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CNIB Response – AODA K-12 Education Accessibility Standards

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In June 2021, the Ontario government published a report that contained 197 recommendations for Kindergarten to Grade 12 (K-12) Standards under the Accessibility for Ontarians with Disabilities Act (AODA). These standards aim to identify, remove, and prevent accessibility gaps and barriers faced by students with disabilities from kindergarten to Grade 12. A further 75 recommendations were put forward addressing the transition from K-12 to post-secondary, the community and/or the workplace.

The government called for members of the public and organizations to submit a response to the recommendations before the K-12 Education Standards Development Committee finalizes them.

To help strengthen our response to these recommendations, CNIB held virtual consultation sessions with our community members to include that feedback in our report to the government. Interviewees included Ontario K-12 teachers and CNIB staff, as well as students who are blind or partially sighted and their parents. Thank you to everyone who participated and provided their feedback. 

You can read our full detailed response to the Committee here. We have also provided a summary below of key points that we would like the Committee to address:

1) Teacher training

We believe that the current Additional Qualifications (AQ) system for training Teachers of the Visually Impaired (TVIs) is inadequate. A person should complete post-secondary to become a TVI. 

Our interviewees also reported that there wasn't always a TVI available for the student but that an EA isn't an adequate replacement. Therefore, we suggest that data on TVIs include areas where someone less qualified is substituting for a full TVI. This way, the school boards can address situations where children with sight loss are underserved.

2) Curriculum

CNIB endorses the implementation of the Expanded Core Curriculum for students with sight loss and recommends the formal adoption of the Canadian National Standards for the Education of Children and Youth Who are Blind or Visually Impaired, Including Those with Additional Disabilities.

Course materials must be gathered and made accessible before the beginning of the school year so that students who are blind or partially sighted will have access to it on the first day of class, like everyone else. 

Accessibility standards for virtual learning platforms should be set and reviewed every year. We believe this should be prioritized in future drafts of these recommendations to ensure virtual learning is accessible to every student.

3) Individual Education Planning (IEP)

Currently, the recommendations have not explicitly identified IEPs as a tool to support students with disabilities. We recommend that IEPs be strengthened to include both extra-curricular activities like after-school programs and off-campus learning experiences, such as field trips. IEPs should also include individualized emergency planning. Finally, the IEP evaluation process should include everyone involved in the student's learning journey: parents/guardians and the student themselves.

4) Expanded co-operative/experiential learning opportunities

The Committee correctly calls out that students with disabilities often have less access to co-op and experiential learning opportunities. Along with offering support and advice to employers, we recommend the Ontario government also set up a fund for students with disabilities for placement accommodations. We support the recommendations for increased experiential learning opportunities but would like to see a detailed plan for how this will be accomplished.

5) Transitions

High schools can help support the transition to post-secondary for students with disabilities by ensuring guidance and career counsellors have adequate knowledge on post-secondary student accessibility offices and how to access them. This information should be published on schools' websites in an easily accessible place. We recommend the Committee strengthen the recommendations surrounding required documentation for post-secondary so the requirements are the same across all colleges and universities (not just "reasonably consistent").

The Ministry of Seniors and Accessibility is considering public input over the coming months and will incorporate that feedback into the final version of the AODA K-12 Standard. Feedback on the recommendations can be provided at this link: Consultation – Initial Recommendations for K-12 Accessibility Standards, with a deadline of November 1, 2021.

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