Prepared by the National Federation of the Blind
We appreciate the opportunity to provide comments on the draft plan entitled "Transforming American Education: Learning Powered by Technology" as released by the Office of Educational Technology, U.S. Department of Education, on March 5, 2010. The comments offered below by the National Federation of the Blind express our serious concern that this plan fails to recognize the need for the U.S. Department of Education to provide concentrated leadership in both policy and practice, in order to ensure that students with disabilities can take full advantage of the opportunities offered by emerging educational technologies in America's classrooms.
We are pleased to see the National Educational Technology Plan (NETP) embraces principles of universal design for learning, including for students with disabilities. However, the attention the NETP pays to accessibility for people with disabilities is disproportionate to its great importance. The significance of accessibility to people with disabilities must play a more prominent role throughout the NETP. Because accessibility to students and teachers with disabilities impinges on every aspect of the NETP, the impact on people with disabilities should be acknowledged consistently and repeatedly throughout the report. Further, because accessible mainstream technology requires specific and significant considerations beginning in its design phase, accessibility for people with disabilities must be treated with greater detail in the NETP, as opposed to merely being a bullet point within the section on universal design.
Overall, what is missing from the NETP is an appreciation of the opportunity and challenge that technology presents for teachers and students with disabilities. We have the opportunity for the first time to change the paradigm--to reduce drastically the necessity for separate and unequal special education resources by allowing people with print disabilities to have the same access to education as their nondisabled peers. If appropriate standards are properly implemented, we have the opportunity to ensure that access to educational materials is a nonissue for a blind student or one with cerebral palsy who cannot hold her head and hands steady enough to read a book. At present these students are consigned to separate and not equal access, and the mainstream resources (many of which will be developed by mainstream, highly capitalized technology companies) will always outstrip any separate special resources.
The challenge is that, as technologies are adopted in the schools, the disability community will be left behind and thus left out. Because of the logarithmic pace at which technology develops, there is no such thing as being a near-follower of technology, and, if the early decisions are made without consideration of students and teachers with disabilities, the educational gap between those with disabilities and those without will widen from the width of the Grand Canyon to that of the Pacific Ocean. If the message of inclusive technology is not to be lost, it must be stated, not just as a bullet point in a section on universal design, but be included consistently, repeatedly, and in detail (as when a goal is stated for equal outcomes for persons without regard to income or race, but not for persons with disabilities).
So that the report can strike effective notes, let's briefly consider some of the barriers. First is the cubby-holing of accessibility at the Department of Education. For example, the Department of Education funds grants for both accessible technology and mainstream educational technology, but in the latter case it fails to include accessibility as a requirement in the RFP or in the actual grant itself, thereby perpetuating a separate and unequal status for those with disabilities. This dichotomy is to be found throughout the educational system. Universities and colleges, for example, routinely procure and adopt new technologies, such as course management systems, iTunes U, and digital reading systems like the Kindle without any consideration of their accessibility, and it is nearly unheard of for the CIO of a college, university, or school system to consult with its own disability service offices in selecting the technology that is adopted.
Without market demand or insistence by the Department of Education on compliance with federal law, the inevitable result is inaccessible technology and a deepening discrimination against those with disabilities. It should be noted that the barriers are not technological and that mainstream access occurs when it is required, as witnessed by (1) the latest version of Blackboard’s becoming substantially more accessible after Cal State refused to let Blackboard bid while its course management software was inaccessible; (2) iTunes U’s becoming fully accessible after the NFB threatened Apple's collegiate partners with lawsuits; and (3) Amazon’s announcing it would produce an accessible Kindle after the Department of Justice secured consent decrees from the colleges to cease and desist its inaccessible Kindle pilot projects.
Although these examples come from higher education, the lesson is equally true for K-12. Unfortunately, however, disability groups do not have the legal opportunities to be an agent for change in K-12 that they do in the college arena. Thus the responsibility of the Department of Education to take a leadership role here is greater.
At present, by largely confining accessibility to people with disabilities to a bullet point within the NETP, the Department of Education loses a unique opportunity to ensure that technology is transformative for this group. It is also critical that the demand be stated unambiguously: that all technology adopted be accessible. Since this is the law, it is a reasonable request. It is in that spirit that we offer the following suggested actions for inclusion in the final version of the plan:
1. Throughout the NETP "disability" should be added when identifying achievement gaps. Blind students and other students with disabilities are underserved in the same way as students of a racial minority or of a lower socioeconomic status. To ensure the current inequality of service delivery is addressed, the NETP must include disability as an overarching theme as it does race, income, and neighborhood.
2. The standard of Universal Design for Learning (UDL) cited in the NETP is very broad and as a result deemphasizes the type of accessibility required for viable nonvisual access. The UDL definition should be appended to include items 3.a.i and 3.a.ii below.
3. Far too many of the interactive educational technologies that enrich the learning experiences of students today are inaccessible to blind, dyslexic, and other print-disabled children. If educational technology continues to be made without consideration of accessibility at the outset, the gap in service delivery--and consequently achievement--between those students with print disabilities and those without will grow exponentially. Accessibility fits the definition of a "grand challenge problem" as outlined in the NETP and should be added as an additional problem to address. The problem should be addressed in the following manner:
a. Research should be done in collaboration with the National Federation of the Blind and other blindness and print-disability organizations to create standards for the development of accessible educational technologies.
i. The standards will ensure the nonvisual experience with technology is as rich as the visual experience.
ii. The standard will require that the ease of use of all technologies is the same regardless of whether the means of access is visual or nonvisual.
b. Once standards are developed, they should be published, and manufacturers of educational technology should be required to adhere to those standards when producing new technologies.
4. Accessibility must be treated with particularity within the NETP. Though there are some overlapping issues between students with disabilities, English language learners, pre-k students, and low-income and minority learners, accessibility for learners with disabilities is distinct. Substantial action must be taken in the design phase of technological development to produce an accessible product. For this reason accessibility should be addressed both throughout the report and in a separate section. The necessity of accessibility needs to be prominent in this report to ensure that all learners can truly benefit from the resulting technological and pedagogical reform.5. As the medium of textbook production shifts from physical books to digital content, the field must move away from the NIMAS standard--a separate and inferior regulation--and capitalize on mainstream technology. The production of mainstream accessible textbooks is a far superior solution for students with disabilities. This issue should be addressed in the separate section on accessibility that we recommended in item four.