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IDEA News
Proposed IDEA regulations have been posted in the Federal Register
IDEA Public Meeting Comments
Thank you for making it possible for special education stakeholders to share with you their thoughts regarding the implementation of the Individuals with Disabilities Education Improvement Act of 2004. To give you some context for my comments, I have been the director of the Delaware Assistive Technology Initiative, our state’s AT Act Program, since its inception in 1991. I am also a member of the American Speech-Language-Hearing Association and the Delaware Speech-Language-Hearing Association. I chair our state’s Partners Council for Children with Disabilities, and I work closely with the Delaware Department of Education’s Exceptional Children and Early Childhood Education Work Group, most recently in the implementation of a UDL initiative.
Several provisions in the new law open up wonderful opportunities to enhance learning for children and youth with disabilities through access to technology. From my experience as a speech-language pathologist in K-12, preschool, and rehabilitation settings, technology is often an essential linkage to communication as well as to the curriculum. The expectation that ALL students will demonstrate achievement is a welcome shift in our nation’s thinking, but it brings with it a responsibility to “interface” students with the curriculum in ways that ensure that they can both access curricular content and demonstrate their new knowledge and skills. Our reliance on traditional print materials immediately excludes large numbers of students—those with visual impairments, those with reading difficulties, and those who cannot manipulate a book due to physical limitations—from accessing information vital to their educational progress.
The new law’s provisions relative to the National Instructional Materials Accessibility Standard (NIMAS) and Universal Design for Learning have the potential to eliminate curriculum access barriers for students, yet that potential will only be realized when states adopt facilitative policies; when students, families, and educators understand how to utilize technology to maximize curricular access; and when the technology infrastructure in schools allows educators to optimize instruction for every student. The law acknowledges that State AT Programs have the expertise to help states achieve these worthy objectives, and I urge you to ensure that states utilize this capability to the fullest extent possible as they implement NIMAS (or a comparable alternative) as one means of achieving curricular access for all students.
Our state AT Program offers equipment demonstrations, equipment loans, an equipment exchange program, and vast amounts of training and technical assistance. We enjoy a goal-oriented collaboration with our state Department of Education, but could do much more at the district and school level. Policy, knowledge, and technology infrastructure barriers are abundant at this level, and vigorous guidance from the U.S. Department of Education could help to open the same channels of communication and collaboration that we now enjoy with our SEA at the district and school levels. For example, IEP teams often struggle with the requirement that they “consider” AT for all special education students. Frankly, it is hard to consider how technology might improve curricular access and achievement if no one at the table is familiar with the tools that are out there and how they work. “Consideration,” for many IEP teams, is merely the checking off of a box on the IEP document. When this happens, students lose out on opportunities to learn more effectively and show what they know.
Likewise, school policies need to be modified to eliminate barriers to technology access. For example, educators often must overcome numerous logistical barriers in order to use a piece of educational software with a student. They have to get the software approved, sometimes by numerous levels of authority, a designated technology specialist must load it onto the machine, and access to internet-based resources is blocked. Such policies were established to address other types of concerns, but their impact on students with special needs is that opportunities for technology-enabled learning are squandered. These barriers can be remedied through development of policies that take the needs of all stakeholders into consideration.
School teams will need clarification regarding the revised definition of AT, whether there are any types of AT that fall outside the school’s obligations, and the extent of the school’s responsibility to provide AT when it is both educationally and medically necessary.
Finally, the technology infrastructure challenges are many. Pursuing technology for technology’s sake can result in costly mistakes, but access to appropriate technology that is instructionally sound and that engages the student is priceless. A few years ago, I was contracted to help a district in a western state to develop a “special education technology plan.” General ed had already conducted its stakeholder meetings, built its new facilities, and filled them with state-of-the-art equipment. Special ed students were not even permitted to access those facilities. Rather, a teacher in one classroom I visited scoured yard sales every weekend to try to find software for the Commodore 64 computer that he had in his classroom. If we truly ascribe to the goal of achievement by all students, I maintain that students with special learning needs can benefit even more than the general education population from access to appropriate learning tools and supports.
In summary, we’re at an exciting juncture. Whether the promise of the new Act is realized, however, depends on the vigor with which its tenets are followed. The facilitative role of technology is acknowledged in the law, but facilitative technology has been around for decades. We need to make sure that 1) federal and state policies streamline, rather than inhibit, technology access; 2) that all stakeholders are sufficiently familiar with technology options, or have an efficient means to access that expertise, so that students are getting the technology supports that they need; and 3) that schools have sufficient technology resources that they can implement Universal Design Principles efficiently and effectively.
Thank you for your consideration of these comments. Please let me know if there are ways that my colleagues and I can be of assistance to you in the days and months ahead.
Beth Mineo Mollica, Ph.D., CCC-Sp/L
Director, Delaware Assistive Technology Initiative
University of Delaware
1600 Rockland Road, Wilmington, Delaware 19803
(302) 651-6836 (voice), (302) 651-6794 (TDD), (302) 651-6793 (fax)
January 28, 2005