[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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