Status of State Systems for the Provision of NIMAS/AIM in 2010
Executive Summary: January 2011
In the summer of 2010, the National Center on Accessible Instructional Materials (AIM Center) conducted a survey aligned to the Quality Indicators for the Provision of Accessible Instructional Materials to determine the current status of systems that support the implementation of the National Instructional Materials Accessibility Standard and Accessible Instructional Materials (NIMAS/AIM) requirement in the Individuals with Disabilities Education Improvement Act of 2004 (IDEA). A total of 54 responses were received. The fifty-four respondents included one designee from each of the 50 states and one designee from each of two outlying areas (OA) and two freely associated states (FAS), all of which will be referred to as “states” or “respondents” in the report. The results of this survey will serve as a baseline for a matching, follow-up survey to be conducted in late 2012 to provide comparative evidence in the evolution of state systems corresponding to the first two years of work by the AIM Center.
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Analysis of the results indicates that the implementation of NIMAS/AIM varies greatly across the country. Data indicate high levels of variation on virtually every element considered critical to an equitable, sustainable system for the provision of AIM according to the Quality Indicators for the Provision of AIM, developed and validated by the AIM Consortium (see Appendix A).
Methods for Acquiring Instructional Materials and for Providing AIM:
Nineteen states (35.2%) acquire textbooks and related materials through state adoptions. Twenty-nine states (53.7%) are described as open territory and six (11.1%) reported using a hybrid system. Thirteen states (24.1%) reported a centralized system for the provision of AIM with primary responsibility at the state level. Fourteen states (25.9%) reported a decentralized system with primary responsibility at the local level and 17 states (31.5%) reported a hybrid system in which shared responsibility at the state and local levels are assumed but not clearly defined. Only eight states (14.8%) indicated a hybrid system in which the shared responsibilities are clearly defined. Overall data indicate that adoption states are more than twice as likely to have a centralized system for the provision of AIM when compared to states with either open territory or hybrid systems for textbook acquisition.
Students Served by the System:
Sections 300.172(b)(2) and (3) of the IDEA regulations require states to ensure the timely provision of accessible formats of printed instructional materials to children with disabilities who need them whether or not those students are certified as having a print disability as defined by copyright. To meet this responsibility, Section 300.172(b)(4) requires SEAs to ensure that all public agencies take all reasonable steps to provide accessible materials at the same time as other children receive their instructional materials. Although this requirement has been in place since the most recent reauthorization of IDEA, data suggest there is much room for progress toward fully meeting this requirement.
Regardless of the type of system implemented, more than 80% of respondents (47) reported that their system provides AIM to students who are blind, visually impaired or have some other print disability as defined by copyright statute whether or not the student was served under IDEA. Only one-third (18) reported providing AIM to students who are served under IDEA but not certified as having a print disability as defined by copyright statute. These data suggest that AIM are being provided based on who qualifies as having a print disability as defined by copyright law, (thus eligible for materials from sources such as the NIMAC and accessible media producers) rather than being provided based on individual student need as required under Section 300.172(b).
Definition and Tracking of Timely Manner:
Forty-seven (87%) respondents reported that timely manner was defined in a way that indicates a level of commitment to having accessible materials available as soon as needed; however, only 18 states (33%) reported that timely delivery was tracked at the state level. Eighteen respondents (33.3%) indicated that districts are expected to track delivery and 15 states (27.8%) reported that timely delivery is not tracked. The data suggest that on a national basis there is little or no evidence upon which to base consistent compliance with the statutory requirement of timely delivery.
Twenty-six respondents (48.1%) reported having comprehensive written guidelines that include responsibilities and procedures across all levels of the system. Open territory states were more than twice as likely to report having comprehensive written guidelines as adoption states. Eleven respondents (20.4%) indicated that guidelines include only statutory information and eight respondents (14.8%) indicated that no written guidelines have been developed. In states where guidelines have been developed, data suggest widespread dissemination most commonly via the web and printed materials. The primary targets for dissemination are reported as local education agency (LEA) personnel in general, most specifically special educators. Slightly more than half of the states (28) indicate that dissemination is also targeted to general educators.
All states have coordinated with the National Instructional Materials Access Center (NIMAC) where NIMAS source files are stored. Fifty-one states (94.4%) have one or more registered authorized users (AU) who can download or assign files to accessible media producers (AMPs) registered with the NIMAC. In addition, 27 states (50%) have named Bookshare as an AU and 17 states (31.5%) have named RFB&D as an AU. Thirty-nine respondents (75%) report that purchasing contracts either at the state or local level are expected to include the requirement to create and provide NIMAS source files to the NIMAC. Some states seek permission or licensing of materials as a means to provide AIM to students who cannot use NIMAC-sourced materials. Only four (7.7%) respondents indicated giving preference to publishers who offer accessible materials for purchase. All but ten (18.5%) respondents reported collaborating with parent information centers in some way, particularly through information sharing, and all but eight (14.8%) indicated collaborating in some way with the agency responsible for assistive technology (AT).
Learning Opportunities and Technical Assistance:
Forty-nine respondents (89.1%) indicated having some level of learning opportunities and technical assistance on accessible instructional materials, most commonly delivered via websites and printed materials. Most often training and technical assistance were directed to LEA staff (88.9%) and to a lesser degree to state education agency (SEA) staff (55.6%) and families (50%). Students (27.8%) and higher education teacher preparation personnel (29.6%) were least likely to be the intended recipients. The most frequently reported topic for training was “statutory requirements and limitations” (75.9%) and the least frequently included topic was identified as “acquisition of accessible instructional materials for students who need them but do not qualify as print disabled as defined by copyright statute” (40.7%).
Data Collection and Use:
Thirty-four respondents (63%) indicate that data are being collected either by a separate data collection system focused on AIM or as a part of the larger statewide student data system while 20 (37%) report that no AIM-related data are being collected. When respondents indicated that data are being collected, data are most likely to include numbers and disability categories of students receiving AIM, the sources used to acquire AIM, and the timely delivery of AIM. Responses suggest that the use of data is most closely related to improving AIM-related services at the state level. There was a noticeable difference between adoption and open territory states on this indicator; responses indicating that that no data are collected included four adoption states and 14 open territory states.
Allocation of Resources:
Thirty-four states (63%) indicated that the greatest allocation of resources related to the timely provision of AIM is made at the state level; however, a substantial number of respondents indicated that the allocation of resources is a shared responsibility of both the SEA and the LEAs and some comments indicated that a variety of state-specific mechanisms are used. Twenty-nine respondents (53.7%) indicated that AIM-related resources are included in the SEA’s special education planning and budgeting process and 17 (31.5%) indicated that LEAs are expected to provide AIM-related resources. Forty-nine respondents (90.7%) indicate that resources are allocated to students served under IDEA and certified as having a print disability, but only 13 (24.1%) reported resources being allocated for students served under IDEA who are not certified as having a print disability as defined by copyright statute. Several respondents commented that separate systems are used to provide AIM to students who are blind or visually impaired.
Summary of Observations and Conclusions
There are multiple complexities involved in developing and implementing comprehensive systems for the timely provision of NIMAS/AIM that are responsive to student needs and provided in accordance with IDEA requirements, the Library of Congress guidelines and the 1996 Chafee Amendment to the U.S. Copyright Act. While a few states reported having well-developed systems expected to ensure the provision of AIM in a timely manner to students who require them and are collecting data that inform the effectiveness of those systems, data collected via this survey indicate that this is not the case for a large number of states. These data suggest that there are many opportunities for improvement of the quality and equity in every important element of AIM-related services included in the snapshot. It is anticipated that collaborative actions by SEAs, LEAs, the AIM Center, the U.S. Department of Education’s Office of Special Education Programs (OSEP), and other federally funded AIM-related projects would have a substantial impact on the continuing development of NIMAS/AIM-related systems. Improved systems would be expected to ensure that students have and can use the accessible instructional materials they need for educational participation and achievement, and are thus anticipated to be highly relevant to improving outcomes for children and youth with disabilities.
Actionable Recommendations for SEAs and LEAs, the AIM Center, and OSEP
Although the ways in which collaboration between SEAs and LEAs would be expected to differ across states data strongly suggest that SEAs and LEAs consider working together to take the following actions:
- Decrease duplication of effort and increase efficiency by implementing a statewide coordinated system for the provision of AIM that aligns common elements and increases communication between separate systems currently providing AIM to different groups of students (e.g., students who are blind or visually impaired, students with learning disabilities).
- Allocate resources needed to develop and maintain high quality, equitable AIM-related services to students with disabilities who require them regardless of disability category.
- Develop and implement data systems that provide the information needed to ensure that students who need AIM receive them in a timely manner, including but not limited to tracking timely delivery of AIM so that delays can be addressed.
- Develop and disseminate written operational guidelines that clearly identify each element within the coordinated system, the roles and responsibilities of each element and how the elements can be accessed.
- Align learning opportunities and technical assistance to the responsibilities included in written operational guidelines.
- Ensure that AIM-related learning opportunities address the needs of all stakeholders including students and families.
- Collaborate with others to develop strategies to increase participation in learning opportunities and access to technical assistance.
- Increase collaboration with federally funded AIM-related projects (e.g., NIMAC, AMPs) to increase the availability of accessible materials at the national level.
- Ensure that all purchasing contracts with publishers include the provision to deposit NIMAS source files in the NIMAC.
- Implement policies that favor publishers with accessible materials for sale.
Data affirm that the planned work of the AIM Center aligns well to what is needed by SEAs and LEAs. Specifically, the AIM Center should provide leadership and/or technical assistance to:
- Develop three models that illustrate how important elements coordinate when service provision is centralized, decentralized or hybrid
- Support SEAs in the development of coordinated AIM-related infrastructure.
- Assist NIMAS/AIM coordinators in defining and addressing their responsibilities.
- Stimulate SEA collaboration with NIMAC, AMPs, publishers, agencies responsible for the provision of assistive technology, and Parent Information Centers.
- Increase collaboration between all federally funded NIMAS/AIM-related projects so that guidance and services provided to SEAs and LEAs are aligned.
- Consider hosting national or regional meetings of SEA personnel involved in AIM-related activities.
- Collaborate with data centers and researchers to determine if and how the use of AIM connects to student outcomes.
Data collected in this investigation affirm that OSEP’s investment in NIMAS/AIM-related projects has enabled progress by many states. However, data also indicate that implementation of NIMAS/AIM varies widely across the nation. In order to improve the development of systems for equitable provision of AIM across the country, OSEP may wish to consider the following actions:
- Encourage the collection of AIM-related data by increasing attention on the implementation of NIMAS/AIM in compliance monitoring processes.
- Support the in-depth analysis of data to determine impact of provision and use of NIMAS/AIM on the achievement and educational outcomes of students with disabilities.
- Work with the AIM Center, other NIMAS/AIM-related projects, other federal agencies, SEA/LEAs, and parent organizations to increase attention on accessibility in the design and development of instructional materials available for purchase regardless of media (e.g., print, eBooks, video, images, audio, eLearning delivery systems).
- Include an assurance within requests for applications and proposals (RFAs and RFPs) that, to the extent possible, all materials developed and/or acquired with OSEP support will be accessible to all users.
- Explore ways to raise awareness about the social justice and civil rights issues related to the provision of AIM.
It is anticipated that these actions on the parts of LEAs, SEAs and the AIM Center, with the guidance and support of OSEP, would lead to the continuing development of systems that ensure provision of AIM in a timely manner, and thus would be expected to be highly relevant to improving outcomes for children and youth with print-related disabilities.
This document was produced under U.S. Department of Education, Office of Special Education Programs Grant No. H327T090001. Michael Slade served as the project officer. The views expressed herein do not necessarily represent the positions or polices of the Department of Education. No official endorsement by the U.S. Department of Education of any product, commodity, service or enterprise mentioned in this publication is intended or should be inferred. This product is public domain. Authorization to reproduce it in whole or in part is granted.
While permission to reprint this publication is not necessary, the citation should be:
National Center on Accessible Materials (January 12, 2011). Status of State Systems for the Provision of NIMAS/AIM in 2010, Wakefield, MA, National Center on Accessible Instructional Materials.