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Universal Design for Learning
Associate Editor Column
David Rose
with Skip Stahl


The NFF: A National File Format for Accessible Instructional Materials

As part of its efforts to ensure that No Child is Left Behind, The Secretary of Education in September, 2002, authorized The Office of Special Education Programs (OSEP) to issue a supplement to the National Center on Accessing the General Curriculum and the Center for Applied Special Technology (CAST), to convene a technical panel to establish a voluntary national standard ­ a National File Format - for accessible digital instructional materials for students with disabilities. This initiative seeks to ensure that no child face an inaccessible curriculum ­ one that creates barriers to progress rather than opportunities for learning.
The traditional print-based materials that dominate classrooms raise barriers for many students with disabilities. For students who cannot see the words or images on a page, cannot hold a book or turn its pages, cannot decode the text or cannot comprehend the syntax that supports the written word, each experience different challenges, and each may require different supports to extract meaning from information that is book bound. For each of them, however, there is a common barrier ­ the centuries old fixed format of the printed book.

What Can Digital Materials Do?
Modern digital materials can present the same content as printed books, but in a format that is much more flexible and accessible. For students who cannot see the words or images, the digital version can be produced in Braille or voice, and provide descriptions of the images. For students who cannot hold the printed book or turn its pages, the virtual pages of a digital book can be turned with a slight press of a switch. For students who cannot decode the text, any word can be automatically read aloud. For students who lack the background vocabulary in the text, definitions (in English or another language) can be provided with a simple click.

The advantage of digital books is that these alternatives, and many others, can be available on an individual basis ­ available for students who need them, invisible or non-distracting for those who don't. Such customizable alternatives can substantially reduce the barriers found in traditional texts, reducing the effects of what are commonly called print disabilities.
Very few students with disabilities presently have access to the accessible books they need. In some cases, the problem is technical ­ schools do not have the technology they need to properly provide accessible versions to students, even if they had such versions. In other cases, the problem is ignorance ­ many teachers and schools do not understand the issue of access or the potential solutions that are available.

What is a National File Format?
A file format is a specification for filing electronic information so that the content can be accurately and efficiently retrieved. Just as a library or home filing system requires some sort of organizational scheme to retrieve the information from it, an electronic book or file also requires a consistent organization or format to retrieve the information from it.
The goal of the National File Format Technical Panel is to assemble a national file format (NFF) that will represent the best attempt of a broad team of knowledgeable individuals to define a common format, one that can serve as a foundation for accessible educational materials. Such a common format will benefit the entire nation: states, districts, publishers, advocates, disability organizations, parents, and, most importantly, students with a range of disabilities.

What Are the Difficulties With the Present System?
For many students the problem is a frustrating distribution system; students cannot obtain the accessible materials they need in a timely fashion. Present policies and procedures for disseminating accessible materials are archaic and inefficient, raising barriers rather than opportunities. Indeed, every element of the complex distribution system faces impediments:

1. Publishers are presently unable, largely because of copyright constraints designed only for print world, to manufacture and distribute accessible digital versions directly to students in much the same efficient way they do their print versions. Instead they, and their consumers, must depend upon various independent third parties to render the printed books accessible. This dependency on third parties for re-designing and re-distributing accessible materials is not only an impediment to efficient distribution, it also raises concerns for the publisher and consumer about quality control, digital rights management, etc. In addition, this process ensures that there are no financial incentives to the publisher for facilitating the process of getting materials to students who need them, or for improving the quality of their original materials for students with disabilities. Publishers who nonetheless try to support the process by providing digital versions of their materials to third parties face a bewildering array of requests for different formats and versions from different states, disability organizations and individual teachers and students.

2. Since schools and school districts cannot get accessible versions of their curricular materials from the same sources as they get their regular materials, they must turn to other agencies and organizations that specialize in re-publishing accessible versions, or they must create them themselves. Either path is complicated and time consuming: districts must identify the format (or formats) they will need for individual students and for the differing technologies available in their various schools and classrooms, select a vendor or process for creating the necessary formats and then order materials, develop a repository and distribution system to match versions to individual students and technologies, and develop local capacity for utilizing and supporting teaches in using accessible versions. All of this is vastly complicated by the fact that there are a variety of technologies and formats. These complicated procedures interpose a delay that often stretches for months and all too often results in materials arriving in classrooms long after the need has passed.

3. Not-for-profit agencies or vendors have evolved to meet the widespread need for accessible materials in schools. These agencies ­ called authorized entities in the Chafee amendment ­ transform inaccessible published materials (like books) into more accessible versions. The largest , like Recordings for the Blind and Dyslexic or American Printing House for the Blind, are national and have long served students by creating alternative versions (audio, large print, Braille, etc.) of print materials. Because of the advantages of digital materials, many of these agencies have begun migrating to digital versions as a better way to serve their clients. But their progress is hampered by the diversity of potential formats. For example, differing publishers tend to use different proprietary formats or templates for digital production and distribution. As a result of that format complexity, it is difficult for authorized entities to develop an efficient process ­ most find it easier to begin with the printed book itself, then recreate a digital version backwards from that. Format complexities similarly inhibit the production and distribution from vendors to students. Since there is no standard format, different states and districts (even schools or classrooms) may request differing formats or versions, enormously complicating the processes of production and distribution. The lack of uniform format thus impedes both the evolution to superior digital materials, and their timely delivery to individual students.

4. Teachers, in turn, face many impediments to using digital accessible versions in their classrooms, impediments that are exacerbated by complexities in format and technology. They have two choices. First, they can determine a format that is appropriate for their student(s) and compatible with their existing classroom technology and then find a vendor or repository that can supply it. Or, they can accept a format provided for them and then adapt their classroom technologies to the format provided for them and find training in how to navigate and use it in their classrooms. Either of these is complicated when each vendor or repository may provide different formats and player technologies that teachers will have to learn to use.

5. Students with disabilities continue to face learning materials that are inaccessible in many different formats, from print to digital.

How will Digital Materials Help?
While there are many barriers to accessibility, the problems that are caused by multiple formats are particularly frustrating, in part because they are so easily remedied. The adoption of a common, or standard, format is a simplifying step that has been crucial to progress in many other fields ­ from railroads (adopting a common track gauge), to video technology (adopting a common format for DVD, and HDTV). Similarly, progress in accessibility will be greatly abetted by defining a common national file format. With that single change, a number of barriers in the educational materials distribution system can be addressed.
1. With one clear and consistent file format to produce, publishers would be able to deliver a high quality digital version expeditiously and simultaneously to all authorized entities for further conversion and distribution. Further, with careful planning, collaboration and design, it is conceivable that ALL existing and varied state requirements for accessible instructional materials could be met with a clear and comprehensive national file format.
2. With one consistent file format coming from different publishers, authorized entities would be able to efficiently transform these common formats into accessible "presentation" formats fot students (accessible digital versions and printed Braille, for example) and deliver them to local schools and school districts expeditiously.
3. With one basic digital format from vendors, schools and school districts could adopt vastly simpler, less costly, and more timely methods for acquiring materials, storing and retrieving them, purchasing additional assistive technologies, and training teachers and others in their use.
4. With one basic digital format from their districts, teachers could get their accessible materials in a timely fashion, in a consistent format that will work with their classroom technologies, and in a consistent format that will be easier for them to learn.
With one basic file format, students would finally get the accessible materials they need, when they need them.

Making all Students Eligible
In the best of all circumstances, accessible and universally-designed digital curriculum resources could be made available to any and all students as an alternative to the traditional print versions. A next best option would be the provision of accessible digital curriculum materials to any student whom an IEP or Section 504 Team considers to be "Print Disabled". Either of these options is potentially viable as long as authors/publishers retain intellectual property rights, the metering of content is controlled, and developers and distributors of proprietary materials are compensated for their work.

At the present time, the qualification of students eligible to receive material in a specialized format is determined by Section 121 of the Copyright Act (Chafee Amendment), as referenced by the Library of Congress, National Library Service statement of eligibility.
Students who are blind, have low vision or have other physical disabilities that render them "unable to read or unable to use standard printed material" qualify, as do students "having a reading disability resulting from organic dysfunction and of sufficient severity to prevent their reading printed material in a normal manner". (NLS Factsheet, Talking Books and Reading Disabilities, Issued March 1997).

Advances in neuroimaging studies indicate that many of the disabling conditions that result in a print disability have an organic and identifiable neuroanatomical basis. In order to not inadvertently exclude students who qualify for accessible materials now, and those who may be deemed eligible in the future, the work of the NFF Technical Panel will address the functional needs of any student who could possibly qualify under the existing guidelines. Further, it is hoped that the work of this panel is only the first step towards establishing the benefits of accessible (and, ultimately, Universally Designed) instructional resources in instructional settings, and how these alternatives can extend the potential of all students.
For more information on the National File Format Technical Panel, please visit the NFF web site at www.cast.org/ncac/nff.




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