Re: Proposed Priorities and Definitions-Secretary's Supplemental Priorities and Definitions for Discretionary Grants Programs, ED-2021-OPEPD-0054
The American Foundation for the Blind is a national nonprofit that engages in research and advocates for a world of no limits for people who are blind or have low vision. AFB is grateful for the opportunity to comment on the Secretary’s priorities and definitions for discretionary grant programs. We greatly appreciate the inclusion of children and students with disabilities in the definition of underserved students as well as the professionals who educate them. In many ways, the COVID-19 pandemic has negatively impacted the education of students who are blind and have low vision as demonstrated in AFB’s research studies over the last sixteen months, including the procurement and use of inaccessible technologies and curriculums, a lack of services, inadequate guidance and best practices for providing related services in a virtual setting, low expectations for student achievement, and insufficient professional development and support for teaching blind and low vision students in a virtual environment. However, in other ways, the pandemic has revealed positive outcomes, notably the strengthening of relationships between professionals and family members that has led to greater awareness of how to support and encourage our blind and low vision children and students.
AFB hopes you will consider the following recommendations to further strengthen the priorities and definitions for serving blind and low vision children, students, and their educators.
- Recommendation: In the “Background” section, edit the fourth paragraph to read, “Additionally, regarding each technology reference, all technology developed or used under these proposed priorities must be accessible to and usable by English learners and individuals with disabilities, as well as interoperable with assistive technology, in accordance with the Rehabilitation Act of 1973, the Individuals with Disabilities Education Act, the Elementary and Secondary Education Act of 1965, and the Americans with Disabilities Act, as applicable.”
Rationale: AFB appreciates the inclusion of technological accessibility for people with disabilities in the “Background” of the priorities. In May 2020, AFB found that 85% of TVIs who had students in a general or special education online class described having at least one student with an accessibility issue. In a November 2020 follow-up study, AFB found that ongoing technology issues resulted from a range of problems, such as a lack of devices or assistive technology tools; insufficient training; improperly setup devices; and inaccessible programs, curricula, and devices. The modified language reflects a more expansive approach to digital inclusion and includes language from laws that protect and ensure access to the full range of educational environments funded by the Department of Education. It also acknowledges the important role of assistive technology in facilitating technological access for many blind and low vision people.
- Recommendation: In Proposed Priority 1, change priority area (e) to read, “(e) Providing students and educators with access to reliable high-speed broadband and devices, including appropriate assistive technology; providing students with access to high-quality, technology-supported learning experiences that are accessible to and usable by children or students with disabilities and educators with disabilities to accelerate learning; providing educators with access to job-embedded professional development to support the effective use of technology; and educating school and district administrators on procuring technologies that are accessible to and usable by children or students with disabilities.”
Rationale: As with the first recommendation, AFB proposes ensuring that accessibility and usability are placed on an equal level and that assistive technology that people with disabilities may need in lieu of or in addition to other devices is available. We appreciate the attention to educator knowledge and use of accessible technologies but note that administrators and procurement officials are often left out of training on procuring and using accessible technologies. Therefore, our proposed modification would include school officials at all levels in efforts to expand access to equitable, accessible technologies that play a role in student learning and supporting educators with disabilities.
- Recommendation: In Proposed Priority 2, change paragraph (b)(11) to read, “(11) Improving the quality of educational programs, including special education, in juvenile justice facilities (such as detention facilities and secure and non-secure placements) or adult correctional facilities,” and change paragraph (b)(12) to read, “(12) Supporting re-entry of, and improving long-term outcomes for, youth and adults after release from correctional facilities by linking youth or adults to appropriate support, education, vocational rehabilitation, or workforce training programs.”
Rationale: A disproportionate percentage of youth in juvenile justice systems have disabilities. As such, ensuring that these youth receive access to the full complement of services to which they are entitled under the IDEA, the ADA, and the Rehabilitation Act of 1973 is important to ensure their rehabilitation, re-entry, and future success in the community. Therefore, these services should be explicitly acknowledged in the priorities.
- Recommendation: In Proposed Priority 3, change paragraph (c) to read: “(c) Promoting knowledge of universal design for learning, accessibility, and accommodations in educator preparation.”
Rationale: AFB believes that educators’ awareness of resources for accommodating students with disabilities and using accessible tools is an important complement to universal design for learning. In institutions of higher education, knowledge about accommodations resources and their impact on student learning has been identified as a barrier to student inclusion, while a 2012 study identified the role of exposure to people with disabilities during pre-service preparation on teachers’ attitudes toward inclusive classroom. For blind and low vision students, a universally designed science curriculum supports students’ acquisition of knowledge and concepts, but individuals may still require accommodations and modified equipment (such as a talking thermometer, braille ruler, or braille periodic table) to fully participate in the scientific exploration and lab work. By complementing Universal Design for Learning with knowledge about accessibility and accommodations, educators are better equipped to help students fully participate and learn.
- Recommendation: In Proposed Priority 3, add a paragraph that reads, “Promoting accommodations and universal design to recruit and retain educators with disabilities.”
Rationale: Just as blind and low vision students need accommodations, accessibility, and specialized instruction to succeed in the classroom, similar accommodations and accessibility are needed to enable blind and low vision educators to succeed. In the background on proposed priority 3, the Department writes, “It is also important that the diversity of our educator workforce reflect the diversity of our Nation.” Therefore, AFB believes that educators with disabilities should be prepared and equipped to teach in the classroom, including those requiring their own accommodations. The benefits of universal design for learning, physical spaces, and technology do not only accrue to students but also to educators with disabilities, and the inclusion of educators with disabilities encourages and supports students who get to see their own experience reflected in successful teachers with disabilities.
- Recommendation: In Proposed Priority 4, change paragraph (f) to read: “(f) Providing all students access to physically healthy and accessible learning environments, such as energy-efficient spaces, for one or more of the following:”
Rationale: A GAO survey of school district officials estimated that two out of three school districts contain school facilities with physical barriers to people with disabilities. The Proposed Priorities have rightfully acknowledged the technological accessibility challenges highlighted by the COVID-19 pandemic. However, in the return to school, a pre-existing inequity for students with disabilities will be physical inaccessibility. In line with the Department’s commitment to equity, we encourage you to include physical accessibility in improvements to physical school infrastructure.
- Recommendation: In Proposed Priority 5, change paragraph (k) to read: “(k) Connecting children or students with disabilities, adults with disabilities, and disconnected youth to resources designed to improve independent living and the achievement of employment outcomes, which may include the provision of pre-employment transition services, transition and other vocational rehabilitation services under the Vocational Rehabilitation program, and transition and related services under IDEA, as well as supporting full participation and inclusion in post secondary institutions, pre-apprenticeship programs, apprenticeships, and other workforce training.”
Rationale: The suggested additional programs all contain education components that intersect with programs administered by the Department of Education and that require additional attention in order to become consistent pathways to employment for people with disabilities.
- Recommendation: Add to the definitions, “Technology means technology, including both hardware and software, that is fully accessible to and usable by English learners and individuals with disabilities, as well as interoperable with assistive technology, in accordance with the Rehabilitation Act of 1973, the Individuals with Disabilities Education Act, the Elementary and Secondary Education Act of 1965, and the Americans with Disabilities Act, as applicable. Examples of technology include but are not limited to computers, mobile devices, and peripheral equipment; information kiosks; laboratory equipment; software; applications; Web sites; and electronic documents.”
Rationale: The COVID-19 pandemic has elevated the role of technology in delivering classroom-based and remote instruction. We do expect the use of technology to end once the pandemic is over, and we believe the Department has acknowledged the role of technology accessibility, usability, and interoperability with assistive technology by including a note on technology references in the “Background” section. The priorities would be further strengthened with a definition technology that comports with educational and civil rights law and that identifies examples of the range of technologies potentially covered by the definition. Similar examples are provided in the Revised Section 508 Standards.
Contact: Sarah Malaier, Senior Advisor, Public Policy and Research
