Braille Monitor                                     February 2017

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Ensuring Our Children Are Literate and Using Reliable Indicators to Determine Their Optimal Learning Medium

by Carlton Walker

Carlton Walker From the Editor: For far too long determining whether a blind child will be taught Braille, print, or both has resulted in a tug-of-war between parents and school administrators. Sometimes it is the school which suggests Braille, but the more likely contest has the parents pulling for Braille and the school district resisting. Like so many issues we tackle in work with the blind, the root of the problem is low expectations and the deep-seated yet often unspoken assumption that to be blind is to be slow, to be unable to compete, and to just make it through whatever the immediate challenge is with little thought as to how what is being learned or not learned will affect the student for the rest of his or her life. Is being a slow reader a natural consequence of visual impairment? Is being unable to read for an extended period of time the unavoidable result of being legally blind? Will the world make allowances for blind women and men when they compete for a job or start their own business? The answer to these questions is an emphatic no. The failure to determine early on the techniques that will make letters, words, sentences, and paragraphs a friend for life too often comes too late, if at all, and the cost is paid by blind people who have missed their greatest window of opportunity for learning to read and write with speed and ease.

One difficulty facing combatants in this tug-of-war has been that no validated and standardized test has existed to determine whether a child’s vision dictates he or she should read print, Braille, or both. Too often schools have relied upon the gut feeling of their professionals or have tried to use the fatally flawed Learning Media Assessment, a test which simply does not meet federal law in determining the appropriate reading media for a child. Without a reliable instrument to measure vision as it relates to reading, this most crucial decision is made by the side which has the most power; frequently this means the school. To create a test that would help parents and others who participate in the construction of a child’s individualized education plan, the National Reading Media Assessment was created. Because the National Federation of the Blind was the prime mover in constructing the test and seeing that it conformed to the traditional standards that indicate whether a test is both valid and reliable, some organizations have taken the position that the test is biased toward Braille, ignoring the fact that one of the test’s recommendations may be that a child learn print or even that both print and Braille are appropriate. Some have taken the position that individualized education as mandated by the law means there is no room for applying a standardized test to blind children. Still others have gone on record opposing the test with the argument that the National Reading Media Assessment is the only standardized test available and that blind students, their parents, and those who teach them should have more than one test from which to choose. If having another standardized and validated test is the answer, one would think it better to create that test than to oppose the use of an instrument which is already available. The need to determine whether Braille, print, or a combination of both is critical given what we know about the limited window of opportunity which exists not only to give students the ability to read but the ability for them to do so rapidly and to consider the reading experience second nature.

Carlton Walker is a first-rate lawyer, a stellar educator, and a mother who is committed to seeing that her daughter can read and write competitively. Carlton is also the manager of Braille education for the National Federation of the Blind, and all of her training and life experience make her the ideal person to explain the law, reading assessments, key words we too often hear but do not understand, and the undeniable requirement that our children leave school armed with the tools and techniques that will let them compete in twenty-first-century America. Here is what she says:

Literacy serves as the foundation for education at all levels. Independent reading and writing allows people to interact with and compose text so that they may more fully and comfortably understand information they receive and may more easily and effectively express their thoughts in written form. Most people use print to meet their literacy needs. These sighted people can easily access print in a variety of lighting situations, can read it at efficient rates, and do not experience physical pain (in eyes, neck, shoulders, or back) as a result of reading for one to two hours at a time.  

However, print is not consistently effective and efficient for everyone. For years, blind people were forced to use raised line print letters to read, and there was no means of independent writing available. Luckily, Louis Braille created a tactile code which provides full and rich literacy without the use of vision. Though it took some time, sighted educators of blind students eventually realized the power of Braille to enrich the educational opportunities and enhance the quality of life for blind people. Schools for the blind began to teach Braille to blind children, and those Braille readers began to succeed in life. Unfortunately, many of the schools still forced students with residual vision to use enlarged print rather than Braille. When blind and low-vision students began attending their neighborhood schools, this avoidance of Braille instruction intensified.

Advances in technology and the increased availability of audio information led some to believe that Braille was no longer needed. They believed that it was reasonable to withhold Braille literacy from blind and low-vision students, even though sighted students are still offered access to print literacy despite audio options in this technologically-advanced world.

Members of the National Federation of the Blind have long understood the vital importance of access to efficient and effective literacy for students whose vision was impaired enough to require special education through an individualized educational plan (IEP). In 1997 the US Congress amended federal law to require that all these students receive 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” 20 U.S.C. section 1414(d)(3)(B)(iii). This section of federal law is commonly referred to as the “Braille Provision” and will be so referenced throughout this article.

While the wording of this law is clear, few schools follow its dictates. In reality students do not receive Braille instruction upon identification as a student with the disability of “visual impairment, including blindness.” Schools refuse to provide federally-mandated Braille instruction until after an assessment is performed. Worse, the assessment that schools used for this purpose, the Learning Media Assessment (LMA), was not appropriate for this task, as discussed more fully below.

In view of this discrepancy between legal requirements and educational practice, the United States Department of Education (USDOE) issued a “dear colleague letter” on June 19, 2013, clarifying that the law is to be followed and that the Braille Provision is the right of every child with the disability of “visual impairment, including blindness.” For those who wish to read the letter in its entirety, it is available at The USDOE noted that the law requires that, “evaluation of vision status … should be thorough and rigorous, include a data-based media assessment” (Id. at 3.) and specifically highlighted the law that non-student-centered concerns, like the availability of qualified personnel, large print, and audio materials, “may not be used to deny Braille instruction to a child.” (Id. at 4.)

The development of the National Reading Media Assessment (NRMA) provided the field of blindness education a much-needed tool for assessing Braille appropriateness. The NRMA was designed to adequately, specifically, and objectively assess whether instruction in Braille would be inappropriate for the student.

The Learning Media Assessment

After field tests in 1992 and 1993, the text Learning Media Assessment, by Alan J. Koenig, EdD and M. Cay Holbrook, PhD was first published by the Texas School for the Blind and Visually Impaired in October of 1993. Its second and most recent edition was published fourteen months later and will be the document discussed below. That text set forth an assessment, also called “Learning Media Assessment,” which will be referred to by its acronym for the remainder of this article.

While the LMA was developed before the Braille Provision, its text acknowledges that, “students will be provided Braille reading and writing instruction if they will benefit from such instruction.” As noted above, current federal law requires Braille use and instruction unless the IEP team finds, based upon an assessment of current and future reading and writing needs, that Braille use and instruction are inappropriate for the student. Despite the fact that this wording has been federal law for almost two decades, the LMA has remained unchanged and has never been updated to comport with the requirements of the Braille Provision. Additionally, the LMA exhorts teachers to continually monitor literacy appropriateness, but current federal law requires further assessment only when an IEP team seeks to withhold from a student the right to learn and use Braille. However, failure to keep up-to-date with federal law is not the only shortcoming of the LMA.

The developers of the LMA acknowledge that literacy media is a part of the overall umbrella of learning media (Learning Media Assessment at page 1 and 7), but the LMA undermines access to literacy for blind or low-vision students by mixing non-literacy factors with literacy indicators. For example, if a child recognizes others using primarily visual means, that is considered an indication that the child’s primary literacy medium is visual (Learning Media Assessment, page 187). Similarly, a child’s visual exploration of a toy or object, visual identification of objects, and exhibition of interest in pictures primarily using vision are all considered indicators that the child’s primacy literacy (reading and writing) medium is visual (print), (Id.).

Using vision to identify individuals is in no way an indicator that a child will be able to read print for hours on end as an adult. Visual identification of people is a relatively short-lived activity and does not necessitate the rapid discernment of complex shapes which is required for print reading. People do not utilize fine details to visually identify people they know. Instead, shapes, body movements, and hairstyle or outfits are often clues blind and low-vision children use for identification. More than once, my daughter ran up to men with beards and moustaches calling them “Daddy,” and she failed to identify me at four feet when I had changed clothes in the middle of the day. Yet her first LMA reported that her primary use of vision to identify people indicated that she did not need Braille instruction.

By equating the use of vision with print use, the LMA ignores the very real impact of behavioral imprinting upon children. Most blind children with residual vision grow up in homes, or at least communities, with typically-sighted adults and peers. These children see adult’s and peer’s visual behaviors and, not surprisingly, imitate them. Moreover, many of these children receive little to no modeling of tactual exploration of objects. Thus, it should come as no surprise that most blind children with residual vision use their residual vision—even when it is not efficient to do so.

The LMA does recognize this lack of opportunity to learning tactual skills to an extent and warns that the number of visual behaviors is not dispositive. However, the direction in such a case is to consider providing “diagnostic teaching” of tactual skills to determine if the child will develop tactual skills rather than to simply begin teaching the child Braille (which should have happened the day that child was identified as needing special education for “visual impairment, including blindness”).

The LMA also fails to compare the visual behaviors observed with those of typically-sighted children. Exploring a toy visually within a few inches of one’s face provides no information as to whether print (of any size) will be an efficient and effective means of reading and writing for a lifetime. In the LMA example for “Initial Selection of Literacy Medium,” the LMA proffers a child, “Kevin,” who uses the following viewing distances:

Identification of objects:
            Accurate visual identification of objects:
                        Object size: greater than two to three inches
                        Distance: about two inches
            Accurate tactual identification of objects:
                        Object size: objects identified visually
Normal Visual working distances:
            Classroom materials (such as wall clocks, calendars): no greater than six inches
            Reading/looking at pictures: two to three inches
            Writing/drawing/coloring: two to three inches

Additional observations (include implications of visual condition and additional disabilities): Kevin relies heavily on vision to accomplish near tasks but is accurate in use of tactual skills when requested. He has had little experience with Braille or tactually interesting materials. He would tactually explore if requested; accurate identification of objects when tactual exploration occurred.
Learning Media Assessment, page 46.

Kevin used a working distance of two or three inches in almost every task where typical working distance would be ten to fourteen inches. Two to three inches is an exceptionally short working distance, and its use can lead to eye strain, eye fatigue, and neck and back problems. Also, Kevin exhibited competence with tactual tasks, even though he had no experience with them.

When I read this assessment, it was clear that this student would absolutely benefit from Braille instruction and that Braille instruction was not “inappropriate” for him. In fact, my experience as a teacher of blind students and as the parent of a blind child have taught me that Kevin will almost certainly need Braille in order to keep up with reading tasks, even in first grade. Nevertheless, the LMA developers indicate that it is not clear whether Kevin would benefit from Braille instruction. They advise as follows:

The decision to begin reading instruction in Braille or in print is difficult in this situation and, indeed, cannot be made at this time. Kevin will need continued diagnostic teaching in reading to evaluate his use of visual and tactual skills before the most efficient reading medium for him can be determined. He should receive instruction to increase his sensory skills and learn to apply them in both print and Braille reading readiness activities. Following diagnostic teaching emphasizing sensory development, a clear pattern may emerge that will indicate Kevin’s most efficient reading medium. It is important to allow enough time for a preferred sensory channel to become evident, even if he is older when a determination is made. If a clear pattern of preference has not emerged by the end of the first semester of first grade, the educational team may wish to consider emphasizing print, with the option of providing supplemental instruction in Braille reading in the future, if indicated during continuing assessment.
Learning Media Assessment, page 48.

Reading this, I was flabbergasted. A two- to three-inch working distance with toys (which, as noted above, are far less visually complex than are print letters) is a strong indication that print will not be an efficient literacy medium for this student at any grade level, and it certainly is not evidence that Braille instruction is “inappropriate” for Kevin. However, the developers of the LMA simply cannot accept that Braille is appropriate for Kevin, and they even advise concentrating on print instruction if Kevin does not pick up tactual skills quickly enough. It is notable that these developers provide no research basis for their assessment or the conclusions they draw from it. They reference a case study, but there is no evidence that Kevin was able to use print to efficiently and effectively perform all of his educational and employment tasks.

Luckily, the Braille Provision does not force children to earn the right to Braille instruction. By including in the assessment factors which are irrelevant to current and future reading and writing needs, the LMA renders itself inappropriate for use as an assessment required by the Braille Provision.

Unfortunately, despite the significant shortcomings of the LMA and despite its failure to adhere to federal law for almost two decades, most teachers in the field of blindness education rely on it to provide information required by the Braille Provision.

The National Reading Media Assessment

The National Reading Media Assessment (NRMA) takes an entirely different approach to the assessment required by the Braille Provision. The NRMA focuses upon visual tasks which are relevant to reading and writing.

First, the NRMA seeks information about a student’s visual functioning compared to typically-sighted students. Significant departures from visual performance indicate that vision may not be an efficient tool for the student. The developers of the NRMA recognized that children will use vision even when it is neither as efficient nor as effective as alternative methods. They recognized that children might choose inefficient vision because they grow up in a visual world and may not have mastered more efficient nonvisual techniques. Thus, by seeking information about the efficiency of vision, the NRMA more accurately assesses whether print will be able to efficiently and effectively serve the current and future reading and writing needs of a student.

Next, the NRMA utilizes five different answers for the reporting of statements concerning observed behavior: always, usually, sometimes, rarely, and never. Developers of the NRMA discarded the binary yes/no answer system in favor of this reporting scale based upon information gathered in the first pilot study of the NRMA. Edward C. Bell, PhD, Jessica V. Ewell, and Natalia M. Mino. "National Reading Media Assessment for Youth with Visual Impairments: Research Report." 2013. The research can be found at jbir030201.html. This answering scale eliminates the subjective determination of the nature of an act and simply requests an estimate regarding the behavior’s frequency.

Samples of the observational questions, which should be answered with one of the five frequency statements, include the following:

Child “leans in or bends over, in order to view near objects?” “Do you have problems seeing the cursor on the computer screen if you are sitting up straight (not leaning in)?” “The student shows signs of fatigue, such as a decrease in reading speed, tearing eyes, etc., the longer he/she reads?” and “Student writes legibly in manuscript, cursive, or both, depending on the child’s age, using standard ink pen or pencil commensurate with sighted peers?”

Additionally, the NRMA requires standardization of environment for assessment. As its developers point out, “Standardized conditions (i.e., eighteen-point font, normal lighting, and good posture) are to be used throughout the assessment process in measuring the youth’s visual reading efficiency to insure that appropriate accommodations and/or interventions may be recommended. It becomes counterproductive to allow extra bright lighting, magnification, high contrast, and similar accommodations to be employed during the assessment process as these interventions cloud a clear understanding of visual reading efficiency and prevent accurate assessment results. Providing standardized conditions ensures that the assessment results will provide the student’s educational team with the information they need to make crucial decisions about the child’s educational needs.” As stated in the NRMA “Quick Start Guide,” available at

The NRMA is easy to administer, requires standardized (reliable) conditions, and, unlike the LMA, is available free of charge. The NRMA employs observational questionnaires, using the frequency scale noted above, which are tailored to parents/guardians, classroom teachers, students, and educators of blind students. Results of these objective questionnaires are combined to produce a score indicating whether the student’s literacy medium should be Braille, Dual Media (Braille and print), or print. This recommendation is then added to information regarding the student’s visual ability, eye condition, stability of vision, and other factors to help the IEP team meet its duties under the Braille Provision.

Attacks on the NRMA

This summer, two organizations, the American Council of the Blind (ACB) and the Association for Education and Rehabilitation of the Blind and Visually Impaired (AER), passed resolutions openly attacking the NRMA. The common basis of their attacks is the growing movement in many states to require research-based, standardized assessments under the Braille Provision. These proposed state laws seek to provide students who receive special education services based upon identification of having the disability of “visual impairment, including blindness” the same access to high-quality assessments that every other child in this nation, both typically-developing and those with disabilities, have.

ACB’s resolution is titled, “Appropriate Learning Media Assessments,” and AER’s resolution is titled, “Advocacy for Appropriate Learning Media Assessments.” The titles of these anti-NRMA resolutions underscore the fundamental misunderstanding of these groups about the subject matter of their resolutions. As noted above, the Braille presumption found in federal law requires evaluations of current and future reading and writing media. Nowhere in federal law are “learning media assessments” referenced or condoned. Instead, federal law calls for evaluations of literacy media, not learning media. For some reason, the proponents of these resolutions wish to abrogate federal law. Their failure to understand the requirements of a federal law which has been in effect for almost two decades indicates that one may not feel comfortable relying upon their conclusions. Indeed, one might reasonably conclude that either they do not understand what is clearly articulated in the law or that their judgement is clouded by other matters, which may include political considerations and an attempt to maintain their status quo in which print is presumed to be the preferred media. It would be quite unfortunate and unsettling if they are willing to stand in the way of accepted and time-tested principles recognized by the rest of the education community for purposes unrelated to preparing blind and low vision students for education, employment, and life.

Opponents of the NRMA also claim that the standard conditions it requires prove a fatal flaw. In making this claim, the ACB and AER show that they fail to understand basic special education law. Federal law instructs us that: “Assessments and other evaluation materials used to assess a child under this section . . . are selected and administered so as not to be discriminatory on a racial or cultural basis; . . . are provided and administered in the language and form most likely to yield accurate information on what the child knows and can do academically, developmentally, and functionally, unless it is not feasible to so provide or administer; . . . are used for purposes for which the assessments or measures are valid and reliable; . . . are administered by trained and knowledgeable personnel; and . . . are administered in accordance with any instructions provided by the producer of such assessments;” 20 U.S.C. section 1414(b)(3)(A)(i)-(v). The NRMA meets each of these five criteria, but the LMA, at best, meets only three of them.

If we were to accept the NRMA’s opponents’ flawed requirements for accommodations for evaluations, there could be no valid evaluations. Imagine the standard vision examination by an eye care professional. These evaluations are performed under standard conditions in the office, using controlled lighting and controlled distance. Would an eye care professional allow a patient who said, “I can’t really see that big letter on top. Let me get a little closer, or let me get my magnifier. Then I can tell you.”? Of course not. The entire concept of acuity (20/20) has to do with what every typically-sighted person sees at twenty feet. A person with decreased acuity of 20/200 (meeting the definition of legal blindness) needs to be no further than twenty feet away from an object to see it as well as a typically-sighted individual can from two hundred feet away. As a society we accept and demand standardized conditions in virtually all situations. It is puzzling and distressing that the ACB and AER do not feel that our children with visual impairment, including blindness, are worthy of benefiting from these practices that are intended to measure and through measurement to enhance the chances for one to be competitive and productive.

Under ideal circumstances, the LMA meets the first criterion (non-discriminatory administration), the fourth (trained administrators), and the fifth (administered according to directions). As shown above, the directions for the LMA are flawed and significantly biased against Braille, but following those directions would technically meet these criteria.

The standardization of environmental conditions required by the NRMA meets the second criterion of the law—its requirement for the evaluation to be administered in a manner most likely to yield accurate information on what the child can do. The LMA’s acceptance (and even encouragement) of using non-standard environmental and testing conditions fails this requirement. The ACB and AER opine that students are entitled to individualized accommodations in assessments, so non-standard conditions should be permitted. However, the individualization of accommodations is predicated upon a documentation of the accommodation needed. Such documentation is garnered through standardized evaluations as set forth in federal law. Non-standard conditions prevent the acquisition of reliable information regarding a student’s abilities in the area of evaluation and subsequent need for accommodations. In other words, without a standard assessment, how can we know what individual accommodations a student will need?

The individualization lauded by the ACB and AER is not present in the evaluation of students with other disabilities. Again, federal law requires the five criteria listed above for all evaluations which are performed to determine if a child has a disability covered by IDEA at 20 U.S.C. section 1414(a)(1)(C)(i)(I) and “to determine the educational needs of the child” at 20 U.S.C. section 1414(a)(1)(C)(i)(II) and section 1414(2)(A). For example, students with suspected specific learning disabilities in the area of reading are not offered the “individualized accommodation” of having a reading passage read aloud to them. While the student might need that accommodation on state assessments, the IEP team will not garner useful information about the student’s possible disability in reading if the student receives an accommodation which masks the impact of the disability in the evaluation process. Federal law ensures that all students with suspected disabilities will be evaluated on matters relating to those disabilities with instruments designed to yield accurate information. For some reason the ACB and AER do not believe that blind/low vision students deserve this same protection.

The NRMA also meets the third criterion for evaluations under federal law, that they be valid and reliable, but the LMA does not. As noted above, the LMA has been in use for more than two decades (since 1994). However, in that time period, the LMA has not been shown to be either valid or reliable in determining whether Braille use and instruction are inappropriate for children with the disability of “visual impairment, including blindness.” In stark contrast, the NRMA has met these requirements.

Reliability describes an instrument’s ability to provide the same results based upon similar input or its consistency. For example, a scale is reliable if it indicates the same weight every time a particular item is placed upon it. The weight shown may be wrong, but the answer is consistent (reliable). The NRMA meets this test of reliability; the LMA has not.

Validity refers to the ability of an instrument to accurately measure that which it purports to measure. Of course, the instrument must be reliable in order to be valid, but validity goes further than mere consistency. The NRMA has demonstrated content validity (it measures functional vision for the purpose of reading and writing), concurrent validity (the result of the questionnaires corresponds to the final recommendation), and construct-related validity (the NRMA yields results which are equally valid regardless of student gender, race, age, grade level, or presence of a specific learning disability). (NRMA citation noted earlier.) Again, despite being used for almost a quarter of a century, the LMA has not been shown to be a valid evaluation of whether Braille is inappropriate for a student with visual impairment, including blindness.

The ACB and AER complain that more than one instrument should be used for evaluation purposes. I could not agree more. However, the fact is that the field of blindness education currently has only one instrument to evaluate whether Braille use and instruction are inappropriate which meets the requirements of federal law.

Through their resolutions, the ACB and AER have demonstrated that they want to turn back the clock and rob our students of their federally-protected rights to quality evaluations and to Braille instruction and use. They try to obfuscate the issue by waxing poetic about individualization, despite the clear federal mandate that evaluations of disability must be standardized, reliable, and valid. One hopes that their positions evince a fundamental misunderstanding of federal law and professional standards in educational evaluation and not purposeful avoidance of the rights of blind children. Regardless, we must not allow our children’s opportunities for success to be derailed by actors trying to strip them of their federal rights.

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