In spring 2020, the American Foundation for the Blind took the lead role in bringing together 22 organizations and companies to conduct the Access and Engagement Study to investigate the impact of the COVID-19 pandemic on the education of students with visual impairments, including those with additional disabilities and deafblindness, and their family members. The families of 455 children with visual impairments from all 50 states; Washington, DC; and Puerto Rico responded to the survey while 1,028 professionals responded, of whom 710 were teachers of students with visual impairments (TVIs), 138 were orientation and mobility (O&M) specialists, and 180 were dually-certified professionals.

Through this study, we confirmed many of the anecdotal experiences of families and students who are blind or have low vision and identified key areas in which children, families, and education professionals need additional action to meet their students’ educational needs during the pandemic. Based on these findings, we encourage the Department of Education to consider the following concerns in finalizing Volume 2 of the school reopening guidance and to support children birth through 21 years who are blind or have low vision and are receiving educational services under the Individuals with Disabilities Education Act or Section 504. A second report based on research from late fall 2020 will be released by early May.

Concerns Relating to Volume 2 of the Reopening Guidance

Meeting the social, emotional, mental health, and academic needs of students.

The Individuals with Disabilities Education Act (IDEA), Section 504 of the Rehabilitation Act of 1973, and Title II of the Americans with Disabilities Act (ADA) affirm the right of students who are blind or have low vision, including those with additional disabilities, to attend a high-quality public school that meets their needs. These students are experiencing unique impacts of the pandemic compared to their peers. Students have had fewer opportunities to engage in tactile instruction and receive intensive supports while accessibility and technology barriers have placed additional limitations on their remote learning experiences. At the same time, many families have had the opportunity to experience firsthand how their child learns and grows at school. The full range of experiences from early intervention through transition has been affected, and teachers have had to adapt to bring accessible instruction into a child’s home. The reopening of schools provides an opportunity to evaluate students’ current needs, adapt the IEP as needed, and equip professionals with the knowledge and resources to compensate for a full range of learning loss socially, emotionally, mentally, and academically.

The Consortium of Citizens with Disabilities Education Task Force prepared a memo on reopening that includes many high-level considerations for students with disabilities. Foremost is the need to provide FAPE and allow students and families informed options for returning to school. Schools must offer clear, complete effective information that guides family decision-making on the return to school. Students should not be forced to return to school earlier than their peers simply because a school is not providing FAPE in the virtual setting. Likewise, students should not be excluded from in-person school in the least restrictive environment if that option is provided to other students.

Supporting educator and school staff well-being.

Students who are blind or have low vision regularly interact with a wide array of educators and service providers, including Teachers of Students with Visual Impairments (TVIs), Orientation and Mobility (O&M) specialists, occupational therapists, physical Therapists, and paraprofessionals. Many of these professionals are itinerant and travel to multiple classrooms, schools, and even districts to serve their full case load of students. When schools reopen for students, these professionals must be able to provide in-person instruction to support students’ needs and rights under the IDEA and Section 504. AFB strongly supports efforts to protect educators and staff from the virus. Foremost among those concerns include access to testing, vaccines, and personal protective equipment. Educational professionals must have equal access to testing, vaccines, and personal protective equipment regardless of whether they are contractors, employed by a district, or employed directly by a school, including specialized schools providing day, residential, or outreach services.

Some of the services that blind and low vision children need most urgently after extended remote instruction include O&M, braille, and hands-on instruction. Because these services may sometimes be less effective in remote settings, students will need to interact with teachers in a way that may not allow physical distancing. Therefore, implementing other mitigation measures takes on heightened importance for these students. Administrators may need to help professionals plan a schedule that maximizes in-person assistance with individual students while minimizing the number of students and classrooms that a teacher engages with in-person during a given time period. Vision professionals may need additional guidance to incorporate appropriate, effective remote learning when students cannot return to school or must limit in-person exposures, to ensure each child continues to receive FAPE.

Well-being extends beyond physical health, however. To further support the well-being of teachers and professionals, administrators may encourage and facilitate planning time and communication with families. Attention should further be paid to the needs of professionals who are themselves parents, family members, or caregivers and the time needed to support hybrid or remote schooling as appropriate.

Addressing lost instructional time for students and Extending learning time.

Numerous proposals for addressing instruction loss have been raised. AFB believes that multiple options can be effective but raises several considerations unique to students who are blind or have low vision. Because blind and low vision students rely on specialized support personnel, a key concern with adding instructional time is the need for additional specialized personnel and other resources to cover the extended learning time and provide appropriate reasonable accommodations. The Department should ensure that COVID-19 relief funds may be used to make qualified specialized personnel, including contractors, and other resources available to students during extended instructional periods. Additionally, educators and families likely need clear guidance on providing compensatory educational services to students who need it. For example, families may need guidance and assistance documenting changes to the services provided, in order to effectively advocate for their child. In some cases, especially children who are very young or have multiple disabilities, remote services may have been provided, but a lack of engagement with the virtual delivery method may have prevented the child from advancing. Such children will need to be evaluated and provided services to make up for lost or ineffective service time. Specific to children with visual impairments, IEP and IFSP teams must be empowered to provide additional services to make up lost learning time on the Expanded Core Curriculum.

Stabilizing a diverse and qualified educator workforce.

The Department has the opportunity to provide substantial support for building a resilient educator workforce. AFB encourages the department to commit to supporting recruitment, training, retention, and professional development. Support for specialized professionals serving blind and low vision students includes preparing more TVIs, O&M specialists, and other vision professionals; supporting specialized professional development with the delivery of remote instruction, evaluation, and assessments; and preparing administrators and general educators to support blind and low vision students through professional development and technical assistance on topics such as training and supporting families to use assistive technology, ensuring digital learning tools are accessible, and delivering accessible lessons that include all students.

Ensuring equitable access to broadband and the devices needed to participate in remote learning.

The American Foundation for the Blind strongly supports efforts to ensure more access to broadband and devices needed for remote learning. In the American Community Survey, children who are reported to experience vision difficulty are less likely than other children to live in households with access to the internet. Moreover, to access instruction over the internet, blind and low vision students need fully accessible devices and/or assistive technology to access instruction. In the first Access and Engagement study, school-age students had had tools at school they did not have access to at home: 17% did not have tablets, 21% did not have laptops, 18% did not have Perkins braillers, 55% did not have large print books, 50% did not have screen reader software, and 28% did not have recreational braille books. Because such devices and tools may be shared in a classroom, schools have not always been able to send appropriate devices – or accessible instructional materials - home with each student. Moreover, some schools are reluctant to provide appropriate devices to students who have been less reachable because of the high replacement cost. Solutions may include procuring additional devices, better and more coordinated parental outreach efforts, and purchasing insurance for devices. An additional barrier is access to training to use assistive technology. When family members support their child’s education, family members as well as the child must receive instruction in using the assistive technology device or software. Finally, some blind and low vision parents have faced obstacles to supporting remote learning for their sighted child when the devices provided have been inaccessible. Incorporating a commitment to procuring, using, and enabling accessible educational technology is key to including both students with visual impairments as well as children whose parents have visual impairments.

Supporting the effective use of technology for in-person learning and periodic shifts to remote learning.

Much of the current in-person instruction retains a hybrid component in which children regularly use computers and other devices to access instruction both in the classroom and at home. Additionally, with the massive investment in computer resources, many teachers have become more comfortable incorporating technology into the classroom. Technology accessibility has been one of the biggest barriers for blind and low vision children during the pandemic. In the first Access and Engagement study, 43% of students attending online had difficulty or were unable to access online programs because of their visual impairment. While education can occur electronically if the materials and digital learning tools are accessible, AFB remains deeply concerned that many programs continue to be inaccessible to many students. In fact, using inaccessible technology in the classroom excludes students from instruction and distracts students, families, and educators from the content while problems are resolved. Students primarily should be focusing on content, not on using their tools. Successful technology accessibility practices include procuring only software and hardware that is accessible with screen reader software and other assistive technologies. Teachers, students, and families must receive training to use assistive technologies. TVIs must be empowered financially and administratively to provide specialized devices such as screen reader software, talking calculators, and braille devices to students in a home setting. Students should not be required to share devices if the devices are used in work completed at home. Additionally, shared devices used in a school building must be cleaned regularly and whenever a different student begins to use them.

Providing all students with access to a safe and inclusive learning environment.

Regarding cohorts of students, Volume 1 of the Reopening Guidance states, “If there are counselors, teachers of electives, related service providers, and specialized instructional support personnel (SISP), they would ideally be assigned to only one cohort/pod or conduct their classes or counseling virtually.” TVIs and O&M specialists may have a caseload covering multiple schools, grades, or districts. A cohort strategy must not force students into a segregated setting consisting only of students requiring similar services, nor should a cohort or pod restrict a student from receiving services from a vision professional. Clear guidance and technical assistance for providing such services remotely may reduce the number of in-person contacts required. However, access to a range of mitigation strategies (including masking, physical distancing, cleaning, testing, and vaccines) may enable multiple service providers to provide in-person support to a child who is in a pod with their peers. After all, most blind and low vision students spend at least a portion of their school day in a general education classroom but still require services from TVIs, O&M specialists, and other professionals.

In some cases, children with complex learning needs or behavioral challenges may struggle to adopt physical distancing and masking behaviors. These children should not be summarily excluded from the classroom or disciplined. Instead, students should be provided appropriate, accessible instruction to understand how and why to follow pandemic rules. Accessible curriculums, such as that published by the American Printing House for the Blind, may assist teachers in preparing students for the classroom. Having students return on a trial basis may also ease the transition to school and develop better understanding of and compliance with the protocols.

When a students’ family chooses to keep a child a home because of difficulties adjusting to the classroom environment, out of concern for medical risk from COVID-19, or for any other reason, it is imperative that each child receive FAPE and all of the services outlined in an IEP or 504 plan in the remote environment. The obligation to provide an accessible remote educational experience must not end when most students return to school.

Addressing resource inequities to provide all students with the educational opportunities they need to succeed, including access to a well-rounded education (including advanced courses, music, and the arts), quality educators, and integrated student support services.

AFB is grateful that Congress provided dedicated funding for the IDEA in the American Recovery Plan and notes that the general education funding may also be used to provide an equitable education to students with disabilities.

Using data to inform students, parents, and educators of progress and areas requiring additional support.

Understanding population-level and individual changes in learning during the pandemic should be an important decision-making tool in both the short and long term. When data is collected, it should be disaggregated by disability type, and the department should support specific research to understand educational changes for students with disabilities. States must conduct an accurate Child Find that ensures all of a child’s disabilities are identified, evaluated, and accommodated. Additionally, districts must conduct appropriate assessments, even if students remain in remote learning. Indeed, conducting ongoing assessment and evaluations may prevent backlogs that require substantial additional resources to resolve. Finally, AFB notes that ensuring all student assessments are accessible with assistive technology is critical to ensuring blind and low vision students’ progress is appropriately and accurately measured.

Contact: Sarah Malaier, Senior Advisor, Public Policy and Research