Views Brief to Ontario Human Rights Commission Right to Read Inquiry

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

www.viewson.ca

Contact@viewson.ca

Brief to the Ontario Human Rights Commission’s Inquiry on the Right to Read

February 14, 2020

1. Introduction

This brief is submitted to the Ontario Human Rights Commission (“the Commission”) by Views for the Visually Impaired, as part of the Commission’s “Right to Read” Inquiry. VIEWS 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. Views 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 this brief as follows:

1. We commend the Ontario Human Rights Commission for undertaking an inquiry into the barriers in Ontario’s education system to the right to read that impede students with disabilities. However, it was wrong and unfair for the Commission to restrict this inquiry to the needs of students with learning disabilities. This inquiry should include and not exclude students with any disabilities that face disability-related barriers to the right to read.
2. In Ontario, students with vision loss, including students with blindness, low vision or deafblindness, face serious, protracted and unfair barriers to the right to read. This is because the training standards required to qualify to serve as a “teacher of the visually impaired” (TVI) are woefully inadequate. They fall well below the requirements in a good number of other jurisdictions inside and outside Canada. They are indefensible. In Ontario, a teacher can be qualified to teach a blind child to read braille through an inadequate training program that does not ever involve that teacher in seeing a student learn braille, or even meeting a student with vision loss. Students with vision loss in Ontario deserve much better.
3. As Ontario’s recognized organization of parents and guardians of children in Ontario with vision loss, Views for the Visually Impaired proposes specific recommendations for action that would bring Ontario forward from its current status of being years if not decades behind. We have tried for over two years without success to get effective reforms. As a low-incidence disability population which is easily overlooked by leaders in Ontario’s education system, the plight facing of students with vision loss in Ontario cry out for the Ontario Human Rights Commission to speak out in strong and decisive terms on this issue, rather than excluding it from this inquiry’s terms of reference.

2. Preliminary Concern: It Was Wrong for the Commission to Restrict This “Right to Read” Inquiry to Children with Learning Disabilities

Views strongly commends the Commission for recognizing that the right to read is essential for students with disabilities, and that disability-related barriers to acquiring literacy are a serious problem. This subject clearly merits the Commission’s attention and action. The deployment of the Commission’s power to hold an inquiry could be a helpful tool for progress in this area.

However, it was wrong and profoundly unfair for the Commission to arbitrarily restrict this inquiry’s terms of reference to only one subset of students with disabilities who face disability-related barriers to access to literacy, namely students with learning disabilities. The Commission’s terms of reference, posted online, are excerpted in Appendix 1. Those terms of reference make it clear that this inquiry focuses on students who have disabilities in relation to reading. However, it also makes it clear that only learning disabilities are the focus of this inquiry.

The disability barriers to literacy facing students with learning disabilities most certainly need to be addressed. It is good that this inquiry includes them and their needs. However, it flies in the face of core human rights values which the Commission is required to advance to limit this inquiry to the needs of students with learning disabilities. As documented below, students with vision loss also face serious impediments to the right to read. These are traceable directly to provincial policy emanating from our public education system, including, among others, from the Ontario Government and the Ontario College of Teachers, as we detail below. These are no less worthy of the Commission’s concern those of students with learning disabilities whom the Commission has chosen to exclusively consider.

The Commission’s announcement on October 3, 2019 recognized:

“Reading is a fundamental skill that students must have to navigate their school experience and their later lives. Our public schools should be able to teach students to read. Yet, this may not be the reality for students with reading disabilities.”

For many students with vision loss, their vision loss is every bit a reading disability. The foregoing quotation speaks directly to and fits their lived experience.

If anything, students with vision loss in Ontario are particularly worthy of securing the Commission’s attention in this inquiry, rather than being categorically abandoned by the Commission’s terms of reference. In Ontario’s education system, vision loss, whether total blindness, deafblindness or low vision, is characterized as and treated as a “low incidence” disability. We have been told that the total number of children with vision loss in Ontario under the age of 18 has been estimated as low as between 2,000 and 4,500. We have found no exact and reliable statistics.

This very small number of children is scattered right across our huge province. As such, parents and guardians of students with vision loss too often find themselves very isolated and alone as they take on the massive challenges of trying to ensure that their child receives a proper education.

These small numbers stand in very sharp contrast to higher incidence disabilities, such as learning disabilities, autism or intellectual disabilities. Because of their greater number and clout, attention from the Ontario Government and key players in Ontario’s education system is commensurately much greater. If students with learning disabilities face serious barriers warranting this inquiry, the situation is at least as serious for students with vision loss.

As the Commission knows well, its assistance is especially needed by those equality seekers who are small in numbers, who are the most vulnerable, and for whom the Government has systemically and repeatedly shown devoted attention. This is such a case. The substantive barriers to the right to read facing students with vision loss, addressed in this brief and excluded from the Commission’s inquiry from the start, are well known to the Ontario Government, the Ontario College of Teachers and other Key leaders of Ontario’s education system. These concerns have been raised with the Ontario Government and the Ontario College of Teachers for years.

Most recently, starting in January 2018, over two years ago, Views has pressed this issue first with the Ontario Government and later with the Ontario College of Teachers, among others. No effective solution from them is in sight. At the present rate, no effective solution can be expected in our lifetime. As such, the Commission’s intervention is desperately required.

We are especially concerned with the Commission’s failure to include this issue within this inquiry’s focus. We have raised this concern directly with Commission staff. Last fall, after learning of the fact that the Commission’s terms of reference for this inquiry were limited to students with learning disabilities, Views board member David Lepofsky (with lead responsibility for government relations for Views) wrote the Chief Commissioner of the Ontario Human Rights Commission, Renu Mandhane to raise this concern regarding this inquiry. He sought an opportunity to speak with her about it.

Instead of agreeing to speak to him, the Chief Commissioner referred the issue to senior Commission staff. As a result, last fall Mr. Lepofsky had a detailed phone conversation with senior Commission staff about this concern. The Views January 28, 2018 brief to the Ontario Government on the substantive TVI issue (set out as Appendix 2 and addressed further below) was sent to Commission staff and discussed. Mr. Lepofsky reiterated Views’ request that the Commission broaden the inquiry’s terms of reference so that the needs of students with vision loss were not shut out.

Mr. Lepofsky repeated his request to speak with the Chief Commissioner. He again emailed the Chief Commissioner. Yet the Chief Commissioner again refused to speak to him. The Commission made no changes to the inquiry’s terms of reference.

The Commission left it open to Views to submit a brief to the inquiry (as we are here doing). However, in doing so, students with vision loss are once again being seriously marginalized and doubly victimized. First, we are left to try to raise an issue that falls outside of the inquiry’s terms of reference. Second, the Ontario Government will no doubt get the strong message that its foot-dragging on this human rights issue need not change, since even the Ontario Human Rights Commission does not consider it worthy of attention during a Commission inquiry on the right to read.

We acknowledge that it remains open to members of the public to make submissions to the Commission, as part of this inquiry, that fall outside the Commission’s terms of reference for the inquiry. We are doing that here. However, that is not enough to address our concerns. In taking the time to prepare this brief, we are keenly and sadly aware that we are trying to get the Commission to address an issue that clearly and categorically lies outside the inquiry’s terms of reference. The Commission has recognized that equality for students with disabilities in our school system means full and equal inclusion. That should apply equally to this inquiry.

We therefore here ask the Commission again to expand this inquiry’s terms of reference to include the barriers facing any students with disabilities to the right to read.

We ask the Commission to deploy its investigative inquiry powers to compel disclosure of key information regarding the issues that this brief raises from the Ontario Government and other relevant public bodies that oversee publicly funded education in Ontario.

Views would welcome a chance to present in person to the inquiry. We regret that according to the information we have received; we cannot attend any of the public hearings that the Commission has schedule. We invite the Commission to add an additional public hearing date, to focus on other disabilities, beyond learning disabilities. We ask the Commission to convene this added hearing in Toronto, but to make it available to presenters around Ontario at the same time through an internet platform such as Zoom.

To this end, we request a phone or in-person meeting with the Chief Commissioner Renu Mandhane to address these pressing issues.

In raising our concerns on behalf of students with vision loss, we don’t for a moment contend that students with vision loss are the only other students with disabilities who should be added to this inquiry. We believe it should be explicitly opened to any students with any disability who faces impediments to the right to read. In pointing to services provided to students with certain other disabilities in this brief, Views is in no way seeking the reduction in the services to students with any other disabilities. To the contrary, we recognize the need to enhance services for students with all kinds of disabilities. We point to certain disparities only to show the disadvantage facing students with vision loss that so desperately needs to be bridged, and the pressing need for the Commission to address this.

We therefore recommend that:

1. The Ontario Human Rights Commission should immediately expand its terms of reference to include students with any disability that impacts on the right to read and the acquisition of literacy.
2. As part of this expanded inquiry, the Commission should require production of documents from the Ontario Government, the Ontario College of Teachers, the school boards that the Commission has selected as its focus, and any other relevant organization in Ontario’s education system that are relevant to the concerns over training and deployment of TVIs in Ontario, addressed in this brief.
3. As part of this expanded inquiry, the Commission should schedule an additional public hearing day for deputations on students with disabilities that have been left out of the terms of reference to date, such as students with vision loss. This hearing should take place in Toronto but should also be available for live participation online for those outside Toronto.
4. the Commission’s Chief Commissioner should agree to speak in person or by phone with Views representatives on this issue.

3. Ontario’s Ongoing Second-Class Treatment of Students with Vision Loss

We here turn our focus to the core substantive issue facing students with vision loss that we wish the Commission to address.

By way of background, students with vision loss begin school with a huge disadvantage, compared to sighted students, when it comes to basic literacy. Sighted students with no other reading-related disability can acquire rudimentary early literacy skills well before they set foot in a junior kindergarten class. Whether it comes from Sesame Street programs or other pre-school educational opportunities, they should often begin their K-12 education wit some key foundations for literacy already laid. This is reinforced by the Government’s focus on early literacy as an important subject.

In sharp contrast, students with vision loss, and especially those who cannot read large print, can begin their publicly funded schooling with no comparable early literacy foundation. Unlike some other jurisdictions in Canada, the Ontario Government does not fund a program for early pre-school literacy training for students with vision loss by teachers of the visually impaired. In the first half of the last decade, a brief endorsed by Views tried to press the Ontario Government to create a provincially funded early pre-school literacy program for students with vision loss, to be delivered by teachers of the visually impaired. This ran into an insurmountable brick wall. Appendix 3 is the June 4, 2012 letter on this topic to senior Ontario Government officials from David Lepofsky (then not a Views board member), which was endorsed by Views, the CNIB and the Alliance for Equality of Blind Canadians. A few high-level meetings with Government officials yielded no substantive reforms.

When students with vision loss reach school, the pivotal and indispensable school board employee who is vital to their acquiring literacy is the teacher of the visually impaired(TVI) The TVI provides the hands-on direct training to students with vision loss on braille reading and writing where needed, on the use of adaptive technology that is critical to literacy, and on other vital skills relevant to reading.

The TVI is also the indispensable person who educated and supports the student’s classroom teacher, special needs and education assistant (if any) and other teaching staff on how to effectively teach students with vision loss. Most of the facetime that students with vision loss spend in school is with teaching staff who have no training or experience in how to teach students with vision loss. Where a TVI is involved, they typically only spend a small proportion of the student’s in-school face-to-face time with the student with vision loss.

In Ontario’s publicly funded education system, everyone from senior management through to the school principal to the classroom teacher all heavily depend on the TVI’s unique expertise. Even teachers with special education specialty qualifications typically do not have expertise with students with vision loss.

There are two vital questions, when it comes to the education of students with vision loss:

1. Are school boards deploying enough TVIs to ensure that all students with vision loss get enough support from these vital professionals to effectively acquire literacy and other related knowledge and skills?
2. Does Ontario ensure that TVIs working in Ontario schools are sufficiently trained and qualified to effectively discharge their pivotal duties for students with vision loss?

We regret that the answer to both questions in Ontario appears to be a resounding “no”.

a) A Growing Shortage of TVIs in Ontario Schools, Possibly Unmonitored by the Ontario Government

We are seriously concerned that Ontario’s school boards do not employ a sufficient number of TVIs to ensure that their students with vision loss get the support they need. We seen no indication that the Ontario Government even tracks how many TVIs are employed by each school board, and their qualifications.

The Ontario Governments method for collecting data on students with special education needs based on their disability is seriously flawed. It cannot be relied on to accurately report how many students with vision loss there are in any school board, or as a total across Ontario. It could well understate those numbers.

Moreover, there can be problems with how school boards supervise and provide oversight for the TVIs who work for them, depending on the board. Where a school board employs one or more TVIs, they report to a supervisor within that school board. That supervisor does not always have the required TVI training and expertise to oversee, mentor and support the TVIs working under them. Here again, we have no idea if the Ontario Government gathers data or monitors how each school board supervises and manages their TVIs.

In contrast, Nova Scotia, New Brunswick and PEI, as well as New Zealand, each use a far more effective and cost-effective approach. They have all TVIs working for a central agency, overseen by TVIs, that deploys them throughout the schools in their jurisdiction. This maximizes the peer support, professional training, mentoring and oversight possible for TVIs, while avoiding wasteful and duplicative levels of bureaucracies within each school board. As well, the Maritime provinces and New Zealand approach makes it far easier to know how many students with vision loss are receiving TVI services, and the amount of services they are receiving.

This is all taking place at a time when we understand that there is a shortage of properly trained TVIs in Ontario. Meanwhile, we are aware of a number of working TVIs retiring, exacerbating this shortage. We know of no Ontario Government recognition of this problem, nor any Government plan or strategy to rectify it.

b) Ontario Training Requirements for TVIs is Woefully Inadequate

Even more troubling is the second issue listed above, Ontario’s standards to qualify to work as a TVI. Both the standard to qualify in Ontario as a TVI and the available training in Ontario are grossly inadequate. This problem has festered for years and years. In this regard, Ontario lags far behind other Canadian provinces such as New Brunswick, Nova Scotia, PEI and British Columbia. Ontario similarly lags far behind a number of jurisdictions outside Canada. This includes any number of US states, as well as the UK and New Zealand.

In those jurisdictions, to qualify to work as a TVI, a certified teacher must then successfully complete at least one year in a university graduate education program, specifically devoted to teaching students with vision loss. That program must include a practicum.

In very troubling contrast, Ontario does not require that much training and has no such comparable graduate university program. Instead, to qualify in Ontario to serve as a TVI, as a practical matter, a certified teacher need only complete a 120-hour AQ (Additional Qualification) course. Theoretically, one must complete three 120-hour AQ courses. However, no one seems to enforce this rule. Once a teacher completes the first of the three 120-hour AQ courses, they can get a job working in Ontario as a TVI, and need not ever go back to do the other two courses.

Any of these AQ TVI courses need not be taught by a university faculty of education. They need not be a graduate level program. They need not include any practicum. All three of these courses, taken together, are insufficient to properly qualify to teach students with vision loss. To just complete one of these courses is even more inadequate.

This concern has been raised for years. We have met no one working in the education system who contends that this is adequate training to qualify as a TVI.

Over two years ago, on January 28, 2018, Views submitted a detailed brief on this concern to the Ontario Government. As indicated above, that brief is included as Appendix 2. Later that spring we submitted that brief to senior officials at the Ontario College of Teachers. Our January 28, 2018 brief spells out in detail the problem and the needed solution. In a January 31, 2018 letter to the Ontario Government, the CNIB endorsed that brief. That letter from CNIB is included here as Appendix 4.

Since we submitted our January 28, 2018 brief, no one in the education system or the Government has disputed its accuracy or claimed that the problem we present is not a problem in Ontario. Yet to date, the Ontario Government has announced no new initiative to address our concerns. We have had two meetings with Ministry of Education officials at the assistant deputy minister level in 2018 and 2019 respectively. Our last such meeting was on Monday June 17, 2019. We were told at that time that the lead Assistant Deputy Minister would get back to us by mid July 2019. There was no commitment to Government action beyond a call-back. We have not heard from them since then, despite our requesting a follow-up.

We have also had meetings in 2018 and 2019 with the Ontario College of Teachers. They too did not dispute the existence or severity of the problems that we presented.

To its credit, the Ontario College of Teachers investigated the issue of the required qualifications for TVIs. However, the only reform they are considering, from what they have told us, is to consider revising the “AQ” courses to qualify to serve as a TVI. We have made it clear to the Ontario College of Teachers that reforming the AQ courses is only a cosmetic reform and is not the solution. It is akin to simply laying out nicer cutlery in the dining room of the Titanic cruise ship.

We have tried without success to get a meeting with York University’s dean of the Faculty of Education. We want to explore the possibility of their offering a graduate level yearlong TVI course. This could be a satellite venue for the successful program offered at UBC. We approached York University because it is in the Greater Toronto Area, which has the greatest concentration of students with vision loss. Moreover, York University offers a comparable program to train teachers of the deaf. We have heard that the York teachers of the deaf program may be funded by the Ontario Government.

Last year we separately asked the Ministry of Education and the Ontario College of Teachers to convene a joint meeting with Views, the Ministry, the College of Teachers and York University’s Faculty of Education to explore this issue. Its resolution cuts across multiple organizations. Neither the Government nor the College of Teachers appears to have acted on this request.

This serious and systemic problem confronts especially vulnerable students with this low-incidence disability. This plight cries out for the Commission to speak out and take strong action. loud and clear.

The enormity of this problem is made worse by the fact that in Ontario, the only place for students with vision loss to get access to TVIs is in the publicly funded education system. For families of students with certain other disabilities, they at least have the option (if they can afford it) to send their child to some specialized private schools when the publicly funded education system does not meet their child’s needs. Of course, the publicly funded system should serve all students. Resort to private schools should not be needed for any students with disabilities.

That being the case, however, students with vision loss only have access to TVI services at publicly funded schools. As far as we have seen, no private schools employ TVIs. This is no doubt because there are so few students with vision loss. What that means is that if effective TVI services cannot be secured in the publicly funded education system in Ontario, students with vision loss have nowhere else to turn.

c) Recommendations

Building on our January 28, 2018 brief (Appendix 2), we urge the Commission’s inquiry to make these findings and recommendations with respect to the right of students with vision loss to read:

1. In Ontario, students with vision loss are a low-incidence population within the larger population of students with disabilities in Ontario’s publicly funded education system. As such, they are vulnerable to systemic barriers that can lack the proper attention of those who run and lead Ontario’s education system.
2. For students with vision loss, the right to read is as fundamentally important as it is for all other students, including the students with learning disabilities who are the focus of this inquiry by the Ontario Human Rights Commission. Ontario’s education system now has serious systemic disability barriers to ensuring that students with vision loss can receive a full and effective education in an inclusive setting, including barriers to the right to read.
3. For a teacher of the visually impaired (TVI) to be properly qualified to teach students with vision loss and to assist other education staff to teach these students, a qualified or certified teacher should be to do more than complete one, two or three Additional Qualifications (AQ) courses approved by the Ontario College of Teachers. They should be required to successfully complete a one-year graduate level university program on teaching students with vision loss. That program should have a mandatory hands-on practicum requirement. This should not be delivered by existing Ontario College of Teachers “Additional Qualifications” courses, nor should those existing courses be upgraded as a solution to this problem. Regulations governing the qualification of teachers in Ontario should be amended accordingly.
4. the Ontario Government should fund the establishment and ongoing operation of a university-level one-year program in Ontario, preferably in the Greater Toronto Area, for training to qualify as a TVI. A retrofit program should also be funded to up-skill those TVIs in Ontario who did not undertake a comparable program.
5. Because there is a current shortage of TVIs in Ontario, which is expected to get worse, the Ontario Government should also fund a pro-active program to substantially increase the available pool of TVIs for Ontario schools. The Government should also explore the establishment of a provincial agency, comparable to the Atlantic Provinces Special Education Authority (APSEA) for employing and overseeing the work of TVIs in Ontario.

We would be pleased to provide this inquiry with any additional information that it may require.

 

 Appendix 1 Excerpts from the Ontario Human Rights Commission Announcement of the Right to Read Inquiry

Originally posted at http://www.ohrc.on.ca/en/right-read-terms-reference

Note: This is excerpted from the Commission’s web posting.

Right to Read: Ontario Human Rights Commission Inquiry into human rights issues that affect students with reading disabilities in Ontario’s public education system : Terms of reference

October 3, 2019

Reading is a fundamental skill that students must have to navigate their school experience and their later lives. Our public schools should be able to teach students to read. Yet, this may not be the reality for students with reading disabilities.

The Ontario Human Rights Commission (OHRC) is concerned that Ontario’s public education system may be failing to meet the needs of students with reading disabilities (dyslexia and other learning disabilities that affect reading). The OHRC is conducting a public inquiry to find out if these students have meaningful access to education as required by the Ontario Human Rights Code (Code). The United Nations Convention on the Rights of Persons with Disabilities also recognizes the right to an inclusive education system directed to the full development of human potential and sense of dignity and self-worth.

A reading disability, formally known as a specific learning disorder with impairment in reading, affects a person’s language-based processing skills. Depending on the person, it can be more or less severe and can affect reading fluency, decoding, reading comprehension, recall, writing, spelling, and sometimes speech. Dyslexia is the most common reading disability. It involves difficulties with accurate and/or fluent word recognition, and poor spelling and decoding abilities.

Reading disabilities can exist along with other related disabilities and affect approximately 10% of the population. Reading disabilities are the most prevalent disability among students with special education needs. There are students with reading disabilities in every classroom.

Dyslexia and other reading disabilities are due to brain differences and are not related to a person’s intelligence. There is no cure, but with scientific evidence-based and systematic instruction in reading, early identification, effective interventions and accommodations, reading disabilities can be resolved or greatly diminished. Failing to do so has serious academic and life-long consequences for students and their families. Students can lose their sense of dignity and self-worth, develop depression and anxiety, and leave school. They may even be more likely to become involved in the criminal justice system, become homeless, or die by suicide. Parents may struggle to get assessments, interventions and accommodations for their children, and in many cases may be forced to pay for services privately, assuming they can. …

…

The OHRC is working to remove systemic barriers that students with disabilities face in accessing educational services, and to increase human rights accountability in Ontario’s public education system.

The OHRC’s inquiry powers

The OHRC is carrying out this public interest inquiry pursuant to its powers under section 31 of the Code. These powers include, but are not limited, to:

The power to request the production of documents, things or information

The power to question a person on matters that may be relevant to the inquiry, subject only to the person’s right to counsel

The power to enter any premises where there may be relevant documents, things or information

The ability to use expert assistance to carry out the inquiry.

The Code places a legal obligation on persons to comply with the OHRC’s inquiry requests. The information obtained on an inquiry under section 31 may be received into evidence in a proceeding before the HRTO.

 

Scope of the inquiry

The OHRC will inquire into potential human rights issues affecting students with reading disabilities in Ontario’s public schools, including:

Universal Design for Learning (UDL): Whether Universal Design for Learning, an approach to education that meets the diverse needs of every student, is being applied within Ontario’s reading curriculum and in classroom teaching methods

Mandatory early screening: Whether all students are being screened for reading difficulties in kindergarten (or in Grade 1, where a child does not attend public school for kindergarten) using scientific evidence-based early screening tools

Evidence-based reading intervention programs: Whether students who have been identified as having reading difficulties through mandatory early screening or psycho-educational assessment have access to timely, scientific evidence-based reading intervention programs

Accommodation: Whether students who have been identified as having reading difficulties through mandatory early screening or psycho-educational assessment have access to timely and effective accommodation and assistive technology.

Psycho-educational assessments: The role of psycho-educational assessments and whether students have access to timely and appropriate psycho-educational assessments where needed (in addition to mandatory early screening for reading difficulties)

The OHRC will consider perspectives on definitions of learning disabilities and dyslexia, including whether these terms are appropriately used and understood.

The OHRC will also examine the unique challenges for students with reading disabilities who face other barriers such as living in poverty or being members of intersecting Code-protected groups [e.g. newcomer students, English-language learners (students who are learning English at the same time as they are learning the curriculum and developing a full range of literacy skills), racialized students, and students with Indigenous ancestry].

The OHRC has selected eight public school boards from across the province to assess their compliance with their obligation to provide equal treatment to students with reading disabilities. This representative sample will allow the OHRC to assess whether systemic issues exist across Ontario’s English public elementary and secondary schools. *

The OHRC will request documents, data and information from the following eight school boards:

Hamilton-Wentworth District School Board
Keewatin-Patricia District School Board
Lakehead District School Board
London District Catholic School Board
Ottawa-Carleton District School Board
Peel District School Board
Simcoe Muskoka Catholic District School Board
Thames Valley District School Board.

To select this representative sample of school boards from across Ontario, working with an expert, the OHRC considered a combination of the following: lived experience accounts; population density; different geographic regions; demographic information; data from the Education Quality and Accountability Office including reading test results; boards’ Special Education Plans; the proportion of students from different Code-protected identities; and public reports.

The inquiry will also recognize systemic and structural issues that may be contributing to human rights issues, including in the areas of teacher training; funding; oversight; monitoring and accountability, including appropriate assessment of student progress; data collection; and curriculum design. In addition to school boards, the OHRC may review the roles of various partners in the education sector, including but not limited to the MOE, faculties of education at Ontario universities, and the Ontario College of Teachers.

The OHRC may examine and report on any other issues relevant to meeting the needs of students with reading disabilities in the delivery of public education in Ontario.

Inquiry process

To carry out the inquiry, the OHRC will:

Seek production of documents, data and information

Conduct research

Retain expert(s)

Consult with key stakeholders

Receive information from affected individuals, groups, experts, organizations, and other stakeholders through a variety of means.

The OHRC will report publicly on the inquiry process and its findings and will make recommendations based on its findings.

Before making its report public, the OHRC will provide an opportunity for the selected school boards, the MOE, and other education sector partners affected by the inquiry’s recommendations to respond.

The OHRC may take further steps available to it under the Code to address any issues identified in the inquiry process.

Any revisions to these Terms of Reference will be posted publicly.

Privacy

The OHRC recognizes the potential vulnerability of affected individuals and the sensitivity of information it will receive during the inquiry.

The OHRC will take all reasonable steps to conduct any surveys and interviews in a way that protects the security of the person and respects their confidentiality. The OHRC will not disclose personal information of affected individuals without informed consent.

The OHRC will take all reasonable steps to ensure that personal information that it obtains is treated confidentially and in accordance with statutory safeguards including the Freedom of Information and Protection of Privacy Act (FIPPA).

The OHRC will be governed by its Protection of Personal Information and Privacy Safeguards Policy and will take all reasonable steps to prevent unauthorized access, use or disclosure of personal information as directed by FIPPA.

The OHRC will destroy any personal information as soon as reasonably possible after it is no longer required.

*The OHRC is aware that issues may exist within French-language school boards, private schools, and in colleges and universities. As the unique issues in each of these contexts require separate consideration, they are outside the scope of the current inquiry.

 

 Appendix 2 January 28, 2018 Brief by Views for the Visually Impaired to the Government of Ontario

January 31, 2018

by email and mail

The Hon. Mitzie Hunter

Minister of Advanced Education & Skills Development
Government of Ontario
3^rd Floor, Mowat Block
900 Bay Street
Toronto, ON M7A 1N3
mhunter.mpp.co@liberal.ola.org

Dear Minister Hunter,

RE:   CNIB support for VIEWS for the Visually Impaired  http://viewson.ca/ brief to the Ministry of Education.

The recommendations identified in VIEWS for the Visually Impaired Brief to the Ministry of Education echo the challenges, barriers, and gaps in support and accessibility that CNIB also identified in our recently submitted feedback to the Government of Ontario’s consultation on the proposed Accessibility for Ontarians with Disabilities Act (AODA) Accessibility Standard for Education.

From surveys within our community, CNIB has found that families often feel isolated and increasingly frustrated when trying to navigate the current educational system in Ontario. The VIEWS brief also illustrates this. Parents and students are looking for more concise and informative support that caters to the varying individual needs of each student especially when it comes to assistive technology. Foundation Programs offered by CNIB, such as Beyond the Classroom and Accessible Technology Support, aid families trying to navigate the educational system, but it is concerning that parents are regularly forced to turn to community organizations for support and advice on how to access accessibility supports for their child with a disability.

The Hon. Mitzie Hunter

Minister of Advanced Education &

Skills Development

Page 2

CNIB and VIEWS also identified the inability to access textbooks and course materials in an accessible format and a timely manner as one of the greatest barriers to academic success.

CNIB supports VIEWS ask that the Ministry of Education update, monitor and modify the standards and qualifications for a teacher to serve as a “Teacher for the Visually Impaired” (TVI) in Ontario. We agree that the current system may not adequately teach educators how to meet the unique needs of students with vision loss especially when it comes to technology.

Additionally, CNIB supports VIEWS ask that the Ontario Government guarantees school boards train students with vision loss on current adaptive technology (including Apple iOS devices) to enhance their educational experience, give them the tools to help succeed and create a more inclusive environment.

Only 65% of students with sight loss graduate from high school, compared to 81% of the sighted population (2011 CNIB Needs Study). We believe that with the correct academic and accessibility supports, students who are blind or partially sighted should be able to perform equally with their sighted peers.

We look forward to receiving a response from the Government of Ontario on this very important submission.

Sincerely,

Len Baker

Regional Vice-President, Ontario and Quebec

 

 Appendix 3 June 4, 2012 Submission by David Lepofsky to the Ontario Government Calling for a New Early Literacy Strategy for Pre-school Children in Ontario with Vision Loss

Via Email

MEMO TO:      Grant Clarke, Assistant Deputy Minister, Learning & Curriculum

Ministry of Education

grant.clarke@ontario.ca

Darryl Sturtevant, Assistant Deputy Minister, Strategic Policy & Planning

Ministry of Children and Youth Services

darryl.sturtevant@ontario.ca

FROM: David Lepofsky, CM, O.Ont

 

June 4, 2012

SUBJECT:         PROPOSAL FOR NEW SUPPORTS TO TEACH EMERGING LITERACY                            SKILLS TO PRE-SCHOOLERS WITH VISION LOSS IN ONTARIO

 

1. OVERVIEW

This is a proposal for the Ontario Government to spearhead a much-needed new low-cost, high-yield initiative to address an important unmet need of Ontario’s pre-school children with vision loss, both those who are totally blind and those with significantly low vision. This initiative would aim to fully develop comprehensive early and emergent literacy skills for pre-school children with vision loss including, where appropriate, early Braille reading skills. This could fit in whole or in part within the Blind/Low Vision Program (BLV) that the Ministry of Children and Youth Services (MCYS) oversees. That program now delivers early intervention services for children with vision loss across Ontario.

Ontario’s pre-school children with vision loss now lack much-needed important, timely literacy learning opportunities that they would enjoy elsewhere e.g. the Canadian Maritimes and Massachusetts. It is a cruel irony that blind pre-schoolers in the heart of Toronto have far less access to pre-school literacy than ones living in the poorest areas of New Brunswick, one of the “have not” provinces. Expertise on how to deliver this low-cost, high-impact training is readily available. Ontario would benefit by catching up.

This submission is supported by the Alliance for Equality of Blind Canadians (AEBC), the Canadian National Institute for the Blind (CNIB) and VIEWS for the Visually Impaired (the organization of parents of children with vision loss in Ontario).

This is not the first time that the government has been urged to support expanded literacy opportunities for pre-school children with vision loss. For example, in its September 2, 2010 submission to the Government’s review of the Blind Low Vision program, Views for the Visually Impaired (the respected organized voice for parents of children with vision loss) called for expanded literacy supports, to be provided by a certified Specialist Teacher of the visually impaired, with qualifications in early childhood development.

2. THE UNMET NEED

Ontario’s pre-school children with vision loss have a major unmet need. This is the need to acquire a full range of early and emergent literacy skills, as they reach developmental stages for which these are suited, before they reach school age and begin attending school.

In sharp contrast, sighted children often acquire early and emergent literacy skills during the pre-school years. They do this through informal activities in the home, by watching TV programs like Sesame Street, and through activities at nursery schools, day care programs and pre-school programs.

Ontario commendably has established a province-wide Blind/Low Vision program under the Ministry of Children and Youth Services, to provide early intervention supports for children between birth and age six with vision loss. However, as now operated, this program does not deliver the full range of comprehensive early and emergent literacy skills that its children need at the pre-school stage. Needed comprehensive early and emergent literacy supports for blind and low vision pre-schoolers could, among other things, aim to prepare a child for reading Braille if that will be worthwhile for him or her, or large print, or some combination of these, as well as other literacy modalities. As but one example, if a child could benefit from starting to actually learn to read Braille while at a pre-school age, the Blind Low Vision program does not provide that training.

Experience in some jurisdictions elsewhere in Canada and the U.S., i.e. the Canadian Maritimes and the state of Massachusetts, shows that providing a child with vision loss and his or her family with comprehensive supports for early and emergent literacy skills can and should begin shortly after birth. It should expand during the infant, toddler and pre-school years, commensurate with the stage of a child’s development.

 

Evidence of the fact that children under age four or four-and-a-half can profit from a full range of early and emergent literacy instruction (including in some cases, hands-on Braille training) is also proven from experience within Ontario. Some children with vision loss, if admitted to junior kindergarten in Ontario before age four, may get hands-on Braille training if they are ready for it, and if the school board to which they are admitted makes it available to them. In contrast the same child with a birthday that doesn’t permit admission to school until after they turn four would be delayed in acquiring that skill, despite their developmental readiness for it.

 

In the area of literacy, the Blind/Low Vision Program now aims to deliver only a limited range of emergent or early literacy supports, namely what it refers to as “pre-Braille” skills, e.g. tactile differentiation, manual dexterity and fine motor skills. It delays until the child enters the school system, comprehensive progress towards acquiring any and all other early and emergent literacy skills including, where appropriate, Braille reading skills.

 

Children with vision loss in Ontario thus can and do start school lagging behind their sighted peers in the area of literacy. In discussions over the past ten months, the Government has not presented any evidence that suggests that all children with vision loss are incapable of acquiring full early and emergent literacy skills until they reach school age. Ontario has generally recognized the benefits of early literacy, and its obvious corollary, the disadvantages of delayed literacy. Beyond this, a delay in acquiring literacy for children with vision loss is especially troubling. This is because the process of learning and becoming fluent in Braille, including the more advanced contracted Braille that Braille readers will use for the rest of their lives, can take a child considerable time.

 

Ontario’s treatment of the early literacy needs of blind and low vision pre-schoolers is markedly and unjustifiably worse than its treatment of pre-schoolers who are deaf or hard of hearing. Deaf and hard of hearing pre-schoolers get early intervention support by teachers of the deaf, through the Ministry of Education’s support, through the pre-school years. No evidence suggests that deaf and hard of hearing pre-schoolers can benefit from comprehensive early literacy support, but blind and low vision children categorically can not.

 

3. THE SOLUTION

 

1. a) Needed Ingredients

 

It would be straightforward to implement a strategy to deliver to Ontario’s pre-schoolers with vision loss a full range of comprehensive early and emergent literacy skills, as they reach the developmental stages that are appropriate for them. Most key resources are in place or are readily available to the Ontario Government to make this happen. Only a few modest but vital steps need to be taken to make these key pieces work together, and to give them needed supplemental support.

 

Comprehensive early and emergent literacy skills should be delivered to children with vision loss at the pre-school stage through a learning process, starting in the earliest months, that is tailored to and appropriate for each child’s developmental stage. This could be delivered in whole or in part through or in conjunction with the Blind/Low Vision Program (BLV) delivered under the Ministry of Children and Youth Services, if the Government wishes to build on it.

 

These early and emergent literacy skills can and should be provided on a planned, coordinated teamwork basis, through a combination of three kinds of providers: teachers of the visually impaired (TVIs), early childhood vision consultants (ECVCs), and the child’s parents and family. Whichever professional is to be involved should have appropriate training and experience both in teaching literacy skills to children with vision loss, and with the distinctive early childhood development process experienced by infants and toddlers with vision loss.

 

The way to do this is straightforward. It has been done in other jurisdictions, and was done by the Ontario Government in a region of Ontario for 18 years up to 2009. An ad hoc initiative that might embody at least some of what is here proposed is now underway with one child at the local level in York Region, under the support of that school board. A local partnership has been arranged between the York Region School Board and the Blind Low vision Program’s ECVC in that region. A York Region School Board TVI provides consultation support and resources to the Blind Low Vision ECVC working with a pre-schooler, in connection with early literacy development, to assist with the transition into Kindergarten.

 

An infant/toddler with vision loss needs to be gradually introduced to the full range of concepts, ideas, experiences and physical skills that underpin literacy, including where appropriate, Braille literacy. Sighted children obtain many of these incidentally, without any active teaching, just by watching the world around them. Others are provided to the sighted child by their parents, by videos and TV programs, and through vision-based activities in pre-schools, day care programs and nursery schools. Many of those mainstream activities are not designed for, or fully and readily accessible to a pre-schooler with vision loss, without carefully-planned accommodations and strategies. Moreover, to acquire literacy skills, sighted children do not need to acquire certain skills (like tactile differentiation and certain kinds of manual dexterity) that a child with vision loss must hone to be able to acquire Braille literacy skills.

 

Once the child with vision loss has acquired these bedrock skills and concepts, and reaches a developmentally appropriate stage, he or she is ready to have hands-on literacy skills introduced, such as learning to read Braille letters. There are a series of mechanical steps that must be followed to introduce these skills.

 

No one-size-fits-all rigid fixed timetable for completing these tasks should be set. Each new stage in acquiring early and emergent literacy skills should be tailored to each child’s developmental progress. As the pre-school child with vision loss progresses through this, they need to be periodically monitored. This is to ensure that they are on the right path, and to decide when they are ready to progress to hands-on Braille instruction. A properly qualified TVI with appropriate knowledge of early childhood development and vision loss is appropriate for this monitoring/assessing role.

 

Parents of pre-schoolers with vision loss cannot be expected to know in advance how to deliver any of these early and emergent literacy skills to their child, and to know when the child is ready for direct instruction in hands-on Braille. This is not something they can be expected to invent on the fly. That is where the teamwork approach involving the parents/family, the ECVC and the TVI plays a critical role.

 

1. b) Existing Resources on Which Ontario Can Easily Build

 

The Ontario Government now has in place a number of key programs and resources that, if brought together and reinforced, can make this an easy and low-cost initiative to institute. Only modest additions are needed.

 

1. Now, Ontario’s Blind/Low Vision Program delivers a range of early intervention services to families and children via ECVCs. It has no TVIs. These ECVC’s could be used as an important part of the team to deliver the full range of early and emergent literacy skills to pre-schoolers with vision loss, and to provide the knowledge and skills to the child’s parents and family to enable them to do the same. The ECVC should not be the one delivering actual hand-on Braille reading skills, as that is something for which a properly-trained TVI is required. However ECVCs can deliver a wide range of skills and knowledge to the pre-school child with vision loss, leading up to that stage.

 

For the Blind Low Vision program’s ECVC’s to be able to deliver as much of this initiative as possible, three modest steps are needed:

 

1. a) It will be necessary to provide the ECVCs and other front-line people in the Blind Low Vision program with additional focused emergent literacy training so they can deliver as much of the full range of comprehensive early and emergent literacy as possible (short of hands-on Braille instruction) . The ECVCs in turn can work with parents and other family members to work effectively with their blind and low vision child on these skills.

 

1. b) Ready-to-use guides, such as instructional videos and appropriate toys and books, need to be developed to be given to parents, family members, child care workers, and the like, depicting activities that can help the child acquire many needed foundations for early and emergent literacy.

 

1. c) The Blind Low vision Program’s ECVC’s and other front line staff need to have access to a TVI to consult on an as-needed basis when working with pre-schoolers with vision loss, and to periodically assess the child’s progress towards full literacy.

 

2. The Ontario Government has within itself a vibrant, insufficiently tapped center of expertise on delivering full literacy skills to children with vision loss, the W. Ross Macdonald School for the Blind, operated by the Ministry of Education. It has added expertise, techniques, tools and experience that the Blind Low Vision program now needs. This expertise comes from the W. Ross Macdonald School’s experience teaching school-age children with vision loss, from teaching teachers to teach children with vision loss, and from having operated a regional pre-school program for children with vision loss for 18 years, up to 2009.

 

The W. Ross Macdonald School could be tapped to provide the key early and emergent literacy components and training that need to be delivered by ECVCs to pre-schoolers with vision loss, and helpful resources to help ECVC’s and parents do this directly with pre-schoolers. As but one compelling but small example, one widely-recommended tool for parents and ECVCs is the “story box.” When a parent reads a book to a pre-schooler with vision loss, they give the child objects to explore that are mentioned in the story. The W. Ross Macdonald School has a number of these. They should be widely shared with the Blind Low Vision program, and with parents of pre-schoolers with vision loss. ECVCs and parents of children with vision loss should not have to reinvent wheels that the W. Ross Macdonald School has already invented.

 

In addition, the W. Ross Macdonald School now provides a service across Ontario for assessing the developmental progress of pre-school children with vision loss, to ready them for transition to school. This existing program can be invoked to periodically monitor the progress of pre-school children with vision loss towards full literacy, under the strategy proposed here. It could, for example, be used to assess when a pre-school child is ready to commence direct hands-on Braille instruction. Because this assessment program is now delivered by TVIs out of the W. Ross Macdonald School, it appears to be perfectly suited for this initiative, without needing any new mandate.

 

Just as W. Ross Macdonald School TVIs are available for ongoing consultation, in connection with an assessment of a child under this existing program, they can continue to do so, to support the work of ECVCs as they deliver early and emergent literacy skills to a pre-schooler in the Blind Low Vision program as recommended in this proposal.

 

1. c) The Key Missing Piece

 

The preceding discussion has shown how much of this new initiative can be delivered by modest training of ECVCs, by developing teaching tools for parents and ECVC’s, and by tapping expertise at the W. Ross Macdonald School. Beyond this, however, another modest addition to this is also needed.

 

If a pre-school child with vision loss reaches the stage, before entering school, of readiness to commence hands-on Braille instruction, they need to have access to a qualified TVI, equipped to work with pre-schoolers, to introduce them to Braille itself. This can include such important things as learning proper hand positioning and finger movement, how to track lines, how to recognize individual Braille letters, etc. If this is improperly taught, it can set a child back, requiring them to later unlearn bad habits and then learn afresh better practices.

 

Now, there is no one made available to provide that training in Ontario to pre-schoolers who are ready for it. The Blind Low Vision program does not provide it. The Ministry of Education limits programs it now operates for pre-schoolers with vision loss to the point in time after they enter kindergarten.

 

This was not always the case. As noted earlier, the W. Ross Macdonald School operated a pre-school program in a radius of one hour driving from the W. Ross Macdonald School that included early literacy programming for 18 years. It was cancelled in 2009. No one has been able to provide a reasoned explanation for the counterproductive step of taking this needed service away from pre-school children with vision loss.

 

To deliver this service would involve minimal cost. There are very few pre-school children with vision loss in Ontario. Of these, there is an even smaller number, who in any year, will be at a stage of readiness for direct TVI instruction in hands-on Braille reading. This would only span a limited period of time for each child. For example, if a child is ready for this direct TVI instruction at age three-and-a-half, but enters junior kindergarten at age four-and-a-half, they would only need this service over one year.

 

Ontario could deploy a small number of itinerant TVIs for this purpose out of the W. Ross Macdonald School Resource Centre and/or explore other cost-effective ways of making the service available where needed in Ontario. VIEWS is emphatic that this should be based out of the W. Ross Macdonald School Resource Centre, to ensure consistency and high quality service.

 

4. Conclusion

 

The Maritime provinces, the state of Massachusetts, and for 18 years up to 2009, Ontario’s W. Ross Macdonald School have demonstrated that effective early and emergent literacy skills can be delivered to pre-schoolers with vision loss. That the Government recognizes the benefits of providing early literacy to pre-schoolers with disabilities is demonstrated by the Ministry of Education’s superior supports for deaf pre-schoolers.

 

It is beyond dispute that delays in delivering literacy skills to a child are harmful. It should also be beyond dispute that blind children entering public school have enough challenges to tackle, without also being behind on literacy.

 

This submission demonstrates that a new strategy for comprehensive early and emergent literacy for pre-schoolers with vision loss can be instituted in Ontario, at minimal cost, and by taking only a few modest steps. Further showing that this is a very low-cost undertaking, substantial vision loss is experienced by a very small number of pre-school children in Ontario.

 

The specifics of any initiative in this area should be developed with input from key stakeholders, including, as one example, Views for the Visually Impaired.

 

In March 2012, the Canadian Vision Teachers from across Canada held an excellent conference in Richmond Hill. The excellent presentations there by various presenters from the W. Ross Macdonald School illustrated that the Ontario Government has within its own organization tremendous expertise that the Ministry of Children and Youth services needs to far better tap, for the benefit of pre-schoolers with vision loss. Now is a good time to break down the silos between ministries which can impede Ontario from effectively meeting the needs of some of its most vulnerable children.

 

cc:        George Zegarac, Deputy Minister of Education george.zegarac@ontario.ca

Alexander Bezzina, Deputy Minister of Children and Youth Services             alexander.bezzina@ontario.ca

Dawn Clelland, President VIEWS clelland@rogers.com

Amal Haddad, President, Toronto Chapter  AEBC amal.haddad@rogers.com

John Rafferty, President CNIB John.Rafferty@cnib.ca

 

 

 Appendix 4 January 31, 2018 Letter to the Ontario Government from the CNIB

 

 

January 31, 2018

 

by email and mail

The Hon. Mitzie Hunter

Minister of Advanced Education &

Skills Development

Government of Ontario

3^rd Floor, Mowat Block

900 Bay Street

Toronto, ON  M7A 1N3

mhunter.mpp.co@liberal.ola.org

 

Dear Minister Hunter,

 

RE:   CNIB support for VIEWS for the Visually Impaired  http://viewson.ca/ brief to the Ministry of Education.

 

The recommendations identified in VIEWS for the Visually Impaired Brief to the Ministry of Education echo the challenges, barriers, and gaps in support and accessibility that CNIB also identified in our recently submitted feedback to the Government of Ontario’s consultation on the proposed Accessibility for Ontarians with Disabilities Act (AODA) Accessibility Standard for Education.

From surveys within our community, CNIB has found that families often feel isolated and increasingly frustrated when trying to navigate the current educational system in Ontario. The VIEWS brief also illustrates this. Parents and students are looking for more concise and informative support that caters to the varying individual needs of each student especially when it comes to assistive technology. Foundation Programs offered by CNIB, such as Beyond the Classroom and Accessible Technology Support, aid families trying to navigate the educational system, but it is concerning that parents are regularly forced to turn to community organizations for support and advice on how to access accessibility supports for their child with a disability.

The Hon. Mitzie Hunter

Minister of Advanced Education &

Skills Development

Page 2

 

CNIB and VIEWS also identified the inability to access textbooks and course materials in an accessible format and a timely manner as one of the greatest barriers to academic success.

 

CNIB supports VIEWS ask that the Ministry of Education update, monitor and modify the standards and qualifications for a teacher to serve as a “Teacher for the Visually Impaired” (TVI) in Ontario. We agree that the current system may not adequately teach educators how to meet the unique needs of students with vision loss especially when it comes to technology.

 

Additionally, CNIB supports VIEWS ask that the Ontario Government guarantees school boards train students with vision loss on current adaptive technology (including Apple iOS devices) to enhance their educational experience, give them the tools to help succeed and create a more inclusive environment.

Only 65% of students with sight loss graduate from high school, compared to 81% of the sighted population (2011 CNIB Needs Study). We believe that with the correct academic and accessibility supports, students who are blind or partially sighted should be able to perform equally with their sighted peers.

 

We look forward to receiving a response from the Government of Ontario on this very important submission.

 

Sincerely,

Len Baker

Regional Vice-President, Ontario and Quebec