that must be addressed through a whole-of-government approach. In our comments, we will discuss the role of both assistive technology (AT) and digital accessibility in digital literacy and resilience. These issues are deeply intertwined as people with disabilities rely on websites, content, and software to be fully accessible in order to use AT, and conversely, many people still cannot access a fully accessible digital tool without AT. Thus, we will focus on digital skills for three key groups: individuals who use AT, trainers who teach AT, and developers who create digital tools.

Q. 2(a) What barriers are individuals (adult and youth workers/learners) experiencing in accessing digital tools and/or training?

People who are blind, deafblind, or have low vision face significant barriers due to inaccessible digital tools, barriers to obtaining assistive technology (AT), and insufficient high quality training to use AT. These barriers are present regardless of age but become more prevalent the older a person is at the onset of blindness. Here we will discuss first the experience of K-12 students, then experience of workers.

Inaccessible Ed Tech

AFB and other researchers have documented these barriers both during and before the COVID-19 pandemic. The pandemic made many of these barriers more apparent as students had to rely almost exclusively on computers for their education. One of the primary barriers that blind and low vision students and family members faced was the discriminatory impact of inaccessible digital equipment, platforms, programs, and instructional materials. These materials could be as simple as educator-developed documents full of undescribed images and graphics or text that was not readable by screen readers and other assistive technologies. [1] Many students also did not receive appropriate hardware, such as laptops with large enough screens, in a timely manner. [2] However, one of the most significant barriers involved websites and applications used for purposes including, but not limited to, student learning, classroom management, file creation and sharing, and communication that were inaccessible to blind or low vision students as well as blind or low vision family members. Too often, Ed Tech companies seem to lack either the knowledge or impetus to make their tools accessible, and school procurement officers and IT professionals are not aware of how to procure fully accessible tools.

In November 2020, AFB found that nearly 60% of educators surveyed reported that their students who were blind or had low vision could not access at least one digital classroom tool or program. 35% reported that their students could not access at least two tools. [3] Additionally, family members who were surveyed reported their children were expected to use an average of 4.9 different tools or programs, and on average, 2.7 tools or programs were reported to be inaccessible. [4]

Inaccessibility of digital learning tools and programs can have significant consequences. Our research revealed that during hybrid and online learning, PK-12 students were unable to complete required assignments and often needed continuous support from a family member to complete schoolwork, negatively impacting that family member’s ability to work. [5] 56 higher education students reported dropping a class, taking an incomplete, leaving their program, or having to file an official complaint because of the lack of accessibility in hybrid or online courses. [6] Because they could not participate and access lessons like their peers, students felt frustrated, discouraged, or excluded.[7] Educators had to invest additional resources to create alternative lessons for their students with disabilities or in the absence of an alternative, simply exempted the child from lessons delivered via inaccessible digital platforms.[8] Additionally, blind parents, who do not have access to specialized supports, struggled to support their children, especially very young children.

For illustration, one family member, who was also an educator of blind students, wrote:

Insufficient Computer Skills and AT Training

Inaccessibility is not the only barrier, however. Indeed, students have reportedly not received as much assistive technology instruction as they need to perform on a equitable level with their peers. Students who are blind may need both specialized hardware, such as a refreshable braille display, and a screen reader, magnifier, or other software-based AT used with a laptop or tablet assigned to all students. Instruction to use these AT tools is imperative, and in AFB’s Access and Engagement research, some teachers and parents reported that their students had not yet received instruction to use screen readers with their laptops, while other students were learning to use laptops at home or at school without formal instruction. The lack of digital skills training with a range of technology and AT meant that students with disabilities faced additional barriers in accessing their coursework. This lack of training also raises questions about students’ readiness to use technology in later grades or after leaving school. The research found that “families, educators, and consultants […] support […] having assistive technology instruction begin at younger ages, and be more intensive, for students who are blind or have low vision.”[10]

One parent of a Spanish-speaking, blind student lamented the digital literacy differential between her blind child and her sighted child:

Many parents do not have AT skills and may not feel equipped to teach their children to use AT with the technology available in the household, yet children with disabilities need just as much exposure to technology as nondisabled children to succeed in our technology-dependent society.

Similarly, a teacher wrote that her student did not yet have the AT skills to efficiently use a laptop, was frequently encountering inaccessible programs when she did attempt to use the laptop, and did not have alternative AT, such as a refreshable braille display, available at home to access her class materials.

Other researchers have explored challenges with AT instruction. Tuttle and Carter (2022) conducted a small survey of twelve teachers of blind and low vision students (TVIs) who work with 51 students. [13] About 90% of the educators surveyed about barriers to effective assistive technology agreed that the expense of devices was a barrier. More than 80% agreed that devices breaking frequently and not knowing how to troubleshoot problems were barriers. About 60% agreed that the repair process was a barrier. The survey also found that while three-quarters of students had an AT assessment on file, under half of the students had a written implementation plan for the AT device. Additional findings indicated that while students were learning to use some form of AT, they did not always have access to high tech AT, such as a screen reader or magnifier used with a computer. The researchers suggest that students may need additional training in high-tech AT and training to use games and the internet that are frequently encountered in the classroom and beyond. Additionally, they propose that students need to be supported in using devices at home while teachers may need additional professional development for AT instruction. Many of the barriers identified in this study could be remedied with greater institutional support for the teachers providing AT training.

Workplace Technology Access

While many people who are blind, deafblind, or have low vision learn the fundamentals of AT use in the K-12 classroom, many more do not become blind or need AT until they are already adults. When vision loss occurs in adulthood, many people are dependent on vocational rehabilitation services, the Older Individuals who are Blind Independent Living Program (OIB), or private services providers to receive initial exposure to and training in AT. Nevertheless, there are systemic issues, including funding, the lack of qualified AT instructors, and simply lack of awareness of these programs, that prevent many individuals from receiving quality digital literacy skills through the use of AT.

In the Workplace Technology Study (WTS) released in January 2022, AFB researchers analyzed survey and interview data from 323 blind and low vision participants who were employed about their experiences with technology in the workplace. [14] The sample skewed toward well-educated, white employees, but still provides a snapshot of the experiences that people face with technology in a predominantly office-based work environment. Most respondents were working remotely at the time of the study but had been working on-site prior to the pandemic.

This study asked respondents how they learned to use AT. 63 reported that they had never received formal training with AT while at least 34 were self-taught. Many of the respondents who had had an early onset of blindness reported that they received training as part of the K-12 education system. 130 had received training from VR staff, 65 from a training working for an AT company, and 62 from another person who was blind or had low vision. Respondents reported relying on AT manuals, videos, and other materials put out by AT companies as well as AT users to keep their skills current. [15] The data suggested that access to instruction from a professional trainer as well as training from AT companies and users is helpful in building and maintaining adequate digital AT skills necessary for the workplace. Yet, a 2020 report on a computer-skills training program run by National Industries for the Blind has found that there is a dearth of AT trainers with advanced skills who are ready to train blind and low vision adults for intermediate and advanced computer skills. [16]

The research study similarly found that employers play an important role in making sure that employees are able to maintain their skills when new workplace technologies are introduced. People who are blind frequently do not receive accessible training in the use of workplace digital tools, nor do they learn how to use those tools with their AT. It is concerning that only 60% of WTS respondents reported that they could generally access the platform, assessments, materials, and presentations during required workplace trainings – whether provided online or in-person – while 25% reported that in general, the online training they are required to complete is inaccessible.[17] 28% reported that they did not receive timely, effective training on use of newly adopted technology from their employer. [18] In another study that focused on the experiences of blind and low vision adults during the early months of the pandemic, one participant wrote about a training for using a new software application: “The training (live and recorded online) would be accessible if there was audio description for the layout of the application, navigation through areas of the application, verbal explanation of what is being done on the screen and if key stroke equivalents are also available. Stating 'click here' or 'see what I just did' are useless comments for a person who cannot see what is being done on the screen.”[19]

This study addressed not only employees’ readiness to use technology but also lack of accessibility in many workplace technologies. Digital documents and tools, both hardware and software, present inconsistent experiences with accessibility with consequences ranging from annoyance to outright exclusion from the workforce.

In WTS, 50% of participants reported that their employer adopted new hardware or software that was not accessible. [20] 48% experienced accessibility challenges when filling out onboarding paperwork electronically.[21] 18% of the 58 self-employed participants reported they had been passed up for a contract or had their contract terminated because they were unable to use inaccessible software.[22] Respondents reported feeling stress and frustration and experienced diminished productivity, a loss of privacy, dismissive attitudes, and job restructuring as a result of technology-related inaccessibility in the workplace.[23]

While many technology developers recognize the importance of building accessible user experiences for consumers, blind and low vision workers also need to have access to the “back end” of systems as well as products that will only ever be used by employees, such as time- or expense-tracking software, accounting databases, and analytics tools for customer databases or websites. Developers of all types should be building the digital environment to be fully accessible, and employers should be procuring technologies that are accessible to all employees and job applicants. Nevertheless, lack of knowledge about accessible and inclusive design and engineering practices is frequently cited as a reason for the inaccessibility of digital content and tools.

Q. 4(c) What is the role of employers in preparing new or incumbent workers for industry-specific digital skills, or how should workforce providers partner with employers? How might employer-specific digital skills be taught by the employer to build on skills taught by workforce grantees or training providers?

Employers should:

· Ensure employee training programs are fully accessible to employees with disabilities and assistive technology users. Procure accessible products and platforms, provide appropriate accommodations before and during trainings, and require presenters to use accessible meeting and presentation practices.

· Implement an accessibility policy that requires all documents, tools, procedures, and procurement to be accessible, usable, and compatible with assistive technology. Seek feedback from employees with disabilities on the accessibility of new procedures and tools and ensure that technology procurement and deployment accounts for the accessibility, technical support, and training needs of employees with disabilities.

· Establish relationships with vocational rehabilitation agencies (VR). Depending on the state, VR may assist employers with recruitment of people with disabilities, accommodation requests by applicants, finding assistive technology contractors/ consultants, disability awareness training, assessment of workplace and job barriers, and resources for training opportunities.

· Allow employees, especially those in IT and HR roles, to attend trainings and develop internal expertise on assistive technology to support employees with accommodation needs. Maintain up-to-date industry knowledge about technology that is accessible to and usable by people with disabilities and compatible with assistive technology. Support professional development for developers and engineers to obtain training in inclusive design and engineering practices.

· Consider hiring external consultants to support procurement, to troubleshoot, and to offer training on assistive technology accommodations to ensure employees are fully supported and are maximizing their productivity.

· Offer dedicated assistive technology training for employees when implementing new technology solutions. Provide opportunities for one-on-one or small group support.

Q. 4(d) Are there any specific digital skills that workforce and education training providers should be responsible for teaching learners, such as how to type or navigate digital devices?

Workers who are blind or have low vision need access to AT trainers with advanced AT and digital literacy skills that allow them to advance beyond the basics of using the internet or word processing. Whether in coordination with the VR system, private service providers, employers, or AT companies, there is a need for additional programming for workers as well as for new and current AT trainers. Workforce and education training providers should either provide or refer learners with disabilities to high-quality AT trainers who will go beyond the development of basic computer skills. At a minimum, workforce and education training providers need an awareness of the kinds of specialized AT training that people who are blind or have low vision should receive and how to connect individuals to those services. This is consistent with the No Wrong Door approach advocated by the Administration on Community Living.

Q. 5(e) How can federally funded workforce and education training programs work together to ensure that participants (adult and youth) receive needed training in foundational and occupation-specific digital literacy skills?

At AFB, we believe that knowing how to create accessible documents and digital experiences is a critical skill for both a typical worker who produces digital content as well as workers who are engineering the software that others use. Without a more inclusive digital environment, people who are blind, deafblind, or have low vision will face barriers in a digitalized workplace, regardless of their AT skill level. Accessibility and usability should be core components of any digital literacy course. For example, when creating a word document or social media post, it is important to know how and why to add alt-text to images. Web and software developers and IT professionals, on the other hand, need more in-depth training to implement accessibility, such as training in designing and testing for the Web Content Accessibility Guidelines.

There is a real opportunity to integrate AT skills and digital inclusion skills in the registered apprenticeship program. Providing workers with disabilities the opportunity to learn AT skills concurrently with other job skills would open doors for adults who have not had sufficient exposure to AT and other digital literacy skills training. Moreover, the apprenticeship system offers an opportunity for training workers who aspire to careers in web and software development or IT. For example, AFB initiated the Talent Lab[24] last year to provide apprenticeships and internships aimed specifically at training new accessibility professionals. Interns are students in collegiate computer science and engineering programs who build skills and gain experience with inclusive design in preparation for their career as a developer. The apprentices are adults with disabilities who train for careers as project managers specializing in accessibility through coursework, mentorship, and client work. AFB is hopeful that this new program will increase participants’ career-specific digital literacy with a strong focus on accessibility and inclusive design as well as produce accessibility-minded developers who remove digital barriers for people with disabilities.

Currently, there are not enough programs producing workers with the knowledge and experience to consistently design for accessibility the websites and software that students, workers and nonworkers use every day. This lack of career-specific digital equity knowledge creates substantial barriers for people with disabilities. AFB encourages DOL to increase the awareness of accessibility in digitally focused workforce training programs from short-term bootcamps and professional development to collegiate computer science programs and everything in between.

Q. 6. Digital Literacy & K-12 Public Education System: Please share successful strategies, key challenges, and lessons learned in addressing digital literacy for K-12 youth: (c) How should the Department of Education better encourage digital skills education in the K-12, community colleges, and adult education settings? (d) What are some recommended strategies to ensure digital skills education evolves alongside society's technological advances?

To ensure that students with disabilities develop strong AT and computer skills, the Department of Education should work to:

· Ensure that teachers of students who are blind or have low vision (TVIs) receive high-quality training to support their students in using assistive technology and computers in school with a focus on lifelong digital literacy skill development. This training should occur in both professional development for current teachers and personnel preparation programs. When teachers only have access to up-to-date training in a personnel preparation program, their training is unlikely to evolve quickly enough to meet student needs over the course of their careers.

· Collaborate among the Offices of Civil Rights, Educational Technology, and Special Education and Rehabilitative Services to ensure that schools are procuring and deploying fully accessible educational technologies, including general curricula for teaching digital literacy. These offices should work together to increase guidance, funding, and enforcement around digital literacy and accessibility specifically for students with disabilities.

· Ensure that schools have policies and funding in place to provide both assistive technology and AT training to students with disabilities. District AT policies should provide for appropriate assessment and implementation of AT plans, professional development, AT at-home use, and support mechanisms for troubleshooting and repairing AT. Students should receive AT instruction that supports their laptop and tablet use at the same age their peers are developing their computer skills whether or not students are receiving classroom instruction in the use of computers.

· Support districts, schools, and teachers in promoting AT device use at home, so that students develop digital literacy skills in multiple areas, not solely with in-class academic work.

· Increase personnel preparation of AT trainers with advanced skills who can serve adults who are blind, have low vision, or are deafblind in using AT with modern technology.

Thank you for the opportunity to provide information on the digital literacy and resilience needs of people who are blind or have low vision. If you have any questions about this issue, please contact Sarah Malaier, smalaier@afb.org.

Sincerely,

Stephanie Enyart

Chief Public Policy and Research Officer