Comments to the Dept. of Education on Improving the Academic Achievement of the Disadvantaged

This document is no longer timely and may be only of historical value.

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Comments

of the

American Foundation for the Blind

submitted to the

in response to a

Notice of Proposed Rulemaking

regarding

published in the

May 19, 2003

Since 1921, the American Foundation for the Blind--to which Helen Keller devoted her life--has been eliminating barriers that prevent the ten million Americans who are blind or visually impaired from reaching their potential. We continue to strive to level the playing field for those blind and visually impaired students because we know that education is the key to their future. This is why we are providing comments on the proposed changes to the assessment regulations of the Department of Education.

Currently, blind and visually impaired students have the highest rate of graduation of all of the disability groups provided services under the Individuals with Disabilities Education Act. Unfortunately, this group also has the highest rate of unemployment. We believe that the system for assessing students needs several critical changes in order to assist blind and visually impaired students in achieving their goals of becoming fully participating citizens.

Today's education system is heavily dependent on standardized assessments to measure the knowledge and understanding of materials possessed by students. For disabled students this trend poses some serious problems. Tests are often not given to disabled students in an effort to ensure that the testing curve does not negatively reflect on the school. In those states where the test scores of disabled students have been counted, the results were disastrous, resulting in many disabled students not graduating even though they had completed the course requirements. The problems lie in four general areas.

1. The assessments themselves are not designed so that they can equitably measure disabled students' knowledge and understanding of the materials.

Assessments should be designed so that the largest number of persons can have the opportunity to demonstrate mastering of skills and understanding of concepts contained in educational goals and objectives. Developers of assessments must clearly document what each specific set of questions is designed to measure. Teams developing assessment tools should include professionals trained in the instruction and curricula development for the full range of disabilities and experts in making materials accessible to disabled students, such as Braille transcriptionists. In this manner, questions can focus on assessing the understanding and level of skill in a given area rather than testing a child's disability. For example, a question which seeks to assess a students descriptive writing skills should ask children to describe something that they can relate to and which does not adversely affect a child with a disability. Similarly questions which require students to use pictoral representation of relationships to answer a question puts emphasis on drawing when it should assess the student's ability to understand relationship. Experts who work with disabled students would be able to advise as to the best way to craft questions so that the emphasis is on understanding and skill rather than the student's disability.

2. The tests are not comparably accessible to disabled students.

Students with disabilities do not have comparable access to assessment tools as do students without disabilities who are given these same assessments. In addition to content issues, attention must be given to graphs, pictures and other representations used in the test. Working with experts, notes can be made so that persons, for example transcribing tests into Braille, will know that the point of the picture of a cat is to show relative size rather than body position or some other aspect. This will mean a greater level of access to the assessment tool itself for the students. Assessments must be transcribed and otherwise made accessible by the same professionals and experts using, for example, the American Braille code, for formatting, graphics and symbols that students are accustomed to using in their daily classroom activities and textbooks, just like their nondisabled classmates. Students have, in the past, been given examinations with nonstandard graphics which blind students were unable to discern and this adversely affected their performance on the assessment. If children use audio copies of textbooks and materials the assessment should utilize the same navigation and indexing system that they are accustomed to using, with the same high standards for production, not an untrained reader on a personal recorder in a corner of a noisy room.

3. The students do not receive appropriate preparation in the subject areas in order to perform well on the tests.

Assessments should be designed to encourage learning goals attainable by the largest number of students. Often, students with disabilities do not receive the same level of instruction to assist them in attaining educational goals because they are out of the classroom learning independent living skills, orientation and mobility or other disability specific skills during the period of time that the other students are receiving those lessons. This is not intentional on the part of the schools, but is partly due to a severe shortage of professionals to provide this valuable instruction. Schools need to address this problem.

Possible solutions to address these needs are, extended school hours, an extended school year and/or provision of these services through alternative agencies if necessary. For example, when students are learning how to graph a problem blind children should be in the classroom learning this skill. This would require that they have previously, or simultaneously be given instruction on the use of a graphic calculator, computer program, Braille notetaker, or other similar technology or technique to accomplish this task.

These methods need to be taught in an integrated fashion so that the skill of graphing is learned at a level to be fairly assessed on a classroom assignment or test, and on a standardized assessment. For example, prior to beginning the 8th grade, a student could attend a summer program specifically designed for blind students where the use of graphic calculators and other similar tools would be emphasized, in order to master the use of the assistive technology and techniques to accomplish these tasks. Then, during the regular school year, students would need minimal specialized assistance during the unit on graphing in the regular classroom. Realizing that this does not directly relate to the assessment, this matter is addressed here because of its potential impact on the measured progress of blind and visually impaired and other disabled students, by standardized assessments.

4. Students do not receive appropriate accommodations for the assessments consistent with that normally provided in the classroom.

Students with disabilities often do not receive appropriate accommodations for assessments. Developers of assessments must be aware of potential accommodations when designing assessments. For example, when an assessment requires students to write a response there must be an opportunity to use scribes, audio recorders, assistive technology, word processors and other similar accommodations. Students must be exposed to testing and learning situations which model those experienced during the standardized assessments. In this way students will not be forced to develop adaptation techniques during the exams which could adversely affect their outcomes. Students need to be able to develop techniques to handle different situations. Each student will need unique accommodations to address their individual needs and these accommodations may vary with the subject matter and situation. Students should receive the same accommodations that they receive during regular education lessons and examinations.

In addition, the use of computers should be incorporated into the assessment to afford greater accessibility.

We appreciate this opportunity to comment on the proposed rule making process. We can recommend various resources and experts to assist you in developing guidelines and regulations. Two major sources of information are the American Printing House for the Blind and the National Center on Educational Outcomes. We are pleased to give any further assistance that you might need.

For further information, contact: