[Nfbmo] FW: Update: NRMA added to House School Transfer legislation

Gary Wunder gwunder at earthlink.net
Thu Apr 13 11:02:51 UTC 2017


Hi, Dan. Here is some information about the National Media Reading
Assessment or the NRMA. I hope it helps, and I hope you are feeling better.

Warmly,

Gary
[PHOTO CAPTION: Carlton Walker]
Ensuring Our Children Are Literate and Using Reliable Indicators to
Determine Their Optimal Learning Medium
by 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
https://www2.ed.gov/policy/speced/guid/idea/memosdcltrs/brailledcl-6-19-13.p
df. 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
https://nfb.org/images/nfb/publications/jbir/jbir13/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
https://www.nfbnrma.org/admin/users/nrma-quick-start-guide-accessible.pdf. 
	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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