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Determining the Accessibility of K12 Digital Materials: Tools for Educators Sean J. Smith, Ph.D. The University of Kansas William M. (Skip) Stahl, M.S. Center for Applied Special Technology, Inc. . The rapid growth in K12 online learning has resulted in the need for developing learning materials that are appropriate forand accessible toall learners, including students with disabilities. Because the development of online learning materials requires an investment of time and resources that are often outside the capabilities of school districts and individual teachers, materials used in the K12 online classroom are typically developed by external, for-profit vendors. . Federal regulations direct state and local educational agencies to follow Universal Design for Learning (UDL) guidelines at crucial levels of planning, implementation, and execution of educational practices. The inclusion of UDL principles in educational practice is intended to create effective, meaningful, and accessible technologies in K12 educationincluding online education. . The Voluntary Product Assessment Tool (VPAT) is used to determine ifand to what degreevarious products, including educational products, meet Section 508 criteria for accessibility. Although widely used by designers and developers of digital products and online learning materials, the VPAT tests primarily for physical accessibility and adherence to accessibility requirements. But as online learning continues to grow and expand, reaching more and more students each day, are these testing measures enough to ensure accessibility for all learners? . Using the UDL framework as a measure, learning materials can be evaluated (beyond VPAT capabilities) for appropriateness and accessibility for all learners. The creation of the UDL Scan Tool allows product developers, school administrators, teachers, and parents to evaluate online learning materials for alignment with the UDL guidelines, thus helping provide accessible materials for all K12 digital learners, including those with disabilities. The State of K12 Online Learning and Digital Materials O ver a relatively short period of time, states and districts have adopted various forms of blended and fully online learning with some estimates suggesting that by 2019 half of all K12 students will be taking online courses (Christensen, Horn, & Staker, 2013). Increases in K12 online learning are taking place in all 50 states. Blended, supplemental, flipped, fully online learning, and the variations of what is increasingly being called personalized learningare changing at an exponential rate and affect all students, including those with identified disabilities. Most school districtssmall and large, urban and ruralhave entered the online learning experience at different rates and levels of commitment (Evergreen Education Group, 2015). Studentsmotivation for taking online courses, especially at the high school level, appears to be related to availability (47% pursue online learning to access courses unavailable through their local school) and learning needs (43% select online courses in order to work at their own pace) (Powell, Patrick, & Roberts, 2015). Likewise, credit recoveryagain, for the high school learneris a primary reason for online The contents of this article were developed under a grant from the U.S. Department of Education #H327U110011. However, those contents do not necessarily represent the policy of the U.S. Department of Education, and you should not assume endorsement by the Federal Government. Project Officer, Celia Rosenquist. Journal of Special Education Leadership 29(2) N September 2016 89
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Page 1: Determining the Accessibility of K 12 Digital Materials ... · Determining the Accessibility of K–12 Digital Materials: Tools for Educators Sean J. Smith, Ph.D. The University of

Determining the Accessibility of K–12 DigitalMaterials: Tools for Educators

Sean J. Smith, Ph.D.The University of Kansas

William M. (Skip) Stahl, M.S.Center for Applied Special Technology, Inc.

. The rapid growth in K–12 online learning has resulted in the need for developing learning materials thatare appropriate for—and accessible to—all learners, including students with disabilities. Because thedevelopment of online learning materials requires an investment of time and resources that are oftenoutside the capabilities of school districts and individual teachers, materials used in the K–12 onlineclassroom are typically developed by external, for-profit vendors.

. Federal regulations direct state and local educational agencies to follow Universal Design for Learning(UDL) guidelines at crucial levels of planning, implementation, and execution of educational practices. Theinclusion of UDL principles in educational practice is intended to create effective, meaningful, andaccessible technologies in K–12 education—including online education.

. The Voluntary Product Assessment Tool (VPAT) is used to determine if—and to what degree—variousproducts, including educational products, meet Section 508 criteria for accessibility. Although widely usedby designers and developers of digital products and online learning materials, the VPAT tests primarily forphysical accessibility and adherence to accessibility requirements. But as online learning continues togrow and expand, reaching more and more students each day, are these testing measures enough toensure accessibility for all learners?

. Using the UDL framework as a measure, learning materials can be evaluated (beyond VPAT capabilities)for appropriateness and accessibility for all learners. The creation of the UDL Scan Tool allows productdevelopers, school administrators, teachers, and parents to evaluate online learning materials foralignment with the UDL guidelines, thus helping provide accessible materials for all K–12 digital learners,including those with disabilities.

The State of K–12 Online Learningand Digital Materials

Over a relatively short period of time, states anddistricts have adopted various forms of blended

and fully online learning with some estimatessuggesting that by 2019 half of all K–12 students willbe taking online courses (Christensen, Horn, & Staker,2013). Increases in K–12 online learning are takingplace in all 50 states. Blended, supplemental, flipped,fully online learning, and the variations of what isincreasingly being called “personalized learning” arechanging at an exponential rate and affect all students,

including those with identified disabilities. Mostschool districts—small and large, urban and rural—have entered the online learning experience atdifferent rates and levels of commitment (EvergreenEducation Group, 2015).

Students’ motivation for taking online courses,especially at the high school level, appears to berelated to availability (47% pursue online learning toaccess courses unavailable through their local school)and learning needs (43% select online courses in orderto work at their own pace) (Powell, Patrick, & Roberts,2015). Likewise, credit recovery—again, for the highschool learner—is a primary reason for online

The contents of this article were developed under a grant from the U.S. Department of Education #H327U110011. However, those contents do notnecessarily represent the policy of the U.S. Department of Education, and you should not assume endorsement by the Federal Government. Project Officer,Celia Rosenquist.

Journal of Special Education Leadership 29(2) N September 2016 89

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enrollments. Although online coursework remains ahigh school option, charter schools, which represent asignificant portion of the fully online K–12 learningexperience, report that more than 60% of their full-time student enrollment is at the K–8 level with theremaining 40% in grades 9–12 (Center for Research onEducational Outcomes, 2015). Annually, statewidevirtual school enrollments continue to grow—asreported in Keeping Pace With K-12 Digital Learning(2015), The Evergreen Education Group's most recentpublication—with states, including North Carolina,Florida, and Michigan, offering a variety of onlineoptions, including online coursework that is tied tohigh school graduation requirements.

Blended Learning 101Online learning takes a variety of forms, such asblended or fully online learning. Blended learning isdefined as a K–12 experience with which students learnin part through online content and they control portionsof the pace, time, and path of the instruction; part is alsosupervised in a brick-and-mortar location away fromhome. Full-time online learning is virtual or onlinelearning that takes place entirely online away from abrick-and-mortar school and typically within the homeenvironment. Online learning may also be used assupplemental learningwithwhich students are enrolledin an online class that is not offered as a face-to-faceoption in their local school (Horn, Staker, &Christensen,2014). Online learning may also be referred to as digitallearning or, increasingly, as personalized learning,which is an approach that seeks to customize content,activities, pace, tools, and supports for each learner’sneeds (Basham, Stahl, Ortiz, Rice, & Smith, 2015).Although the field of K–12 online learning is relativelynew, its practices are in wide use, and the relatedvocabulary continues to increase to further clarifyelements of the overall online learning experience.

Blended learning is defined as a K–12 experience

with which students learn in part through online

content and they control portions of the pace, time,

and path of the instruction; part is also supervised in

a brick-and-mortar location away from home.

With the rapid growth in online learning at theK–12 level, districts and classroom teachers face a

dilemma in providing online learning experiences thatare suitable for all students (Watson, Gemin, & Coffey,2010). Identifying the digital materials to be used anddesigning them for an effective online learningexperience requires extensive resources. For example,consider a classroom teacher interested in teaching ablended class for which a portion of the assignments isavailable online, including readings, interactiveactivities, and formative assessments. All of thesematerials take time and expertise to develop in amanner that is effective for good instruction and alsoconsiders the amount of information that a teacherwould need to address in a traditional face-to-faceexperience. The limitations are in the time, expertise,knowledge of instructional design, basic capacity tocreate virtual materials that work within a content orlearning management system, and a host of othervariables that often prevent classroom educators(as well as school district leadership) from developingmaterials for effective online learning. Due to theseconstraints and the rapid growth in online learning,instead of the teacher or district personnel developingdigital materials, publishers and outside vendors havestepped in to fill the void. Estimates are that 85–90% ofall K–12 online learning content and related digitalmaterials are developed by outside vendors (Powell,A., Patrick, S., & Roberts, V., 2015).

Development of Digital Materials forthe K–12 ClassroomMany of these vendors include traditional bookpublishers (e.g., Pearson Learning) that havehistorically provided districts with content andlearning materials. In addition, a number ofcompanies have been created to focus entirely on thedevelopment of the lessons, activities, assessments,and other learning resources to be used as part of adigital or online learning experience (Smith, 2016).For educators, these resources fill a void, allowingthem to concentrate on their students and classroominstruction. The digital materials or the prepackagedonline lessons that are created by these outside entitiesoffer the foundation from which blended or fullyonline learning takes place for the student.

Estimates are that 85–90% of all K–12 online

learning content and related digital materials are

developed by outside vendors (Powell et al., 2015)

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Consider the experience of a sixth-grade Englishlanguage arts classroom teacher attempting toincorporate blended learning into the face-to-faceclassroom. To develop this content on her own, shewould need to consider the state standards and thefocus of the content she traditionally teaches andidentify digital materials that align with theinstructional needs of her students and a host of othervariables. Instead, her district identifies an Englishlanguage arts digital learning package that provideslessons and accompanying activities for the sixth-gradeclassroom aligned with the required state standards.The teacher then assigns the online lesson. Here, eachstudent works independently or in small groups withthe assigned material, which has been sequentiallyorganized into a series of required steps. Often thelessons will embed various resources and activities andend with some sort of assessment to ensure the studenthas gained knowledge as part of the activity. The roleof the teacher is to facilitate the learning process and toengage the students at different levels while thestudent is focused on the digital materials contained inthe prepackaged online lesson. The teacher (or districtlevel curriculum specialist) selects the relevant digitalmaterial, but once assigned, the prepackaged onlinelesson provides and directs the primary structure forthe learning experience.

The decision on the part of K–12 educators anddistrict leaders to utilize prepackaged digital materialsis often made out of necessity. Schools simply lack theresources to invest in creating learning experiencestailored to individual learners. Instead, schoolspurchase online learning materials that are developedby an external educational product vendor. Studentsinteract with these prepackaged materials at everylevel of their blended or fully online experience, fromcontent to instruction to assessment. Teachers workwithin the content management system (e.g., digitalmaterials) assigning lessons and activities andreviewing completed assessments to determine thenext lesson. Figure 1 offers an overview of a sample ofblended and fully online vendors.

At the district or the department level, the decisionto engage with a specific online company or series ofprepackaged digital material is critical, particularly forstudents with disabilities (Basham et al., 2015).Because of how digital materials are developed andthen used by individual teachers—as well as acrossbuildings—educational leaders making decisionsabout the digital material should be well informed

about the products they are selecting. An incorrect butwidely held assumption is that online material alignedwith state standards and content norms will beappropriate for all students at the specific grade level.Additional assumptions are that digital materials aremore accessible and that the accommodations andmodifications often required for struggling learnersand those with disabilities are automaticallyembedded in online lessons. Research indicates thatthese assumptions are unfounded (Hashey & Stahl,2014; Smith, 2016). For the educational leadersworking to ensure appropriate access for all learners,including those struggling learners and particularlythose with identified disabilities, it is critical to haveaccess to tools to determine whether or not theprepackaged materials are appropriate for the needs ofall learners.

This article explores the manner in which teachersand district leaders can further determine whether ornot the digital materials they are considering areaccessible for all learners—particularly those withdisabilities—and appropriate to the accommodationsand modifications provided in the brick-and-mortarschool environment. The article introduces the issuesof how to consider accessibility, discusses tools thathave been created to assist in the evaluation ofaccessible digital materials, and reviews ways inwhich district leaders and individual classroomteachers can further determine whether digitalmaterials used for blended and fully online learningexperiences are appropriate for the learning demandsof students, particularly those with disabilities.

Reaching Students Is aPrerequisite to Teaching StudentsFederal ExpectationsThe recent Congressional authorization of the EveryStudent Succeeds Act (ESSA, 2015; PL 114-95)explicitly guides state and local education agenciesto incorporate inclusive and accessible designprinciples into educational practices. ESSA directsthese agencies to follow the Universal Design forLearning (UDL) principles in state plans whenselecting and implementing assessments,accountability, literacy instruction, and state use offunds (ESSA Secs. 1005; 1204; 2221(b)(1); 4104). ESSAreferences the definition of UDL in the HigherEducation Opportunity Act of 2008 (HEOA;

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PL 110-315): Universal Design for Learning (UDL)means a scientifically valid framework for guidingeducational practice that

. provides flexibility in the ways information ispresented, in the ways students respond ordemonstrate knowledge and skills, and in the waysstudents are engaged

. reduces barriers in instruction, providesappropriate accommodations, supports, andchallenges, and maintains high achievementexpectations for all students, including studentswith disabilities and students who are limitedEnglish proficient

In a similar commitment, the National EducationTechnology Plan (NETP) emphasizes the importanceof UDL as a means of personalizing learning and as aframework for designing and deploying educationaltechnologies in effective, meaningful ways:

Education stakeholders should develop a born acces-sible standard of learning resource design to helpeducators select and evaluate learning resources foraccessibility and equity of learning experience.…Using the principles and research-base of UD andUDL, this standard would serve as a commonlyaccepted framework and language around designfor accessibility and offer guidance to vendors andthird-party technology developers in interactions

Figure 1. Sample of blended and fully online vendors.

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with states, districts, and institutions of higher educa-tion (U. S. Department of Education, Office of Educa-tional Technology, 2016, NETP, p. 22).

NETP 2016 reemphasizes a commitment to ensuringthe accessibility of instructional materials and practicesthat was previously articulated in NETP 2010:

… the Department is committed to taking a leadershiprole in ensuring that the benefits of educational tech-nology are accessible to all learners “regardless ofbackground, languages, or disabilities.” To meet thatgoal, theDepartmentwill not only exercise its authorityunder sections 508 and 504 of the Rehabilitation Act of1973 as necessary to achieve compliance, but also willwork with and encourage the broader educationalcommunity to ensure that individuals with disabilitiesare not denied the benefits of educational technologydue to accessibility issues (ED: NETP 2010, p. 7).

Accessibility Expectations in K–12EducationIn June 2010, the Office of Civil Rights (OCR) of theU.S. Department of Education and the Department ofJustice published a joint “Dear Colleague” letter tocollege and university presidents, focusing on the useof electronic book readers and other emergingtechnologies that may be inaccessible to students whoare blind or have low vision (U. S. Department ofEducation, Office of Civil Rights, 2010). This letteridentified that instituting the use of a particulartechnology for instruction—if the technology isinaccessible to students with disabilities—constituteddiscrimination, which is prohibited by the Americanswith Disabilities Act (ADA) and Section 504 of theRehabilitation Act. In May 2011, a letter was issued bythe Office of Civil Rights, further noting that these civilrights requirements apply not just to postsecondaryschools, but also to elementary and secondary schools(U.S. Department of Education OCR, 2011). The 2011publication noted that the principles articulated in the2010 letter related to all instructional technologies (notjust eBook readers) and that the protected class ofstudents was not limited to those who are blind or lowvision, but also to students with other disabilities (e.g.,dyslexia) that affect their ability to access materials in atraditional manner. These ADA and Section 504requirements apply to all aspects of a school, and allfaculty and staff must comply with them.

Although the legal mandates regarding accessiblelearning materials establish the foundation for what

needs to occur, implementation of these mandatesrequires guidelines that are appropriate for bothcurriculum developers and the state and localeducation agencies seeking to acquire accessiblematerial and delivery systems. For digital materialsand associated technologies, Section 508 of theRehabilitation Act of 1973 was established.

Identifying Accessible ProductsEnacted in 1998 as an amendment to the RehabilitationAct of 1973, Section 508 is a mandate for the federalgovernment and its agencies to assure thatinformation and computer technology is accessible(United States Access Board, 2000). It is also a series offunctional specifications for meeting that mandate. In2015, the United States Access Board began theprocess of finalizing an update to Section 508 (36 CFRParts 1193 and 1194) to align its requirements withother related statutes and to the accessibility standardsof the World Wide Web Consortium, aninternational body.

The Section 508 access standards cover software,

operating systems, web and Internet,

telecommunications, video and multimedia, self-

contained products, and desktop and portable

computers and have become a baseline for the

nation’s de facto accessibility specifications.

Although Section 508 applies only to federalagencies as a procurement requirement, specifics ofthe law have been adopted by states, productdevelopers, and educational entities because itrepresents a widely accepted set of accessibilitystandards. The Section 508 access standards coversoftware, operating systems, web and Internet,telecommunications, video and multimedia, self-contained products, and desktop and portablecomputers and have become a baseline for the nation’sde facto accessibility specifications:

. Their development was crafted by a broad group ofstakeholders and overseen by the independentUnited States Access Board.

. The Section 508 standards were adopted by theUnited States Department of Justice forenforcement.

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. Vendors who sell to federal agencies also offerproducts to the nonfederal marketplace; meetingthe Section 508 compliance standards supports bothmarket sectors.

Functional Performance CriteriaThe Functional Performance Criteria definitions fromSection 508 detail the intent of the technicalspecifications by including a set of functional criteria—how components should act for whom—designed toensure that individualswith sensory, physical, andotherdisabilities are providedwith appropriate, effective, andequitable product use (Section 508 §1194.31). Becausethis information is descriptive and unambiguous, itoffers nontechnical explanations that can be helpful fordefining the intent of the specifications:

. At least one mode of operation and informationretrieval that does not require user vision shall beprovided, or support for assistive technology usedby people who are blind or visually impaired shallbe provided.

. At least one mode of operation and informationretrieval that does not require visual acuity greaterthan 20/70 shall be provided in audio and enlargedprint output working together or independently, orsupport for assistive technology used by peoplewho are visually impaired shall be provided.

. At least one mode of operation and informationretrieval that does not require user hearing shall beprovided, or support for assistive technology usedby people who are deaf or hard of hearing shall beprovided.

. Where audio information is important for the use ofa product, at least one mode of operation andinformation retrieval shall be provided in anenhanced auditory fashion, or support for assistivehearing devices shall be provided.

. At least one mode of operation and informationretrieval that does not require user speech shall beprovided, or support for assistive technology usedby people with disabilities shall be provided.

. At least one mode of operation and informationretrieval that does not require fine motor control orsimultaneous actions and that is operable withlimited reach and strength shall be provided(United States Access Board, 2000).

The U.S. General Services Administration hascreated a DigitalGov website (http://www.digitalgov.gov) to provide federal government agencies with adetailed orientation to and instruction in identifyingand procuring accessible digital products (http://www.digitalgov.gov/2015/06/05/using-section-508-guidance-to-improve-the-accessibility-of-government-services/#Criteria).

DigitalGov’s Section 508 Checklist for FunctionalPerformance Criteria (see Figure 2) provides somecheckpoints for reviewing a product’s accessibility detail.

The Voluntary ProductAccessibility Template (VPAT)The Center on Online Learning and Students withDisabilities (Center) finds that the Section 508functional accessibility standards provide an

Figure 2. DigitalGov’s Section 508 Checklist for Functional Performance Criteria. DigitalGov.gov: http://www.digitalgov.gov/2015/06/05/using-section-508-guidance-to-improve-the-accessibility-of-government-services/#Criteria

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appropriate and widely adopted descriptive baselinefor detailing the accessibility of digital media anddelivery systems available for deployment in K–12schools. In addition, given the publicly available detailassociated with the performance criteria, productdevelopers and consumers can use the VoluntaryProduct Accessibility Template (VPAT) mechanism foridentifying the degree to which a product meets theSection 508 accessibility criteria. Although the creationof a VPAT by a product designer or developer is avoluntary procedure, every contributor to a VPAT’sdevelopment has a strong vested interest in itsaccuracy.

Voluntary Product Accessibility Template(VPAT) DetailThe Information Technology Industry Councilprovides a VPAT template (Figure 3) that containsinformation about a product’s alignment with theFunctional Performance Criteria as well as detailsabout its interaction with or dependency on aparticular operating system, the Internet, or specificdevice requirements.

An accurate VPAT provides a detailed descriptionof product specifications, including the ways in whichthe Section 508 Functional Performance Criteria areaddressed. Although VPAT detail—and, in somecases, accuracy—may vary from vendor to vendor, thefact that the VPAT is designed to reference astandardized set of functional specifications allows apurchaser to determine whether or not the productwill meet the needs of students with disabilities. Byproviding a complete and accurate VPAT forinstructional materials and delivery systems used in

digital learning, a product developer can significantlyaid the informed decision making of their state or localeducation agency clients.

An accurate VPAT provides a detailed description of

product specifications, including the ways in which

the Section 508 Functional Performance Criteria are

addressed.

Designers and developers seeking to documenttheir product’s conformance want the information tobe as accurate as possible, and because accessibilitymay be a contractual requirement, consumers (statesand local education agencies, in particular) need theinformation to be sufficiently detailed to documentdue diligence in the procurement process. Studentswith disabilities (and their families) can use VPAT toidentify the extent to which a product may (or maynot) be appropriate for their use. These cross-stakeholder needs work as a series of checks andbalances to ensure that VPAT documentation is asaccurate as possible.

A Representative Sampling of VPATsFigure 4 represents a limited sampling of digitallearning technologies presently marketed or availableto elementary and secondary schools (the originaltable was created in 2012 and updated in 2015). Theproducts listed are in widespread use in the nation’sschools. The intent of this listing is to identify whichproducts offer readily discoverable and publiclyavailable accessibility information, with an emphasis

Figure 3. VPAT template. https://www.itic.org/policy/accessibility/ https://www.itic.org/dotAsset/5644ecd2-5024-417f-bc23-a52650f47ef8.doc

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on Section 508, and whether or not a public VPAT ismade available for review.

The products are categorized as either A, B, or Caccording to the following rubric:

A 5 VPAT availableB 5 Accessibility/Section 508 referencedC 5 No accessibility information available

This information may be useful to both thoseproducing and distributing digital learning productsand materials and those purchasing or otherwiseacquiring them. Every effort has been made to ensurethat accuracy of the information presented, and theCenter will update information regarding any of thelisted products should inaccuracies be identified.

States and districts looking to acquire products orassess the accessibility of digital learning content orthe systems that deliver them can use the VPAT tableas a launch point for examining accessibility. Productsthat offer a detailed VPAT provide the most specificinformation, and those without a VPAT (but withpublicly available accessibility information) tend to bemore general. The table is sortable by product, VPAT,product category, and other indicators, and canprovide information as a starting point for productconsideration.

Beyond AccessibilityRequirementsAlthough accessibility is critical, the Section 508guidelines and measures that are meant to determinethe accessibility of digital materials can possibly belimiting due to what accessibility is meant to measure.That is, federal mandates and most internationalaccessibility standards concentrate on physical andsensory disabilities in their efforts to determinewhether or not a digital resource is accessible for

individuals with disabilities. As indicated, tools suchas the VPAT are essential to ensure that additionalmaterials will be able to reach students, particularlythose with disabilities.

However, if the function of the accessibilitystandard is to provide an understanding of whether ornot digital materials are accessible from both aphysical and sensory perspective, the limitation in aVPAT review particularly affects the individuals withdisabilities who do not have physical or sensory needsbut instead are challenged due to learning andcognitive limitations. In these cases, tools such as theVPAT are of limited value in determining whether ornot virtual materials and online lessons areappropriate to the instructional needs of individualswith these disabilities as well as their struggling peers.Although it is important to determine whethermaterials are physically accessible to students, it isequally important to clarify whether or not those samematerials are appropriate for the learning needs of allstudents.

Universal Design for Learning andFederal and State LegislationConsidering the limitations of the accessibilitymeasures that focus on physical and sensorydisabilities, the Center engaged in the development ofadditional measures to determine the appropriatenessof digital materials and online resources usedpredominately in K–12 blended and fully onlinelearning experiences. The Center, funded by theUnited States Department of Education, focuses on theappropriateness of K–12 blended and fully onlinelearning for students with disabilities to betterunderstand and identify strengths and potentialchallenges affiliated with the K–12 online learningenterprise. Looking to established frameworks as well

Figure 4. VPAT example. http://centerononlinelearning.org/resources/vpat/

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as guidance from federal standards and regulations,the Center determined that UDL and itsaccompanying principles would be an effectiveframework for evaluating digital learning materialsfor students with varied learning needs.

With the passage of ESSA, federal education lawgoverning K–12 education includes a definition andendorsement of the UDL framework (ESSA utilizes theestablished definition of UDL found in the HigherEducation Opportunity Act of 2008). ESSA expands onthe essential requirements of the 2008 legislation byreferencing state plans and requirements states need tofollow when implementing “high-quality studentacademic assessments in mathematics, reading orlanguage arts, and science.” These assessments shall“be developed, to the extent practicable, using theprinciples of universal design for learning.” Inaddition, “for students with the most significantcognitive disabilities,” states may provide for alternateassessments aligned to standards. They shoulddescribe in their plan “the steps the State has taken toincorporate universal design for learning, to the extentfeasible, in alternate assessments…” (ESSA, 2015,p. 28).

ESSA further requires state education agencies toestablish innovative assessment systems thatdemonstrate that they will “be accessible to allstudents, such as by incorporating the principles ofuniversal design for learning …” (ESSA, 2015, p. 28).States are also directed to utilize funds in support oflocal education agencies to provide programs thatincrease access to personalized learning experiencesthrough the use of technology, consistent with theprinciples of UDL. Furthermore, ESSA states that theuse of UDL is to further support the learning needs ofall students, including those with disabilities and theirEnglish language learner peers. This last point iscritical in that UDL is not stated as a framework forthose with disabilities or those participating on thealternate assessment but, instead, all learners—including those with specific learning challenges.

As of 2016 Louisiana, Michigan, Kentucky,Maryland, and Maine had established statewideinitiatives involving UDL and universal designactivities. Maryland established a UDL task force thatdeveloped and supported the successful passage of aUDL bill and the State Board of Education adopted thetask force’s primer on UDL for all learners. Michiganestablished a statewide project focused on sharing

resources and expanding professional learning onUDL and its impact on student outcomes.

Universal Design for Learning as aMeasurement FrameworkThe UDL framework provides a structure for teachingand learning that includes proactive planning ofinstructional goals, assessments, materials, andmethods to enhance the potential success for alllearners. UDL assumes that one size does not fit alland, instead, emphasizes proactive planning that takesinto consideration the variability of all learners. Thegoal then of UDL is to build purposeful andmotivated, resourceful and knowledgeable, andstrategic and goal-directed learners (Center forApplied Special Technology [CAST], 2015). To thisend, the UDL framework realizes that there is nosingle pathway for effective learning that works foreach and every child and, instead, works to helpeducators and students make choices about what is tobe learned and how the individual can make decisionsabout their own learning. Central to UDLimplementation is the design of flexible curriculumand learning experiences that are consistent acrossconditions and yet varied to allow for the individualneeds of the learner.

UDL assumes that one size does not fit all and,

instead, emphasizes proactive planning that takes

into consideration the variability of all learners.

The components of UDL curriculum that comprisegoals, methods, materials, and assessments are thecornerstone of UDL. UDL curricula is not limited tostudents mastering a specific body of knowledge but,instead, designed to assist the learner in masteringlearning itself or becoming what is commonly referredto as an expert learner (Gronneberg & Johnston, 2015).Thus, if we look to use the framework and theessential UDL curricula as a way to measure learning,understanding the four essential elements is necessary:

. Goals focus on the learning expectations. Theyinclude the curriculum standards that often drivegrade- and content-level instruction but arepredicated on the fact that learners learn differently,and due to this variability, goals should bedifferentiated. This then allows the teacher to offer

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more options and alternatives utilizing variedpathways, tools, strategies, and scaffolds to reachthe expected outcomes.

. Methods are the instructional decisions, approaches,procedures, or routines teachers utilize to facilitateinstruction and enhance learner outcomes.Increasingly, evidence-based interventions are atthe forefront of the methods teachers are asked toutilize, and UDL curricula seek to extend theseapplications, allowing for flexibility to addresslearner variability and what the task requires.Simply put, UDL methods adjust instruction basedon continual monitoring of learner progress.

. Materials are often seen as the “what” of instruction.For the UDL framework, materials considerconceptual knowledge by offering multiple andembedded media to provide backgroundknowledge and just-in-time supports. For strategiclearning and expressions of knowledge, UDLmaterials offer tools and supports needed to access,analyze, organize, synthesize, and demonstrateunderstanding. For student engagement, multiplepathways are offered to provide choices and varythe level of supports offered to sustain interest andfurther engage the learner.

. Assessment seeks to determine the student’sperformance. Within the UDL framework, the goalis to ensure that what is being measured actuallyprovides an accurate measurement of the student’sknowledge, skills, and level of engagement. This isachieved through designed-for-learner variability,providing scaffolds and embedding supports toremove irrelevant items and maximize theassessments that truly determine a learner’s ability.

CAST (http://www.cast.org/) and the UDLCenter (http://www.udlcenter.org/) have developedan extensive set of resources to inform educators (andthe broader community) about what UDL is (http://www.udlcenter.org/aboutudl/whatisudl), theessentials and purpose of UDL curriculum (http://www.udlcenter.org/aboutudl/udlcurriculum), andways to further develop expert learners through theUDL framework (http://www.udlcenter.org/aboutudl/expertlearners). These materials areavailable free of charge.

The UDL Scan ToolEmploying the UDL framework, the Center (seehttp://centerononlinelearning.org/resources/udl-

scan-tool/) developed an instrument that sought tomeasure digital materials, including online lessonsand related resources. Seeking to extend measures ofaccessibility, the UDL Scan Tool uses the essentialUDL framework as a way to measure the availabilityand the appropriateness of digital materials foronline learning. The tool includes a series of itemsthat align with one of UDL’s three principles, nineguidelines, and at least one checkpoint. When used,the tool provides a detailed description of how thedigital lessons/activities/materials are alignedto UDL.

The tool contains 37 initial questions that areanswered by a response of “Yes,” “No,” “Don’tKnow,” and “Not Applicable.” Beyond the 37 items,the tool employs skip logic whereby if the informationbeing sought in the particular question is not foundwithin the online product, the reviewer selects theappropriate response (e.g., no), and then the tool skipsto the next series of questions. If, however, the digitalmaterial offers an embedded scaffold, then another set ofquestions, meant to go deeper into the guidelines andcheckpoints of a particular principle, appears to bescored. The flexibility of the tool requires a minimumof 37 initial questions to be completed with as many as146 questions possible based on how questions areanswered.

As the UDL Scan Tool was constructed, Centerstaff engaged experts in the field to determine thevalidity of the instrument. Reliability wasdetermined through an extensive review of lessonsacross six primary developers of online materials inthe K–12 market. To assess, three researchersevaluated six blended and online K–12 contentmanagement systems. After identifying a series oflessons for each of the six online products, a total of1,000 different learning objects (e.g., activities,assessments, materials) across 90 lessons werereviewed.

To extend the utility of the UDL ScanTool, the Center conducted a series of studiesacross an additional six vendors of blended andonline learning materials. For each online developer,digital lessons were randomly selected to include arepresentative sample of all content areas and gradelevels. Researchers then examined each lesson usingthe UDL Scan Tool. Figure 5 offers an illustration of thedata collected on one of the vendors, specific to theprinciple multiple means of representation. Thefindings indicated a significant difference between

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what was possible (in regard to UDL alignment) andwhat was actually occurring in digital learningmaterials.

Findings are categorized across the three primaryprinciples, but, as Figure 5 illustrates, data also drillsdown to the three accompanying guidelines (nineacross the three principles). For the classroomteacher, building instructional leader, and districtcurriculum decision maker, this informationmay be useful in determining the accessibility of the

district’s digital materials for all learners.Developers and educators looking for measures toinform future development and thus designingfor learning variability can use the UDL ScanTool as part of their iterative design process. Foradditional information about the UDL Scan Tool,including the tool, instructional videos, anddata templates for analysis, or the Invited In report,which includes an analysis of six popularonline learning vendors, see the Center’s website athttp://centerononlinelearning.org/.

The Importance of Due DiligenceThe identification and selection of accessible learningmaterials, especially digital materials, presents anongoing challenge. Despite the presence of clearexpectations and guidance in the form of federalmandates, national and international accessibilitystandards, and multiple civil rights investigations,accessibility awareness is not widespread at the pointof product review and procurement. Systematicapproaches—even voluntary ones such as the VPATevaluation process—can help inform digitalcurriculum developers and the state and localeducation agencies that are their customers.Furthermore, measurements such as the UDL ScanTool can improve user awareness of what criticalelements need to be in place during the initial designprocess, thereby further facilitating the developmentof digital materials for the online learning experience.Awareness builds understanding, and understandingbuilds expertise. Unless students with disabilities areable to access and interact with curriculum materials,it makes little difference whether or not the materialshave been proven to be academically effective.Without reaching the students, there is no way to teachthem. District and building leaders and accompanyingeducators need to examine blended and fully onlinedigital materials determining their appropriateness forall learners and make these decisions beyond what isprovided by the vendor who developed and is seekingto sell the prepackaged digital materials to thedistrict/school, and thus, to the student and theirspecific learning needs. Fortunately, tools suchas the VPAT and the UDL Scan Tool offer educationalleaders options when increasingly faced withdecisions on blended and fully online learningconsiderations.

Figure 5. Online learning content alignment to multiple means ofrepresentation.

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About the AuthorsSean J. Smith, Ph.D., is a Professor of Special Educationand Researcher for the Center for Research on Learningat the University of Kansas, 1122 West Campus Road,Lawrence, KS 66047. Email: [email protected]

William (Skip) Stahl, M.S., Center for Applied SpecialTechnology, Inc., 40 Foundry Street, Wakefield, MA01880. Email: [email protected]

Mr. Stahl is Senior Policy Analyst, is CAST’s ProjectDirector of the Center on Online Learning andStudents with Disabilities, and Co-Director of theNational Center on Accessible Educational Materialsfor Learning (AEM Center) at CAST. Mr. Stahl hasextensive experience in the development of technicalstandards, policies, and implementation practicesrelated to accessible instructional materials and akeen interest in the role of data in assessing theimpact of digital learning and student withdisabilities.

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