Braille Monitor                                                     December 2007

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Avoiding a Big Testing Headache

by Peggy Elliott

Peggy ElliottFrom the Editor: The following article and resolution deal with the topic of standardized testing for blind people, a subject of immediate personal interest to many of us and our families, and general interest to those of us who sometimes advocate for blind students and job seekers. To the careful reader they teach several important lessons. One is that blindness accompanies us into every facet of life and that, the more complex the setting, the more complex must be any solutions that include blind people. Another is that even the most complicated settings can be modified to be blind-user-friendly if blind people apply enough knowledge and advocacy. Yet another lesson is that our path to solutions is always made immeasurably smoother by finding and partnering with people of good will.

The Educational Testing Service (ETS) looms large in the standardized testing field, and Federationists have been immensely lucky in finding a person of vast good will at ETS, Ruth Loew, who has been coming to the student meetings at the Washington Seminar and the national convention for a number of years now. While her responsibilities at ETS include handling all disabilities, she has been wise and clever enough to understand the Federation�s position that blind people are largely an identifiable and routinely handled subgroup of the broader disabled community. Through her attendance at Washington Seminars and the focus groups and field-testing of ETS products that she has conducted at national conventions, she has come to know many capable blind people and has applied what she has learned and observed to her professional work.

The following article grew out of a talk Ruth gave several years ago at the Student Mid-Winter Seminar at which she mentioned a little-known method allowing blind students to achieve standard blindness accommodations simply and with relatively little bother. Through further conversations with Federationists on the subject, Ruth has clarified and strengthened this simplified route for ETS test takers to such an extent that it is now routine at that company. The biggest problem blind test takers now report is their inability to apply for accommodations in ETS testing at more or less the last minute. Through Ruth�s interaction with the Federation, the ETS application process has been greatly simplified. The article below describes this process and contains important information for potential ETS test takers. More important, in this sense ETS serves as a role model for other test owners and administrators, whose processes for achieving standard blindness accommodations are much more complicated and difficult. The 2007 resolution reprinted after the following article defines as Federation policy an approach with all test owners and administrators for establishing a simple, clear path like the one ETS is already using.

Peggy Elliott is second vice president of the National Federation of the Blind. She has spent countless hours grappling with the access problems blind people face in taking standardized tests of all kinds. The good will and clear understanding established between Peggy and Ruth Loew are responsible for the signal progress that ETS and we have made on behalf of all blind test takers. Here is Peggy�s explanation of what we have accomplished together:

The Educational Testing Service (ETS) is one of the names about which most blind people have come to feel less than warm. There are two reasons for this lack of warmth, only one of which blind people share with the rest of the country. The first is that most people seeking to attend college or graduate school or enter professions�blind and sighted alike--have encountered an ETS test at the gateway of admission either to school or to a profession. The role of ETS as the keeper of the gate through which we must successfully pass to achieve our goal causes anxiety in most of us, blind and sighted alike. The second reason for coolness we share with other disabled students only: the stress involved in seeking and acquiring accommodations for taking the test.

With ETS tests, however, it turns out that many blind students actually can avoid this second cause for headaches, leaving us, like our sighted counterparts, with merely the universal anxiety to account for our feelings about ETS. To describe this headache-avoidance technique, I�m going to use simplified terms. I�ll add the ETS technical terms in a few places and Website information at the end of the article so that potential test takers can find the desired information in ETS online or printed material.

Let me also specify that this technique works only for tests in which accommodations are administered by ETS. These include the GRE (Graduate Record Examinations), the Praxis teacher licensure series, the Test of English as a Foreign Language (TOEFL), the Test of Spoken English (TSE), the National Board for Professional Teaching Standards (NBPTS), and the TExES Teacher Licensure series. Other testing agencies such as ACT and the Law School Admission Council (for the LSAT) administer other standardized tests, and their approaches to accommodations may or may not mirror those of ETS. And, although ETS creates the tests for many of the College Board�s programs, such as the SAT and AP tests, the College Board, not ETS, itself establishes the accommodations policies for its tests. People planning to take a non-ETS test should carefully check the rules of the agency handling the test they are facing.

The headache-avoidance technique takes advantage of a poorly understood ETS method for requesting accommodations known as the Certification of Eligibility (COE). I call this the �short route� to distinguish it from a full documentation review by a panel of experts retained by ETS, which I call the �long route.� In a nutshell, for blind test takers the short route provides a method for establishing eligibility for accommodations because of blindness and then choosing and being granted routine accommodations normal for blind people, but only if the potential test taker carefully follows very specific rules. The payoff for following the rules with care is that the set of required documents is small and precisely defined, and the ETS response is much quicker and more predictable.

To use the short route, a potential blind test taker recruits an official familiar with him or her, such as a vocational rehabilitation counselor or college disability services provider, to certify that the person is blind and routinely uses the requested accommodations in college or work. ETS recognizes certain accommodations as typical ones for blind people: Braille, recorded audio, large print or screen magnification, scribes, and human readers. ETS also treats time and a half or double time to complete a test as routine for a blind person. To trigger the short route, the applicant submits the certification from one official, the applicant�s choice of medium, and the request for extra time, if desired. Submitting anything else may divert the application to the long route with all the time and frustration this longer route can occasion. Please note that this explanation is simplified for readers of this article and that the details for the short route are specifically provided by ETS in its online and printed publications. And, please, please note that providing any document beyond those specified for the short route can divert the application into the long route, with its much longer timelines and its paperwork requirements.
It�s my guess that most blind students qualify for the short (COE) route and accidentally drop themselves into the long (documentation review) route by adding paperwork not required by the short route, adding to the stress of the pre-test time. This accidental move to the long route arises out of the ETS policy of examining everything the test taker sends. The ETS legal staff has laid down a very firm rule that the short route is available only to an applicant who specifically follows the short-route rules and who does not offer any additional information. If an applicant intends to use the short route but nonetheless adds a letter from an eye doctor or the results of the last vision assessment or a stack of forms from a college documenting blindness and the accommodations used, ETS legal staff has ruled that ETS must assume that this documentation was provided because the applicant wants this additional material to be evaluated. The result is sometimes that the application cannot be considered as a short-route application and must be moved to the long route, which entails external review by ETS consultants.

This internal processing rule may trip up a lot of blind students. Blind students ourselves, along with parents, teachers, and college officials working with blind students, are very used to explaining a lot. If someone asks a question or challenges a proposed method or wants to discuss an alternative, we and those working with us explain and explain and explain. It becomes a way of life, which is understandable, since blindness is a low-incidence disability. In other words, few people know very much about blindness, so we are forever explaining how we do things and why we do them in certain ways. We have all long since learned that most people not only don�t know anything about blindness; they make assumptions about us that we have to anticipate and explain away, or the assumptions will cause substitution of wrong or ineffective solutions assumed necessary by uninformed members of the public in place of our carefully thought-out plan. It is this explaining that can get us in trouble with the ETS short route and can bump the applications of blind people into the long route.

That route is long because ETS contracts with professionals in various fields to provide individual professional opinions on the disability diagnosis and the appropriateness of the requested accommodations. These can be granted in full, granted in part, or denied, based on this individual, file-by-file professional review. Such a review is essential in many cases of learning disability, attention deficit/hyperactivity disorder, psychiatric disability, and traumatic brain injury. These disabilities are invisible and very, very individual. The long route gives ETS a professional judgment about the exact nature of the disability, the resultant functional limitations, and the reasons the requested accommodations are justified.

This long-route-review process is also necessary for blind people who have additional disabilities, whose blindness is recent, who are requesting unusual accommodations (for example, specialized computer equipment), or whose requests present other complexities. Those blind applicants who wish to use an accommodation or combination of accommodations other than the typical ones should recognize that they must build in a longer time between application and the accommodations decision because their applications will be submitted to the document-review process by experts in the field, referred to in this article as the long route. The task of such applicants is to show that the accommodations they request are the ones they customarily use and that they do so for reasons specifically rooted in their disability and often the length of time they have been disabled. People who have been blind longer have usually had more time to master ways of doing things than people who have lost their sight more recently. Of two blind applicants, one may be able to take advantage of more of the standard options than the other. Thus for many blind students the expert review is not needed or wanted while for others documentation review is the only way to take a high-stakes test the way they are used to studying or working.

As a side note, blind people can more readily understand some of the questions asked of all disabled applicants by ETS in light of this potential for individual file review by professionals. Much of the information is sought to allow the file reviewer to assess the disability and the methods the individual customarily uses to deal with that disability. We�ve probably all read those questions and thought to ourselves: �Why do they need to know that? Isn�t it obvious that I�m blind and just need Braille or a human reader?� The answer to these questions is that, for most blind ETS test applicants, ETS knows perfectly well that it doesn�t need a stack of documentation, so they have created the short-route application process for this very reason.

Some blind people are triggering file review when it is not really necessary. For others, the file review may be necessary due to the presence of additional disabilities or due to recent onset of blindness. But, if recent onset is explained straightforwardly enough and other short-route rules are followed, recently-blinded applicants may reach the short route as well. Please remember: the applicant should ask for only the accommodations he or she actually wants to use. There is folklore in the disability community that it�s best to ask ETS for more accommodations than are actually needed because then, even if ETS denies some of the accommodations, it will still grant some others. This is bad advice for blind applicants. A straightforward request for Braille will very likely be approved without delay, but a request for Braille, audiocassette, reader, and a CCTV magnifier will cause processing delays because no one test taker could use all those media simultaneously. If an applicant needs a combination of accommodations and the reason for such a combination might not be obvious because it is rooted in the applicant�s own personal situation and not blindness in general, then the applicant should provide a few lines of explanation. Please remember to keep the explanation simple and straightforward such as �I need both Braille and a reader because, though I prefer Braille, I have only been using it for about two years, and I�m not 100% fluent. I may need a reader for backup.�

Even if you qualify for and carefully design your application to take advantage of the short route, plan to register for the test and apply for accommodations as soon as possible. The need to take ETS and other standardized tests can be anticipated well in advance by most test takers, and applying for accommodations even months in advance is a good strategy in case the test owner or administrator is slow. At least at ETS some commonly requested tests are already on the shelf in alternate formats while others, usually those less frequently requested, are not. So if a blind student needs a test in Braille, it is possible that the test will have to be produced to order, which can add weeks to the time between requesting accommodations and being scheduled for a test date. Also a request for a reader may mean that ETS needs time to prepare test materials for the requested test, since ETS often creates scripts so that readers are told exactly how to describe graphics or present other nonprose material. Time can also be required for preparation of tactile graphics for blind test takers working with readers. All these circumstances suggest applying and seeking accommodations months in advance if possible and accepting any test date provided, even if it is not the same date as that issued to one�s sighted peers. It�s more important to pass the gatekeeper than to do things just like one�s sighted peers, who do not need to request accommodations or wait for production of Braille.

Here are a few additional tips that may speed up processing or avoid unnecessary delays for some ETS test takers: particularly for Praxis II tests, be sure to request the correct test number. A surprising number of accommodations requests are delayed because the test taker was using out-of-date information and requested a test that is no longer offered or is no longer required by his or her state. For those blind and low-vision test takers who do need to use the long route and are planning to submit documentation for review, ETS now has a form for your optometrist or ophthalmologist to fill out indicating exactly what information is needed to evaluate the request. And for all applicants for ETS tests: if in doubt, check ETS printed or online resources, and, if the answer is not obvious or clear, ask. For example, if you�re not sure what provision will be made for handling graphics if a reader reads you the test, ask a customer service representative: <[email protected]>, (866) 387-8602.

Here in slightly more detailed language is a step-by-step description of the short route, loosely taken from the ETS Website describing the Certification of Eligibility (COE):

(1) The blind applicant has a track record of accommodations used in the workplace or in college;

(2) The blind applicant�s DSS provider, VR counselor, or HR representative has documentation on file that meets ETS standards and will vouch for this fact; and

(3) The only accommodations the test taker requests are certain typical ones (Braille, recorded audio, large print or screen magnification, reader, scribe, or time and a half or double time).

Under these circumstances the approval of accommodations is generally simple and, relatively speaking, quick. However, as has already been mentioned, if the applicant adds any information not specifically named in the short-route rules, then that application may be moved to the long-route pile.

For most of us testing is a fact of modern life with which we must deal, like it or not. For blind students the added necessity of getting exceptions from the standard method of administration can add another layer of stress and pressure. For all blind students who can take advantage of the ETS shortcut (COE) accommodations application procedure, following the rules meticulously can result in this step�s being handled with a minimum of stress. Now we can all look forward to ETS and other test owners and administrators� adding access to tests by computer to that list of typical options for blind test takers on at least some of its tests. There are strong indications that ETS is working hard on this urgently needed and surprisingly complex approach to test administration, and all blind people should cheer on an organization working to identify computer testing as appropriate for them.

Disability information on the ETS Website: <>

Specific information on how to apply for accommodations, including all necessary forms, is in the �Bulletin Supplement for Test Takers with Disabilities,� available in pdf format at <>. This publication is also available in plain text format for screen reader compatibility at <>.

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