Brief to the Ontario Government on Plans for the Return to School in the Face of the COVID-19 Pandemic

Ontario Parents of Visually Impaired Children — Views for the Visually Impaired

www.viewson.ca

Brief to the Ontario Government on Plans for the Return to School in the Face of the COVID-19Pandemic

To: The Hon. Stephen Lecce, Minister of Education

June 18, 2020

1. Introduction

This brief is submitted to the Ontario Government by OPVIC (Ontario Parents of Visually Impaired Children). This is the name which our organization now uses in our daily activity. Our corporate name remains Views for the Visually Impaired.

OPVIC is the provincially recognized non-profit and non-partisan advocacy voice of parents and guardians of children with vision loss in Ontario. That includes children and youth who are blind, who have low vision, or who have deaf blindness. We have moved towards using the name OPVIC as it more effectively explains who we are.

OPVIC advocates at the provincial and local levels around Ontario on behalf of students with vision loss. OPVIC has representatives on several Special Education Advisory Committees around Ontario. It is entitled to be represented on those committees, as the grassroots voice advocating for the needs of children with vision loss.

We summarize our position in this brief:

OPVIC endorses the recommendations that the AODA Alliance has made regarding the needs of students with disabilities during the COVID-19 crisis in its June 18, 2020 brief to the Ontario Government on school re-opening. OPVIC here provides additional recommendations that focus specifically on the needs of students with vision loss.

It is especially important during the COVID-19 crisis for the Ministry of Education to be far more attentive and responsive than it has been in the past to the needs of students with low incidence disabilities such as vision loss. During this period, as much just as in the past, the Ministry has been far more attentive and responsive to the needs of students with higher incidence disabilities. We do not want to take away anything from students with high incidence disabilities. We only seek the attention and responsiveness that our children deserve.

The Government needs to create a concerted new provincial plan to ensure that the learning needs of students with vision loss are met during the transition to school re-opening. The experience over the past three months shows that there can be no confidence that this will happen unless the Ontario Government steps in and shows the required strong leadership. We are eager to help.

During the period of school closures due to COVID-19, students with vision loss have had wildly varying experience. Some have gotten great support from their school board. Some have gotten far less. The fact that some have been well-served shows that it is possible to do more for them than has been the consistent case.

This brief offers six recommendations to meet the important needs of students with vision loss, to supplement those which the AODA Alliance has presented to the Government. These six recommendations are listed in one place in this brief’s appendix.

2. The Reality Facing Students with Vision Loss in Ontario Schools Before COVID-19 Arrived

As a starting point, for the Ontario Government and school boards to effectively plan for the return to school for students with vision loss, it is vital for the Government to reliably and accurately know about the situation before COVID-19 pandemic arose that confronted students with vision loss.

For example, the Government needs to track important and very basic information about the population of students with vision loss in Ontario-funded schools. Yet as far as we have been able to learn, this critical province-wide information is not effectively and accurately gathered, if it is gathered at all. For example:

* How many students with vision loss are there in Ontario-funded schools? What is their distribution across Ontario?

* Where and at what school boards are students with vision loss in school around Ontario?

* What proportion of Ontario’s students with vision loss is educated in the regulator regular classroom setting and what proportion of them is educated in a segregated disability-only setting?

* How many and what proportion of Ontario’s students with vision loss are receiving their schooling at the W. Ross Macdonald School for the Blind in Brantford, and what proportion and number of them is receiving their education from their own school board?

* How many students with vision loss have low vision that is sufficient for visual reading, and how many have too little or no vision or insufficient vision to visually read print?

* How many students with vision loss are braille users or are aiming to become braille users?

* How many students with vision loss have additional disabilities that can affect their learning?

* How many hours per week of support does each student with vision loss need from a teacher of the visually impaired (TVI) and from an orientation and mobility instructor (O&M)? How many hours per week were these students getting of TVI support and O&M support per week respectively, as compared to the hours of support that they individually need, before the COVID-19 crisis?

* How many TVIs and O&Ms are employed by each school board? What is the ratio at each school board of their TVI and O&M staff to that board’s number of students with vision loss whom those specialists are to serve?

On the eve of the COVID-19 pandemic, at most only reasoned speculation was available about the number of students with vision loss in Ontario-funded schools. There is no assurance that any such estimates are accurate.

Ministry of Education data-collection from school boards about students with special education needs is inherently unreliable. It does not include all the information needed and does not ensure accurate and comprehensive data-collection.

For example, if a student has both vision loss and autism, a school board decides whether, for provincial data collection, they are to be listed as a student with vision loss or as a student with ASD. Provincial data-collection has not allowed them to be recorded as having both vision loss and ASD.

We and the Government have no idea how each school board makes such arbitrary decisions. The resulting data is not accurate or reliable. A student who has both vision loss and ASD is not accurately represented if they are treated for provincial data purposes as having vision loss but no ASD, or if they are accounted for as having ASD but no vision loss. This deficiency in the province’s data collection has been known to the Ministry for years.

Students with vision loss are a low incidence population within the overall population of students with disabilities in Ontario. Long before the COVID-19 pandemic as a low-incidence disability among children and youth, students with vision loss have chronically found their needs to be insufficiently addressed at school boards and within Ontario’s Ministry of Education.

Parents of students with vision loss are scattered far and wide in small numbers across this great province. It is an enormous challenge for OPVIC, a volunteer organization, to find and reach out to them. There is no master list of them. It is even harder during the COVID-19 pandemic, when people are shut in at home, overloaded, stressed and struggling to cope with the pandemic’s horrific impact on families and society. Reaching out to parents of children with vision loss is a major OPVIC priority.

Making this situation worse, we understand that there is now a shortage of both TVIs and O&Ms in Ontario. We are aware of no provincial strategy to address this. As more TVIs and O&Ms retire or leave this field, this situation will get worse. We and others have been this concern with the Ontario Government for years.

Also making this situation much worse, Ontario has exceedingly inadequate and substandard requirements to qualify to work in this province as a TVI. Ontario’s qualifications are entirely inadequate. They are substantially lower than the requirements in at least five other Canadian provinces, most of the US, and a number of other countries like the UK and New Zealand. They are substantially lower than the requirements to qualify in Ontario to work as a teacher of the deaf. Neither the Government nor the Ontario College of Teachers have attempted to offer any policy justification for this situation.

OPVIC and blindness rehabilitation and teaching professionals have been raising this problem with the Ministry of Education and with the Ontario College of Teachers for years. See for example, our January 25, 2018 brief to the Minister of Education and our February 14, 2018 brief to the Ontario Human Rights Commission’s “Right to Read” Inquiry.

Only recently has the Ontario College of Teachers given this increased attention. Ministry staff have started to give this attention only after we got sought the help of the Minister of Education. We have no assurances at this point that either the Ministry or the Ontario College of Teachers will effectively address this serious problem.

As a result, many if not the vast majority of TVIs working in Ontario school boards, who are dedicated and want to do their best, have not had sufficient training in their important field.

As one more factor that made the situation for students with vision loss still worse before the advent of COVID-19, there are no provincial requirements and monitoring in place to ensure that Ontario’s school boards have a sufficient number of TVIs and O&Ms on their staff, so that students with vision loss get equitable levels of service across Ontario. From what we have heard, levels of support for students with vision loss before COVID-19could vary widely, and certainly did not ensure that all students with vision loss got the amount of support they need.

As a final pre- COVID-19 factor creating difficulties for students with vision loss in Ontario schools, the Ontario Government does not require each school board to include the vision loss “Expanded Core Curriculum” (ECC), widely used in the US for students with vision loss. The ECC supplements the regular curriculum with key elements that a student with vision loss requires to succeed in their education. Some Ontario school boards voluntarily include the ECC. Others do not. The Ministry of Education would not likely know which boards use it in full, which might use it in part, and which might not use it at all. As such, students with vision loss around Ontario are not consistently assured the full education that they require.

All of these pre-COVID-19 problems fly in the face of the Government’s oft-stated commitment to early literacy as an important priority for Ontarians.

3. What Students with Vision Loss Are Experiencing During the COVID-19School Closures

Imposed on that troubling background has been the COVID-19 pandemic and the necessary closure of Ontario’s schools. Especially during the COVID-19 crisis, it is essential to know what TVI and O&M supports and what actual accessible educational instruction is being delivered to students with vision loss around Ontario during the school closure. Here again, the Ontario Government has in place no way to reliably know this information.

At most, the Government may receive incomplete anecdotal information gathered by the W. Ross Macdonald School for the Blind in Brantford, part of the Ontario Government. It got that information from speaking to those school boards and those TVIs or O&Ms that have communicated with that school. That anecdotal information is not verified, systematic or comprehensive.

That information does not account for the actual experiences of students with vision loss or of their parents and families during the COVID-19crisis. For example, at a virtual meeting this spring addressing online learning issues for students with disabilities, the W. Ross Macdonald School advised that from feedback it received from TVIs at some 30 school boards, things were going well. That evidently included no feedback from parents. The feedback from parents summarized in this brief paints a far more troubling and inconsistent picture, based on parents’ reports of their front line experience.

Under the difficult circumstances that COVID-19 presents to us all, OPVIC and CNIB have done our best to get direct feedback from any parents of students with vision loss that could be reached. We wish we had been able to reach more.

Our best information shows that in Ontario, students with vision loss are having wildly varying experiences when it comes to learning at home during the COVID-19 school closure. Different students get exceedingly different numbers of contacts, hours of contact and quality of contact from their school board.

At one end of the spectrum, some families report that their child is getting little or no support at all from their school board. At the other end of the spectrum, some students with vision loss q1are doing fine, getting extensive supports, with phone contact from their TVI several times per week, even as much as once per day. In between, some students with vision loss have only irregular contact with their TVI.

It appears that the TVI tends to be the linchpin that makes all the difference for students with vision loss when stuck at home during COVID-19. That is not surprising, in light of the TVI’s important role in the school system.

Some students are getting regular braille instruction while at home. At the other end of the spectrum, some report that their braille instruction has entirely stopped during the COVID-19crisis. For students who cannot read print visually, even if enlarged, braille is the key path to literacy.

Feedback ranged from students with vision loss whose adaptive equipment was quickly sent home from school and with which the student is working well at home, to not having the adaptive equipment sent home at all. Feedback ranged from a student who is getting great support from school to a parent reporting that the parent is getting no support and has to support their child 100% themselves. Feedback ranged from a student whose orientation and mobility specialist offered to call weekly with tips for the family to try at home to a student whose family has received no contact whatsoever from an orientation and mobility instructor during the COVID-19 school closure.

Some families reported very positive experiences. That shows that it is possible to deliver at least some effective education to students with vision loss during remote learning.

Other families reported troubling incidents including these difficulties. None need have occurred:

* A classroom teacher who sent work to a student with vision loss using inaccessible formats. Assignments must be in an accessible format for the student to read using adaptive technology such as a screen-reading program on a computer. The requirement to provide people with vision loss documents in an accessible format has been in place for many years. It is not new.

* Sending assignments home for reading where no braille of the reading material is provided.

* A teacher sending the student’s class a video to watch which did not include any audio description. There is no reason for this in 2020. There is a great deal of video content available with audio description. Unfortunately, TVO’s website does not provide a way to search its educational content to discover which content has audio description. Audio description is an accommodation for people with vision loss that has been around for decades. Even if a video lacks audio description, a teacher or other school staff could offer to watch the video remotely and provide audio description to the student with vision loss as the student is watching that video at home.

* The break in the school routine has been especially hard for students with vision loss who have additional disabilities such as autism.

* Students can be given video games for learning math that lack accessibility for students with vision loss. OPVIC notes that this is a problem with at least some of the TVO online math learning tools to which the Ontario Government points school boards and parents during the COVID-19 pandemic.

* Some families report difficulty using adaptive equipment at home. If the student is not familiar with it, a parent may not be not equipped to teach the student to use it and should not be relied on to do so.

* Some families have reported getting far less hours of TVI support while at home compared to what the student received at school. OPVIC notes that during the COVID-19 school closure period, a school board’s TVI should be able to give or at least to offer a student the same hours as was the case during open schools, unless the TVI has family duties preventing full time work during COVID-19. During the COVID-19 school closures, unlike during times when schools are open for students, TVIs do not have to spend any time travelling from one school to another to reach their students.

* Some families reported difficulties with the accessibility of the digital platform for classes that the school board or teacher is using. Others did not report problems with this.

We do not know how many families and students with vision loss if any are getting access to the distance online learning tools for students with vision loss that are offered through the ObjectiveEd website. ObjectiveEd has made these resources available to our school boards for free during the current COVID-19 crisis up to the end of June 2020. It is unclear to us whether the Ontario Government has alerted all Ontario school boards to this free service and has encouraged school boards to alert all families of Ontario students with vision loss. We don’t know how many school boards know about this free resource, and of them, how many notified families of students with vision loss of this free resource.

The Ontario Ministry of Education is aware of this free resource. On May 4, 2020, the AODA Alliance held an online virtual town hall on teaching students with disabilities during the COVID-19 crisis. One of the experts speaking at that virtual town hall was the co-founder of ObjectiveEd, Marty Schultz. Also speaking at that virtual town hall was Jeff Butler, Ontario’s Assistant Deputy Minister of Education responsible for special education.

4. Looking Towards Eventual Return to School

OPVIC identifies several important concerns and foreseeable needs for students with vision loss during the eventual return to school, beyond those outlined in the AODA Alliance’s June 18, 2020 Return to School brief which we endorse. The Ontario Government and school boards need to plan now for these predictable and known needs.

a) Need for Surge in Specialized Supports Relating to Vision Loss

During COVID-19, many students with vision loss fell behind in important areas. Important among these are vital vision loss-related skills that they learn directly from TVIs and O&Ms. This could include learning braille literacy skills, learning to safely navigate using such tools as a white cane, learning to effectively use adaptive technology such as screen-enlargement or screen-reader software, and learning social engagement skills. These vitally underpin almost all other learning. A deficit in these areas therefore will substantially set a student back in most if not all other learning areas.

As such, students with vision loss will need a planned and concentrated surge in the hours of TVI and O&M support that they will get this fall. When school resumes in person, this will need to be substantially ramped up. If distance learning is to resume for all or part of the time this fall, students with vision loss need to be assured consistent, reliable and increased hours of TVI and where feasible, O&M distance support. From the feedback parents have provided us, it is clear that a significant amount of TVI support can be delivered in a week to a student with vision loss, at least in some circumstances.

School boards cannot be expected to deliver this surge in TVI and O&M support to their students with vision loss using their existing pool of TVIs and O&Ms. As a general matter, it is our experience that students with vision loss too often need more hours of these supports than their school boards now deliver. school boards will need added TVIs and O&Ms to deliver the additional hours that students with vision loss will need this fall. This may require added provincial funding. It will definitely require additional provincial planning to ensure that a sufficient supply of qualified TVIs and O&Ms are available for employment by those Ontario school boards that will need them.

We therefore recommend that:

#1. the Ontario Government and school boards should now plan to provide a significant surge in vision-loss related rehabilitation and education services to students with vision loss on the return to school, including such key services as those of teachers of the vision impaired, and orientation and mobility specialists.

b) Challenges with Social Distancing

The Ontario Government and school boards need to be alive now to the added challenges that students with vision loss can and will predictably face when it comes to social distancing at school. They need to plan effective strategies to address these needs. The recent submission on school re-opening by Sick Kids Hospital did not address this need in sufficient detail or with sufficient emphasis.

We offer these examples of important considerations:

* Demarcations on the floor or elsewhere to mark areas for each student to keep away from their classmates, if done by tape, may not be cane-detectable by students with vision loss. For students with low vision, they may not be visually detectible unless there is sufficient colour contrast. Some students with low vision may not be able to visually recognize the presence of people immediately around them, if they are more than 2 meters away. If they are silent, students who are blind may not know they are there.

* Students with vision loss, and especially those who are totally blind, frequently touch their environment with their hands, as a way to orient themselves and to interact with their environment, both when navigating around a building, and when in a class. This risks exposure to COVID-19 virus that is present on a surface they touch. Simply washing hands five times during the school day, as Sick Kids Hospital treats as generally sufficient for students at large, will not be sufficient for students with vision loss.

* Students with vision loss who have certain other disabilities, such as autism will face additional challenges., For example, some may not be able to tolerate wearing a mask.

We therefore recommend that:

#2. the Ontario Government should provide detailed directions to school boards on how to most effectively support and assist students with vision loss in connection with social distancing during any return to school.

#3. School boards will need to have in place action plans on how to effectively accommodate the needs of students with vision loss in connection with social distancing.

#4. Physical markings for social distancing should be designed to accommodate the needs of students who are blind or low vision to detect them.

c) The Need to Protect the Health and Safety of Students with Vision Loss During any Return to School

For some students with vision loss, social distancing will be impossible, e.g. for younger students with vision loss who need the ongoing assistance of an Educational Assistant (EA) or Special Needs Assistant (SNA) before the advent of COVID-19. For example, the EA or SNA will assist some students with vision loss to navigate around the school or classroom. Especially for students with vision loss with more complex needs, the EA or SNA can help the student with personal needs such as going to the washroom, dressing or meals. This assistance cannot be undertaken from two meters away from the child.

As such, EA’s and SNAs will need to have ample and reliable access to personal protective equipment PPE such as masks. They will need effective training on how to use that PPE, and how to assist students with vision loss to avoid the risks of exposure to COVID-19 through touching counters and other surfaces. They will have major responsibility for the student repeatedly washing their hands. This in turn will require substantial training for them. A school board cannot simply send the SNA or EA links to videos to watch. Their school board needs to ensure that the EA or SNA has effectively learned what they need to know and be vigilant in ensuring that the student with whom they are working is protected. Otherwise there is a real risk that the child could contract COVID-19 and could bring it home to spread it to vulnerable family members.

We therefore recommend that:

#5. To protect students with vision loss from the risks of contracting COVID-19during a return to school, each school board should:

a)ensure that EAs and SNAs working withstudents with vision loss have reliable access to personal protective equipment PPE such as masks, and have appropriate training on how to use PPE.

b) Especially for youngerstudents with vision lossand those with multiple disabilities, the school board needs to have in place a planned regiment for protecting the student from being exposed to COVID-19 while at school, including, where needed, expanded one-on-one support by a properly-trained teacher, EA, or SNA.

d) Need for Adaptive Technology Both at Home and School

For students with vision loss, adaptive technology is a vital part of their education. They need to learn how to use it over an extended period of time. It can play a critical role in their literacy and access to curriculum, whether they are totally blind, have low vision, or have vision loss plus other disabilities.

This adaptive technology is typically quite expensive. Traditionally, school boards buy some or all needed adaptive technology using provincial “SEA” funding, on a condition that the technology must remain at school. This has presented a barrier for students with vision loss before COVID-19 if they wish to also do school work at home. Indeed, using that technology at home can be an important part of their learning to use it more effectively.

During the COVID-19 school closures, school boards were eventually permitted to deliver a student’s school-based adaptive technology to their home, for use at home during the period of school closures. As noted earlier, this sometimes happened quickly. In other cases it took longer. In still other instances we were told that it did not happen at all. This is complicated by the fact that some of the adaptive equipment that students with vision loss used at school was not uniquely assigned to one student, but was shared among more than one student with vision loss. We have no information that school boards ensured that each such student was supplied that equipment at home by purchasing duplicate equipment for each student who shared in its use. If not, then the provincial strategy of having school boards send home students’ adaptive technology did not protect some students with vision loss.

When schools re-open, students with vision loss will need to have a set of their school-related adaptive technology at home and a set of that technology at school. This is so for two reasons. First, we understand that school re-openings will likely not be full-time, at least at first. There is expected to be some blended model of some learning at school, and some continued distance learning. Moreover, with the real possibility of a second wave of COVID-19, there is a realistic possibility that there will be a return to 100% distance learning.

Students with vision loss should not all be expected to lug their adaptive technology to and from school each day. Some of this technology is large, heavy and not portable. Especially for younger students with vision loss, or that have multiple disabilities or those with limited orientation and mobility skills, even carrying lighter adaptive technology to and from school each day can present difficulties. Families should not be put to the financial burden of having to buy a duplicate set of this adaptive technology for the home.

We therefore recommend that:

#6. the Ontario Government and school boards should plan now to ensure that students with vision loss, where needed, have a set of their learning-related adaptive technology at school and a duplicate set at home, starting before schools re-open.

Appendix – List of Recommendations

#3. School boards will need to have in place action plans on how to effectively accommodate the needs of students with vision loss in connection with social distancing.

#4. Physical markings for social distancing should be designed to accommodate the needs of students who are blind or low vision to detect them.

#5. To protect students with vision loss from the risks of contracting COVID-19during a return to school, each school board should:

a) ensure that EAs and SNAs working with students with vision loss have reliable access to personal protective equipment PPE such as masks and have appropriate training on how to use PPE.

b) Especially for younger students with vision loss and those with multiple disabilities, the school board needs to have in place a planned regiment for protecting the student from being exposed to COVID-19 while at school, including, where needed, expanded one-on-one support by a properly-trained teacher, EA, or SNA.

Brief to the Ontario Government on Plans for the Return to School in the Face of the COVID-19 Pandemic

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