What are the public policy issues involved in making math accessible?

Learning Points: Section 504 and the ADA guarantee the rights of students with disabilities to participate in all class offerings of an educational institution in an equal, effective and inclusive manner.  Educational institutions have a responsibility to ensure that students with disabilities have accessible math content on par with the level of access that students without disabilities receive. Section 508 of the Rehabilitation Act mandates that individuals with disabilities must "have access to and use of information and data that is comparable to the access to and use of the information and data by such members of the public who are not individuals with disabilities." Universally designed math content will guarantee that the same math can be accessed by both students with and without disabilities at the same time without having to do additional work, which fits the framework of comparable access under Section 508. No Child Left Behind places a significant responsibility on schools to close the achievement gap between students with and without disabilities. Although the current math achievement gap is large, universally designed math resources will aid schools in closing the achievement gap between students with and without disabilities. The IDEA statute cites the need to apply universal design principles to student instruction and assessment, and mandates that States adopt the National Instructional Materials Accessibility Standard (NIMAS) as a required file specification. State and Local Education Agencies will want to ensure that publisher provided files of math textbooks are authored using the MathML based modular extension to ensure accessible math content for all students. Both NCLB and IDEA contain mandates for accessible assessment that can be used by all students. Creating universally designed math assessments using MathML will help schools meet the mandates of both NCLB and IDEA.

All discussions of accessibility ultimately revolve around public policy, whether the focus is on education, employment, or public access to services and information. Math accessibility is likewise a topic that policy makers need to address. Education policy needs to be developed which provides for full support of accessible math instruction and assessment. This includes such policies as requirements for math accessibility in textbook adoption and software selection policy, as well as similar mandates that require all math instructional content and math assessments be created in formats that are accessible to students with disabilities. Below are some of the legal mandates that can be applied to the need to make math accessible.

Section 504 and the ADA

Section 504 of the Rehabilitation Act prohibits educational institutions (or other entities that receive federal funds) from discrimination on the basis of disability. The Federal regulations enforcing this statute further indicate that recipient organizations cannot deny individuals with disabilities the "opportunity to participate in or benefit from" any aid, benefit, or service. Very similar language is provided which likewise affords protection against discrimination by any State or local government entity under the Americans with Disabilities Act (ADA), regardless of any connection to Federal funds. Both of these statutes guarantee the rights of students with disabilities to participate in all class offerings of an educational institution as a fundamental tenet of law.

Federal regulations also indicate the extent to which participation by students with disabilities is to be provided under law. In particular, Section 504 regulation 34 C.F.R.104.4 states that an educational institution cannot provide students with disabilities an opportunity to participate in any aid, benefit, or service that is: (a) not equal to that afforded to others; (b) not as effective as that provided to others, or; (c) different or separate than those provided to others, unless such a treatment is necessary to provide one that is effective.

Institutional responsibility to ensure accessible math content

To extend these concepts to math accessibility, it follows that all instructional content and assessments that include math must be made accessible to students with disabilities in such a way as to provide an equal, effective, and inclusive opportunity for participation by all students. Educational institutions, therefore have a clear responsibility to ensure that students with disabilities have accessible math content on par with the level of access that students without disabilities receive. Such a level of equal, effective, and inclusive math accessibility can be provided by requiring that all mainstream math instructional content and math assessments be universally designed to be equally useable by students with and without disabilities. Such a goal can be accomplished by ensuring math content is authored in MathML and that assistive technology vendors adequately support the MathML standard.

Section 508

One of the fundamental principles of information accessibility is expressed in the language of Section 508 of the Rehabilitation Act: that individuals with disabilities must "have access to and use of information and data that is comparable to the access to and use of the information and data by such members of the public who are not individuals with disabilities." The concept of "comparable access" in Section 508 is an extension of the Section 504 requirement that individuals with disabilities be provided a level of access which is equal, effective, and inclusive. When applied to information in electronic formats, this has been understood to mean that individuals with disabilities who use assistive technologies such as screen enlargement, synthetic speech, or speech dictation will be able to effectively utilize and benefit from these electronic formats on par with the way that people without disabilities use standard computer displays, keyboards and mice.

The framework of comparable access to math

Therefore, math accessibility policy should also be understood within the framework of comparable access. Although basic mathematical information can be expressed using the alphanumeric characters found on the common computer keyboard, one does not have to go very far in complexity of math to run into problems. The common usage of elements such as superscripts and square root symbols, for instance, will typically be inaccessible to a blind person using synthetic speech unless this information is properly imbedded in the digital content to provide for accessibility.

This circumstance occurs because math equations which are found in electronic information such as in computer software or on a web page are typically created using graphical image files, or digital pictures, of math equations. Images such as this can only be viewed and interpreted with human eyes, so that people who depend upon computer technology to synthetically read out loud the information on the screen will be unable to access these mathematical expressions. Thus, in this case, students who are blind or have some other form of print disability, like dyslexia, dyscalculia or other types of learning disabilities that require computer-based reading accommodations will have absolutely no access to this information.

Although the commonly used stop gap technique of providing a "text equivalent" for images does provide a person with a disability some information that can be accessed with assistive technology, in the case of math it is clearly inferior to the level of access that the non-disabled person would have through standard means, and therefore falls short of the legislative intent of Section 508. The usage of standard encoding like MathML, on the other hand, will allow for the creation of universally designed math content, which will guarantee that the same math materials can be accessed by both students with and without disabilities at the same time without having to do additional work. This is because MathML provides sufficient information about the structure and content of math equations so that the student-ready digital versions will be just as effective for the student with a disability using assistive technology as it is for the student without a disability who simply reads the math by traditional visual access. Such capability clearly fits the framework of comparable access.

No Child Left Behind

No Child Left Behind was passed by Congress in 2001 as a reauthorization of the Elementary and Secondary Education Act of 1965. The purpose of NCLB is stated as, "To close the achievement gap with accountability, flexibility, and choice, so that no child is left behind." The statute places a significant responsibility on schools to close the achievement gap between various groups of students, including the achievement gap between students with and without disabilities.

Unfortunately, the math achievement gap between students with and without disabilities has been shown to be quite large among America's school children. Although the underlying reasons for this disparity may be complex, one of the essential contributing factors revolves around accessibility. Virtually all math instructional content and assessments used in educational settings are not designed to be accessible with the assistive technology many students with disabilities use. Therefore the instructional value of math materials commonly used today are being compromised for many students with disabilities.

One of the major benefits of accessible math content that is digitally created and universally designed (such as math created using MathML), is that these materials can be used by all students--both those with and without disabilities--allowing everyone to benefit from the enhanced instructional value that is available. Both students who use assistive technologies, and those who do not, will be able to equally use these materials with similar effectiveness. Such universally designed math resources will go a long way toward helping schools close the achievement gap between students with and without disabilities.

IDEA and NIMAS

In 2004, Congress reauthorized the Individuals with Disabilities Education Act (IDEA) and included provisions meant to increase the availability of accessible materials. The IDEA statute makes a number of references to the need to apply universal design principles to student instruction, including the requirement that State and Local Educational Agencies shall, to the extent feasible, use universal design principles in developing and administering student assessments. In dealing with the need to provide instructional materials to students with print disabilities in a timely manner, the IDEA mandates that States adopt the National Instructional Materials Accessibility Standard (NIMAS) as a required file format that textbook publishers must use to create digital source files from which accessible instructional content may be produced.

NIMAS is an XML-based standard which is a subset of tags available within the DAISY-NISO standard for Digital Talking Books. Although the original temporary guidance on NIMAS suggested that math images with text equivalents may be used, now that the DAISY modular math extension has been adopted, publishers should be including MathML encoded equations in NIMAS-compliant files. State and Local Education Agencies will want to ensure that publisher-provided files of math textbooks submitted in compliance with the IDEA/NIMAS provisions are authored using the MathML based modular extension to ensure accessible math content for all students.

The mandate for universally designed assessments

Both NCLB and IDEA contain mandates for accessible assessment that can be used by all students. According to the Federal Regulations implementing Title I of NCLB, the required State assessments in reading, mathematics and science must be "designed to be valid and accessible for use by the widest possible range of students, including students with disabilities." IDEA further directs States to include students with disabilities in both State and Local Education Agency assessments, and to develop accommodation guidelines for ensuring their access to standard or alternate assessments as appropriate. The IDEA also directs State and Local Education Agencies to use universal design principles in creating assessments.

One of the best ways of ensuring that math assessments will be accessible using assistive technologies is to allow students to use a digital version which has been created using a format which is universally designed for use by all students, like MathML. This way, the same assessment can be used by all students--both those with and without disabilities--allowing everyone to benefit from the enhanced accessibility of this format. Both students who use assistive technologies, and those who do not, will be able to equally use these assessments without forcing the testing entity to reformat the content. Creating universally designed math assessments using MathML will help schools meet the mandates of both NCLB and IDEA.

Further Information and Resources

• Universal Design for Math Learning: Bridging the Technology and Policy Divide -- a discussion of the connections between the technological capabilities now available for creating universally designed math, and the body of public policy supporting it
• Why is Technology Access for Students With Disabilities Important? -- an overview of Federal and State policies mandating accessible technologies for students
• Electronic Textbooks: US Accessibility Laws & Issues -- an overview by Cynthia D. Waddell delivered at the CSUN 2004 Conference
• A New IDEA: The Individuals with Disabilities Education Act -- a policy overview by Jessica M. Brodey
• Universally Designed Assessments -- an introduction and list of resources provided by the National Center on Educational Outcomes