AMERICAN EDUCATIONAL RESEARCH ASSOCIATION, INC. et al v. PUBLIC.RESOURCE.ORG, INC.

Filing 138

LARGE ADDITIONAL ATTACHMENT(S) by PUBLIC.RESOURCE.ORG, INC. 136 Second MOTION for Summary Judgment filed by PUBLIC.RESOURCE.ORG, INC., 137 SEALED MOTION FOR LEAVE TO FILE DOCUMENT UNDER SEAL filed by PUBLIC.RESOURCE.ORG, INC. (This document is SEALED and only available to authorized persons.) filed by PUBLIC.RESOURCE.ORG, INC.. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5, # 6 Exhibit 6, # 7 Errata 7, # 8 Exhibit 8, # 9 Exhibit 9, # 10 Exhibit 10, # 11 Exhibit 11, # 12 Exhibit 12, # 13 Exhibit 13, # 14 Exhibit 14, # 15 Exhibit 15, # 16 Exhibit 16, # 17 Exhibit 17, # 18 Exhibit 18, # 19 Exhibit 19, # 20 Exhibit 20, # 21 Exhibit 21, # 22 Exhibit 22, # 23 Exhibit 23, # 24 Exhibit 24, # 25 Exhibit 25, # 26 Exhibit 26, # 27 Exhibit 27, # 28 Exhibit 28, # 29 Exhibit 29, # 30 Exhibit 30, # 31 Exhibit 31, # 32 Exhibit 32, # 33 Exhibit 33, # 34 Exhibit 34, # 35 Exhibit 35, # 36 Exhibit 36, # 37 Exhibit 37, # 38 Exhibit 38 FILED UNDER SEAL, # 39 Exhibit 39 FILED UNDER SEAL, # 40 Exhibit 40, # 41 Exhibit 41, # 42 Exhibit 42, # 43 Exhibit 43, # 44 Exhibit 44, # 45 Exhibit 45, # 46 Exhibit 46, # 47 Exhibit 47, # 48 Exhibit 48, # 49 Exhibit 49 FILED UNDER SEAL, # 50 Exhibit 50 FILED UNDER SEAL, # 51 Exhibit 51 FILED UNDER SEAL, # 52 Exhibit 52 FILED UNDER SEAL, # 53 Exhibit 53 FILED UNDER SEAL, # 54 Exhibit 54 FILED UNDER SEAL, # 55 Exhibit 55 FILED UNDER SEAL, # 56 Exhibit 56, # 57 Exhibit 57, # 58 Exhibit 58 FILED UNDER SEAL, # 59 Exhibit 59 FILED UNDER SEAL, # 60 Exhibit 60 FILED UNDER SEAL, # 61 Exhibit 61 FILED UNDER SEAL, # 62 Exhibit 62, # 63 Exhibit 63, # 64 Exhibit 64, # 65 Exhibit 65, # 66 Exhibit 66, # 67 Exhibit 67, # 68 Exhibit 68, # 69 Exhibit 69 FILED UNDER SEAL)(Bridges, Andrew)

EXHIBIT 62

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
AMERICAN EDUCATIONAL RESEARCH
ASSOCIATION, INC., AMERICAN
PSYCHOLOGICAL ASSOCIATION, INC., and
NATIONAL COUNCIL ON MEASUREMENT IN
EDUCATION, INC.,

Case No. 1:14-cv-00857-TSC-DAR

Plaintiffs/Counter-defendants,
v.
PUBLIC.RESOURCE.ORG, INC.,
Defendant/Counterclaimant.

EXPERT REPORT OF JAMES R. FRUCHTERMAN

Table of Contents
Introduction ..................................................................................................................................................1
Background and Qualifications .....................................................................................................................2
What Does Accessibility Mean for a Person Who is Blind? ..........................................................................3
Locating an Accessible Version of the 1999 Standards.................................................................................5
Testing the Public.Resource.Org Website’s Accessibility..............................................................................7
Making the 1999 Standards Accessible Today..............................................................................................8
The Public.Resource.Org Version of the 1999 Standards .............................................................................9
Confirming Accessibility for People Who Are Blind ......................................................................................9
The Archive.org Version of the 1999 Standards .........................................................................................11
Conclusion...................................................................................................................................................12

Introduction
As an expert in accessibility of written materials for people who have disabilities that
affect using standard print (people who are print disabled), I have been retained by
Public.Resource.Org to evaluate the accessibility of certain content that had been available on
the website of the defendant in this case. As someone dedicated to improving accessibility for
the benefit of people with disabilities and in the public interest, I agreed to evaluate the
accessibility to people who are blind of this specific commonly used standard document.
This expert report is a summary of certain opinions that I intend to give, if asked, at trial
regarding the accessibility of specific documents to people who are blind or print disabled. This
report also states the bases for my opinions, and it discloses the data or other information
considered in forming those opinions. I reserve the right to change or supplement this report if
additional evidence comes to my attention, and to prepare demonstratives and/or exhibits to
illustrate or explain my opinions, as appropriate.
A copy of my curriculum vitae, including a list of my publications and presentations, is
Exhibit A to this report. I provide my expertise in this case pro bono, and I am not receiving
compensation for my time researching, writing this report, or testifying. I previously served as
an expert in The Authors Guild, Inc. et al. v. HathiTrust, et al., Case No. 1:11-cv-06351-HB
(S.D.N.Y.) (case filed September 12, 2011) and I am serving as an expert in American Society of
Testing and Materials, et al. v. Public.Resource.Org, Case No. 1:13-cv-01215-TSC-DAR,
although I have not testified in either case. I have not given deposition or trial testimony in the
past four years.

1

Background and Qualifications
I serve as Founder and Chief Executive Officer of Benetech, a nonprofit dedicated to
creating new technology solutions that serve humanity and empower people to improve their
lives. In 1980 I earned a B.S. in Engineering and an M.S. in Applied Physics from California
Institute of Technology. I co-founded Calera Recognition Systems in 1982. Calera developed
optical character recognition (OCR) technology that allowed computers to read virtually all
printed text.
In 1989, I founded Arkenstone, a nonprofit social enterprise, which produced reading
machines for the print disabled community based on the Calera technology, and was at one time
the largest maker of affordable reading systems for the blind. The Arkenstone product line was
sold in 2000 and the resulting capital funded the next phase of Arkenstone under its new name,
Benetech. I have been the CEO of Benetech/Arkenstone since 1989.
I have served on three U.S. federal government advisory committees for disability issues:
the Section 255 Telecommunications Access Advisory Committee, the Section 508 Electronic
Information and Technology Access Advisory Committee, and the Advisory Commission on
Accessible Instructional Materials in Postsecondary Education for Students with Disabilities.
I have received numerous other awards and recognition for my work making print materials
accessible to people who are blind or otherwise print disabled. In 2006 I received a MacArthur
Fellowship. I was named an Outstanding Social Entrepreneur in 2003 by the Schwab
Foundation and have frequently participated in the World Economic Forum Annual Meetings in
Davos, Switzerland. Benetech received the Skoll Award for Social Entrepreneurship under my
leadership. I also received the Migel Medal from the American Foundation for the Blind, the
Robert F. Bray Award from the American Council of the Blind, and the American Library
2

Association’s Francis Joseph Campbell Award in recognition of my successful efforts to make
literary works more accessible to people who are blind or visually impaired.

What Does Accessibility Mean for a Person Who is Blind?
Accessibility is usually defined in a functional way: can a person with a disability
independently access the same information and perform the same tasks as a person without a
disability? When it comes to accessing materials traditionally available as print, such as
standards, there are many groups of print disabilities. The most severe is blindness, where a
person cannot perceive the printed text at all. The next is vision impairment, where a person
generally cannot perceive the text directly or with corrective lens, but may be able to use
magnifiers of different types to read the text. Another group is learning disabilities that interfere
with reading, such as dyslexia. A closely related group of disabilities involve brain injuries that
affect reading or the retention of material read. Another group is physical disabilities that
interfere with the holding or seeing of books or the turning of pages.
In this report, I focused on the accessibility challenges that would be experienced by
blind people, because they are generally the most severe print disabilities. The other groups of
people with print disabilities use similar technologies to access print (such as having it read
aloud), and experience similar challenges as blind people. In the accessibility field, it is
generally understood that if you make information accessible to a blind person, it will probably
also meet the accessibility needs of the great majority of people with other print disabilities.
The most common technology used by a blind person for accessibility is called a screen
reader. As the name suggests, a screen reader is a program that runs on a personal computer or a
smartphone that reads the information on the screen aloud (using a computer-synthesized voice)

3

to a blind person. The screen reader runs “on top of” other programs, figuring out not only what
text is on the screen, but also the controls that are displayed: items such as buttons, menus, textentry boxes and the like. Because of the amount of information on a complete screen, and its
complexity, blind people need to be able to focus on the most important information so that they
do not waste time listening to everything on the screen.
For the purpose of this report, measuring the accessibility of standards, I am assuming
that the blind user is using a screen reader on top of a web browser or word processor program
on a personal computer. Based on the information the screen reader can glean from the pages
displayed on the screen, can a blind person locate the standard and read it?
The accessibility tasks I tested were designed to assess whether a blind user with basic
assistive technology skills could perform the same kind of tasks one might expect a user without
a disability to perform in accessing a given standard, without requiring the intervention of a third
party. This functional approach is the most common method of assessing accessibility.
The specific tasks I investigated were:
!

Could a blind user with basic assistive technology skills independently access a
specific standard of interest?

!

Could a blind user independently read the entire standard using assistive technology?

!

Could a blind user independently navigate to a specific place in the standard and read
the content in that place?

!

Could a blind user independently do a full text search and find specific mentions of
terms of interest?

4

I conducted these tests on a standards document that was represented to me as having been
available on the Public.Resource.Org website. I primarily used the Window-Eyes screen reading
software and the ABBYY FineReader optical character recognition software to perform my tests.

Locating an Accessible Version of the 1999 Standards
I was asked to review the accessibility of the 1999 edition of The Standards for
Educational and Psychological Testing (hereafter, the “1999 Standards”) for people who are
blind or otherwise print disabled. The first step in determining the accessibility of a document is
to try to locate a version of the 1999 Standards that would be accessible to people who are blind
or have print disabilities. I attempted to locate an accessible version of the 1999 Standards
through two separate avenues: by searching the catalogs of the main libraries that serve people
with print disabilities, and also by doing a standard Google search to try to locate an electronic
version of the 1999 Standards. From my work with people who are blind or print disabled, I
know that this would be the typical procedure that people who are blind or print disabled would
perform when looking for an accessible version of a document.
The four main libraries that serve people with print disabilities are the American Printing
House for the Blind, Bookshare (which I founded), Learning Ally, and the National Library
Service for the Blind and Physically Handicapped, Library of Congress. I performed a thorough
search of all four of these catalogs and found that the 1999 Standards were not available through
any of these resources, either in an electronic form, or in mail-delivery braille or audio recording.
I then performed a Google search to attempt to locate an electronic version of the 1999
Standards online. I was unable to find an electronic version of the 1999 Standards online, but I
did locate a used print version for sale on Amazon.com. I have been informed by counsel for

5

Public.Resource.Org that although Public.Resource.Org previously hosted an electronic version
of the 1999 Standards on its website, it had been taken down during the course of this litigation.
From my research I believe that a version of the 1999 Standards that is accessible to people who
are blind or print disabled is currently unavailable to the public.
The unavailability of a version of the 1999 Standards that is accessible to people who are
blind or print disabled is problematic because the 1999 Standards are important references for
those making tests that are accessible to students who are print disabled, as well as those
impacted by these tests. For instance, the 1999 Standards were referred to in several works
concerning test accessibility for blind students, specifically: Test Access: Making Tests
Accessible for Students with Visual Impairments: A Guide for Test Publishers, Test Developers,
and State Assessment Personnel, Second Edition, by Carol B. Allman, Ph.D., published by the
American Printing House for the Blind (Exhibit C), and an online resource published by the
American Foundation of the Blind, Building Assessment Initiatives for Schools: Guidelines to
Support the Contract Development Process Between Test Publishers and States (Exhibit D). As
an expert in the field, this means that the 1999 Standards are important references today for those
making tests accessible to students with disabilities such as blindness. This also means that it is
an important resource to any students or other individuals with print disabilities that want to
assess compliance with the 1999 Standards. The unavailability of the 1999 Standards means that
some of those who are most impacted, people who are blind or print disabled, are unable to
independently access the 1999 Standards.

6

Testing the Public.Resource.Org Website’s Accessibility
Because the 1999 Standards are no longer hosted on the Public.Resource.Org website
during the course of this litigation, I was not able to locate the full text of the 1999 Standards on
the Public.Resource.Org website while performing my Google search referenced above.
However, searching the terms “1999 Standards for Educational and Psychological Testing” on
Google (for me) shows the page where the 1999 Standards had been located on the
Public.Resource.Org website, located in the first page of links in the search results. However,
the file I found there was a placeholder noting the voluntary takedown of the file. I have also
searched for other standards that Public.Resource.Org has posted on its website, such as NFPA
101-2000, and I have found that it would be relatively easy for a person who is blind or print
disabled to use screen reader software and perform a Google search to locate a standard if it was
available on Public.Resource.Org’s website. Therefore, when the 1999 Standards had been
hosted on the Public.Resource.Org website, a person who is blind would have been able to locate
the 1999 Standards through a simple Google search, with the assistance of screen reader
software.
The Public.Resource.Org website has no required sign-up procedure. It is possible to go
directly to a specific standard either by using a direct weblink or by navigating the text-oriented
website. This is important because sign-up procedures can often have the effect of preventing
people who are blind or print disabled from accessing certain parts of websites due to the fact
that many sign-up procedures use unlabeled buttons or other elements that screen reader software
cannot read. Therefore, a person who is blind or print disabled would have been able to locate a
version of the 1999 Standards on the Public.Resource.Org website when it was still hosted there,

7

and that person would then have been able to gain access to that electronic version of the 1999
Standards.

Making the 1999 Standards Accessible Today
Because an accessible version of the 1999 Standards is not currently available, if a blind
person needed to have an accessible version of the 1999 Standards, they would need to create it
themselves or request that their employer, educational institution, or a specialized library for the
blind create it. Generally, most blind people themselves do not have the ability to convert books.
Some blind people have their own home scanners, and if they purchased a used copy online,
would be able to scan the 1999 Standards page by page on a home scanner, which would take at
least two hours of labor, and then perform optical character recognition on the title. Optical
character recognition is the process by which a computer converts images of printed text into
machine-encoded text that can be read aloud by a screen reader. If the scanning quality wasn’t
very good, significant numbers of errors would be introduced through the optical character
recognition process. The resulting word processor file of recognized text could then be read
using a screen reader.
If Bookshare were to make the 1999 Standards accessible to a blind person, we would
purchase a used copy of the printed version, chop off the bindings and then process it through a
high speed scanner to obtain a high quality scan of the book in less than fifteen minutes. We
would then perform optical character recognition on the image scans of all of the pages of the
book, which typically creates a Microsoft Word file version of the text, and then send it to an
outside service (or a volunteer) to have it proofread, correcting errors introduced by the
limitations of optical character recognition. Public.Resource.Org has already performed the

8

great majority of the most expensive and time consuming steps needed to create an accessible
version of this document, specifically purchasing a print version of the title, waiting a few days
to receive it, chopping off the binding and scanning it with a high speed production scanner, or
utilizing a library-grade nondestructive book scanner. This is a valuable contribution to anyone,
individual or organization, that wanted to ensure that the 1999 Standards are accessible to people
who are blind or print disabled, if that file were still available.

The Public.Resource.Org Version of the 1999 Standards
I was supplied with a version of the 1999 Standard in PDF format. It was represented to
me that this file had been available online at the Public.Resource.Org website. I examined the
file, and found it to be a high quality image scan of the 1999 Standards. If the file was still
online, this would have meant that a blind person wanting to have an accessible version of the
1999 Standards would be able to do so by performing optical character recognition on the
Public.Resource.Org image file, creating an accessible text version of the 1999 Standards in
minutes.

Confirming Accessibility for People Who Are Blind
I then performed the steps of taking the Public.Resource.Org version of the 1999
Standards and making it accessible, while using Window-Eyes screen reading software to read
the words on the computer screen aloud. For the version of the 1999 Standards that was on the
Public.Resource.Org website, I used ABBYY FineReader optical character recognition software
to recognize page images, and it converted those pages into a Microsoft Word document. In
addition, the process of using the ABBYY software and reading the document was something a
9

blind person could do independently using Window-Eyes software to perform the tasks in an
accessible way, because the program speaks the menus and converted text aloud. Because the
image scan by Public.Resource.Org was high quality, there were few optical character
recognition errors. In addition, I also tested a typical page image from the Public.Resource.Org
version using the website Free Online OCR (http://www.onlineocr.net/), and confirmed that it
also recognized the text well. In my opinion, most of the OCR solutions that would be available
to people who are blind should be able to convert this image PDF document into accessible text.

I then examined in Microsoft Word several pages of the standard as processed by
ABBYY FineReader, and confirmed that Window-Eyes could read the text aloud in logical
reading order. I also successfully performed full text searches on a key word, a standards
number, and a page number, using Window-Eyes.

10

My tests therefore indicated that a blind person using a screen reader would be able to
perform all of the functional tasks: reading the entire standard, navigating to a specific place in
the standard, or searching on key terms. Because the text is provided in a standard format, such
as Microsoft Word, a blind person is able to listen to the text, or access it using a digital braille
device. This kind of text content is also highly accessible to people with other print disabilities
and the assistive technology they use to access print. For example, people with low vision or
with dyslexia often use a screen reader to read text aloud.

The Archive.org Version of the 1999 Standards
I was also supplied with a version of the 1999 Standard in TXT (text) format, by a staff
person at the Internet Archive, operator of the Archive.org website. It was represented to me by
this person that this file, aera.standards.1999_djvu.txt, had been available online at the
Archive.org website. According to the Internet Archive’s “Derivatives” page located at

11

https://archive.org/help/derivatives.php, when a PDF file is uploaded to the Internet Archive
website, the website automatically creates derivative file types that are also accessible on that
website, including TXT format. The deposition testimony of Christopher Butler from the
Internet Archive, as well as the deposition testimony of Carl Malamud from Public.Resource.Org
indicate that when Public Resource uploaded the PDF file of the 1999 Standards to the Internet
Archive website, the Internet Archive automatically created this text file of the 1999 Standards,
which was publicly accessible on the Internet Archive website.1 I examined the file, and found it
to be a text version of the 1999 Standards, preceded by informational material about the Internet
Archive in HTML format. It appeared to me that the text version had been created by optical
character recognition, because there were a few uncorrected errors typical of that process.
As established in my discussion of the 1999 Standards on the Public.Resource.Org
website above, once the 1999 Standards are available in an electronic text format, a blind person
using a screen reader would be able to perform all of the functional tasks: reading the entire
standard, navigating to a specific place in the standard, or searching on key terms. I confirmed
that this was the case with the aera.standards.1999_djvu.txt file. Because the text is provided in
a standard and compatible format, a blind person is able to listen to the text, or access it using a
digital braille device. This kind of text content is also highly accessible to people with other
print disabilities and the assistive technology they use to access print.

Conclusion
I was asked to review the accessibility of the 1999 edition of The Standards for
Educational and Psychological Testing. I was unable to find an accessible version of the
1

Deposition of Christopher Butler of the Internet Archive, December 2, 2014, at pp. 48-49, 87, 102-105;
deposition of Carl Malamud of Public.Resource.Org, May 12, 2015, at pp. 281-284.
12

Exhibit A

James R. Fruchterman
Founder and CEO
Benetech

Education
California Institute of Technology
B.S. Engineering, 1976-80
M.S. Applied Physics, 1978-80
Stanford University, 1980-81
Ph.D. Studies in Electrical Engineering
Professional Experience
CEO and Founder, 2015-present
President, CEO, Chairman, Founder, 2000-2014
Benetech (name changed from Arkenstone in 2000)
Palo Alto, California
President, CEO, Chairman, Founder, 1989-2000
Arkenstone, Inc.
Moffett Field, California
Director, 1989-present
Vice President Finance, CFO, 1989-2004
President & CEO, Founder, 1989-95
RAF Technology, Inc.
Palo Alto, California and Redmond, Washington
Vice President, Marketing, 1987-89
Founder, Vice President, Finance, 1982-88
Calera Recognition Systems, Inc.
Santa Clara, California
Prior engineering positions with:
Phoenix Engineering, Inc.
G.C.H., Inc.
IBM T.J. Watson Research Center
General Motors Company
NASA — Jet Propulsion Laboratory
Fermi National Accelerator Laboratory

Publications
Technology Serving Humanity (chapter). In Schultz, R. (editor) Creating Good Work, Palgrave
Macmillan, February 2013
Guest Editor’s Page, AFB Journal of Visual Impairment & Blindness, October-November
2012
An Interview With Technology Guru George Kerscher, AFB Journal of Visual Impairment
& Blindness, October-November 2012
For Love or Lucre, Stanford Social Innovation Review, Spring 2011
Developing Information Technology to Meet Social Needs. In Innovations, MIT Press, 2008
Accessing Books and Documents, a chapter in the book, Assistive Technology for VisionImpaired and Blind People, Springer Verlag 2008
Everyone Deserves Access to Technology, OpEd in The Sacramento Bee by Jim Fruchterman
and Gregg Vanderheiden, June 17, 2007
Document Recognition Serving People With Disabilities, Proc. SPIE 6500, International
Society for Optics and Photonics, 2007
Pattern Recognition Technology Helps Disabled People Access Books, SPIE Newsroom,
International Society for Optics and Photonics, May 14, 2007
Nothing Ventured Nothing Gained, Addressing the Critical Gaps in Risk-Taking Capital for
Social Enterprise, by Jed Emerson, Tim Freundlich and Jim Fruchterman, published by
Oxford Said Business School, 2006
Build Great Companies, Then Help Build a Great World, OpEd in The San Jose Mercury News,
November 13, 2006
Comments on Accessibility of Google Print and Google’s Library Project, white paper,
February 2005
Technology Benefiting Humanity, published in the Association for Computing Machines
Ubiquity magazine, March 2004
The Power of Technology Social Enterprises, published in the N-TEN forecast series,
February 2004
In the Palm of Your Hand: A Vision of the Future of Technology for People with Visual
Impairments, published in the American Foundation for the Blind’s Journal of Vision
Impairment and Blindness, October 2003
The Chafee Amendment: Improving Access to Information, published in Information
Technology and Disabilities, a journal published by Equal Access to Software and Information
(EASI), co-authored with Bookshare Senior Product Manager Alison Lingane, October 2003
The Soundproof Book: Exploration of Rights Conflict and Access to Commercial EBooks
for People with Disabilities, published in First Monday, co-authored with George Kerscher,
the International Project Manager of the DAISY Consortium, May 2002
Bookshare, Books without Barriers, at the Closing the Gap conference, Minneapolis, MN,
October 2001

Two presentations given at the IT Accessibility 2001 Conference, May 2001 at the National
Institute of Standards and Technology
I Dream of Software
The Business Case for Adaptive Technology
Humanizing the Voice of the Machine, with Prof. Mari Ostendorf (University of
Washington), Annual Meeting of the American Association for the Advancement of the
Machine, Boston, MA, February 2000
The Many Facets of Open Book: Ruby Edition, California State University, Northridge
(CSUN), 15th Technology and Persons with Disabilities Conference, March 2000
Corporate Responsibility for Adaptive Technology, California State University, Northridge
(CSUN), 14th Technology and Persons with Disabilities Conference, March 1999
Developing Partnerships for Assistive and Universally Designed Technology for Persons
with Disabilities, Testimony before United States House of Representatives, Committee on
Science, Subcommittee on Technology, August 4, 1998
Access to Maps and Location Information through Virtual Reality Techniques and GPS
Satellite Receivers, 3rd International Technical Aids Seminar, Tokyo, Japan, July 1994
Invited Talks
“Innovation in America: The Role of Technology,” August 1, 2013, Testimony before U.S.
House of Representatives, Judiciary Committee’s Subcommittee on Courts, Intellectual
Property, and the Internet.
“Social Change at Scale – That’s Innovation!” May 2012, TEDxSanJoseCA 2012, San Jose,
CA.
“The Power of Failure, People and Karma Banking,” May 20, 2012, Commencement speech, St.
Mary's College, Moraga, CA.
“Raising the Floor,” October, 2011, Keynote Speech, Association for Education and Rehabilitation
of the Blind and Visually Impaired Conference, Cleveland OH.
Keynote speech, IEEE Sections Congress, August 2011, San Francisco, CA.
“Making the Book Truly Accessible,” Tools of Change Conference, New York, NY, 2011
Keynote Speech
UBS-Ashoka Visionaris Award, Keynote Speech, Social Entrepreneur of the Year Award,
Mexico City, Mexico, September, 2010
A series of three invited speeches on Bookshare and accessible books, in Tokyo, Shizuoka
and Osaka, Japan, February, 2009
Keynote Speech, Social Enterprise World Forum, Edinburgh, Scotland, September, 2008
“Raising the Floor: Providing Accessible Technology and Content to Every Person with a
Disability on the Planet,” International Conference on Computers Helping People with
Special Needs, Linz, Austria, July, 2008 Keynote Speech
“Raising the Floor,” CSUN Conference on Technology and Persons with Disabilities,
March, 2008 Keynote Speech

Extensive speaking engagements to students about technology serving people with
disabilities. Have done invited talks at:
Stanford University
University of California at Berkeley
Brigham Young University
University of the Pacific
Santa Clara University
California Institute of Technology
San Jose State
University of California at Santa Cruz
University of California at Davis
Loyola Marymount University
Pepperdine University
University of Washington
Columbia University
Harvard University
University of Geneva
Oxford University
Inflection Point Opportunities in Social Investment, Closing Keynote for the UBS
Philanthropy Forum, Lisbon, Portugal, July 2007
It’s Not Rocket Science: Building Social Enterprises, Keynote for the 7th Gathering of the
Social Enterprise Alliance, Atlanta, Georgia, March 2006
Opening Keynote for the Global Social Venture Competition, New York, April, 2006
Keynote for the 7th IAPR Workshop on Document Analysis Systems, Nelson, New
Zealand, February 2006
Building a Global Library for People with Print Disabilities, a speech for the World Summit
on the Information Society, Tunis, Tunisia, November 2005
Innovating Information Technologies to Protect Human Rights, a speech for the World
Affairs Council of Northern California, February 2004
Setting the 2004 Agenda: Technology, speaker at the World Economic Forum, Davos,
Switzerland, January 2004
Seizing Market Failure as an Investment Opportunity, Keynote for the Business for Social
Responsibility Annual Conference, Los Angeles, November 2003.
In the Palm of Your Hand, Keynote for the World Blind Union Asia Pacific conference,
Singapore, November, 2003
Technology and Human Rights, University of Peradeniya, Sri Lanka, November, 2003
When Markets Fail, Who Responds? Discussion Leader at the World Economic Forum,
Davos, Switzerland, January 2003
Technology for Nonprofits, with Michael Gilbert, National Gathering for Social
Entrepreneurs, Minneapolis, MN, December, 2002
Bookshare: Large Scale, Web-Based Accessible Books, TechShare conference organized by

the Royal National Institute of the Blind, Birmingham, UK, November 2002
Putting Technology to Work for Development, speech at the United Nations to the joint
meeting of the World Technology Network and UNOPS, July 2002
Bookshare: The Project for Creating Accessible Books through Computers, at the General
Session of the National Federation of the Blind 2002 Annual Convention, July 2002
Stanford Social Entrepreneurship Conference, January 2002
The Once and Future Web: Tenth Anniversary of the First U.S. Web Page at the Stanford
Linear Accelerator Laboratory, December 2001
NetImpact Annual Conference at Kenan-Flagler Business School, November 2001
American Council of the Blind Annual Convention, July 2001
Bringing Socially Beneficial Technology into the Service of Humanity, EE380 at Stanford
University, April 2001
Information Technology in the Service of Human Rights at the Computers, Freedom and
Privacy Conference, March 2001
Rank Prize Fund Symposium, Grasmere, England
Guest Lecturer for CSUN program in disability leadership
Professional Associations
Association for Computing Machinery
Institute of Electrical and Electronics Engineers
American Association for the Advancement of Science
Social Enterprise Alliance
Awards and Public Service
Head of Benetech Delegation, Diplomatic Conference to Conclude a Treaty to Facilitate
Access to Published Works by Visually Impaired Persons and Persons with Print Disabilities,
World Intellectual Property Organization, Marrakesh, Morocco (2013)
Member, Global Agenda Council on Measuring Sustainability, World Economic Forum
(2012-2014)
Member of the Board of Directors, ZeroDivide, foundation investing in community
enterprises that leverage technology to benefit people in low-income and other underserved
communities (2007-2013)
Commissioner, Federal Advisory Commission on Accessible Instructional Materials in
Postsecondary Education for Students with Disabilities, 2010-2011
Duke University, CASE Award for Enterprising Social Innovation, 2011
Brigham Young University, Center for Economic Self-Reliance Social Innovator of the Year,
2009
AT&T Technology Innovation Award from the Alliance for Technology Access, March

2008
Strache Leadership Award from the California State University, Northridge, 2007
John D. and Catherine T. MacArthur Foundation Fellowship, 2006
Technical Advisory Committee Member, National Instructional Materials Accessibility
Standard, U.S. Department of Education (2005-2008)
Advisory Committee Member, National Instructional Materials Accessibility Center, U.S.
Department of Education (2006-present)
Skoll Award for Social Entrepreneurship, 2004 and 2006
Fast Company Social Capitalist Award: Top 20 Groups Changing the World, 2004
Laureate, The 2003 and 2001 Tech Museum Awards
American Library Association Francis Joseph Campbell Award, 2003
Schwab Foundation Outstanding Social Entrepreneur of 2003 Award
Member, the Community Partnership Committee, which oversees a diversity and disability
agreement with SBC, Inc.
Runner-up, Yale-Goldman Sachs National Nonprofit Business Plan Competition, 2003
American Foundation for the Blind Access Award, 2003
Robert S. Bray Award, The American Council of the Blind
Winner, Education Category, 2002 Stockholm Challenge
Fast 50 Champion of Innovation 2002
Judge, 2002 National Social Venture Competition
Member, Board of Directors of the Social Enterprise Alliance (2000-2010, chair 2008-2010)
Member of the Advisory Board, Telecommunications Access Rehabilitation Engineering
Research Center, a joint effort of the Trace R&D Center of the University of WisconsinMadison and the Technology Access Program of Gallaudet University, 2001
Panelist, National Science Foundation Small Business Innovation Research Program, 1998,
2000, 2003
Participant, 1998 NSF Workshop for Discussing Research Priorities and Evaluation
Strategies in Speech Synthesis, August, 1998
Member, Electronic Information and Technology Access Advisory Committee, a federal
advisory committee responsible for drafting federal acquisition standards for accessibility
under Section 508, 1998-1999
Member, Telecommunications Access Advisory Committee, a federal advisory committee
responsible for making recommendations to the U.S. Access Board and Federal
Communications Commission on implementing portions of the 1996 Telecommunications
Act, 1996-1997
U.S. Patent Number 5,470,223: System and Method for Tracking a Pedestrian

Finalist, 1996 Discover Magazine Awards for Technological Innovation
1996 Access Award, American Foundation for the Blind
Major Works and Areas of Expertise
Founder and CEO of Benetech, a highly innovative nonprofit company focused on using
the power of technology to address social needs in areas such as disability, literacy, human
rights and the environment.
Founder of Arkenstone, Inc., a leading nonprofit organization providing adaptive
technology for education and employment for people with disabilities and the largest maker
of reading systems for people with blindness, vision impairment and learning disabilities.
Developer of the Arkenstone Reader, the first affordable reading system for the blind.
Designer of Open Book, the first talking Windows program for the blind. Co-inventor of
Atlas Speaks, the first accessible map software for the blind, and of Strider, a talking GPS
locator for the blind.
Cofounder of RAF Technology, Inc., the nation's leading company in optical character
recognition technology for processing forms in postal and medical applications. RAF's
software is used to route the United States mail.
Cofounder of Calera Recognition Systems, Inc., the first company to develop omnifont
optical character recognition that works without user training.

Exhibit B
Documents, Facts, or Data Considered in Forming My Opinions:
!
!
!
!
!
!

!

!
!
!
!
!
!

The Public.Resource.Org website, at www.public.resource.org
The American Printing House for the Blind website, at www.aph.org/
The Bookshare website, at www.bookshare.org/cms
The Learning Ally website, at www.learningally.org
The National Library Service for the Blind and Physically Handicapped, Library of
Congress website, at http://www.loc.gov/nls/catalog/?loclr=blognls
Test Access: Making Tests Accessible for Students with Visual Impairments: A Guide for
Test Publishers, Test Developers, and State Assessment Personnel, Second Edition, by
Carol B. Allman, Ph.D., published by the American Printing House for the Blind, and an
online resource published by the American Foundation of the Blind, available at
www.aph.org/tests/access2
Building Assessment Initiatives for Schools: Guidelines to Support the Contract
Development Process Between Test Publishers and States, available at
www.afb.org/info/afb-national-education-program/jltli-2005-educationsummary/checklist-for-rfp-building/235
Window-Eyes screen reader software
ABBYY FineReader optical character recognition software
The 1999 Standards in image only PDF format, as provided to me by
Public.Resource.Org
The 1999 Standards in TXT format, as provided to me by the Internet Archive
The deposition of Christopher Butler of the Internet Archive, December 2, 2014
The deposition of Carl Malamud of Public.Resource.Org, May 12, 2015

Exhibit C

Making Tests Accessible for
Students with
Visual Impairments:
A Guide for Test Publishers,
Test Developers, and
State Assessment Personnel*

i

TEST ACCESS:
Making Tests Accessible
for Students With
Visual Impairments
A Guide for Test Publishers,
Test Developers, and State
Assessment Personnel*
Fourth Edition
Carol B. Allman, Ph.D.
Published by
American Printing House for the Blind
Louisville, Kentucky
July 2009

ii

*Book Number two in the TEST ACCESS Series, promoting
accessibility of testing materials for persons who are blind or
visually impaired
©2004, 2007, 2008, 2009 American Printing House for the Blind,
Inc. With the exception of ETS Guidelines for a Test Reader, which is
material presented in Appendix G, this document may be copied in
whole or in part and distributed free of charge for educational and
nonprofit use as long as appropriate credit is given to the author and
publisher, and the "Work in Progress" notice is included on each copy.
No other use of this material is allowed without written permission.
Work in Progress: This document represents a set of guidelines
for making tests accessible to students with visual impairments.
These guidelines are a "work in progress" and will be routinely
updated and revised as additional information is collected and
research results are learned. Please address questions, concerns,
and suggestions regarding these guidelines to the director of APH's
Accessible Tests Department at 1-800-223-1839 or e-mail them to
[e-mail].
Disclaimer: Web links in this document were current as of the
date of publication, but may have become deactivated or modified
since then. These links are for informational purposes only and do
not constitute an endorsement or approval of policy, views,
products, or services of the publishing organization.
Preferred Citation:
Allman, C. (2009). Making Tests Accessible for Students with Visual
Impairments: A Guide for Test Publishers, Test Developers,
and State Assessment Personnel. (4th edition.) Louisville, KY:
American Printing House for the Blind. Available from
http://www.aph.org.
Trademarks are of their respective companies.

American Printing House for the Blind
1839 Frankfort Avenue
P.O. Box 6085
Louisville, KY 40206-0085
Toll Free: 800-223-1839
Fax: [phone]
www.aph.org

iii

iv

TABLE OF CONTENTS
Acknowledgements ................................................................. vi
Introduction ................................................................ 1
General Guidelines for Accessible Test Formats ....................... 5
Braille and Tactile Graphics ................................................ 11
Large Print Test Formats and Graphics ................................. 19
Uses of Color for Signage, Graphics, Text, Tests and Power Point
Presentations to be Viewed by Persons Who Are Color Blind or
Color Vision Deficient .............................................................. 26
Guidelines for Audio Versions of Tests ................................ 29
Guidelines for Oral Reading or Signing of a Test .................... 32
Accommodations in Testing Students with Visual
Impairments ........................................................................ 35
Guidelines for Braille and Large Print Test Response
Transcription ....................................................................... 40
Reporting Test Results of Students with Visual Impairments.... 41
Alternate Assessments.............................................................. 43
References ............................................................................ 46
Resources .............................................................................. 51
Appendix A: Braille versus Auditory Access: A Discussion ........... 54
Appendix B: Template for Test Administration Braille Tests ....... 57
Appendix C: Template for Test Administration Large Print
Tests .................................................................................... 59
Appendix D: Position Paper: Use of an Abacus in Test-Taking
Situations .......................................................................... 61
Appendix E: Position Paper: Use of Extended Time ................... 63
Appendix F: Position Paper: Accommodations for Testing
Students with Visual Impairments ............................................ 67
Appendix G: ETS Guidelines for a Test Reader ............................. 78

v

ACKNOWLEDGEMENTS
The American Printing House for the Blind (APH) and the author
wish to acknowledge and express appreciation to all the individuals
who contributed information, guidelines, feedback, editing, reformatting, and graphic design expertise in order to develop and
make this document available.

vi

INTRODUCTION
Purpose of Document
The American Printing House for the Blind (APH) is committed to ensuring
that educational materials are accessible to students with visual
impairments. Students with visual impairments include those with some
usable vision, as well as students with no usable vision. This document is
provided as a guide for making tests accessible in tactile, large print, and
audio formats. It is anticipated that this guide will be used as a tool for
implementing appropriate guidelines as test publishers, test developers, test
editors, and state assessment personnel are developing and adapting tests
and assessments. Prior planning using the contents of this document will
help ensure that tests are accessible and will reduce the need to retrofit a
test. Questions concerning this document, the specific guidelines, or resources discussed can be addressed to APH's Accessible Tests Department at
1-800-223-1839 or [e-mail].

Federal and State Mandates
Federal and many state laws require that all students be assessed through
state assessment procedures using the appropriate accommodations. In the
school year 2005-2006, states were required to assess all students'
progress annually in mathematics and reading in grades 3-8 and once in
grades 9-12. In addition, by 2007-2008, states were required to assess all
students' progress in science, at least once in grades 3-5, 6-9, and 10-12.
Assessment results of all students must be reported publicly, and these
results are to be incorporated into the state’s accountability plan.
Satisfying these federal requirements necessitates careful attention to
making tests accessible for all students. Students with visual impairments
have some unique communication needs that must be addressed as tests
and assessments are made accessible for them. Converting test items into
braille, tactile graphics, large print, or audio format fails to guarantee that
the items are accessible. For example, test items that instruct the student
to "draw the results of the following" or "write a story based on the
picture" are not truly accessible to braille readers. Other examples of this
misconception are discussed within each media-specific section of this
document. Careful planning during test development can help ensure that
tests are accessible, while maintaining the rigor intended.

1

Expectations for Students with Visual Impairments
If students with visual impairments are to participate effectively in state and
national testing programs, they must have opportunities to learn academic
skills that will be assessed. These opportunities often are overshadowed by
special skills training to such students, who may miss all or part of academic
classes in order to obtain the skills essential for using braille, assistive
technology, and/or independent living skills, including orientation and
mobility.
In addition to providing the training of special skills, school personnel must
be aware of each student's need for instruction in all academic areas. This
may entail extended days or school years or supplemental instruction by
other agencies that serve students with visual impairments.
Students with visual impairments must spend their educational time
working toward academic content standards, learning special skills needed
for independent living, exploring appropriate media for access to printed
material, and evaluating ways of communication that are effective for them.
Access to printed material may include braille, tactile graphics, regular print
with magnification devices, large print, the use of a human reader, auditory
access, or technology access that provides braille, print, or auditory information. No single method will work for every student, in all situations.
Educational personnel must ensure that students are exposed to and have
opportunities to try all options of access. A student's communication mode
must be based on what works for him or her. See Appendix A for a
discussion of braille versus auditory access.
School personnel must maintain high expectations for the education of
students with visual impairments. If opportunities to learn are present in
the curricula, students will have the experiences needed to learn difficult
skills such as map and graph reading, production of graphs and charts,
reading technical materials, or computation of advanced mathematics.
Students cannot be denied their right to learn difficult skills just because
they have a visual impairment. It is these more difficult skills that are being
assessed routinely on most state and national assessments of student
progress in reading, mathematics, and science.

2

Universal Design
In the construction and administration of tests, the process of universal
design helps to ensure accessibility for a multitude of students. Universal
design provides the widest range of students the ability to demonstrate
adequately their skills and knowledge. This process should retain the
validity of inferences drawn from the test results.
The concepts of universal design apply to instruction as well as assessment.
During instruction, universal design enables investigating appropriate
methods, practicing skills and knowledge using appropriate methods,
experiencing trial and error to determine the best methods, and
discovering the success of knowledge and skills learned using the best
methods for each individual student. During assessment, universal design
becomes the process of ensuring that the majority of students can
demonstrate their knowledge and skills. Both aspects of learning,
instruction and assessment, are driven by the standards of each individual
state.
To ensure that an assessment system is fair and accessible to all students,
states are required to document how they include the principles of universal
design in the item review process. Generally the principles of universal
design include (Thompson & Thurlow, 2002, Thompson, Johnstone, &
Thurlow, 2002):
•
•

•

•
•
•
•
•

Attention to an inclusive assessment population,
Constructs, including content and cognitive complexity, that are
precisely defined either through states’ standards or the test item
specifications,
Accessible test items, as determined by item writers and review teams
that include personnel familiar with various media (braille, tactile
graphics, large print, regular print, and audio),
Non-biased test items, as determined by item writers and review
teams,
Test formats, response options, and scoring policies that are amenable
to various approved accommodations needed by students,
Simple, clear, and intuitive instructions and procedures,
Comprehensive and relevant language that provide needed distracters
in test item foils but are not designed to confuse the student, and
Maximum legibility of print formats including formats that are free from
clutter and void of grayscale.

3

Suggestions for applying universal design to item development include:
•
•
•

•
•
•

Ensuring that test item writers are trained in concepts of universal
design,
Providing test item writers and reviewers with construct and constructrelated information during the construction and review of test items,
Examining each test item for universal design principles(linguistic
complexity; cognitive complexity; formatting; bias issues; modalities
of braille, large print, and audio; and response formats to be allowed),
Recommending allowable accommodations for test administration,
Re-examining all test items for fidelity to the construct, and
Field testing all test items with intended populations.

The principles of universally designed assessments are the basis for many of the
guidelines provided in this document. Additionally, the references listed at the
end of this document have been written by individuals involved in ensuring the
accessibility of materials for students with visual impairments. This document
describes guidelines that support braille, tactile graphics, large print, and audio
production of test items.

4

GENERAL GUIDELINES FOR
ACCESSIBLE TEST FORMATS
Students with visual impairments may require testing materials in regular
print, large print, braille, tactile graphics, audio formats, or some
combination of these formats. The provision of a test and related materials
in braille, large print, or audio provided an individual student should be
based on the medium used by the student, as identified in the
Individualized Education Program (IEP) document. Alternate format tests
should be used only by students who use that medium to access printed
textbooks and other instructional materials.
Students with visual impairments can be, and must be, made part of the
state's assessment program through use of accommodations that allow
them to demonstrate their knowledge and skill acquisition, as outlined in
each state's standards and assessment system specifications. Regardless of
the media chosen, students may need access to special materials such as
braille paper, bold line writing paper, talking calculators, abacuses, raised or
bold line rulers, braillewriters, slates and styluses, word processors, or other
materials and devices. A more thorough discussion of accommodations is
provided in the section on Accommodations in Testing Students with Visual
Impairments and in Appendix F.
The following general guidelines are recommended for all formats that are
developed for accommodating students with visual impairments. Various
aspects of test construction and implementation are addressed in this
section.

Contract Development
1.

2.

3.

Contracts between states and test publishers/producers must include
provisions for state approved alternate media (braille, large print,
audio editions of tests, and scripts for oral presentation of tests)
including answer sheets and practice tests.
Test publishers need to have the capability of providing the test
administration manual in braille, large print, or audio for test
administrators who are visually impaired and need accessible media.
The contract should state if test administration manuals are needed in
accessible media.
Contracts must include timelines for development, proofreading,
revising, and production of braille, tactile graphics, large print, and
audio test formats and accompanying practice materials.

5

4.

5.

6.

Contracts regarding accessible media should guarantee that each
medium of test materials and practice materials is produced by the
same entity to ensure consistency in format and graphic production
techniques. Every effort should be made to ensure consistency of
presentation from one year to the next, and from one level of the
test to the next.
Contracts may need to include specifications on tools and materials
that need to be developed or provided to test takers using alternate
media, e.g. a braille ruler, a tactile or large print protractor, or
periodic table of the elements, real money for money related test
items, or some actual objects such as a ball or cube.
Contracts may need to include plans to ship special versions of tests
separately from regular print versions so that distribution of the
accessible formats occurs in a timely manner.

Test Development
1.
2.
3.

4.

5.

Test development must ensure that test score inferences reflect
intended constructs and not disability characteristics (AERA,
2000).
The construct to be measured must be specified in documents and
made available to test item writers and reviewers and to accessible
media producers.
Availability of item specifications is essential in determining
appropriate accommodation use and in the reproduction of test
items to be presented in braille, tactile, large print, or audio
formats.
Test publishers must maintain access to experts in the media of
braille, tactile graphics, large print, and audio, who can provide
information concerning test development and transcription and
tactile graphic design, and who are able to proofread test materials
before mass duplication, and otherwise ensure that materials are
provided in a timely and accurate manner. Proofreading the braille,
large print, or audio version of the test before multiple copies are
made confirms that the material is readable and that the adapted
test follows the print copy in numbering and lettering of test items
and answer choices, and that the graphics are readable and located
correctly. The proofreader must also check for proper formatting.
Validity issues concerning all accessible formats and accommodation
needs should be discussed during test development (Phillips, 1994).
The provision of a test in accessible media should be considered a
valid accommodation as long as it retains the construct that the test
was designed to measure. If a performance item requires drawing,
consider allowing an explanation or description as a valid response
6

6.
7.

8.

option. If such a revision is allowed, scoring criteria must include
information on this option.
All directions on a test should be worded to allow for alternate
response methods. For example, use of directions like "circle the
answer" should be replaced with "indicate or mark the answer."
Specific guidelines on any test format changes, allowable
accommodations (including time allowances), and general
assistance that can be provided to the student must be stated in
the test administration manual or supplemental administration
materials.
Test item development and review committees should be made aware
of alternate media issues regarding the use of either complicated or
nonessential pictures and graphics.

Item Development and Review
1.
2.
3.

4.
5.
6.

7.
8.

Educators with specialization in the field of visual impairments
must be included in the test item development process.
All test items must be reviewed by persons familiar with visual
disability issues to ensure that no test item is biased or
discriminatory toward persons with visual impairments.
It is recommended that as much information as possible be
included in the text of a test item. This will help prevent the
introduction of pictures that contain information necessary for
selection of the correct answer, but which cannot be adequately
brailled, presented in large print or tactile graphics, or described in
audio format.
In general, use of "vision specific" language can be maintained,
e.g., "Look at the following list of animals.”
The test item pool must be large enough for bias and item review
committees to replace items determined to be biased or inaccessible
in braille, large print or audio formats, or tactile graphics.
A representative sample of students with visual impairments
must be included in any field-testing of the assessment, as
prescribed in Standard 10.3 (p. 106) of the Standards for
Educational and Psychological Testing (1999).
All practice materials must be provided in accessible format at the
same time that print practice materials are provided. Allow
sufficient time for accessible format preparation.
Provisions should be made to conduct item analyses for accessible
format test items.

7

Accessible Test Development
1.

2.
3.
4.
5.
6.

7.

8.
9.

To ensure that quality materials are developed, state assessment
programs should contract with an agency or persons experienced
in producing braille, tactile graphics, large print, and audio formats.
If a multimedia presentation is to be used by test takers, it is
important that the accessible media producer(s) coordinate presentation of the test items between each of the media.
Production of the alternate format test includes the editing, transcription, reformatting, design, and proofreading of the
alternate media.
Holding a conference call with all parties involved before the
accessible media producer begins to review/ edit the test items helps
to maximize a successful experience and end product.
The name and phone number of the customer's primary contact
person needs to be provided to the producer of accessible media
to facilitate timely production.
Accessible format producers will need access to a primary contact
person, as well as item specifications that include information
about the skill and construct being assessed.
Test items should be deleted or substituted only if the item cannot
be provided in braille, tactile graphics, large print, or audio format
without significantly changing the item and the intent of the
question. Although not recommended, some test items may need
to be omitted if they are not adaptable as determined and advised
by item reviewers with expertise in the format under consideration.
The deletion or substitution of items should happen infrequently,
particularly if educators with specialization in visual impairments
have been involved in the item development process. Attention to
universal design during test development will also reduce the
probability that a test item will have to be deleted.
If items are omitted in alternate versions, the test score
must be rescaled so that braille, large print, and audio format users
are not unfairly penalized and so that scores can be obtained for
diagnostic and accountability use. The original numbering system
should be maintained and the word “omitted” inserted in place of any
item that had to be omitted.
Responses from the primary contact person regarding questions and
requests for substitutions require a quick turn-around time in order to
ensure accuracy and timeliness of delivery of accessible media.
Substituted items should assess the same skill and have equal
value and validity. Substituted items must maintain the correct
answer in the same position as that of the original test item.

8

10. All field test items and sample questions must be included in
accessible format test versions.
11. Test contracts must indicate preferred publication strategies, such
as brailling on both sides of the braille paper (referred to as
interpoint braille), preferred methods of producing tactile graphics,
and binding of the braille test materials. Assistance with determining
these specifications is available from APH.
12. Braille tests are generally produced using contracted braille, the
typical method for producing braille in which short forms of words are
used. If the test is for a young child, a new braille reader, or
someone struggling to learn braille, a test may be needed in
uncontracted braille, whereby every letter of every word is
represented by an individual braille cell.
13. The format of an accessible media test edition must follow the
print format as much as possible. That is, ideally the number of
test items and test sections should match that of the print format,
as should the order of the test items and test sections. Deviations
from the print version of the test must be outlined in a print copy of
Test Administration Notes for the altered format. Test Administration
Notes must include reference to print versions with associated
accessible format page numbers, identify passages and items by page
(print and alternate format), and provide indication of any changes
made to the alternate format. Appendices B and C contain templates
for creating Test Administration Notes for braille and large print
formats.
14. Special requirements, such as an independent proofreading of test
materials, exact print reproductions of the braille/tactile test items,
or any print labels to be included on braille or tactile graphics need
to be considered and included in the contract.
15. APH's policy in accessible test production includes close collaboration with, and approval from, test publishers and content
specialists to ensure that edited items are acceptable as edited.
16. Test security and confidentiality standards must be upheld during
the process of developing accessible formats.

Test Administration
1.

Computers and adaptive technology, electronic note takers,
cassette player/recorders, the cassettes, CDs, etc., must be
inspected for proper functioning prior to their use during a test.
The test administrator or proctor should be instructed on how to
proceed if equipment fails or malfunctions during administration of
the test.

9

2.

3.

4.

5.

6.

Each test administrator or proctor of a student using an alternate
medium test or a combination of media should be assigned a
testing packet that includes a list of materials needed (approved
technology or other manipulatives, such as a talking calculator,
braille or large print ruler, braille paper, bold line writing paper,
raised line graph paper, etc.)
The test administrator or proctor must ensure that special
tools and materials noted on the student's IEP and used for
instructional purposes as accommodations are available, as
needed, to students in the test-taking environment. For example,
if a visually impaired student routinely uses an abacus in the
classroom when sighted students are allowed to use a pencil and
paper for computational purposes, then an abacus must be
available during a test. See Appendix D for further explanation on
the use of an abacus in test-taking situations. Specialized tools
and materials should not be provided if their use presents an
unfair advantage.
In preparation for test administration, the test administrator needs
to review the original test(s), the alternate format/s of the test/s,
the original test administration manual(s), the test administration
manual/s for accessible media, and the test administration notes
for the special format/s. These materials should be provided to the
test administrator under secure and confidential means two full days
prior to test administration. This time is needed so the test
administrator can plan appropriately for administration of the test(s)
in alternate media.
Prior to testing, the test administrator or teacher must ensure
that the test is available in a student's primary or preferred reading
medium or combination of media, and that the student has sufficient
proficiency in use of this medium and related tools such as
computers, assistive devices, CD players, or braillewriters.
If students are expected to bring select tools and materials to the test
environment, they need to be notified of this ahead of time.

10

BRAILLE AND TACTILE GRAPHICS
The information in this section describes methods for developing and
implementing assessments for students with visual impairments who
require braille text or tactile graphics. While some technology provides
auditory access to print, braille is critical to literacy and must be an
option for those students who routinely use it. See Appendix A for a
discussion of braille versus auditory access.
Generally, learning to read braille is no more difficult than learning to
read print. The tactile process is different from the visual process and
creates the following considerations:
•

•

Braille (tactile reading) consumes more time than does visual
reading, as students who read braille typically read at fewer words
per minute than do students who read print (Trent & Truan, 1997),
and
Braille reading requires tactile training in page orientation and
reading and interpretation of tactile graphics.

Designing Tactile Graphics
The following are aspects of test items that need special consideration
when reviewing and designing for production as tactile graphics:
•
•
•
•

•

•
•
•

Complicated graphics that contain multiple layers or pages of
information
Three-dimensional objects from a particular visual perspective, e.g.,
a top view of a house or pyramid
Rotation items that use letters of the alphabet (print letters
rotated or flipped)
Science items that use pictures to demonstrate
experiments and other scientific concepts or processes (cell,
digestive or muscle systems, etc.)
Map reading items that depend on visually recognizable and
unlabeled continents, countries, or states, e.g., Africa, Italy, or
Florida
Visual recognition items (interpreting a picture without supporting
text)
Items that require interpretation of complicated drawings, e.g.,
cross-sections of diagrams
Optical illusions

11

These types of items frequently require extensive revision during the
production process. For example, a text-based description in addition to
the tactile graphic may be needed. The accessible media producer may
request a test publisher to substitute such items with those that can be
made more accessible and which will retain similar, if not identical,
concepts and have the same weighted score.

Braille Translating (Transcription) Process
Consideration of the following points will facilitate the production of test
materials in braille format for students with visual impairments:
1.

2.

3.

4.

Test developers and publishers must ensure that contracts for braille
materials specify the use of braille transcribers who are certified by
the National Library Service (NLS), experienced at transcribing tests,
and knowledgeable of braille formats. Braille formats must be
modeled after those of the Braille Authority of North America (BANA)
Guidelines, found in Braille Formats: Principles of Print to Braille
Transcription, 1997.
As a test is edited for braille transcription, necessary changes will
be made to make the material accessible to braille readers.
Correct braille transcription also requires that BANA specifications
be observed. Simplification and/or labeling of some graphic material
will likely be necessary. Simplification entails the elimination of some
artistic features, removal of some superfluous material (without
eliminating distracters and other text material that is necessary to
maintain the validity of the test item), or movement on the braille
page of some text or graphic components for more efficient
readability by the braille reader (moving a scale, legend, or compass
rose on a map to a different location). Even simple tactile graphics
can be very difficult to interpret; some additional labeling may be
needed for the test taker to read and understand the tactile graphic.
Note that simplification and labeling are done relative to the
construct being tested. If during the test editing process, it is not
clear what is being tested, the test publisher will be consulted for
clarification.
Reproduced references, such as tables of content, dictionary pages or
indices, may need to be shortened in the braille test version while
maintaining correct answer choices and foils. This is done to contain
the braille item to one page, if possible.
Provision of open-ended items in braille format must indicate to
the braille reader the amount of space provided for the answer.
Directions must specify the space provided by suggesting the time
12

needed to complete the item or by indicating the approximate
page area or the number of lines or paragraphs. Generally, one page
of print is equal to about two pages of braille unless graphics are
involved which will add to the page length. Directions may indicate
that there are four print lines or eight braille lines available for
responding.
5. Unnecessary boxes and framing of material may be omitted
unless the framing provides a separation of graphic material from
text or encloses a group of scattered or randomly placed objects.
6. Specific braille codes exist for transcribing literary works,
mathematics, and science materials into braille. When brailling the
content of the print version of the test, braille transcribers must
follow the standards of code for braille transcription. These codes
are provided in English Braille American Edition, 1994; The Nemeth
Braille Code for Mathematics and Science Notation, 1972 Revision;
and Braille Formats: Principles of Print to Braille Transcription, 1997.
All three manuals are available from the American Printing House for
the Blind.
7. An experienced braille proofreader must be utilized for proofreading
all materials and, in particular, examining all tactile graphics to
ensure readability and accuracy.
8. Experienced braille readers might also need to transcribe students'
braille responses into print for scoring. See the section on Guidelines
for Braille and Large Print Test Response Transcription.
9. Braille versions of a test may include transcriber's notes (notes to the
braille reader from the braille transcriber about the use of special
symbols, and use of any special formats). Transcriber's notes must
be written in print within the Test Administration Notes for Braille
Edition (Appendix B). The number of transcriber's notes in tests
should be kept to a minimum.
10. Test security and confidentiality standards must be upheld by braille
test transcribers, tactile graphic designers, and proofreaders. This
includes the following:
•
•
•
•
•

Keeping testing materials in a secure place to inhibit access by
unauthorized persons,
Not sharing information or implying content contained in the
testing materials with other persons,
Maintaining discretion about the work being performed,
Returning all materials to the contracting source, and
Maintaining confidentiality of test content.

13

Tactile Graphics
This section offers information regarding the use of tactile graphics when
testing students with visual impairments. Graphic material, which
includes maps, charts, graphs, diagrams, and illustrations, frequently
contains information that is difficult to present in a tactile format.
Research supports the use of tactile graphics and "the idea that visual
experience and visual imagery are not required for the perception of
simple tangible pictures . . ." (Heller, et al., 2002, p. 349). It is possible
to provide many types of graphic material in braille or raised line
drawings. However, certain types of graphic materials either cannot be
provided in braille or tactile formats, or they are so complex that doing
so produces a graphic that cannot be read and interpreted by the test
taker.
Most maps, charts, graphs, and diagrams can be translated into tactile
form if the test publisher will allow some editing. Editing could involve
eliminating the shading used solely for visual effect, reducing the number
of distracters, providing two or three charts to present the same
information as one complex print chart, using text based descriptions to
supplement or replace graphics, or using symbols and words with a key
to provide information. Edits needed to convert print graphics to tactile
graphics need to be approved by test developers or publishers.
Most print materials use graphics to emphasize a point, provide another
format for information, or provide visual appeal. Because graphics are
common in text, training in reading graphic material and interpreting a
written description of a graphic are important skills for the student with
a visual impairment to learn. Guidelines for tactile graphic materials are
described on the next few pages in terms of general guidelines, design,
symbols, lead lines, labels, and indicators and scale.
General Guidelines:
1.

2.

3.

Graphics in mathematics tests must follow provisions of The
Nemeth Braille Code for Mathematics and Science Notation, 1972
Revision, BANA (1983).
Decide if a tactile graphic is needed. Omit the graphic if it is
purely decorative. Consider using a text based description to
either supplement or to replace all or part of a graphic.
Graphics should be tactually clear and contain only relevant
information based on an understanding of what is being taught

14

and what the student’s task is. Visual information that is
irrelevant to the meaning or purpose should be omitted.
4. Graphic material should be simplified without omitting needed
information or creating an unfair advantage by alluding to the
answer.
5. Picture descriptions should be presented concisely within the
student's test booklet if information in the picture is vital to
answering one or more test items.
6. Picture descriptions will appear as needed in transcriber's notes
in appropriate places throughout the test and must be included in
the Test Administration Notes.
7. Some graphics are best handled by supplementing the image
with a heading, label, description, or key. Edits must be made
carefully so that the braille reader is not unintentionally given an
advantage or cue to the correct response.
8. Consider splitting complex graphics into separate drawings
showing layers of information, unless this adds complication for
the test taker.
9. In general, use texture to add information and draw attention to
select parts of a tactile graphic.
10. When necessary, to avoid confusion and accentuate important
information, use different areal symbols (texture) to differentiate
between bodies of water and land on maps.
11. Charts and graphs should be confined to one page when possible.
If graphics and the accompanying test item require more than
one page, use facing pages to present graphics and the
accompanying test item if possible.
12. If a braille test taker is asked to produce a graphic as part of the
test item, such a task can be achieved through the use of tactile
graphic materials that are familiar to the braille reader. Another
option that may be acceptable to test developers is for the
student to describe or explain data or other information. This
option must be approved by the test contractors and included in
the scoring criteria. The test administrator and the braille
reader’s teacher, using the braille reader’s current IEP, must
collaborate prior to the administration of the test to ensure that
appropriate materials are provided. For the purpose of scoring,
student-produced graphics will need to be hand-scored or
transcribed into a print graphic by persons familiar with braille,
braille readers, and the content area being tested. See section
on Guidelines for Braille and Large Print Test Response
Transcription.

15

13. An experienced braille reader must proofread all tactile graphics
prior to mass production of the braille test to ensure readability
and accuracy.
(Kapperman, G., Heinze, T. & Sticken, J., 2000; Poppe, K. & Otto., F. 2002; Ross, D.
B. & Robinson, M. C., 2000; Spence, D. & Osterhaus, S., 2000)
Design:
1.
2.
3.
4.
5.
6.
7.

Avoid clutter and simplify.
“Clutter” occurs when different symbols and lines are so close or so
similar that they become hard to distinguish. Spacing is the key to
avoiding clutter.
Symbols and lines closer than ¼” may be difficult to differentiate,
depending on the medium and tools being used.
Shapes with sides less than ½” long may not be recognizable.
Use different textures for lines so that test takers know which part of
a line to follow when two or more line segments cross or meet.
“Simplify” means to eliminate unnecessary elements of the original
picture. Focus on the relevant parts and omit details that are purely
decorative or distracting.
When the print picture includes people, animals, objects, etc., replace
them with simple lines, symbols, and/or labels (e.g., use the label
“hand” instead of drawing a hand or use a triangle instead of a cat or
dog).
Symbols (Lines, Points, and Textures):

1.

Limit the lines, points, and symbols on a drawing to those that can be
easily differentiated by touch. Use the most prominent symbols for
the most important features in the graphic. Avoid high or “noisy”
texture, which draws attention away from the key features.
2. Be consistent in using symbols within graphics of the same type
within the same transcription (e.g., always use the same symbol for
water on maps).
3. Use different tactile symbols for different types of information (e.g.,
in a map of the United States, the tactile line used to indicate state
borders should differ from the tactile line used to indicate
international borders).
4. Lines, points, and braille must be physically separated by at least
1/8”.
a. This distance may need to be extended to at least ¼ inch depending
on the medium and symbols used.

16

b. Apply the 1/8 inch separation rule to all features that are separate,
even if doing so introduces some spatial distortion.
Lead Lines:
1.

Use lead lines only as needed; options for lead lines include use of
keys or notes.
2. Avoid using arrows as lead lines.
3. The linear symbol used for lead lines should be different from any
other lines used in the graphic and should be tactually distinctive but
less prominent, such as a low relief raised line.
a. A lead line should begin as close as possible, without causing
interference, to either the first or the last letter in the label, and it
should end as close as possible to the feature being labeled.
b. In general, a lead line should not cross over another line. When this
is unavoidable, it may make the graphic more readable by breaking
the lines of the graphic to allow the lead line to “pass through.”
Labels and Keys:
1.
2.

3.
4.
5.
6.
7.

Explain and define all graphic symbols.
Identify all important features (e.g., capitals, bodies of water, etc.) of
the graphic, even when not labeled in the print version. Place titles
at the top of the page. Avoid making unlabeled graphics. Exceptions
may exist in some testing situations.
Position labels closely to the objects to be identified to better ensure
recognition. Single letters on the graphic should be preceded by
either the letter sign or the capital sign.
Use two-letter U.S. postal codes where applicable (and other twoletter codes where postal codes are not applicable) for labeling state
names on maps.
Words in labels need not be capitalized if their meaning will not be
confused and rules of punctuation are not violated.
Place all abbreviations in a key and place the key above the tactile
graphic.
Present all braille labeling within tactile graphics horizontally.
Indicator and Scale:

1.

Graphics depicting measurements must maintain accurate and true
proportions to match the answer choices. If answer choices must be
changed, the correct response must be located in the same position
as the original correct response option.

17

2.
3.

Position scale and other indicators as consistently as possible,
preferably above the accompanying tactile graphic.
When it is necessary to change the scale, this fact may need to be
indicated in a transcriber’s note.

18

LARGE PRINT TEST FORMATS AND GRAPHICS
Some students with visual impairments read regular print materials and
enlarge the print, as needed, by using optical devices. Some read large
print materials. This section offers information regarding the development and implementation of assessments for students with visual
impairments who require large print materials. Generally, two popular
methods exist for enlarging tests. The regular print test can be enlarged
through photocopying, or an electronic version of the test can be
manipulated to reformat test items and enhance the readability of text
and graphic as needed. The latter method is preferable unless issues
outlined in this section have been addressed during the test development
and the regular print test has been designed using universal design
principles. Manipulating an electronic version of the test can best yield a
large print version that incorporates the optimum reading mode for the
student who uses large print.
Generally, reading skills that are difficult for a person with low vision who
reads print include the following:
Reading at a speed commensurate with regular print readers,
Reading for extended periods of time,
Visual scanning and skimming of text,
Shifting gaze from a picture or graph to test item and back
again,
Shifting gaze from test booklet to answer sheet documents,
Visually capturing an entire picture,
Moving from one line of text to the next,
Locating pictures and text presented in random locations on
page,
Interpreting pictures (particularly complex pictures),
Differentiating between subtle colors and patterns used in
pictures or graphs, and
Filling in answer choices on regular print answer documents.
Consideration of these points, particularly in relation to universal design
of test format and printed text, will facilitate the production of test
materials in large print format. As well, most of these guidelines are
applicable to regular print tests that may be used by students with low
vision. Information provided on font, spacing, shading and contrast,
pagination, and test booklets is a summary of work done by Elaine
Kitchel, presented as "Reading, Typography, and Low Vision," a PowerPoint
presentation (APH, 2002). Research completed by G. E. Legge et al.,

19

(Reported in "Psychophysics of Reading" 1985 through 2002 in Vision
Research) supports the guidelines listed in the following section.

Test Format
1.

2.
3.
4.

Large print versions of a test and test practice materials should be
reformatted from the regular print version so that adaptations can be
made to font style, print size (point size), line length spacing,
shading, graphics, and the number of items on a page.
Text should consistently begin at the top left-hand side of a page.
Titles of pictures or graphs should appear at the top of the graphic.
Labeling should be presented horizontally rather than vertically as a
general rule. Exceptions may be labeling of y-axes on graphs, etc.
Items that typically present the most difficulty during conversion to
large print format include the following:
Complicated, multi-shaded drawings with extensive details,
Grayscale drawings that provide little contrast,
Colors that cannot be differentiated by persons with color
blindness,
Large maps that cannot be contained on one page if enlarged,
Extensive charts with multiple columns, and
Charts and graphs that extend over several pages.

5.

If testing materials are enlarged merely through photocopying
(not recommended), the font size will vary depending on the original
print font. When tests are enlarged, the font size of all text,
including labels on graphs, rarely meets the 18-point size required.
Enlarged materials must be reviewed and proofread before mass
copying or distribution to ensure that print and background contrast
are adequate, that pictures and graphs are readable and complete on
the page, and that items assessing measurement are accurate and
have viable answer choices.
Fonts

1.
2.
3.

Print measuring 18 points or larger is considered large print. Point
sizes between 12 and 16 points are considered enlarged print.
Occasionally a test in a print size larger than 18 point will be
requested. In such cases, the publisher must determine if material
can be adequately presented in a larger point size.
Decisions about the size of print and font style must be made by
the test publisher and discussed with a person who has knowledge
of large print use and the intended test takers.

20

4.

5.

6.

7.

8.

Font styles that are decorative or cursive should not be used.
Standard sans serif fonts with easily recognizable characters are
recommended. Verdana, APHont, Arial, Antique Olive, and Helvetica
are reliable choices for readability. Note: APHont, a font for people
with low vision, developed by the American Printing House for the
Blind (APH), embodies characteristics needed by low vision readers as
identified by research. A free version of APHont is available from APH
at http://www.aph.org/products/aphont_get.html.
Large print should have x-heights (distance from the top to
bottom of a lower case “x”) and t-heights (distance from the bottom
of the "t" to the cross bar of the "t") of at least 1/8" with a
thickness of 2 points. Eighteen point Verdana, APHont, Antique
Olive and Helvetica meet this standard.
The use of bold print, underlined print, or quotation marks for
highlighting text is preferable to using italics. Italics should only be
used when absolutely necessary. Sample test items, if provided,
should be presented in the same font size and style as that used for
the actual test items. Letters incorporated into math problems, e.g.,
letters within algebraic equations, are also more readable when
displayed in a non-italic, sans serif font.
Headings and subheadings (captions, titles of diagrams and charts)
should be larger and bolder than other print and set in a font style
that differs from that of the general text. Acceptable typefaces for
this use include Arial Black, Helvetica Black Bold, Lucida Sans Bold,
Era Bold ITC, Verdana Bold, Antique Olive Bold, and Helvetica Bold.
All text, including labels and captions on graphs, pictures, diagrams,
maps, charts, equations, exponential numbers and letters, subscripts
and superscripts, notes, and footnotes, must be presented in at least
18-point type, in order to meet the APH definition of large print
(Kitchel, 2001).
Spacing

1.
2.
3.
4.
5.

Leading or spacing between lines should be at least 1¼ spaces to
allow persons with low vision to effectively move from line to line
in the text.
Block style formatting and 1" margins are recommended.
Format should include justification of left margins, and unjustified
right margins (rag right) for ease in reading and transferring from
line to line. Avoid the indentation of paragraphs.
Avoid dividing words between lines.
Columns of text, excluding graphic material, should be at least 39
characters in line length. Generally, for efficient reading, columns
should be avoided.

21

6.

7.

Test items and accompanying diagrams, pictures, and graphics
should be located close to each other and on the same page if
spacing permits. If this is impossible, test questions, diagrams, and
answer choices should be placed on facing pages or follow closely so
that page turning is reduced to a minimum.
Research indicates that readers with low vision and readers with
normal vision read a wide-bodied font faster and with better
comprehension than they read a variable-spaced font (Mansfield, &
Legge, & Bane 1996).
Shading and Contrast

1.
2.

3.
4.

5.

Grayscale and shading should be avoided, particularly when
information needed for answering a test item is provided.
The highest possible contrast should be used for text and background, with attention to the use of color. Certain color combinations other than black and white may be unreadable to
persons with low vision or persons with color blindness. A good
rule of thumb on use of colors is to use colors that are far apart on
the color wheel and avoid using colors that have similar saturation
(color depth). Blue and yellow, for example, provide a high degree
of contrast when used together. Red and green should be avoided
because they are the most troublesome colors for persons with color
blindness.
Large print must not be used over a background design or other
graphic material.
Glossy paper may cause unnecessary glare. Dull finish paper in white,
ivory, cream, or yellow is recommended and best complemented
with black print.
Unnecessary boxes and framing of material should be omitted unless
the framing provides a separation of graphic material from text or
encloses a group of scattered items.
Cautions for Use of Recycled Paper

Whether recycled paper is appropriate or not for use by individuals
with low vision depends on its color and its thickness. The color
cannot tend toward gray, blue, or green. If it is slightly gray, blue, or
green (and many recycled papers are) it can substantially reduce
contrast. What seems like a minor contrast difference to a sighted
person can be a big contrast difference to a person with low vision.
However, if the tint of the paper tends toward beige, peach, pink, or
yellow then it would be fine. In addition, there should be no speckles

22

in the paper. Best color choices for recycled paper would be cream,
beige, or white. Finally, the paper should be thick enough to prevent
bleed-through of inks. The paper needs to be thick enough to allow
printing on both sides of the sheet with no bleed-through. The same
cautions apply to materials for persons with color blindness or color
vision deficiencies (Kitchel, 2009) (see section on color vision issues
below).
Pagination
1.
2.

3.

Repagination of original test materials is preferable to increasing the
overall page size.
While double-sided pages are generally preferable, avoid double
sided copying if print will "bleed" or show through or otherwise
obstruct clear reading.
Where blank pages must appear, type the words "Blank Page"
near the top left hand side of the page.
Format of Test Booklets

1.
2.

3.

Depending on test length, large print copies may need to be
separated into several booklets.
Generally, the test booklet should be no larger than 9" x 12",
particularly for young students as well as other students with various
physical conditions.
The binding of the large print booklet(s) should allow each page to
lie completely flat for whole page viewing and ease of handling.

Large Print Graphics
The following guidelines provide information concerning the use of
graphics in testing students with visual impairments who use large print
formats. Work by the Large Print Atlas Focus Group (2001), who met at
the American Printing House for the Blind, is included in this discussion.
The complexity of some graphic materials prohibits their being provided
in large print unless they are modified to become more readable when
enlarged. Most maps, charts, graphs, and diagrams can be enlarged if
the test publisher agrees to some editing. Editing could involve the
elimination of shading, the reduction of some distracters, the insertion of
a key, or the separation of one chart into two or three.
Guidelines for large print graphics include the following:

23

1.
2.

3.

4.

5.

6.
7.
8.
9.

10.
11.
12.
13.
14.

15.

Graphics in large print must exhibit good contrast, clarity, and
accurate details and information.
No test item should rely solely on a picture for information
needed to answer the test item. In consideration of universal
design, include a text description of every non-text item.
Generally, pictures should be retained in the large print format.
Editing for shaded material and clarity may be necessary. Some
pictures that would need extensive editing and provide little or no
cues for the large print reader may be considered for elimination.
Purely decorative graphics should be deleted.
Overlaid print on a diagram or graph should be avoided. While
visually pleasing in some instances, this technique is difficult for
persons with low vision to read.
Multi-color graphs that use closely related colors may conceal
vital information from the test taker who is unable to
distinguish between the colors. Two to three contrasting colors
or black and white are recommended.
All graphs should contain short, descriptive headings or titles.
Compass points, numbers, and vital information on graphs must
be enlarged sufficiently for the low vision reader.
Map symbols must be easily distinguishable and relevant.
Map legends should appear near the top left hand corner of a
map, if possible, and include a visually distinctive border. Use
contrasting colors and distinguishable symbols rather than
reproducing different sizes of the same symbol.
If possible, map scales, too, should be positioned near the top
left-hand corner of the map.
Labels should be arranged within the boundaries of the country or
state borders whenever possible.
Symbols used should be reasonable and meaningful
representations, e.g., a fish for fishing.
Boundaries between countries should be bolder and thicker than
boundaries between states or provinces on a map.
Pictures and graphs used in test questions requiring measurement
must be true to the size intended in order to ensure that a
correct answer is available.
Test publishers and contractors will need to address the degree of
accuracy that is expected for questions involving measuring or
drawing. For example, some large print readers may not be able
to distinguish between 7/16" and 8/16" on a ruler. If at all
possible, specially designed measurement devices, such as large
print rulers and protractors, should be provided for students in
both the classroom and testing situations.

24

16. If a graph or table does not exceed one page in the original
materials, then the large print version should be edited to fit on
one page, if possible. Pertinent information and distracters must
be maintained.

25

USES OF COLOR FOR SIGNAGE, GRAPHICS,
TEXT, TESTS AND POWERPOINT
PRESENTATIONS TO BE VIEWED BY PERSONS
WHO ARE COLOR BLIND OR COLOR
VISION DEFICIENT
Introduction
Color is critical to the conveyance of meaning in signage, graphics, text,
PowerPoint® presentations, tests, and other written presentations.
However, some people, specifically those with color discrimination difficulties,
need special consideration when color planning for educational purposes.
Virtually all color-deficient individuals have varieties of red or green
deficiency. (Blue deficiency is rare indeed, with only about .001% of the
population having it.) Color blindness is normally diagnosed through clinical
testing by a licensed practitioner.
PROBLEMATIC AREAS
When one considers educational materials for students who are color blind or
color deficient, some problematic areas come to mind:
Use of gray-on-gray bubble sheets on test answer sheets
(scannable answer documents)
Maps with indistinguishable adjacent colors, such as coloring Spain
brown and Portugal green
Graphs with indistinguishable adjacent colors
Use of text over graphic backgrounds, as when a poem or other
text is superimposed over a photo or drawing
Test questions which depend upon color identification for correct
answers
PREPARATION OF MATERIALS FOR PERSONS
WHO HAVE COLOR VISION DEFICIENCIES
Color is one of the most important aspects of visual communication and can
be employed to generate interest or to communicate ideas or feelings. Yet
colors for an audience with members who have color discrimination problems
should be selected carefully to avoid conveyance of unintended meaning.
This is especially true in educational and testing materials. Many of these
materials rely on good color perception for the interpretation of graphs,
26

charts and illustrations. Yet even the most carefully thought-out graphic may
lead the user to an incorrect answer because of poor color selection.
Select colors carefully. Besides black and white, most color blind
individuals can only see two colors, blue and caramel (golden brown).
Red, yellow, orange, and green take on shades of caramel; purple takes
on shades of blue when viewed by a person with colorblindness.
Less is more. Too many colors used thoughtlessly can confuse and
negate the message of a graphic. Settle on four or fewer colors and stick
with them. Black and white are counted as colors when designing
graphics, even though they are not usually considered colors when
talking about vision.
Use contrasting colors. Contrast is an important influence on the
legibility of graphics, especially for persons with color discrimination
problems. Substantial contrast, i.e., the use of dark values with light
values, between the color of the foreground and the background should
be employed. High contrast makes materials easier to read by both
persons with colorblindness and those with typical vision. Light letters on
a dark background or dark letters on a light background are most
legible, but remember the actual colors of those combinations are
important.
CONTRASTING COLORS APPROPRIATE FOR PERSONS WITH COLOR
PERCEPTION DIFFICULTIES
(in order of best contrast value)
Use
Use
Use
Use
Use
Use
Use

black and white.
dark blue and white.
black and bright yellow.
dark blue and bright yellow.
dark brown and white.
pale blue and black.
yellow and purple.

Notice that yellow is recommended as a common color for graphics to be
used by persons with poor color discrimination. This is because yellow
maintains luminance longer than any other color. Even though it is perceived
as a light caramel color by persons with color blindness, it holds its
brightness longer than any other hue, and therefore maintains its contrast
when paired with a dark color.

27

COLOR COMBINATIONS TO BE AVOIDED
Avoid
Avoid
Avoid
Avoid
Avoid
Avoid
Avoid
blue.
Avoid

gray with any color, even another value of gray.
red with any color except white or blue.
green with any color except white.
brown with any color except white or blue.
purple with any color except yellow or white.
orange with any color except blue or white.
two values of the same color, such as light blue and dark
a neutral color with any other neutral color.

The importance of proper attention to color selection cannot be overlooked
when developing tests for individuals or groups that have color vision or
color perception deficiencies.

28

GUIDELINES FOR AUDIO
VERSIONS OF TESTS
This section is written to provide assistance in the development and
implementation of accessible tests for students with visual impairments
who require audio versions of a test. Audio formats include cassette tape,
video, CD, computer-based, or spoken (read aloud) test versions. When
an audio version of a test is administered, the audio version should be
accompanied by a print, large print, or braille version of the test, or a
large print or tactile graphic supplement at the very least. In this multimedia approach, a student can access illustrations or other visual
material that may not be described, or only minimally described, on the
audio version of the test.
Some illustrations can be described orally in an accurate manner, while
other graphic material cannot be described without revealing the answer
or providing an unfair advantage to the audio user. A complete script for
audio versions should be written with the assistance of a content expert
and provided to test administrators.
Audio versions of a test serve to standardize oral delivery of the test
content and may reduce the number of school staff needed for proctoring
or administering tests orally. Consideration of these points will facilitate
the production and administration of test materials in audio format. (See
Appendix A for a discussion regarding braille versus auditory access.)
Production of Audio Tests

1.
2.
3.

4.

Test publishers may only have the capability of providing one version
of a test in audio format. The version selected should be parallel in
content and difficulty to other versions.
An experienced test editor should be involved in editing for an audio
presentation of a test. The audio edition will need to be coordinated
with other media in which the test will be provided.
Audio versions should be developed using the resource The Art and
Science of Audiotape Book Production published by the National
Library Service for the Blind and Physically Handicapped, Library of
Congress. Requirements for narrator, monitor, and proofreader are
provided in this document.
The National Braille Association in Tape Recording Manual, Third
Edition (1979) provides instructions for reading mathematics
instructional materials. This source recommends that graphic
materials be described, if possible, and accompanied by print or
tactile versions of the graphics. Such modifications need to be

29

5.
6.

7.

8.

9.

10.
11.
12.
13.

approved by the test publisher. Moreover, the audio descriptions,
print, and tactile versions of the material need to be coordinated. If
different departments within the same company or different vendors
are responsible for developing and producing the accessible media,
one source should be responsible for ensuring that the media are
coordinated to the extent specified.
Narration of print materials must follow National Library Service
(NLS) specifications of minimum acceptable requirements
(Specifications #300 and #304).
Test publishers must ensure that narrators follow confidentiality and
security assurance standards of test materials. Security measures
taken when working with audio formats should mirror those required
for handling print or braille materials (Kentucky Core Content Test
Administration Manual Supplement, 2000).
Test publishers must give attention to packaging and labeling of the
audio test. Audio tests may be packaged for each individual student,
with the appropriate print and/or braille supplements needed by the
student and the test administrator.
Ascertaining whether the audio format will be administered on an
individual basis or in a small group setting is important, as the
information on the audio format and the information to be provided
by the test administrator may vary depending on the setting.
The audio test should instruct the student to stop at certain
points. Audio procedures must ensure that test takers work only on
allowable sections of the test. For example, selected subtests may be
recorded on separate cassette tapes or CDs and then collected as
required.
Directions for navigating through the audio version should be
provided in print for the test administrator.
Test publishers must select an experienced narrator with appropriate
voice, speech, accuracy, and pronunciation skills. (Pronunciation
resources are available from NLS.)
Narration must be evaluated and proofread to ensure that test
content is conveyed accurately and that questions are presented
without unintended emphasis on correct answers.
A person with identical test materials should monitor the narrator to
ensure accuracy during audio production. A third person should be
used for the proofreading of audio materials.

30

Administration of Test Items in Audio Formats
1.
2.

3.

4.

5.

Students using audio versions of a test should have had an adequate
amount of experience using the specific audio medium and audio
equipment independently before the testing situation.
Test administration materials should indicate the equipment
required by the student for using audio versions of a test. For a
cassette tape version of a test, a standard two-track tape player/
recorder and headphones will be needed. An audio test on CD will
require use of a common CD player or a digital talking book player,
depending on the audio file type of the CD. Regardless of the player
used, a backup player capable of playing the same audio medium
should be available. Access to electrical power or sufficient batteries
for player/recorder use should be indicated. Test administrators
should be instructed to inspect the equipment functions before
testing begins.
Test administrators will need to monitor student "movement"
through audio versions to ensure that the student maintains the
appropriate place in the test and to ensure that the audio version is
playing properly. When using a two-sided cassette tape, students
may need to be reminded to play the other side of a tape. Prior to
administering the test, and in the absence of students, test proctors
should spot check audio formats to ensure proper operation of the
audio medium and equipment.
Students using an audio version of a test must be seated in a quiet
area and away from other students so that other students are not
disturbed by the audio medium or equipment operation. Students
can choose to use headphones.
Provisions must be made in the test administration manual for the
malfunctioning of audio equipment. Students may have to be tested
at a later time if malfunctioning occurs. Students must not be denied
access to the administration of a test because of equipment
malfunctioning or failure.

31

GUIDELINES FOR ORAL READING OR
SIGNING OF A TEST
Students who are visually impaired or deafblind may need the accommodation of a reader or sign language interpreter. Occasionally, an audio
version of a test is not produced, and a test publisher, developer, or
assessment personnel will allow the reading or signing (use of sign
language) of a test or portions of a test for students whose Individual ized Education Program (IEP) specifies this accommodation. Before using
oral reading or sign language as an accommodation, careful attention
must be given to the constructs being measured. For example, if a
section of the test is designed to assess reading as a decoding skill, then
the reading or signing of the test to a student would invalidate the results
for the intended purpose. In these instances, consider an alternate test
or redefine the construct for the individual student. Always check with
the test publisher or test developer to determine the construct intent
and accommodation use for particular sections of a test.
State policy dictates if passages and stimuli can be read aloud and/or
signed for large scale statewide assessments. Check with the District Test
Coordinator or with the State Department of Education assessment office
for the policy in your state.
For the oral reading or signing accommodation to be allowed on statewide
assessments, a student must have had exposure to and have used this
accommodation during daily instruction and on classroom tests. This is
especially true when mathematical symbols and technical or contentrelated language is being read and accessed. It is recommended that a
student have access to print or braille graphic material even if the reading
or signing accommodation is used.
The Educational Testing Service recently posted on their web site ETS
Guidelines for a Test Reader (July, 2000), which have been made available
in Appendix G of this document through special permission from ETS. This
document is helpful in outlining the characteristics of a good reader,
providing general information for readers, indicating special considerations for multiple-choice tests, addressing mathematics reading, and
providing test center procedures for using a reader. In addition,
consideration of the following points will ensure appropriate provision of
oral reading or signing of a test or portion of a test:
1.

Test security and confidentiality standards must be upheld.

32

2.
3.
4.
5.

6.
7.
8.

9.
10.
11.
12.

13.
14.

The test purpose must be specified to ensure that reading or signing
a test or portions of a test do not invalidate results or preclude how
the results will be reported.
An experienced test editor and professionals involved in working with
students who require readers or interpreters need to be included in
the team of persons that adapt tests which are to be read or signed.
A prepared script must be provided for test administrators to ensure a
consistent, standardized presentation of the test items.
A reader or sign language interpreter must have skills in
presenting various types of test materials. For example, someone
familiar with mathematical symbols is needed in order to correctly
read and convey higher level math formulas and equations.
A standard video presentation of the test in sign language is
recommended to ensure quality, consistency, pacing, and accuracy.
The person selected to read a test to a student should have the
characteristics of good voice quality and appropriate speed and tone.
The person signing a test must be a trained interpreter and be able
to translate in the same method of sign language typically used by
the student. It is not recommended that the student's teacher be
the interpreter for the testing situation unless a second person is
present to monitor for quality and fairness during administration of
the test.
Voice inflection (regional dialect and pronunciation) familiarity is
recommended.
The narrator or interpreter must avoid voice inflection that stresses
or otherwise indicates the correct answer.
The interpreter must avoid facial expressions and body language that
may cue the correct response.
Students tested through oral reading of the exam must be tested
individually to prevent the testing situation from becoming a group
effort. Moreover, testing individually helps ensure that each student
receives the specific oral reading structure required by his or her
individual needs.
Directions can be read or signed to groups of students.
The interpreter or reader must be allowed to review test
administration materials and items on the test to ensure that they
have knowledge of the vocabulary/signs required for that
assessment. This is important so that the reader/interpreter does
not accidentally cue the correct response. The reader/interpreter
should have access to pronunciation dictionaries, sign language
dictionaries and technical skills manuals to use as references. It is
important that the reader/interpreter sign a confidentiality agreement before reviewing the materials to ensure test security.

33

15. Oral readers and interpreters will need to pause at appropriate
intervals to provide the student an opportunity to answer test items
or access graphic material provided in print or tactile formats.
16. Graphic materials may be described as detailed in the prescribed
script, but must also be made available in print or tactile formats.
17. Oral readers or interpreters must avoid providing an answer to a
student's question concerning clarification of testing content. Doing
so would provide an unfair advantage. Developing some standard
responses to students' questions prior to the testing situation is
helpful. For example, you can encourage the student to listen to or
watch the signing of the question again.
18. Readers or interpreters may need to provide multiple readings or
signings of passages, parts of passages, or items. Unless instructed
otherwise in the Test Administration Manual, professional judgment
and any guidance provided in the IEP should be used to determine
the number of readings necessary.
19. If the oral reader or interpreter is also completing an answer sheet
for a student, the transfer of answers must be performed carefully to
ensure that the student's answers are recorded as intended. See
section on Guidelines for Braille and Large Print Test Response
Transcription.
20. Two readers or interpreters should be used for presenting a test or
portions of a test to a student. Using two readers or interpreters
helps ensure accuracy of test presentation and provides the
opportunity for readers or interpreters to rest after 15-20 minutes
of presenting test material.

34

ACCOMMODATIONS IN TESTING STUDENTS
WITH VISUAL IMPAIRMENTS
The use of accommodations during testing is intended to level the
playing field for any student with a disability. There are, by nature of
the disability, certain accommodations that are needed by students
with visual impairments. Not all of them discussed in this section are
intended for use by all students with visual impairments. Likewise,
some needed by students with visual impairments may not be
presented here.
Accommodations and various technologies exist to provide learners
with visual impairments access to academic instruction and tests. The
term “technology” comes under the definition of assistive technology
as described in federal law and is considered an accommodation to the
testing of students with visual impairments.
The need for one or more accommodations is the decision of the
Individualized Education Program (IEP) team and must be recorded on
a particular student’s IEP. Accommodations used during testing should
generally match those used by the student for classroom instruction,
assuming they are familiar and effective for the student. Their use is
determined by evaluating factors unique to each student and must be
implemented as outlined on the IEP. Evaluation of their effectiveness
for an individual student is highly recommended. Further, students
must be trained to use accommodations. For example, providing a
test orally by a qualified person or on computer might actually penalize
a student who has not been trained to listen to orally presented
material or trained to use a computer for assessment.
Accommodations should be periodically evaluated to ensure that they
are still effective for the student. Some may need to be eliminated or
revised when and if the student arrives at a point where he or she
either does not need the accommodation, it is ineffective, or it is not
the most effective option available. If an accommodation is needed by
a student and is not on the list of those approved for state use, the
local test administrator should contact the state assessment office to
request a review of its use.
The next segment presents general as well as specific accommodations
for test takers with visual impairments who use braille, large print,
and/or audio formats. See Appendix F for additional information on
this topic.

35

Types of Accommodations for Students
with Visual Impairments
Presentation Accommodations
1.

2.

3.

4.

5.

Braille, large print, and audio are accommodations that some
students with visual impairments will use interchangeably. A student
may, for example, read a passage in braille and prefer to access a
table or chart in an enlarged version of the test. Therefore, students
should be allowed to use a large print (or regular print with
magnification) and a braille version of the test, if requested.
Some students who are visually impaired may need to have read to
them the test directions or some of the test items, as long as those
items read do not assess reading as a decoding skill. See section on
“Some Guidelines for Oral Reading and Signing of a Test. “
Computer-administered testing is an accommodation that has
received some attention through research, though studies
concerning its benefit are inconclusive (Tindal & Fuchs, 1999).
Generally, however, when a student uses a computer for daily
classroom activities, then this accommodation may prove useful
during testing if the concepts being tested are not undermined. There
are several programs and peripheral materials that can be used to
adapt the computer for use by persons with visual impairments.
Screen readers, text to speech technology, and keyboard access
through braille or switches are available. Depending on the construct
being tested, test administrators must verify that the student is
inhibited from accessing software or hardware that may provide an
unfair advantage. For example, if a student's basic math skills are
being assessed and the intent is not to use a calculator, then the
keyboard functions or software used for computations must be
blocked.
When testing allows the use of non-scientific or scientific calculators,
students with visual impairments should be permitted to use an
equivalent device that has been adapted for use by a visually
impaired user. Should a state provide non-scientific or scientific
calculators for the sighted population taking the test, then nonscientific or scientific, talking calculators should be provided to
students with visual impairments who are taking the test.
An abacus is often useful for students when mathematics problems
are to be worked without a calculator. The abacus functions as paper
and pencil for some students with visual impairments who have
received instruction and practice on the use of the abacus. See

36

6.

Appendix D for the position paper "Use of an Abacus in Test-Taking
Situations."
Students may want to use manipulative devices, such as a ruler or
template, to maintain placement on a line of braille or print. Other
tools available for use by visually impaired students include braille or
large print rulers and protractors, raised line or bold line graph
paper, or raised line or bold line writing paper, to name a few.
Contact the American Printing House for the Blind (APH) toll free
at 1-800-223-1839 to request a catalog of available accessible
materials, or visit APH on the Internet at www.aph.org.
Response Accommodations

1.

2.

3.

4.

Students with visual impairments may need to present answers
orally to a test administrator who completes the answer sheet. See
section on Guidelines for Braille and Large Print Test Response
Transcription.
Students with visual impairments may need to write answers in the
test booklet or on separate paper using a braillewriter or slate and
stylus.
The student's answers must then be transcribed and transferred to
the answer sheet. See section on Guidelines for Braille and Large Print
Test Response Transcription.
Students may need to write answers using a word processing
program, to be transferred to the answer sheet. Depending on the
construct being tested, test administrators must verify that students
are inhibited from accessing software or hardware that may provide
an unfair advantage. For example, if a student is responding to a
writing prompt and the writing will be judged based on correct
spelling and grammar, then the spell check function and grammar
functions must be disabled.
If a student must draw or somehow demonstrate a response, then
accessible tools and materials that are typically used by the student
for instructional purposes must be made available in the testing
environment as long as no unfair advantage is provided. For this
type of open response item, it is very important that scoring criteria
be well defined and allow for variation in response methods.
Timing Accommodations

1. The use of extended time for test completion is a testing

accommodation that has received considerable attention since state
testing and accountability systems have been implemented. Research
investigating the use of extended time has yielded little conclusive

37

2.

3.

4.

information about its benefit (Tindal & Fuchs, 1999). However,
students with visual impairments will usually require extended time
during testing because using braille, print, and audio formats require
more time than does reading print with acceptable visual acuity. A
study by Wetzel and Knowlton (2000) suggests that experienced adult
braille readers may need no more than 50% more time than the
stated duration, with additional time allowed for the manipulation of
an audio device or the marking of an answer sheet. In contrast, an
earlier researcher found that braille readers with far less braille
reading experience than the subjects mentioned in the Wetzel and
Knowlton study may need between 2 and 3 times as much time as
their sighted peers to read the same material (Nolan, 1966, p.1).
Traditionally, extended time for testing readers who are visually
impaired has been 1½ times, and for braille readers time allotted has
been 2 times the amount allowed for regular print readers
(Lowenfeld, Abel, & Hatlen, 1969, pp. 91-92). Regardless of the time
allowed, the student should be carefully monitored to ensure that time
is being used appropriately. If students need an inordinate amount of
time, educators may need to investigate the efficiency of the chosen
reading mode or initiate remediation to improve speed. Generally,
timing accommodations should be individualized according to the test
taker's reading rate and testing situation (Wetzel & Knowlton, 2000).
See Appendix E on the "Use of Extended Time."
Reading braille, print, or listening to material presented orally,
especially when accompanied by graphic material, can be a fatiguing
and often frustrating experience in a high stakes testing environment
for students with visual impairments. Therefore, students may need
several brief sessions in which to take the test. Additional break
options should also be considered.
Students may need to be tested over a longer time period, a week
rather than two days, for example. However, any alteration of the
timetable will necessitate close supervision to ensure test security.
Students may need to be tested at different times of the day
depending on their optimal functioning time.
Setting Accommodations

1.

2.

Some students with visual impairments may need to be administered
a test or select subtests individually, or in small groups as
recommended on their IEP, to ensure that the test accommodations
needed by the students are implemented without interfering with
the concentration and test taking results of other students.
If a student is recording answers by using technology that is noisy or
is recording answers orally, then he or she must take the test

38

individually and under the supervision of a test administrator in order
to avoid distracting or influencing the responses of other students.

Specific Accommodations in Testing Readers Who
Require Enlarged or Large Print
Enlarged print is that which is 14 point, 16 point, or regular print that
has been enlarged using magnification devices. Large print is 18-point
type and larger. Enlarged print and large print are accommodations.
Some students may choose to use a regular print test and enlarge it
manually with a magnification device with which they are familiar.
Magnification devices include eyeglass-mounted magnifiers, free standing
or handheld magnifiers, and electronic equipment such as the closed
circuit television (CCTV) or a computer that has text enlargement
software installed. These devices do not provide a student with an unfair
advantage. Rather, they are devices that the student requires to access
print, and they should be allowed as standard accommodations.
Proper lighting and freedom from glare, while sometimes overlooked, are
critical for many readers with visual impairments. Lighting that has been
adjusted to suit the student's particular visual needs and minimize glare
will help promote sustained reading efficiency.

Specific Accommodations for Audio and Oral Test
Administration
Students using an audio version of a test or having the test orally
administered as an accommodation should also be allowed to have print
(large print or regular print with a magnification device) and braille
versions of the test, if requested. A student may wish to listen to a
passage by way of audio, but access a table or chart in a large print or
braille version of the test. Listening to an oral description of a geometric
figure can be difficult or impossible to follow unless an enlarged graphic
or a tactile graphic accompanies the oral description.

39

GUIDELINES FOR BRAILLE AND
LARGE PRINT TEST RESPONSE
TRANSCRIPTION
Some students with visual impairments will use the accommodation of
oral response, written response (on the test booklet or on paper other
than the test answer sheet provided by the test publisher), or taped
response. Each of these accommodations requires that a person
transcribe the answers onto the answer sheet or booklet that will be
scored. These guidelines are provided to ensure that transcription is
performed appropriately.
1.

2.
3.
4.

5.

6.

Confidentiality of the test materials and the student's individual
responses is critical. Transcribers must treat the testing materials
and the student responses in a secure and confidential manner to
ensure test and student identification security.
Response transcribers must know braille if transcribing braille
responses.
It is best if the response transcriber is a "neutral" person, not
someone with a vested interest in the student's scores.
Response transcribers must provide the exact answers that the
student has written using the same punctuation, spelling, and
grammar structure. They cannot guess what the student might
have meant if answers are incomplete.
It is recommended that the response transcriber have a second
person proofread the responses to ensure accuracy and fairness to
the student. When transcribing graphics that a student has
produced, two transcribers should work together in transferring
student answers to the answer sheet or booklet.
For a period of time, student responses must be maintained in a
secure file with test name, copyright year, form and level
administered so that the student's actual responses can be
reviewed if questions arise.

40

REPORTING TEST RESULTS OF STUDENTS
WITH VISUAL IMPAIRMENTS
Following the requirements of federal law, the scores of students who
take assessments in accessible format must be reported for accountability purposes. When reporting the results of students with visual
impairments, care must be taken to protect the student's privacy while
appropriately representing the test score in consideration of the
accommodation(s) used. Students must not be penalized for use of
approved accommodations that do not change the test construct and do
not provide an unfair advantage to the test taker. Reporting of scores
should be a consideration during the test development phase so that all
parties understand the purpose of the testing and how the results will be
reported and used.

Reporting Test Results for Braille Editions
For most assessments, braille test versions should be regarded as
appropriate accommodations for students who use braille daily. Any
rescaling of braille test versions that is performed because of item
omission should be reported. The scores of those students taking a test in
braille should be considered valid as long as the test has been prepared
using the guidelines presented in this document. Students who read
braille daily need to use braille to respond to test items. This dual use
provides an instructional/ assessment validity match. Extensive efforts
to "prove" a braille test invalid because of a difference in format are
neither recommended nor useful. If the purpose of a test is to determine
educational skill progress, the validity can be addressed by confirming
that the media used for instruction matches that which is used for
assessment.

Reporting Test Results for Large Print Editions
Large print versions of tests also qualify as appropriate accommodations
for use during the assessment of students who use large print daily.
Unless the assessment has been reformatted, the large print version is a
camera-enlarged version of the original version. If the test is altered
through removal of shading, or other clutter from graphics, the use of
the large print format should be considered an appropriate and valid
accommodation. Generally, if reformatting is performed in a manner
preserving the original test content, the reformatted version should be
considered valid. Producers of large print must work with test publishers
to verify that the test material has not been altered in content or
purpose in order to maintain test validity.

41

Reporting Test Results for Audio and
Orally Administered Tests
Regarding most assessments, the use of audio and orally administered
tests should be considered appropriate accommodations for students who
use audio and oral formats on a routine basis to access materials. For
tests that assess reading as a decoding skill (visually or tactually), audio
and orally administered versions may change the skill being tested, and
this should be noted in any report of scoring.

42

ALTERNATE ASSESSMENTS
The guidelines presented in this section address some specific issues
related to accessibility of alternate assessment for students who are
blind or visually impaired. The guidelines addressing general state
testing that are presented throughout this book are appropriate
considerations for providing alternate assessment materials for some
students in this population; however, the specific needs of this group
must be discussed because so many are non-readers. Best practices in
this arena are still being formulated.

General Issues
Students who meet the criteria for alternate assessment, by definition
of the federal law, are those students who have significant cognitive
disabilities (often referred to as the 1% population assessment).
As allowed by federal law, some states have chosen to provide a
second alternate assessment for those students who are not expected
to meet the state standards as demonstrated on the general state
assessment within the same time frame as students taking the general
state assessment. In addition, these students are to be working
toward the state standards using modified achievement standards as
identified by each state. In some states, this alternate assessment
(generally referred to as the 2% population assessment) mirrors the
general state assessment with the exceptions of having fewer answer
choices and in some cases using simpler language in the test items.
Since alternate assessments are very similar to the general state
assessment in most cases, the same requirements for accessibility are
applicable for the alternate assessment as are outlined for the general
assessment.
The needs of students who are blind or visually impaired and have
additional disabilities that may qualify them for these alternate
assessments, must be considered in the planning and developing of
alternate assessment formats and items. Providing accessibility for this
population of students requires that test publishers and state
personnel have access to professionals who are familiar with braille,
large print, and regular print and know the learning styles of these
students.
Because many students who take alternate assessment have limited
reading ability, it is expected that students who are blind who qualify

43

for alternate assessment will have very limited braille reading
capabilities as well. Likewise, students with low vision who qualify for
alternate assessment may have limited ability to read print or large
print.
While providing a general assessment in braille for accessibility
purposes has its challenges, the provision of an alternate assessment
in tactile format can be even more challenging. Alternate assessments
typically have formats that either require the student to answer
questions by looking at a visual stimulus or demonstrating skills from a
checklist of desired tasks. Alternate assessments often include
performance tasks, such as picture identification or demonstration of
skills using manipulatives. Generally, demonstration of specific skills
on alternate assessments can be easily accommodated to allow the
student who is blind or visually impaired to perform tasks in the usual
way they perform tasks in the classroom. Validity and reliability can
usually be maintained when accommodations have been welldocumented on a student’s IEP and assessment report.

Considerations in Alternate
Assessment Design
Because reading is an issue for the population of students taking
alternate assessment, test items often require picture identification.
Test administrators must be able to describe the pictures for
students who are blind. All test items need to be reviewed to assure
that the picture can either be described (accessible) without giving
the answer away or that the picture is not needed (inaccessible)
and has been omitted. Keeping the task appropriate to the student
who takes the test is crucial: For example, it is appropriate to ask a
student about the function of an object (i.e. Which of these can you
eat-- a book, a rock or a banana?). An item would not be accessible
if it asked: “Which of these pictures shows a banana?” In this later
example, naming the pictures (book, rock, banana) would give the
answer away.
It is recommended that the test publisher provide picture descriptions for the test administrator. Picture descriptions should be
developed in conjunction with content experts and state
assessment personnel, keeping in mind the construct (skill) being
assessed and the cognitive level of the students taking the test.
If pictures cannot be described without compromising the test item,
it is preferable to present manipulatives (objects) to students in lieu
of pictures. If this is allowed by the state, such objects should be
44

real objects (i.e. actual familiar classroom objects and shapes such
as pencils; paper; books; notebooks; toys; food; geometric shapes;
and counters) and not replicas.
Replicas or miniatures of animals or of other large objects are not
appropriate for use because they cannot be distinguished by the
student. These should be used with caution and only if the student
is familiar with the models or miniatures.
Real money should be used rather than a tactile representation.
Tactile representation of simple graphs (charts) is appropriate. If
the test administrator is allowed to read the chart or graph, a script
for reading it is preferred and should be included in the test
administration manual.
Tactile representation of shapes (circles, squares, stars, rectangles,
etc.) is appropriate and should be used in place of letters, animals,
and people to present counting or other mathematics items.
If the skill being assessed is not reading, then test administrators
should be allowed to read aloud all words and passages used in the
test items. Care must be taken not to give vocal clues by
emphasizing certain words.
If the construct being assessed is decoding of words (i.e. reading)
and simple words and/or passages are provided, then these words
and passages must be provided in braille. It is important for state
assessment personnel to determine if contracted or uncontracted
braille, or both will be provided. This can best be done by surveying
a sample of teachers who work with this population to determine
which format is preferred or by requesting school districts to specify
the number of alternate assessments that are needed in contracted
braille and the number needed in uncontracted braille. Making this
decision part of the ordering process ensures that the appropriate
braille test format is provided for each individual student.
Large print is defined by research as optimal at 18 points. A sans
serif font should be used for best readability.
It is important that any pictures or graphics provided in print or
large print are clear, uncluttered, black line drawings with no grey
scale.

45

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Haven, CT
American Association of Workers for the Blind, Association for Education of
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The Nemeth braille code for mathematics and science notation.
Louisville, KY: American Printing House for the Blind.
American Educational Research Association (July, 2000). AERA position
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http://www.aera.net/policyandprograms/?id=378
American Educational Research Association, American Psychological
Association, & National Council on Measurement in Education.
(1999). Standards for educational and psychological testing.
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American Printing House for the Blind (July, 1997). Guidelines for design
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Arditi, Aries, (2009). Effective Color Contrast: Designing for People
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Arditi, Aries, (2009). Making Text Legible: Designing for People with
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York, NY
Arditi, A. (1996). Typography, print legibility, and low vision. In R.
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Birren, Faber,(1969). Light, Color, and Environment, Van Nostrand
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Bothwell, Dorr,(1968). Notan: The light-dark principle of design,
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46

Braille Authority of North America. (1997). Braille formats: Principles of
print to braille transcription. Louisville, KY: American Printing House
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Braille Authority of North America. (1994). English braille American
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Braille Authority of North America. (1990). Guidelines for mathematical
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Association.
Braille Authority of North America. (1983). Guidelines for mathematical
diagrams, 1983, American Printing House for the Blind, Louisville,
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Chung, S. T. L., Mansfield, J. S., & Legge, G. E. (1998). Psychophysics of
reading. XVIII. The effect of print size on reading speed in normal
peripheral vision. Vision Research, 38, 2949-2962.
Corn, A. L., & Koenig, A. J. (Eds.). (1996). Foundations of low vision:
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3, 663-665.

53

APPENDIX A
BRAILLE VERSUS AUDITORY ACCESS: A
DISCUSSION
Federal law requires that consideration be given to accommodations in
testing students with disabilities. With this focus comes the responsibility
of the educator to identify needed and useful accommodations for
students with disabilities. For students with visual impairments,
accommodations that provide access to print can vary considerably. The
range of accommodations includes braille, tactile graphics, large print,
regular print with magnification, auditory media, or any combination of
these accessible media. This discussion suggests methods for identifying
the most appropriate accessible media, identifies uses of braille and audio
materials, and provides recommendations for consideration in choosing
testing media.
Since the early 1990s authors have identified methods of evaluating the
"mode of reading" or method of print access for students with visual
impairments (Koenig & Holbrook, 1993; Wormsley & D'Andrea, 1997).
Federal law indirectly requires that print access be evaluated by defining
the consideration of braille as a mode of reading for students with visual
impairments as part of the Individualized Education Program (IEP)
process. A major part of the early and ongoing assessment of a visually
impaired student’s unique needs is the use of various media to access
printed materials. Identification and use of appropriate media includes:
• Determination of the student's primary and secondary sensory
channels for learning through observation of the student's use of
vision, use of touch, and use of hearing in familiar and unfamiliar
settings, at structured times and unstructured times, and in outdoor
settings as well as indoor settings (Koenig & Holbrook, 1993)
• Attention to the student's current print access needs, instruction and
remediation in accessible media or alternate media, and recognition
of future needs in print access for the student
• Provision of initial sensory channel identification and ongoing sensory
channel use to determine changes in use and need for instruction in
additional media access skills
• Instruction in a variety of accessible media that could be used by the
student
• The opportunity to learn skills that enable the student to choose the
appropriate medium for various tasks

54

Specifically, the appropriate uses for braille are determined by each
individual who uses braille. Most blind individuals access printed materials
by using a combination of media. One issue in using braille has typically
been the lack of braille materials. Currently, there are improved methods
of providing braille materials through the expansion of technology.
Computer software and hardware that translate print to braille, provide
braille displays, and emboss braille through a translation program are
used to provide most braille text in a timely fashion. It should be noted
that print with highly graphic and technical content does not translate to
braille easily and with the type of accuracy expected for testing
materials.
Congress has recently passed legislation that will ensure accessibility of
instructional materials in braille for students with visual impairments.
While assessment materials are not included in this legislation, it seems
that making instructional materials readily available and accessible will
drive the need for a similar pattern in the testing arena.
Persons with visual impairments routinely use auditory means to access
large volumes of literary or recreational reading material, such as novels
or magazines. The expansion of technology and the ability to translate
printed text into speech has enabled persons with visual impairments to
access information via computer software and/or hardware. Additionally,
many persons with a visual impairment make use of a screen reader for
print access, a skill that requires some training.
The availability of a wide range of ways to access print is important for
persons with visual impairments. This range of availability should exist
for students but should not be confused with, or used as a replacement
for, the skill of learning to read (decode language). If society values the
reading of materials as a decoding skill, then access to printed material
for students who are visually impaired must include the learning of
reading through tactual or visual processes. For some individuals the
reading process is too tedious to be efficient. These individuals may
choose to use primarily auditory materials as adults, but as students
they should be given the opportunity to learn reading as a decoding skill.
The skills involved in reading braille, reading print, and listening to audio
materials are unique to each medium. Therefore, during the development
of test items, test publishers must be clear about which constructs are to
be assessed by a particular item. If reading as a decoding skill is to be
assessed, then a fair assessment can only result if the student is
provided with material that can be visually or tactually read. If
comprehension is the construct being assessed, then the test developer
must determine whether reading comprehension or listening
comprehension is the skill to be assessed. Comprehension would need to
be defined to ensure that students are using appropriate accommodations
when taking a particular test.
55

The following recommendations should be reviewed when considering the
use of braille or audio materials for students with visual impairments:

1.
2.
3.

Braille and tactile graphics interpretation should be taught as media
access skills so that students may learn reading as a decoding skill
and have the option of using braille and tactile materials.
Auditory listening skills should be taught as a media access skill so
that students can learn listening comprehension skills and have the
option of using audio materials.
Test publishers must be certain about the construct being assessed
on all test items. This enables educators and test administrators to
make valid judgments about appropriate accommodations for
students with visual impairments during test administration and helps
to ensure correct interpretations of test results.

References
Koenig A. J., & Holbrook, M. C. (1993). Learning media assessment of
students with visual impairment: A resource guide for teachers.
Austin, TX: Texas School for the Blind and Visually Impaired.
Wormsley D. & D'Andrea, F. M. (1997). Instructional strategies for braille
literacy. New York: AFB Press.

56

APPENDIX B
TEMPLATE FOR TEST ADMINISTRATION
NOTES FOR BRAILLE TESTS
Name of Test:

Edition of Test:

Section:
Preliminary Pages Transcriber's Notes:
Special Symbols Page:
General Test Direction Notes:

Print Page
Number(s)

Braille Page
Number(s)

Accompanying
Test
Administration
Manual Page
Number(s)

57

Item
Number(s)

Notes

Explanation of Fields on
Test Administration Notes for Braille Tests
Name of Test: Provide the full and exact name of the test.
Edition of Test: Provide the copyright or other edition listing to further
identify the test.
Section: Provide the section name and other identifying information.
Preliminary Pages Transcriber's Notes: Provide in print the exact
wording of transcriber's notes that refer to preliminary pages in the
braille version of the test. Indicate the page number of the transcriber's
notes.
Special Symbols Page: Provide in print the exact wording of the special
symbols page that may be present within the braille version of the test.
Indicate the page number of the special symbols page.
General Test Direction Notes: Provide information about the methods
a student may use when responding to test items that differ from print
test versions and which require special equipment or attention.
Print Page Number(s): Provide the location of test material within the
regular print version of the test.
Braille Page Number(s): Provide the location of test material within
the braille version of the test.
Accompanying Test Administration Manual Page Number(s):
Provide the page number(s) in the test administration manual that
correspond with each regular print test page.
Item Number(s): Provide the test item number(s) that appear on that
print page.
Notes: Provide comments that indicate transcriber's notes specific to
particular pages, changes made to the braille version of the test, and
changes made to directions, as listed in the test administration manual or
on the test.

58

APPENDIX C
TEMPLATE FOR TEST ADMINISTRATION
NOTES FOR LARGE PRINT TESTS
Name of Test:

Edition of Test:

Section:
General Test Direction Notes:
Print
Large Print
Accompanying
Page
Page Number(s) Test
number(s)
Administration
Manual
Page Number(s)

59

Item
NOTES
Number(s)

Explanation of Fields on
Test Administration Notes for Large Print Tests
Name of Test: Provide the full and exact name of the test.
Edition of Test: Provide the copyright or other edition listing to further
identify the test.
Section: Provide the section name and other identifying information.
General Test Direction Notes: Provide information about the methods
a student may use when responding to test items that differ from print
test versions and which require special equipment or attention.
Print Page Number(s): Provide the location of test material within the
regular print version of the test.
Large Print Page Number(s): Provide the location of test materials
within the large print version of the test.
Accompanying Test Administration Manual Page Number(s):
Provide the page number(s) in the test administration manual that
correspond with each regular print test page.
Item Number(s): Provide the test item number(s) that appear on that
print page.
Notes: Provide comments that indicate changes made to the large print
version of the test and changes made to directions as listed in the test
administration manual or on the test.

60

APPENDIX D
POSITION PAPER:
USE OF AN ABACUS
IN TEST-TAKING SITUATIONS
By Terrie Terlau and Fred Gissoni

Definition and Description
The mathematical abacus is a frame with beads or balls that can be slid on
wires or in slots for calculating or teaching arithmetic (The American
Heritage Dictionary of the English Language, 1996). The abacus has been
used as a calculation device in Europe, Japan, China, and the Middle East
since the third century A.D. It continues to be used widely in Japan
(http://www.syuzan.net/english/education/education.html).
The Cranmer abacus was developed as a calculation device for persons who
are blind or visually impaired and is currently produced by the American
Printing House for the Blind (APH: Abacuses, 2001). The Cranmer abacus
frame is made of high impact plastic, measures 6-1/8 x 3-1/4 x 7/16 inches,
and contains thirteen vertical rods and one horizontal cross bar. Four beads
can be moved vertically on each of the thirteen rods below the cross bar and
one bead can be moved vertically along the rods above the cross bar.

Abacus Functionality
When calculating with the Cranmer abacus, vertical rods represent units,
tens, hundreds, etc. Numbers are recorded and manipulated by moving
beads toward the cross bar on their respective rods.
The abacus is a passive device. It is not a calculator or a slide rule. The
abacus does not perform mathematical operations. It does not contain
information that would enable an abacus user to achieve calculation results
without a solid knowledge of mathematical concepts and relationships.
Abacus users produce calculations as a result of their understanding of the
behavior of numbers, not because of any inherent property of the abacus.
Both abacus and pencil-and-paper users must learn strategies for performing
mathematical operations. The primary difference in the activity of abacus
and pencil-and-paper users is that pencil-and-paper users apply and record
steps in these operations by writing while abacus users apply and record
these processes by moving abacus beads.

61

Persons who are blind or visually impaired and who have had appropriate
abacus instruction can use the abacus to perform addition, subtraction,
multiplication, division, and square and cube roots. The abacus does not
permit permanent storage of problem solutions because beads must be
rearranged to perform subsequent problems. After each calculation using an
abacus, answers can be recorded in a variety of formats including braille,
large print, voice recording, word processing, or dictation into an electronic
device.

Position Statement
Whenever a test-taker is allowed to use a pencil and paper for working
calculations, an abacus should be considered an equivalent substitution.

References
APH: Abacuses. (2001). Retrieved August 6, 2008 from
http://www.aph.org/tests/abacuses.htm
The American Heritage Dictionary of the English Language (3rd edition).
The League of Japan Abacus Associations. (2001). Soroban in education and
modern Japanese society. Retrieved August 1, 2008, from
http://www.syuzan.net/english/education/education.html

62

APPENDIX E
POSITION PAPER:
USE OF EXTENDED TIME
Introduction
In addition to the use of braille and large print, the use of extended time
is also a commonly used accommodation for students with visual
impairments. This position paper provides a brief summary of the results
of research on the use of extended time in testing students, while
suggesting best practices for implementing this accommodation.

Research
For several years, researchers have suggested that students with a visual
impairment need more time to complete assignments and tests (Harley &
Lawrence, 1984; Kederis, Nolan, & Morris, 1967; Morris, 1974; Spungin,
2002; Bradley-Johnson, 1994).
Moreover, some researchers have reported results indicating that
students with a visual impairment generally read at a slower rate than
students without a visual impairment (Packer, 1989; Legge, et. al.,
1985, 1989; Wetzel & Knowlton, 2000). Not only does the reading of
braille and large print generally require more time than reading regular
print, but the time needed to explore and interpret pictorial information
presented as tactile or enlarged graphics can be a tedious and timeconsuming process. Therefore, extended time seems to be an obvious
accommodation for this population. Some suggested time extensions
based on classroom experience or research include
• 1.5 to 2 times for students with low vision (Gompel, van Bon, &
Schreuder, 2004),
• 2.5 times for braille and 1.5 times for large print (Morris, 1974),
• 1.5 times for all students with a visual impairment (Spungin, 2002),
• 2 times for braille (Kederis, Nolan & Morris, 1967),
• More than 2 times for braille and a little less than 2 times for visually
impaired readers who read print (Packer, 1989), and
• .5 times for experienced adult braille readers (Wetzel & Knowlton,
2000).
The most recent synopsis of research on accommodations demonstrates
the wide range of results among studies seeking to validate the use of
extended time during testing. Based on the varied results, authors

63

recommend that a well-designed test for standard administration be
untimed (Tindal & Haladyna, 2002).
Research conducted by the National Center on Educational Outcomes
(NCEO) summarizes at least four studies in which the use of extended
time had a positive effect on student test scores. NCEO provided
preliminary results of a Universal Design Research project which suggest
that unlimited time reportedly helps students "think better," a conclusion
drawn after interviewing students who had completed a universally
designed test (with no time limits) and a regular test (with time limits)
(Presentation: Universal Design Research, C. Johnstone & A. Morse, June
24, 2003 at CCSSO Large Scale Assessment Conference, San Antonio, TX).
Several authors seem to agree that timed conditions may not allow
students to reflect their full abilities on achievement tests (Tindal &
Fuchs, 1999) and that adequate time should be provided for all students.
Parr, et. al. (1996) argue that extended time examinations taken under
ideal circumstances can be more equitable and practical than timed
examinations. In another investigation, Marquart (2000) found that
extended time failed to significantly improve the test scores of disabled
students. The author, however, does conclude that extended time likely
produces a more accurate measure of a student's skill by helping to
reduce test anxiety and by allowing a greater opportunity to use good
test taking strategies.

Conclusions
Extended time is a commonly used accommodation for students with
visual impairments. Some literature concerning the subject recommends
that the accommodation of extended time be of specific duration, e.g.,
2.5 times for braille readers and 1.5 times for large print readers.
Certainly, a topic in need of additional information is a comparison of
time used among the following: a braille reader who must explore and
interpret tactile graphics, a large print reader who must visually examine
and synthesize enlarged graphics, and a sighted student using regular
print test materials. Moreover, several current researchers suggest
placing less emphasis on designating a uniform, "one size fits all" duration
of extended time as an accommodation for disabled students during
testing. Rather, these researchers suggest that the accommodation of
extended time consist of "adequate time." That is, a specific length of
time, which must be determined by educators through careful
assessment of the student's physical disability, skills, and needs. In lieu
of extended time, some test administrators are finding that more
frequent breaks are effective for braille and large print test takers. Once
64

the need for, and duration of, adequate time and/or breaks has been
assessed, educators should include that information on the student's IEP,
ensure use of the accommodation, and monitor its use.

Position Statement
To implement extended time or adequate time for students with visual
impairments, four basic steps should be followed:
1.
2.
3.
4.

Assess the need for extended time and frequent breaks.
Include specific information about extended time and the need
for breaks on the student's Individualized Education Program (IEP).
Ensure that extended time and frequent break accommodations
are implemented as specified during testing.
Monitor the student's use of extended time to assure that the
student uses extended time/break time appropriately and that
the student is on task.

References
Bradley-Johnson, S. (1994). Psychoeducational assessment of visually
impaired and blind students: Infancy through high school. (2nd e
d.). Austin: Pro-Ed.
Gompel, M., van Bon, W. H. J., & Schreuder, R. (2004). Reading by children
with low vision. Journal of Visual Impairment & Blindness, 98(2),
77-89.
Harley, R. K. & Lawrence, G. A. (1984). Visual impairment in the schools.
(2nd ed.). Springfield, IL: Charles C. Thomas.
Kederis, C. J., Nolan, C. Y., & Morris, J. E. (1967). The use of controlled
exposure devices to increase braille reading rates. Unpublished
manuscript, The American Printing House for the Blind.
Legge, G.E., Rubin, G.S., Pelli, D.G., & Schleske, M.M. (1985).
Psychophysics of reading. II. Low vision. Vision Research, 25, 253266.
Legge G. E., Ross, J. A., Maxwell, K. T., & Luebker, A. (1989).
Psychophysics of reading. VII. Comprehension in normal and low
vision. Clinical Vision Sciences, 4(1), 51-60.
Marquart, A. M. (2000, June). The use of extended time as an
accommodation on a standardized mathematics test: An
investigation of effects on scores and perceived consequences for
students of various skill levels. Paper presented at the Annual

65

Meeting of the Council of Chief State School Officers for the Large
Group Session, "Studies of the Effects and Consequences of
Accommodations on Student's Achievement Test Scores" Snowbird,
UT.
Morris, J. E. (1974). The 1973 Stanford Achievement Test Series as
adapted for use by the visually handicapped. Education of the
Visually Handicapped, 6(2), 33-46.
Packer, J. (1989). How much extra time do visually impaired people need
to take examinations: The case of the SAT. Journal of Visual
Impairment & Blindness, 83(7), 358-360.
Parr, P., Levi, N., & Jacka, K. (1996). Unspeeded examinations: An
equitable practical method of assessment. (ERIC Document
Reproduction Service No. ED397108)
Spungin, S. J. (Ed.). (2002). When you have a visually impaired student
in your classroom: A guide for teachers. New York: AFB Press.
Tindal, G. & Fuchs, L. (1999). A summary of research on test changes:
An empirical basis for defining accommodations. Lexington:
University of Kentucky, Mid-South Regional Resource Center
Interdisciplinary Human Development Institute. Retrieved June 4,
2008 from
http://www.rrfcnetwork.org/images/stories/MSRRC/DOCS/ACCOMMO
DATIONS/tindal&fuchs%20march%202000.pdf
Tindal, G. & Haladyna, T. M. (Eds.). (2002). Large-Scale assessment
programs for all students: Validity, technical adequacy, and
implementation. London: Lawrence Erlbaum Associates.
Wetzel, R. & Knowlton, M. (2000). A comparison of print and braille
reading rates on three reading tasks. Journal of Visual Impairment

& Blindness, 94(3).

66

APPENDIX F
POSITION PAPER:
ACCOMMODATIONS FOR TESTING STUDENTS
WITH VISUAL IMPAIRMENTS
By Carol Allman, Ph.D.

Introduction
Accommodations and technologies exist for the purpose of providing a
disabled student with access to academic materials that may otherwise be
inaccessible. The term "technology" comes under the definition of assistive
technology as described in federal law and is considered an accommodation.
Accommodations and assistive technologies needed by students with visual
impairments should be outlined on the student's Individualized Education
Program (IEP). These accommodations should be monitored periodically for
their effectiveness with the individual student and revised or updated as
appropriate. Any accommodations provided for students during the
testing window should be ones typically used by that student in the
classroom and not new or unfamiliar ones.
This paper provides an overview of accommodations in testing that might be
effective for students with visual impairments and should be documented on
their IEP. Five major categories of accommodations that include
presentation, response, setting, scheduling, and special tools are discussed.
Not all of the accommodations presented in this paper are intended for use
by every student with a visual impairment. Likewise, some accommodations
needed by students with visual impairments may not be discussed.

Determining Accommodations
The need for accommodations is the decision of the Individualized Education
Program (IEP) team and must be recorded on the IEP. Accommodations used
in testing should match those used by the student for classroom instruction.
Accommodation use is determined by evaluating factors unique to each
student and must be implemented as outlined on the IEP. Evaluation of the
effectiveness of accommodations for individual students is highly
recommended. Further, students must be trained to use accommodations.
For example, providing a test orally or on a computer might actually penalize
a student who has not been trained to listen to material presented orally or
trained to use a computer for assessment. Accommodations should be

67

continually evaluated to ensure that they are effective for the student. Some
accommodations should be eliminated if the student arrives at a point where
he or she either does not need the accommodation or the accommodation is
ineffective.

Presentation Accommodations
Students with visual impairments have several options for accessing test
materials. According to data collected by the American Printing House for the
Blind (2003), 9% of the visually impaired student population use braille as
their primary mode of reading. Approximately 26% use large print materials,
while only 6% are auditory readers who would require test materials to be
presented in audio format. Prereaders (27%) may use auditory materials
until they learn braille or print. Of the nonreaders (32%), some may use
braille, large print, and audio on a very limited basis. However, there are
many whose significant cognitive disability would inhibit them from
successfully using braille, large print, and audio materials. Most of these
students are involved in educational programs that do not rely heavily on
traditional reading media and modes of learning and communication. This
population of students may use augmentative or tactile communication
systems and might qualify for alternate assessment in the statewide
assessment program. The remainder of the visually impaired school-aged
population who are readers access standard print materials with or without
low vision aids.
Braille, large print, magnified print, and audio presentation are
accommodations that allow visually impaired students access to the testing
environment. Some of these students may use a combination of these media
to complete a single test. A student may, for example, read a passage in
braille and prefer to access a table or chart in a large print or magnified
format. Students using an audio version of a test as an accommodation
would also be allowed to use print (large print or standard print with a
magnification device) and/or braille versions of the test, if requested.
Further, a student may prefer to listen to an orally presented passage but
access a table or chart in a large print or braille version of the test. If a
multimedia presentation is used, the various media must be coordinated to
ensure accuracy and accessibility. It should be noted that computer-assisted
testing is becoming very popular and requires special attention to be
accessible for students with visual impairments.

68

Braille and Tactile Graphics
Braille is a system of raised dots that represent words and letters. It is used
as a presentation method for those students who typically read braille for
classroom instruction. Braille may be presented as contracted (using short
forms for words as outlined in English Braille Code) or in uncontracted format
(using no short forms, i.e., spelling each word letter by letter). Most students
will use the standard contracted braille. A few students, such as those who
are just learning braille in the early grades or who are newly blinded, may
need uncontracted braille to access a test.
The production of a braille test is a unique process that often necessitates
the review and limited editing of test directions and test items so that the
items are understandable when presented in braille and tactile graphics
format. Such editing may involve subtle word changes to directions
(replacing "circle the answer" with "mark the answer"), relocation of stimulus
information (moving the question above a graph or chart), simplification of a
graph or chart (removing extraneous information without deleting answers or
foils), or replacing an item that cannot be reflected in braille with an item of
equal weight, value, and difficulty (replacing an item that requires strictly
visual skills, such as visual illusion, with a similar item that assesses the
same concept and is more accessible to blind students).
However, an item need not be replaced or omitted simply because it is
presented in a manner that requires some visual interpretation. For example,
the concept of understanding a shadow and what causes a shadow is an
important concept for a blind student to understand. Therefore, this skill can
be assessed through use of descriptions and tactile graphics. If, however, a
test or particular subject includes a high percentage of visual items, then
consideration may be given to substituting some of the "visual" items.
Students who read using braille are expected to meet the same standards
that other students meet, even though they are doing so tactually. The
process of editing a test for braille production should in no way simplify or
reduce the difficulty of the test material.
Once test material has been edited for braille transcription, qualified persons
will transcribe the print into braille by using the recommended edits and
guidelines for braille transcription and formatting. The transcribed braille test
must be proofread and produced so that the braille reader receives a high
quality test in the same timely manner as sighted students receive their test.

69

Large Print Text and Graphics
Large print is considered such when it is 18-point type and larger. Enlarged
print is typically that which is 14 point, 16 point, or standard-sized print that
has been enlarged using magnification devices. Enlarged print and large print
are accommodations.
Large print should be produced by using an electronic version of the test to
reformat the test so that fonts are larger, fewer items are on a page,
graphics are contained on one page, answer choices are presented with the
questions, and attention is given to improving the contrast and reducing the
shading and gray scale that interferes with reading the material presented.
The process of using a photocopier to enlarge test content should be avoided
since this method lacks the control needed to ensure that all test material
(exponential numbers, footnotes, and graphic material) is represented in a
readable point size, that text is clear and without gray scale interference,
and that problems dealing with measurement are presented accurately. For
example, a butterfly measuring two inches in the standard print test must
remain two inches in the large print version.
Some students will use magnification devices (discussed in more detail in the
section of this paper on special tools considerations) with large print or with
standard print to access test materials.
Therefore, it is important that the standard print version of a test exhibit
good contrast and a clear print style to allow effective use of magnification.

Audio
Generally, students with visual impairments should be expected to read
materials by using print or braille. Access to print is a critical literacy skill for
all individuals. However, where audio presentation is allowed, and for
reducing the time needed to complete a test, some students who are visually
impaired may need directions or some test items presented orally to them.
Audio presentation of print materials is a presentation accommodation
allowing for all or part of a test to be presented on cassette tape, CD,
computer and specialized screen reader or text reader software, or read
aloud to a student. Students should use these accommodations only if they
use audio media for classroom instruction. The skill of listening to spoken
material and manipulating a computer, cassette tape player or CD player is

70

different from the skill needed to read and interpret print or braille.
Therefore, navigating through a cassette tape, computer with screen reader,
or audio CD in a testing environment requires practice. Further, the test
purpose must be specified to ensure that oral presentation of a test or
portions of a test do not invalidate results or preclude the reporting of test
results. For example, if the reading skill of decoding print (or braille) is being
assessed, audio presentation of the text could invalidate the purpose of the
test.
The transfer of test material onto audio tape requires a process similar to the
construction of test materials in braille. Print text must be edited for audio
presentation, produced in audio format by experienced audio engineers, and
then proofed for accuracy. Additionally, any graphic material must be
described and provided as a supplement in braille, large print, or standard
print. Accurately describing graphic material requires attention to the critical
components of the graphic and careful consideration of which details can be
included in or omitted from the description without providing the answer or
excluding the foils imbedded in the question.
If a test or part of a test is to be read to a student, there are recommended
practices for ensuring that this accommodation is provided correctly:
A reader must be skilled in presenting various types of test materials.
For example, a reader familiar with mathematical symbols is required for
the correct delivery of higher level math formulas and equations.
The person selected to read a test to a student should exhibit good voice
quality, appropriate regional dialect, pronunciation, speed, and tone.
The reader must avoid voice inflection that stresses or otherwise
indicates the correct answer to test items.
Prior to the testing situation, difficult words within the test material must
be reviewed by the person assigned to read the test. Pronunciation
dictionaries should be used as references.
Readers must pause at appropriate intervals so that the student has an
opportunity to answer test items or access graphic material provided in
print or tactile formats.
Readers must avoid answering a student's question concerning
clarification of testing content. Doing so would provide an unfair
advantage. Developing some standard responses to students' questions
prior to the testing situation is helpful. For example, instead of
answering a student's question about test content, the reader can
encourage the student to listen to the question again.
Readers may find it necessary to provide multiple readings of passages,
parts of passages, or items. While addressing the needs and requests of

71

the test taker, the reader should also use professional judgment to
determine the number of readings necessary.
Two readers should be used for presenting a test or portions of a test to
a student. Using more than one reader helps ensure accuracy of test
presentation and provides the opportunity for readers to rest during the
presentation of test material.
Students tested through oral reading of the exam must be tested
individually to prevent the distraction of other students. Moreover, the
testing of students individually helps ensure that each student receives
the specific oral reading structure required by his or her specific needs.

Computer-assisted Testing
Computer-assisted testing is an accommodation that has received some
attention through research, though studies concerning its benefit are
inconclusive (Tindal & Fuchs, 1999). Generally, however, when a student
uses a computer for daily classroom activities, then this accommodation may
prove useful during testing if the concepts being tested are not undermined.
There are several programs and peripheral materials that can be used to
adapt the computer for use by persons with visual impairments. Screen
readers, text to speech technology, and accessible keyboard access through
braille or switches are all available. Depending on the construct being tested,
test administrators must verify that the student is inhibited from accessing
software or hardware that may provide an unfair advantage. For example, if
a student's basic math skills are being assessed and the intent is not to use a
calculator, then keyboard functions or software used for computations must
be blocked. For more information on this topic, refer to Test Access:
Guidelines for Computer-Administered Testing. American Printing House for
the Blind: Louisville, KY. Available from:
http://www.aph.org/tests/access/access.pdf

Response Accommodations
Students with visual impairments who use the presentation accommodations
discussed above may also need to use certain response accommodations so
that answers can be recorded appropriately. As with presentation
accommodations, response accommodations with which the student is
familiar are recommended.
Considerations regarding response accommodations include the following:
The student may present answers orally to a test proctor who completes
the answer sheet.
72

Students may record onto audio tape answers that then must be
transferred to the answer sheet.
The student may need to write answers in the test booklet or on
separate paper. The student's answers will then need to be transferred
to the answer sheet.
Students may use word processors to write answers that will be
transferred to the answer sheet. Depending on the construct being
tested, test administrators must verify that students are inhibited from
accessing software or hardware that may provide an unfair advantage.
For example, if a student is responding to a writing prompt and the
writing will be judged based on correct spelling and grammar, then the
spell check function and grammar functions must be disabled.
Each of these accommodations requires a person to transfer the answers
onto the scanable answer sheet or booklet that will be scored. If computerbased testing is used, the transfer of answers is not necessary as this
process happens as part of the computer test program. The transfer of
answers must be performed carefully to ensure that the student's answers
are recorded as intended.
The following guidelines are provided to ensure that this transfer of
information is performed appropriately:
1.
2.
3.
4.

5.

6.

Testing materials and the student responses are secure and confidential
materials, and they must be treated as such to ensure test validity and
the non-disclosure of the student's identity to unauthorized persons.
Response transcribers must know braille if transcribing braille responses.
Ideally, the response transcriber should be a "neutral" person, not
someone with a vested interest in the student's scores.
Response transcribers must record the student's use of punctuation,
spelling, and grammar structure, and provide the student's answer
exactly as it was delivered by the student. The response transcriber
cannot record speculative responses for items that the student failed to
complete.
A second person should be made available to proofread the work of the
response transcriber in order to ensure that the student's answers have
been recorded accurately. For the same reason, two transcribers should
work together in transferring to the answer sheet those graphics that
the student has produced as an answer to a test item.
For a period of time, student responses must be maintained in a secure
file with test name, copyright year, form and level administered so that
the student's actual responses can be reviewed if questions arise.

73

Setting Accommodations
Frequently, students with visual impairments will need to take a test
individually or in small groups to ensure that test accommodations are
implemented without interference to the concentration and test taking of
other students. If a student is being read to, is recording answers by using
technology that is noisy, or is recording answers orally, then the student
must take the test individually and under the supervision of a test
administrator to prevent the distraction of other test takers.
The setting for the testing situation must allow space for the materials to be
used by the student. The manipulation of braille, large print materials,
braillewriters, talking calculators, and large print materials requires that the
student be allowed access to a flat, fairly large work area. Moreover, proper
lighting, while sometimes overlooked, is critical for many readers with visual
impairments. Lighting that has been adjusted to suit the student's particular
visual needs will help promote sustained reading efficiency.

Scheduling Accommodations
The use of extended time for test completion is a testing accommodation
that has received considerable attention since state testing and
accountability systems have been implemented. Research investigating the
use of extended time has yielded no conclusive information about its benefit
(Tindal & Fuchs, 1999). However, students with visual impairments will
usually require extended time during testing because using braille, large
print, and audio format require more time than does reading standard print
with acceptable visual acuity.
A study by Gompel, van Bon, and Schreuder (2004) found that students with
low vision can read effectively with their low vision aids, using 1 ½ to 2 times
that needed by regular students. Traditionally, extended time for testing
large print readers has been 1 ½ time, and for braille readers time allotted
has been twice as much as that allowed for the standard print reader.
Another study suggests that experienced braille readers may need no more
that 50% additional time than the stated duration, with additional time
allowed for the manipulation of an audio device or the marking of an answer
sheet (Wetzel & Knowlton 2000).
Regardless of the time allowed, the student should be carefully monitored to
ensure that time is being used appropriately. If students need an inordinate
amount of time, educators may need to investigate the efficiency of the
chosen reading mode or initiate remediation to improve speed. Generally,

74

timing accommodations should be individualized according to the test taker's
reading rate and testing situation (Wetzel & Knowlton, 2000).
Reading braille or large print and listening to material presented orally,
especially when accompanied by graphic material, can be a fatiguing and
often frustrating experience in a high stakes testing environment. Therefore,
students may need several brief sessions in which to take the test. Additional
break options should also be considered.
Students may need to be tested at different times of the day depending on
their optimal functioning time. Students may also need to be tested over a
longer time period, a week rather than two days, for example. However, any
alteration of the timetable will necessitate close supervision to ensure test
security.

Special Tools Accommodations
There are a number of special tools that students with visual impairments
may need during the testing process. Tools provided for sighted students
during testing, such as calculators, rulers, protractors, or other measurement
devices, must be provided for students with visual impairments, as well.
Talking calculators, braille or large print rulers, protractors, and other
measurement devices do exist, and the student should be allowed to use
them. When testing allows the use of non-scientific or scientific calculators,
students with visual impairments should be permitted to use an equivalent
device that has been adapted for use by the visually impaired user, e.g., a
non-scientific or scientific talking calculator. Should a state provide
calculators for the sighted population taking the test, then talking calculators
should be provided to students with visual impairments who are taking the
test. Before they are used in a testing situation, electronic and batteryoperated devices should be inspected to ensure they function properly and
that the devices contain no saved information, which might provide the user
an unfair advantage.
Some other special tools that students with visual impairments might use
include:
Abacus: An abacus is often useful for students when mathematics
problems are to be calculated without a calculator. The abacus functions as
paper and pencil for some students with visual impairments.
Graphic Tools: If students are required to produce graphic
information on a test, they should be allowed to use one of several graphic
tool kits that exist. It is best if the student uses whatever method he or she
has used during classroom instruction of graphic construction. The student's
75

constructed graph, if done in braille, will need to be transcribed into print for
scoring.
Line Markers and Templates: Occasionally students may want to
use manipulative devices, such as a ruler or template, to maintain placement
on a line of braille or print.
Magnification Devices: Magnification devices include eyeglassmounted magnifiers, free standing or handheld magnifiers, and electronic
equipment such as the closed circuit television (CCTV) or a computer that
has text enlargement software installed. These devices do not provide a
student with an unfair advantage. Rather, they are devices that the student
requires to access print, and they should be allowed as standard
accommodations. Should a computer be used as an accommodation, the test
administrator must ensure that only allowable computer options, such as
screen enlargement, are used.
Scientific Tables: Frequently, students may need to refer to a braille
or large print edition of a scientific table, such as the periodic table of
elements.
Physical Manipulatives: Some testing situations may allow that
objects presented on paper (i.e. money, geometric solids) can be substituted
with a physical representation of the picture (i.e. penny, nickel, dime,
quarter, or geometric solids used in instruction).
Special Paper: Students may need specially designed bold line or
raised line paper for constructing answers and producing graphs.

Summary
This paper has outlined the typical accommodations used by students with
visual impairments when being tested through use of a written assessment
such as an academic achievement test. While this discussion is not
exhaustive of all accommodations that might be used, it is intended to
provide an understanding of the general accommodations that are expected
when assessing a student with a visual impairment. Documentation of these
accommodations on the IEP is crucial as is routine evaluation of their
effectiveness.

References
Allman, C. et al. (2005). Assessment Issues: An Accommodations Guide.
19th Annual Josephine L. Taylor Leadership Institute: Boston,
Massachusetts, March 11, 2005. Retrieved May 16, 2006 from the
American Foundation for the Blind web site:
http://www.afb.org/Section.asp?SectionID=58&TopicID=264&Docume
ntID=2762

76

American Printing House for the Blind. (2003, September). Distribution of
eligible students for fiscal year 2003, based on the federal quota
census of January 7,2002. (Annual Report, 2003) Louisville, KY:
American Printing House for the Blind.
Gompel, M., van Bon, W. H. J., & Schreuder, R. (2004). Reading by children
with low vision. Journal of Visual Impairment & Blindness, 98(2), 7789.
Tindal, G. & Fuchs, L. (1999). A summary of research on test changes: An
empirical basis for defining accommodations. Mid-South Regional
Resource Center, Lexington, KY. Retrieved May 14, 2004, from the
Mid-South Regional Resource Center Web site:
http://www.ihdi.uky.edu/msrrc/PDF/Tindal&Fuchs.PDF
Wetzel, R. & Knowlton, M. (2000). A comparison of print and braille reading
rates on three reading tasks. Journal of Visual Impairment & Blindness,
94(3).

77

APPENDIX G
Educational Testing Service (ETS)
GUIDELINES FOR A TEST READER
The following guidelines will assist in providing the testing
accommodation of a reader for a test taker with disabilities. If you have
questions about a specific test, please contact a testing program
representative.

Characteristics of a Good Reader
1.
2.
3.

4.
5.

Ability to read aloud clearly, at a normal pace, and with good
pronunciation.
Familiarity with the words, terms, symbols, or signs that are
specific to the test content.
Ability to follow instructions to read, verbatim, only the words in
the test book or on the screen, without changing or adding words
or assisting the test taker in selecting a response.
Willingness to be patient and to understand that the test taker
may need to have many test questions repeated several times.
Ability to work with the test taker comfortably and compatibly
without creating unnecessary pressure or unrealistic expectations.

General Information for Readers
1.

2.

3.

You must review the test format, subject matter, and sample test
questions in the testing program's information bulletin or by
visiting the testing program's Web site.
Prior to beginning the test, you will have the opportunity to meet
with the test taker, who should be encouraged to discuss matters
that will affect test performance, e.g., how to determine the
amount of remaining time and how you can help pace the test taker
through the test. The opportunity to discuss such questions and
concerns before the test administration begins will make the test
administration more effective and fair and will help to minimize
misunderstandings and misinterpretations.
Test takers who are blind or who have low vision may also have
special tools or equipment (e.g., abacus, brailler, slate, and stylus)
that have been approved for use during the test. These tools offer
neither an unfair nor a special advantage; they are comparable to
paper and pencil and accomplish the same task. The most
important consideration is for you and the test taker to have the

78

same set of expectations about what is to happen, how much time
is allowed, and how all the tasks will be accomplished.

4.

5.

6.

7.

8.

9.

10.

Test takers who are blind or who have low vision may also have
special tools or equipment (e.g., abacus, brailler, slate, and stylus)
that have been approved for use during the test. These tools offer
neither an unfair nor a special advantage; they are comparable to
paper and pencil and accomplish the same task. The most
important consideration is for you and the test taker to have the
same set of expectations about what is to happen, how much time
is allowed, and how all the tasks will be accomplis hed.
The test taker may require all or portions of the test to be read
aloud. The test taker depends on the reader to read the test
questions accurately, to pronounce words correctly, and to speak
in a clear voice throughout the test, which may go on for several
hours. It is a demanding and somewhat tedious task, and not
everyone is suited to do it. Drinking water should be available for
you.
Your task is to read only the test questions. Do not try to solve
problems or determine the correct answer as you read because
this may result in an unconscious pause or change in inflection
that could be misleading or disconcerting to the test taker. The
expression on your face should remain neutral. Do not look at the
test taker or smile or frown to indicate approval or disapproval.
Read each question as clearly as possible. Give special emphasis
to words printed in boldface, italics, or capitals, and tell the test taker that the words are printed that way. Do not give your own
emphasis to words not emphasized in print.
If you find an unfamiliar word or one that you are not sure how to
pronounce, advise the test taker of your uncertainty about the word
and spell it.
When reading a word that is pronounced like another word with a
different spelling, if there can be any doubt about which word is
intended, spell the word after you have pronounced it. Spell any
words requested by the test taker.
Avoid getting into conversation about the test questions, but try to
respond to the test taker's questions by repeating the item, words,
or instructions as needed.

79

11. When reading passages, be alert to all punctuation marks. Read
the passage through once so that the test taker can grasp the
content of the passage. Some test takers may ask for the passage to
be read through a second time with punctuation marks indicated.
When required or asked to read, with punctuation, specific lines
within a passage, indicate all punctuation found within those lines.
12. When test questions refer to particular lines of a passage, reread
the lines before reading the question and answer choices. For
example, you might say, "Question X refers to the following
lines..." Reading the lines referred to would then be followed by
reading question X and its response options.
Special Considerations for Multiple-Choice Tests
1.

2.

3.
4.

Be particularly careful to give equal stress to each response option
and to read all of them before waiting for a response. The test taker will record the answer or provide the answer to the test
administrator (writer), who will record it for the test taker.
If you are recording answers and if the test taker designates a
response choice by letter only ("D", for example), ask if you
should reread the complete response before the answer is
recorded.
If the test taker chooses an answer before you have read all the
answer choices, ask if you should read the other response options.
Allow the test taker to pause before responding. However, if the
test taker pauses for a considerable time following your reading of
the answer choices, say: "Do you want me to read the question
again...or any part of it?" In rereading questions, be careful to
avoid any special emphasis on words not emphasized in the
printed copy by italics or capitals.
Mathematics Reading

A test taker is permitted to ask the reader to write notes and to assist
with intermediate steps in computing mathematics problems, especially
if the test taker has no tools or equipment for taking notes or is unable
to do so. For example, in the multiplication of numbers (e.g., 17 x 521),
a test taker may say, "Seven times one is seven. Put down the seven.
Seven twos are fourteen. Put down the four to the left of the seven and
carry the one." The test taker should be specific in directions to the
reader as to what he or she writes, in which column to write it, what to
carry, etc.
Mathematical expressions must be read precisely and with care to avoid
misrepresentation for a test taker who has no visual reference. For math

80

items involving algebraic expressions or other mathematical notation, it
may be preferable for the reader to silently read the entire question
before reading it aloud to the test taker. Use technically correct yet
simple terms, and be consistent in the treatment of similar expressions.
Some typical expressions and the manner in which they should be read
follow:
(a) Lowercase letters that are juxtaposed should be read as a
multiplication expression:
e.g., xy should be read as "x y," unless it is part of a complex
expression or this reading is otherwise unclear, in which case read
it as "x times y."
(b) Capital and lower-case letters should be differentiated because
they can have different meanings in mathematical or scientific
expressions:
e.g.,
R - 2y = 6
should be read as "Capital R minus two y equals six."
(c) Simple numerical fractions should be read as fractions:
e.g.,
5/6
Should be read as "five sixths."
(d) However, similar letter expressions can be read as one letter
"over" another:
e.g.,
a
______
b
Should be read as "a over b."
b+d
______
c
Should be re ad as "a fraction with numerator b plus d and
denominator c.”
If there is any question as to where the fraction ends, say "end fraction."
(e) Negative numbers should be read as "negative":

81

e.g.,
-5
should be read as "negative five," not "minus five."
When a subtraction operation is involved, read the sign as "minus,"
e.g. :
x -5
should be read as "x minus five."
(f) Expressions containing multiple mathematical operations should
be read exactly as they appear. Expressions containing
parentheses or brackets can be read in any of the following three
ways:
1. quantity, close quantity
2. paren, close paren (or bracket, close bracket)
3. left paren, right paren (or left bracket, right bracket)
For "paren, close paren" or "left paren, right paren," it is also
acceptable to use "parenthesis" instead of "paren."
If you use the term "quantity," in complicated expressions, announce
where enclosed portions end by saying "end quantity:"
e.g.,
(2x - 6y) - 10
could be read
• As "The quantity two x minus six y, close quantity, minus ten;"
• As "paren, two x minus six y, close paren, minus ten;"
• Or as "left paren, two x minus six y, right paren, minus ten."
a (x - y)
could be read as "a, parenthesis, minus y, close parenthesis."
a x b2

82

could be read as "a times the square of b."
Use pauses to audibly group sections of an expression together:
e.g.,
z + (-a)
could be read as "z plus [PAUSE] paren negative a close paren."
(g) If equations are used in the test you will be reading:
Since equations are a shorthand means of stating relationships between
quantities, the reader's job is to translate this shorthand back into
everyday English. Read equations in this order:
1.
2.
3.

If the equation is numbered, read its number first.
Give the meaning of each letter or symbol
Read the equation.
e.g.:
Eq. 6-2
E = energy in ergs
m = mass in grams
c = speed of light in cm./sec.
E = mc2
Read as "Equation six dash two. Capital E equals energy in ergs, m
equals mass in grams, and c equals the speed of light in
centimeters per second. Then, Capital E equals m c squared."
Test Center Procedures for Using a Reader

1.
2.

3.
4.

An approved reader should be admitted to the test center with the
test taker. The reader's photo-bearing identification should be
checked.
Prior to the start of the exam, the test center administrator/
supervisor will review the Guidelines with the test taker and the
reader and will set the ground rules for the conduct of the
examination.
The test administrator must remain in attendance at all times
during the test administration.
An approved reader is not present to function as an aide to the
test center staff. It is inappropriate to ask the reader to perform
clerical duties of any kind. The reader should not be asked to

83

5.

6.

assume any responsibilities belonging to either the center staff or
the test taker.
Test center staff must ensure that proper test security is maintained
at all times. It is important that the test administrator ask
questions and avoid any hasty interpretations of what may be
communication of test content or exchange of information between
the test taker and the reader that might give the test -taker an
unfair advantage. The task requested by the test taker might be
acceptable once understood. Discussion or communication concerning
interpretation of test content is not permitted. If such discussion
occurs and cannot be controlled, or if test center staff observe
anything they deem unusual, the situation should be reported on the
Supervisor's Irregularity Report (SIR) or the Electronic Irregularity
Report (EIR) and the test taker advised of this action.
The test center administrator may also stop the test and dismiss
the test taker if he or she believes that the reader has provided
the test taker with any unfair advantage. In such instances, ETS
reserves the right to cancel the test taker's score.
References

Educational Testing Service. (2003). ETS Guidelines for a Test Reader.
Retrieved August 1, 2008, from
http://www.ets.org/portal/site/ets/menuitem.c988ba0e5dd572bada20b
c47c3921509/?vgnextoid=7889bc914be45010VgnVCM10000022f95190
RCRD&vgnextchannel=d7f7be3a864f4010VgnVCM10000022f95190RCR
D
ETS materials selected from ETS Guidelines for a Test Reader, 2003.
Reprinted by permission of Educational Testing Service, the
copyright owner. For limited use by the American Printing House for
the Blind, Inc.

84

Notes:

85

Notes:

86

AMERICAN PRINTING HOUSE
FOR THE BLIND, INC.
1839 Frankfort Avenue
P.O. Box 6085
Louisville, KY 40206-0085

Toll Free: 800-223-1839
Fax: [phone]
Internet: www.aph.org

Exhibit D

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AFB

American Foundation®
for the Blind

Expanding possibilities for people with
vision loss

Building Assessment Initiatives for
Schools: Guidelines to Support the
Contract Development Process Between
Test Publishers and States
Braille Downloads
Download .BRF version of guidelines for contract development
Download .DXB version of guidelines for contract development

19th Annual Josephine L. Taylor Leadership Institute
Boston, Massachusetts
Friday, March 11, 2005

Introduction
Contracts and Requests for Proposals (RFPs) negotiated between state assessment agencies
and test publishers carefully outline the responsibilities and expectations for the state
assessment development and implementation process. While these documents have specific
points for consideration, often language does not include the assurance of accessible test
development and implementation. Accessible test items enable all students to participate in the
assessment process in a way that allows abilities rather than disabilities to be assessed.
Accessible formats of tests, including the practice tests, must be available for students with visual
impairments at the same time as their sighted peers. The checklists provided below outline
considerations for inclusion in each state's RFP or test contract. The usual contractual language
found in state contracts should be employed, with these special considerations added.

Universal Design Principles

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The following guidelines are general considerations for contract and RFP development that
ensure test development and use for all students, including those with disabilities:
The same assessment system is used to measure the achievement of all public school
students in the state. Groups to be included in the state assessment need to be clearly defined.
The student assessment system provides coherent information on attainment of state
standards across grades and subjects.
The tests are designed to be valid and accessible for all students. This includes students with
disabilities and students with limited English proficiency.
The tests are aligned with the state's challenging academic content and student achievement
standards.
The tests are valid, reliable, technically sound, and consistent with nationally recognized
professional and technical standards such as national test publisher standards and guidelines
of the American Psychological Association (APA) and American Educational Research
Association (AERA).
The reporting system allows results to be disaggregated (according to the No Child Left Behind
Act (NCLB) and Individuals with Disabilities Improvement Act of 2004 (IDEA) guidelines) within
each state and local education agency and school by gender, racial and ethnic group, migrant
status, disability, socioeconomic status, and limited English proficiency.
The tests involve multiple up-to-date measures of student academic achievement, including
measures that assess higher-order thinking skills and understanding.
The reporting system allows production of individual student reports.
Roeber, E. (2003). Assessment models for No Child Left Behind.
Education Commission of the States. http://www.ecs.org/html/Document.asp?chouseid=4009

Item Development and Review Process with Publisher
The following guidelines are provided for consideration as language to include in contracts and
RFPs that ensure the development and implementation of accessible test formats, specifically for
students with visual impairments.
Test publishers must maintain access to experts, i.e. individuals who know and have either
taught or are knowledgeable about braille, tactile graphics, large print, and audio. These
individuals can provide information during each phase of test development.
Experts in visual impairment must be included on Item Writing Committees and Bias Review
Committees.

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The use of accommodations must be considered during test item development to ensure
appropriateness to test purpose and test access.
The test item pool must be large enough for Bias and Item Review Committees to replace items
determined to be inaccessible when presented in braille, large print, audio formats, or as tactile
graphics.
A representative sample of students with visual impairments needs to be included in any fieldtesting of the assessments, as prescribed in Standard 10.3 (p. 106) of the Standards for
Educational and Psychological Testing (1999).
An adequate amount of time for tests and practice tests to proceed through a subcontractor's
processes needs to be built into contracts so that accessible media as required by each
student's Individualized Education Program (IEP) are delivered at the same time as the original
test materials.
All test administrators' manuals, supplemental manuals which accompany the accessible media
versions of tests, and local test administrators'/proctors' instructions and training manuals must
be provided in accessible formats for visually impaired staff. These accessible materials must
be requested far enough in advance to allow for delivery at the same time as the original test
materials.
At the end of each testing season, both students and teachers should give input regarding the
testing experience.
Item analyses for accessible format test items will be carried out at the end of each school year
(or testing season) as part of a continuous improvement plan.
Allman, C.B. (2004). Test Access: Making tests accessible for students with visual impairments:
A guide for test publishers, test developers, and state assessment personnel. Second Edition.
Louisville, KY: American Printing House for the Blind.
http://www.aph.org/tests/access2/index.html

Accessible Media Development with Subcontractors
This section provides guidelines for consideration when contracts are developed with
subcontractors such as agencies or individuals who will provide tests in one or more accessible
formats (braille, tactile graphics, large print, and audio). The process may include steps for
editing, transcribing, designing tactile graphics, proofing, producing and quality checking the
accessible media. It is essential that the timeline allow adequate time for each of these steps.
Additional time may need to be built into contracts depending on specific requirements of the
state such as an independent proofreading by another person or agency, or aligning various
media for multimedia presentations.

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The subcontractor must agree to work closely with the test publisher, the state department of
education, and the test editor.
The construct to be measured must be documented by the test publisher in test item
specifications and made available to test editors and accessible media producers.
Proofreading by a qualified individual, i.e. a person who knows the needed codes and formats
and is experienced or certified (if applicable), in braille, tactile graphics, large print, and audio
versions of the test must occur before multiple copies are made. High-stakes tests should be
proofed a minimum of two times.
Accessible versions of the test must be aligned so that a multimedia presentation (as approved
by state assessment programs) is possible if specified by a student's IEP.
Allowable test format changes, accommodations, and general assistance to test takers by the
test administrator or proctor must be stated in the test administration manual or supplemental
materials produced by the subcontractor.
Subcontractors must be able to meet their deadlines so that high quality accessible media are
delivered to school systems at the same time as the original test materials.
Test security and confidentiality standards must be upheld by testing subcontractors.
Allman, C.B. (2004). Test Access: Making tests accessible for students with visual impairments:
A guide for test publishers, test developers, and state assessment personnel. Second Edition.
Louisville, KY: American Printing House for the Blind.
http://www.aph.org/tests/access2/index.html

Resources
Assessment Models for No Child Left Behind,
from Education Commission of the States (ECS)
http://www.ecs.org/clearinghouse/40/09/4009.doc
Building Tests to Support Instruction And Accountability: A Guide for Policymakers,
from National Education Association (NEA) http://www.nea.org/accountability/buildingtests.html
Designing School Accountability Systems,
from Council of Chief State School Officers (CCSSO)
http://www.nciea.org/publications/desigSchAccSyst_Gong02.pdf
Illustrative Language for an RFP to Build Tests to Support Instruction and Accountability,

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from American Association of School Administrators (AASA)
http://www.aasa.org/issues_and_insights/assessment/Illustrative_Language_for_an_RFP.pdf
Information on Writing a Request for Proposal (RFP)
http://www.arches.uga.edu/~ninaaug/ITclasses/7550/
Model Contractor Standards and State Responsibilities for State Testing Programs,
from Education Leader's Council (ELC) http://www.accountabilityworks.org/publications
National Federation of the Blind (NFB/New Hampshire Resolution on Accountability)
http://www.education-rights.org/brailletwomey11399.html
Tennessee RFP for Development of Online Tests
http://www.state.tn.us/finance/rds/ocr/rfp/rfp33104001.pdf
Test Access: Making Tests Accessible for Students with Visual Impairments:
A Guide for Test Publishers, Test Developers, and State Assessment Personnel. Second Edition.
American Printing House for the Blind. http://www.aph.org/tests/access2/index.html
The Standards for Educational and Psychological Testing (1999),
American Psychological Association http://www.apa.org/science/standards.html
Thompson, S., & Thurlow, M. (2002). Universally designed assessments: Better tests for
everyone! (Policy Directions No.14).
Minneapolis, MN: University of Minnesota, National Center on Educational Outcomes.
Retrieved 1-28-05 from the World Wide Web:
http://education.umn.edu/NCEO/OnlinePubs/Policy14.htm

Contributors
Dr. Carol Allman, Accessible Tests Department with the American Printing House for the Blind,
[e-mail]
Barbara Henderson, Accessible Tests Department with the American Printing House for the
Blind, [e-mail]
Debra Sewell, Texas School for the Blind and Visually Impaired, [e-mail]
Mary Ann Siller, American Foundation for the Blind, [e-mail]

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Debbie Willis, Accessible Tests Department with the American Printing House for the Blind,
[e-mail]
Permission is given to distribute copies with appropriate credit: American Foundation for
the Blind, American Printing House for the Blind and Texas School for the Blind and
Visually Impaired from the Josephine L. Taylor Leadership Institute, March 11, 2005.

Copyright© 2015 American Foundation for the Blind. All rights reserved.

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