[Nfbnet-members-list] Contents of Braille Letter

David Andrews dandrews at visi.com
Fri Jun 21 16:29:01 UTC 2013


Dear Fellow Federationists:

On Wednesday I sent out copies of a letter 
concerning the teaching of Braille to our K-12 
students.  One of the attachments was the letter 
in a PDF image format.  Since this is 
inaccessable, (sorry about that,) I am including 
below, the text of the letter.  Another 
attachment to that mailing included the letter in a Microsoft Word document.

David Andrews


[]

UNITED STATES DEPARTMENT OF EDUCATION OFFICE OF 
SPECIAL EDUCATION AND REHABILITATIVE SERVICES

JUN 1 9 2013
Dear Colleague,
For decades, Braille has been a key tool for 
literacy for many blind and visually impaired 
individuals. The Individuals with Disabilities 
Education Act (IDEA or Act),1 in section 
614(d)(3)(B)(iii), specifically addresses a 
public agency's responsibility to make provisions 
for Braille instruction in educating blind and 
visually impaired students. This requirement 
states that, "in the case of a child who is blind 
or visually impaired, [the Individualized 
Education Program (IEP) Team must] provide for 
instruction in Braille and the use of Braille 
unless the IEP Team determines, after an 
evaluation of the child's reading and writing 
skills, needs, and appropriate reading and 
writing media (including an evaluation of the 
child's future needs for instruction in Braille 
or the use of Braille), that instruction in 
Braille or the use of Braille is not appropriate 
for the child." In the 1997 reauthorization of 
the IDEA, Congress added this requirement to 
ensure that blind and visually impaired students 
are provided the Braille instruction that is 
necessary for them to receive a free appropriate 
public education (FAPE). It was retained without 
change when the IDEA was reauthorized in 2004.2 
This requirement applies equally to children who 
need Braille instruction when they enroll in 
kindergarten, as well as to children who will 
benefit from Braille instruction because they 
face the prospect of future vision loss later on in their educational careers.
Despite this requirement, one of the most serious 
concerns voiced by parents and advocates of blind 
and visually impaired children is that the number 
of students receiving instruction in Braille has 
decreased significantly over the past several 
decades. As a result, these individuals believe 
that Braille instruction is not being provided to 
some students for whom it may be appropriate. The 
purpose of this letter is to provide guidance to 
States and public agencies to reaffirm the 
importance of Braille instruction as a literacy 
tool for blind and visually impaired students, to 
clarify the circumstances in which Braille 
instruction should be provided, and to reiterate 
the scope of an evaluation required to guide 
decisions of IEP Teams in this area.3 This letter 
also identifies resources that are designed to 
help strengthen the capacity of State and local 
personnel to meet the needs of students who are blind or visually impaired.
[]
' Part B of the Individuals with Disabilities 
Education Act, 20 U.S.C. §§1401, 1411-1419 (2004).
2 The IDEA Part B regulation in 34 CFR 
§300.324(a)(2)(iii) incorporates this statutory requirement verbatim.
3 Blind and visually impaired students are also 
protected by two other Federal laws: Section 504 
of the Rehabilitation Act of 1973 (Section 504), 
which prohibits disability discrimination by 
entities, such as public schools, that receive 
Federal financial assistance (29 U.S.C. § 794, 34 
CFR part 104); and Title II of the Americans with 
Disabilities Act of 1990 (Title II), which 
prohibits disability discrimination by public 
entities, including public schools, regardless of 
whether they receive Federal financial assistance 
(42 U.S.C. §§ 12131-12134, 28 CFR part 35). The 
Office for Civil Rights (OCR) in the U.S. 
Department of Education enforces Section 504 in 
public schools and, along with the U.S. 
Department of Justice, enforces Title II in 
public schools. Information about OCR enforcement 
is available on OCR's website at <http://www.ed.gov/ocr.>www.ed.gov/ocr.
400 MARYLAND AVE. S.W., WASHINGTON, DC 20202-2600
www,<http://ed.gov/>ed.gov
The Department of Education's mission is to 
promote student achievement and preparation for global competitiveness by
fostering educational excellence and ensuring equal access.

Page 2 ­ Dear Colleague; Braille Instruction Background
In the fall of 2010, nearly 30,000 of the 
students served under Part B of the IDEA were 
reported as having "visual impairment including 
blindness" as their primary disability, 
(approximately 0.07% of the total school 
population4). The population of children who 
receive services under Part B of the IDEA due to 
blindness or visual impairment is extremely 
diverse. These children display a wide range of 
vision difficulties and varying adaptations to 
vision loss. With regard to the degree of vision 
loss, the student population includes persons who 
are totally blind and persons with minimal light 
perception, as well as persons with varying 
degrees of low vision. With regard to adaptations 
to vision loss, persons with similar degrees of 
vision loss may function very differently. A 
significant visual deficit that could pose 
formidable obstacles for some children may pose 
far less formidable obstacles for others. This is 
because adaptations to vision loss are shaped by 
individual factors, such as availability and type 
of family support and the level of the child's 
intellectual, emotional, physical, and motor functioning.
The challenge for educators of blind and visually 
impaired children is how to teach skills that 
sighted children typically acquire through 
vision. Blind and visually impaired students use 
a variety of methods to learn to read, write, and 
acquire other skills. For reading purposes, some 
students use Braille exclusively; others use 
large print or regular print with or without low 
vision aids. Still others use a combination of 
methods, including Braille, large print, low 
vision aids, and devices with computer generated 
speech, while others have sufficient functional vision to use regular print.
Despite the wide range of vision difficulties and 
varying adaptations to vision loss in the 
population of blind and visually impaired 
students, Braille has been a very effective 
reading and writing medium for many of them. 
Research has shown that knowledge of Braille 
provides numerous tangible and intangible 
benefits, including increased likelihood of 
obtaining productive employment and heightened 
self-esteem.5 Given these benefits, it is 
important that States and their public agencies 
ensure the appropriate implementation of the IDEA 
requirement regarding Braille instruction.
[]
4 Source: 
<http://www.ideadata.org/>www.ideadata.org; see also 34 CFR §300.8(c)(13).
s Bell, E. C. & Mina, N. "Blind and Visually 
Impaired Adult Rehabilitation and Employment 
Survey: Final Results." Journal of Blindness, 
Innovation & Research, Vol.', No.1 (2013): 
Accessed April 8, 2013. See www.pdrib.cominages/researchreports.pho.

Page 3 ­ Dear Colleague: Braille Instruction Other IDEA Requirements
In implementing the IDEA requirement regarding 
Braille instruction, the following additional 
IDEA requirements are applicable. Under IDEA, 
each State and its public agencies must make FAPE 
available to children with specified disabilities 
residing in the State in mandatory age ranges 
through a properly developed IEP. Each child's 
IEP must include the special education and 
related services and supplementary aids and 
services that are necessary to ensure each 
child's meaningful involvement and progress in 
the general education curriculum offered to 
nondisabled students. 34 CFR §§300.101, 300.201, and 300.320-300.324.
Under 34 CFR §300.304(c)(4) and (6), an 
evaluation must assess the child in all areas 
related to the suspected disability and must be 
sufficiently comprehensive to identify all of the 
child's special education and related services 
needs. Also, under 34 CFR §300.304(c)(1)(iv), any 
assessments and other evaluation materials used 
to assess a child must be conducted by trained and knowledgeable personnel.
Instruction in Braille and the Use of Braille
IEP Teams must ensure that children who are blind 
or who are visually impaired are provided with 
the Braille instruction they need in order to 
receive FAPE and to ensure their meaningful 
access to the general education curriculum 
offered to nondisabled students. To this end, IEP 
Teams for blind and visually impaired students 
should consider each child's need for appropriate 
Braille instruction on an individual, 
case-by­case basis, and without undue delay. 
Systematic and regular instruction from 
knowledgeable and appropriately trained personnel 
is essential for a child to become proficient in 
Braille. IEP Teams must ensure that the 
instructional time allotted for Braille 
instruction is sufficient to provide the level of 
instruction determined appropriate for the child. 
For example, if a particular student has little 
or no skill in Braille reading and writing, the 
IEP Team may conclude that frequent and intensive 
instruction in Braille likely would be necessary 
to enable the student to have meaningful access to the general curriculum.
Scope of Evaluation Related to Braille Instruction
The IDEA requires that Braille instruction must 
be provided to a child who is blind or visually 
impaired, unless the IEP Team determines, based 
on an evaluation of the child's current and 
future reading and writing needs, that Braille 
instruction is not appropriate for a particular 
child. Generally, determinations regarding the 
components of evaluations for particular children 
are matters within the purview of State and local 
officials. The evaluation of vision status and 
the need (or future need) for Braille instruction 
should be thorough and rigorous, include a 
data-based media assessment, be based on a range 
of learning modalities, including auditory, 
tactile, and visual, and include a functional 
visual assessment. An assessment of a child's 
vision status generally would include the nature 
and extent of the child's visual impairment, and 
its effect, for example, on the child's ability 
to learn to read, write, do mathematical 
calculations, and use computers and other

Page 4 ­ Dear Colleague: Braille Instruction
assistive technology, as well as the child's 
ability to be involved in and make progress in 
the general curriculum offered to nondisabled 
students. Such an evaluation generally would be 
closely linked to the assessment of the child's 
present and future reading and writing 
objectives, needs, and appropriate reading and 
writing media. The information obtained through 
the evaluation generally should be used by the 
'EP Team in determining whether it would be 
appropriate to provide a blind or visually 
impaired child with instruction in Braille or the 
use of Braille as required by the IDEA. Factors, 
such as shortages of trained personnel to provide 
Braille instruction; the availability of 
alternative reading media (including large print 
materials, recorded materials, or computers with 
speech output); or the amount of time needed to 
provide a child with sufficient and regular 
instruction to attain proficiency in Braille, may 
not be used to deny Braille instruction to a 
child. Rather, it would be appropriate to deny 
Braille instruction to a child only when the 
child's IEP Team, based on the results of a 
thorough and rigorous evaluation, determines that 
instruction in Braille would be inappropriate for 
that child. In addition, because the evaluation 
also must assess a child's future needs, a 
child's current vision status should not 
necessarily determine whether it would be 
inappropriate for that child to receive Braille 
instruction while in school. This is particularly 
true for a child with a degenerative vision 
condition who may have a high degree of 
functional vision when the evaluation is 
conducted. The evaluation of such a child would 
need to assess whether, despite the child's 
current vision status, the child still could 
benefit from Braille instruction while in school 
to increase the likelihood that the child will 
obtain productive employment and be able to 
participate more fully in family and community life.
Office of Special Education Programs' Investments 
and Supports A. Personnel Preparation
To help ensure that children with blindness and 
visual impairments receive appropriate services, 
evidence-based interventions, and appropriate 
materials and media, including Braille and 
Braille instruction, the U.S. Department of 
Education's Office of Special Education Programs 
(OSEP) awards competitive grants to support 
university programs that prepare teachers of 
students who are blind or visually impaired. 
During Fiscal Year (FY) 2012, OSEP invested 
approximately $18.6 million of discretionary 
grant funds specifically to improve services and 
results for children who are blind or visually 
impaired. These funds supported a variety of 
personnel preparation and technology projects to 
increase the numbers of certified and licensed 
professionals with the unique and specialized 
skills necessary to support the education of 
students with blindness and visual impairments. 
OSEP funds personnel preparation programs for 
teachers of blind or visually impaired students, 
Braille teachers, and orientation and mobility 
instructors. OSEP requires these personnel 
development programs to include curricula and 
coursework in Braille and Braille instruction.

Page 5 ­ Dear Colleague: Braille Instruction B. 
Accessible Instructional Materials
OSEP also funds technology investments that 
promote the development, demonstration, and use 
of technologies that provide students with print 
disabilities equal access to the general 
education curriculum through collaboration with 
various industry, educational, and consumer 
collaborators. These funding opportunities are 
designed to help strengthen State and local 
capacity to meet the educational needs of 
children who are likely to experience vision loss 
later in childhood or early adolescence.
Additionally, OSEP supports several initiatives 
to promote timely access to accessible 
instructional materials for blind and visually 
impaired students. The National Instructional 
Materials Access Center (NIMAC) is a national 
repository that makes National Instructional 
Materials Accessibility Standard (NIMAS)6 files 
available for the production of print 
instructional materials in specialized formats. 
The NIMAC receives files in NIMAS format from 
textbook publishers, State educational agencies 
(SEAs) and local educational agencies (LEAs), and 
makes these files available for download in a 
variety of specialized formats, such as Braille, 
audio, or digital text, on behalf of elementary 
or secondary school students who are blind, are 
visually impaired, or have other print 
disabilities. Consistent with the IDEA 
requirements for SEAs and LEAs to make accessible 
instructional materials available to persons who 
are blind, are visually impaired, or have other 
print disabilities, all States must adopt NIMAS; 
however, SEAs and LEAs may choose, but are not 
required to, coordinate with the NIMAC in carrying out this responsibility.7
SEAs and LEAs are encouraged to access Bookshare, 
an online, accessible, digital library that 
allows students to access a large and diverse 
collection of titles for school or pleasure 
reading including textbooks, literature, leisure 
reading, reference materials, newspapers, and 
magazines. Students can read multimodally (e.g., 
see and hear words as they are being read and 
highlighted) and download reading materials to be 
used with other technologies such as personal 
computers and cell phone devices.8 In 2007, 
Bookshare received a $32 million five-year grant 
from OSEP to provide free access for students 
with a qualified print disability.
The Office of Special Education and 
Rehabilitative Services (OSERS) provides a direct 
appropriation to the American Printing House for 
the Blind (APH) to produce and distribute books 
and other educational materials for students who 
are blind.9 SEA representatives may order Braille 
textbooks from APH at no cost. In 2012, APH 
offered 955 unique products designed to assist 
with the education of students who are blind or visually impaired.
[]
6 NIMAS describes the minimum standard that SEAs 
and LEAs must meet in order to comply with their 
responsibility under the IDEA to provide 
instructional materials to blind persons or other 
persons with print disabilities. See sections 
612(a)(23)(A), 613(a)(6), and 674(e)(4) of IDEA.
7 For more information regarding NIMAS and NIMAC, 
go to <http://www.aim.cast.org/>www.aim.cast.org.
8 For further information about Bookshare, go to 
<http://www.bookshare.org/>www.Bookshare.org.
9 See 20 U.S.C. §§101-106a (2009); See also 
<http://www.anh.org/>www.anh.org for further information.

Page 6 ­ Dear Colleague: Braille Instruction Conclusion
Braille is a very effective reading and writing 
medium for many blind and visually impaired 
persons, and research has shown that knowledge of 
Braille provides numerous tangible and intangible 
benefits.1° Therefore, it is imperative that IEP 
Teams for blind and visually impaired students 
provide for instruction in Braille and the use of 
Braille for those students, unless, based on a 
thorough and rigorous evaluation, the IEP Team 
determines that instruction in Braille or the use 
of Braille is not appropriate for a particular student.
We hope this information is helpful in clarifying 
the application of the IDEA requirements 
regarding Braille instruction for children who 
are blind or visually impaired. Thank you for 
your continued interest in improving results for children with disabilities.
Sincerely,
\(N\iN,--- 2
Melod              ove, 
Ed                                              Michael K. Yudin
Director, 
Delegated the Authority
Office of Special Education 
Programs                         to perform the functions
and the duties of Assistant Secretary for Special
Education and
Rehabilitative Services

[]
i° Bell & Mino, op.cit.

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