Accessible Educational Materials (AEM) are accessible print- and technology-based learning materials that increase access to general education content and grade level standards to learners with disabilities. Accessibility allows the learner with a disability to acquire the same information in an equally effective and integrated manner with substantially equivalent ease of use as a learner without a disability. Examples of AEM include:
- Captioning of video content
- Digital content with accessibility integrated
- Providing transcripts of audio content
- Print materials provided in accessible formats including braille, digital and large print
It should be noted that “accessible formats" as described in the final bullet point are a subset of AEM that is based on eligibility. AEM can also be provided in other ways for use by all students, such as purchased, teacher-created, or curated at no cost (i.e., Open Educational Resources).
AEM defined nationally is described as "print- and technology-based educational materials, including printed and electronic textbooks and related core materials that are required by SEAs and LEAs for use by all students, produced or rendered in accessible media, written and published primarily for use in early learning programs, elementary, or secondary schools to support teaching and learning." CFDA 84.327Z Footnote #10
While Iowa Administrative Code 281-41.172 and 281-41.210 reference accessible instructional materials (AIM), AIM refers only to print-based materials. Due to the increased use of technology-based learning materials there has been a shift, nationally, to use the term accessible education materials (AEM) which encompasses both print- and technology-based materials.
AEM Procurement Update
Beginning Oct. 1, 2022, the Iowa Department of Education will transfer the responsibility for procurement of braille, tactile graphics, and large print to local districts. This webinar recording describes the changes and processes districts may use to procure these accessible formats.
Accessibility is not an issue limited to special education or to educational learning materials. In 1931, when the current Copyright Law was written, provision was made for individuals who were blind, so that it was not an infringement of copyright for an authorized entity to reproduce a copyrighted work if the copy was in an accessible format such as braille or audio recording for a person who was blind or had a disability. A variety of accessibility considerations emerged from Civil Rights Laws such as the Americans with Disabilities Act and the Rehabilitation Act of 1973 (Sections 504 and 508). Many accessibility innovations such as curb cuts, closed captioning, and doors that open automatically are a result of Civil Rights legislation and the concept of Universal Design for Learning.
The 2004 Reauthorization of the Individuals with Disabilities Education Act (IDEA) Section 300.172 added provisions to IDEA “to help improve the quality and delivery of accessible formats to students with disabilities who need such materials. Among these provisions, States were required to adopt NIMAS, which stands for the National Instructional Materials Accessibility Standard. NIMAS is a technical standard used by publishers to prepare “electronic files” that are used to convert instructional materials into accessible formats.” The Reauthorization includes expectations for State Education Agencies (SEAs) and Local Education Agencies (LEAs) to provide learners with disabilities with AEM in a timely manner. National Center on Accessible Educational Materials. (August 15, 2022) NIMAS & NIMAC. Retrieved Nov. 16, 2022 from https://www.oercommons.org/courses/nimas-nimac
Section 121 of the U.S. Copyright Act, the Chafee Amendment (17 U.S.C. 121 & 121A), expanded the concept of copyright exempt individuals. This exemption to Copyright Law opened the door for making accessible materials a reality for learners. The Marrakesh Treaty Implementation Act (2018) provided an update and then in December 2019 Congress also updated the statute authorizing the National Library Service for the Blind and Print Disabled. These changes have implications for the provisions of IDEA, specifically the National Instructional Materials Accessibility Standard (NIMAS). The revisions replace previously used terms with “eligible person” and “accessible formats” and are defined as follows.
- “Eligible person” is now used to describe a learner who qualify for NIMAS-derived materials and includes an individual who regardless of any other disability
- (A) is blind;
- (B) has a visual impairment or perceptual or reading disability that cannot be improved to give visual function substantially equivalent to that of a person who has no such impairment or disability and so is unable to read printed works to substantially the same degree as a person without an impairment or disability; or
- (C) is otherwise unable, through physical disability, to hold or manipulate a book or to focus or move the eyes to the extent that would be normally acceptable for reading.
- “Accessible formats” replaces the previous term “specialized formats.” Accessible formats is now used to describe the types of formats that may be developed from NIMAS file sets that give an eligible person access to the work when the copy or phonorecord in the accessible format is used exclusively by the eligible person to permit access as feasibly and comfortably as a person without such disability. “While the previous term ‘specialized formats’ had identified four specific alternative media – namely, braille, audio, digital text, and large print – the new term ‘accessible formats’ is a more inclusive and functional term that focuses on the experience of the user, emphasizing that an alternative format enables the eligible person to have access to the work ‘as feasibly and comfortably as a person without such disability.’” National Center on Accessible Educational Materials. (n.d.) NIMAS Terms Clarified Post Marrakesh. Retrieved November 16, 2022 from https://aem.cast.org/nimas-nimac/nimas-terms-marrakesh
- “Going forward, in order to be eligible for NIMAS-derived materials, students must be receiving services under IDEA and fall under one of the disability categories identified above. In February of 2021, the Library of Congress published the following list of professionals who can certify a student as eligible to receive NIMAS-derived materials: doctor of medicine, doctor of osteopathy, ophthalmologist, optometrist, psychologist, registered nurse, therapist, and professional staff of hospitals, institutions, and public or welfare agencies (such as an educator, a social worker, case worker, counselor, rehabilitation teacher, certified reading specialist, school psychologist, superintendent, or librarian). (CAST citation https://aem.cast.org/nimas-nimac/nimas-terms-marrakesh
- “Accessible format” replaced “specialized format.”
- The term “eligible person” is now used to describe learners who qualify for accessible formats.
- A medical doctor is no longer required to certify individuals with reading disabilities.
On May 26, 2020 the U.S. Department of Education issued a Notice of Interpretation (NOI) permitting the National Instructional Materials Access Center (NIMAC) to accept files derived from digital instructional materials. The NOI clarifies that the term ‘‘print instructional materials,’’ with regard to the scope of NIMAS in IDEA 2004, includes digital instructional materials.
In recent years, additional federal action has expanded the expectation of accessibility in telecommunications and education. The 2016 National Education Technology Plan specifically draws connections between the flexibility and power of today’s technology in its learning recommendation that “Education stakeholders should develop a born accessible standard of learning resource design to help educators select and evaluate learning resources for accessibility…” Next Generation Assessment Recommendations also address increasing accessibility in technology-based assessments.
The Office of Special Education Programs (OSEP) occasionally writes Dear Colleague Letters (DCL) to clarify positions. Several of these letters focus on issues related to accessible learning materials.
Dear Colleague Letters (DCL)
- June 29, 2010 - DCL on Electronic Book Readers (joint letter with the U.S. Department of Justice and Department) addresses accessibility of emerging technologies and requires educational institutions to provide learners the opportunity to acquire the same information, engage in the same interactions, and enjoy the same services as learners without disabilities, with substantially equivalent ease of use.
- June 19, 2013 - DCL on Braille discusses the importance of braille instruction. In addition, the letter states that “Factors, such as shortages of trained personnel to provide braille instruction, the availability of alternative reading media (including large print materials, recorded materials, or computers with speech output); or the amount of time needed to provide a child with sufficient and regular instruction to attain proficiency in braille, may not be used to deny braille instruction to a child.” and identifies resources to help meet the needs of learners who are blind or visually impaired.
- October 23, 2015 - DCL on Dyslexia Guidance focuses on the educational needs of learners with dyslexia, dyscalculia and dysgraphia as those conditions could qualify a learner as having a specific learning disability. This letter references accommodations and supports that these individuals may need and refers state and local education agencies, as one resource, to the National Center on Accessible Educational Materials.
- November 16, 2015 - DCL clarifies that IEPs “must be aligned with the State’s academic content standards for the grade in which the child is enrolled.” In an example of implementation, “audio textbooks and electronic versions of longer reading assignments that can be accessed through synthetic speech” (i.e. accessible educational materials), show a way that an Individualized Education Plan (IEP) could provide access to the grade level content and standards for a learner with a disability.
Iowa Administrative Code for Special Education procedures takes accessible instructional materials provision a step or two beyond what is in Federal Regulations. It defines “timely manner” to be “at the same time as peers” so there is no lag for a learner who needs AIM in getting the general education curriculum materials. Iowa Code also uses a larger lens in identifying learners who receive AIM by stating that any learner with a disability who needs accessible instructional materials will receive them. Iowa Code obligates general education curriculum adoption and acquisition decision makers to purchase accessible materials by including in contract language that publishers or vendors provide materials that are accessible or can be rendered into specialized formats. The Iowa Department of Education and the Area Education Agencies (AEAs) partner to support these legal requirements. Iowa Administrative Code 281-41.172 and 281-41.210
School districts have the responsibility to provide learning materials that are accessible to all learners who qualify as eligible persons. Core curriculum material and textbooks that are in a traditional hard copy may need to be converted to an accessible format, including braille, large print, audio, and digital text. These accessible formats enable learners with print disabilities to gain the information they need to complete tasks and access content to make growth toward grade-level standards. In addition, digital learning materials, whether an online textbook, website, or material added by teachers to a learning management system, must be fully accessible to eligible individuals.
Within the school system, many people have a critical impact on the success of acquiring and providing AEM.
- Administrators provide support for the overall system.
- Technology experts provide critical skill and coordination in selecting accessible technologies as well as configuring the technology infrastructure to accommodate web-based AEM.
- Curriculum specialists are the conduit between learning materials’ publishers and the school to assure that purchases are fully accessible and that accessible formats can be provided.
- Special Education staff play an essential role in identifying and collecting convergent data to determine whether a learner needs AEM.
- General Education teachers are on the front line in observing, assessing, interacting with, and identifying learners who would benefit from the use of AEM.
- Parents, who know their children best, can provide valuable insight for educators.
- AEA staff responsible for Child Find
- Teachers of the Blind and Visually Impaired
- Regional Directors
- Directors of Special Education
Timely Manner is defined in Iowa Special Education rules to be “at the same time as peers,” so there is no lag in getting the general education materials to learners who need AEM. The learner’s IEP team should discuss whether or not the materials that the learner requires are accessible. If the content is not readily accessible to the learner the team will need to determine the following:
- What is needed to make the content accessible?
- Do materials need to be purchased, ordered, or developed?
- If materials need to be ordered, who will complete the ordering?
- Do staff need training in creating accessible materials?
- Who will be responsible for providing the materials to the learner?
Ultimately, the LEA is responsible for assuring that AEM is provided in a timely manner and that the materials are produced according to quality parameters. Within the IEP or 504 plan the team may describe specifics that must be adhered to in order to meet the standard of quality for an individual learner. For example, in the IEP a team might indicate that a learner who uses braille for instruction and assessment needs to have literary materials produced in braille and math materials produced in Nemeth within the UEB context. Graphics such as maps or charts should be produced as tactile graphics and illustrations should have meaningful image descriptions. A process for timely acquisition and provision of AEM can be designed and individual responsibilities assigned and documented in the IEP or 504 plan. For example, the special education teacher in coordination with the general education teacher and teacher of the blind and visually impaired (TVI) may be designated as the person who will request specific curriculum, including textbooks, be transcribed and submit that request so that the material is delivered in time for the first day of school.
Members of the learner’s IEP or 504 team will determine if the learner may benefit from accessible educational materials in order to access content and standards. Some questions that may be helpful in determining the need for AEM include:
- Does the learner understand grade-level reading material at a higher level when it is read to them?
- Does the learner’s rate of reading impact comprehension or the time it takes to complete the task?
- Does the learner have difficulty decoding words and reading with fluency at or near grade level?
- Does the learner have accommodations listed in the IEP that require an adult reader at specific times?
- Does the learner have hearing, vision or physical difficulties that prevent them from independently using print or digitally-based materials?
- Does the learner require accessible materials for working or living?
If the answer is ‘yes’ to any of these questions then the learner may need AEM. The IEP team will need to document this information within the learner’s IEP or 504 plan then develop a plan to acquire and provide the accessible materials to the learner.
For learners with visual impairments, the Teacher of the Blind and Visually Impaired (TVI) conducts a Learning Media Assessment (LMA) which includes observations, interviews and assessments to determine a learner’s use of print, braille or auditory media. The LMA reviews a learner’s use of and access to technology, optical devices and assistive technology that provides them access to print within the educational environment. With information collected through the LMA, the IEP team will determine the most appropriate educational materials for the learner.
Access to learning is improved when materials and technologies are provided that are accessible to all learners. There are two paths to acquiring accessible educational materials and technologies. Preferably, purchase materials and technologies that are accessible at the time of acquisition. This is most cost-effective and efficient. If that doesn’t happen, materials require retrofitting to remove barriers for learners with print disabilities. For more information visit the AEM Center’s page on Pathways to Acquiring Accessible Materials and Technologies.
Purchase Accessible from the Beginning
Assuring that materials purchased from vendors are accessible means that learners who use assistive technology will have access to content in a timely manner i.e. at the same time as their peers. In addition, materials that have been designed to be accessible are likely to have features that enable other learners to customize their learning.
Materials and technologies should be vetted for accessibility as districts consider adopting new curriculum, a new Learning Management System (LMS) or technology. A process for vetting accessibility uses the acronym “POUR”.
- Is it Perceivable? Materials are accessible to a wider array of learners when there are digital resources available and adjustments can be made to the text size, background/text colors and there are alternative text for images, captions for videos and transcripts for audio content.
- Is it Operable? There are flexible navigation options and learners have multiple ways to access the content interface.
- Is it Understandable? Materials are presented in a logical, intuitive, predictable manner so that learners can focus their attention on learning the content.
- Is it Robust? Materials work well with current and future technologies, including assistive technologies.
The other component of acquiring accessible formats from the beginning includes language that LEAs include in purchase orders or contracts with vendors. To ensure the LEA meets federal statutes and regulations, it is essential to include accessibility requirement language. There are additional specifications that should be included when materials being purchased are web-based publications and documents such as PDF and EPUB, and software and apps. Sample contract language is available on the AEM Center website.
Purchasing Materials that are not Accessible from the Beginning
Some materials are not “born” accessible. These require a NIMAS (National Instructional Materials Accessibility Standard) fileset to be submitted to a national center (NIMAC) where the filesets can then be downloaded by an Accessible Media Producer (AMP) for the creation of the accessible format that the eligible learner needs. LEAs play an important role in obligating publishers to submit NIMAS-conformant files of textbooks and related core instructional materials to the NIMAC. Language requiring publishers to submit a NIMAS file to the NIMAC should be included in purchase orders or contracts. When math materials are being purchased, the contract language should also reference the need for the materials to be rendered according to MathML3 Structure Guidelines. Sample contract language when ordering materials requiring NIMAS files can be found on the AEM Center website.
IDEA 2004 defined the types of materials that should be provided in NIMAS format i.e. “printed textbooks and related printed core materials”. A May 2020 Notice of Interpretation (NOI) clarified that definition to include digital instructional materials. There is a limited range of digital instructional materials that can conform to the NIMAS specification- examples include PDF, HTML and EPUB formats that are not primarily or substantially composed of interactive or audio-visual content.
- Organizations that Provide AEM
There are federally-funded and commercially available services that provide accessible educational materials in a variety of formats. LEAs and AEAs may choose to use these organizations as part of their plan to provide high quality materials in a timely manner.
Bookshare is an e-book library containing over a million books for individuals with print disabilities, in digital text, audio and refreshable braille formats (BRF). All items in Bookshare’s collection can be read in braille, using compatible reading tools such as a refreshable braille display. Bookshare also offers reading tools that allow learners to customize their reading experience, so that material is presented in the manner that works best for them and can be read on the device of the individual’s choice. For example, text highlighting options are available; visual display can be changed with colors and font sizes; auditory features, such as voices or reading rate, can be customized. Every LEA can have a free organizational account so that educators and qualified learners can download textbooks and other reading materials they need. Qualified learners with print disabilities can also have a free individual account.
Learning Ally is a subscription-based service that has over 80,000 human-read audiobooks including popular fiction, literature, and textbooks. Books are recorded in one of three audio formats: human-read audio only; human-read with visible, highlighted text; or synthesized speech with highlighted text. Students receive unique login credentials and download audiobooks to their personal online bookshelf. Students then log in to the free reading app and download books from their bookshelf directly to their home or school-issued technology. Learning Ally tools are compatible with PCs, Macs, Chromebooks, Android and iOS devices.
Anamosa Braille Center
The Anamosa Braille Center provides a variety of services including Braille On Demand. Braille on Demand is a service that LEAs may use to have content quickly transcribed into braille. Tactile graphics and hard copy braille can be produced through Braille On Demand. The Center also provides textbook and worksheet transcription in addition to large print textbook conversion. Contact the Center for a quote and timeline for work completion.
Instructional Materials Center
Iowa Department for the Blind partners with LEAs to provide a variety of accessible formats including braille, tactile graphics, large print, digital audio, and electronic text to learners who are eligible under the Chafee amendment.
Beginning Oct. 1, 2022, the Iowa Department of Education transferred the responsibility for procurement of braille, tactile graphics, and large print to local districts. This webinar recording describes the changes and processes districts may use to procure these accessible formats.
- Creating and Teaching with Accessible Classroom Materials
Teachers often create materials for use in the classroom. Considerations for accessibility are required to ensure access for all learners. The following list of questions will help you identify your level of skill and need:
- Do you know how your learners with print disabilities access curriculum materials?
- Do you want to check the accessibility of materials in your Learning Management System (LMS)?
- Can you create accessible documents?
- Are you able to create accessible documents by scanning documents using OCR?
- Are you able to create accessible presentations?
- Can you find or make an accessible video? Here are suggestions on Teaching with Accessible Video from the AEM Center.
- How do you provide accessible math? Here are suggestions on creating accessible STEM materials as well as Teaching with Accessible Math from the AEM Center.
- Do you use graphs, charts, maps or illustrations in instruction? How can your learners with print or vision disabilities access this content?
- If you have a student who uses braille you may consider the following for a quick turnaround of materials:
- Braille On Demand
- A trained transcriptionist at the local level using just-in-time transcription tools such as:
- Transcription software installed on a school computer
- to create literary braille in UEB or
- to create math or technical materials using Nemeth tools within a UEB context.
- A braille embosser (printer) required to print braille documents created at the local level.
- Additional tools to create braille versions include:
- Braille writers/braillers for use at school and home
- Slate and stylus which is similar to paper and pencil
- Transcription software installed on a school computer
Training Opportunities and Certification for Braille Transcription
Training in transcription is essential for producing AEM for learners who are blind or visually impaired. The Braille Authority of North America (BANA) has detailed and specific standards that should be followed in preparing literary, math, science notation, chemistry notation, and tactile graphics. Formatting braille pages properly is a critical component of transcription as is using the appropriate form of braille e.g. contracted or uncontracted, needed by the individual reader. In Iowa, braille users learn UEB (Unified English Braille) for literary content and Nemeth within UEB context for math and technical content. A previous code (EBAE) is no longer supported as an official code now that UEB has been implemented. BANA recommends that materials in EBAE should be phased out and new materials should no longer be produced in this code. The Local Education Agency is responsible for assuring that materials are acquired and provided in a timely manner and that the quality of AEM meets braille standards.
Training opportunities for braille certification are available through these resources:
- Navigation of Braille Certification - The process for learning and becoming certified in braille.
- #AtHomeWithAPH Resources - Videos, handouts, webinars and other learning and support resources.
National Instructional Materials Access Center (NIMAC) - Free training courses for braille transcribers working with NIMAS files.
Iowa Department for the Blind
- Braille Bits
- Instructional Material Center-Braille Production Process
- Summer Online Course for Paraeducators
Iowa Educational Services for the Blind and Visually Impaired
Vetting and ordering accessible materials is an essential part of providing accessible educational materials to learners who need them. The other critical piece is to provide supports so that learners can effectively use those accessible formats.
These supports include
- providing technology that accommodates the accessible material;
- training on features of the technology for teachers, personnel and learners and families;
- instructional strategies, support services and potential accommodations that are needed for learners to use the accessible formats for optimal learning.
For further information, visit the AEM Center’s page for Using Accessible Formats.
AEM requires consideration of technology from two perspectives: can the learner access the content with the technology that is available for all learners in the school district? If not, what tools (assistive technology) are required for the learner to access the content?
A preponderance of new technology has built-in features for accessibility. These features can be explored and selected through settings on a device or in a software application. In addition, a district technology administrator has access to additional tools that can add to the accessibility of the technology in terms of permissions to use individual features of the product. Accessibility features are included in hardware, operating systems, learning management systems (LMS), handheld technology and individual applications. Examples of accessibility features that may be built-in include: voice input, text to speech/read aloud, changes in background or font color, changes in font size, screen reader support, alternative text (alt text) for images, closed captioning for video and text highlighting.
When a learner has a disability that cannot be fully accommodated with built-in features, other assistive technology is considered by the IEP team. There is a wide range of assistive technology, but common items include alternate keyboards, braille writers, large monitors, augmentative alternative communication (AAC) devices, and Hearing Assistive Technology (HAT) systems to increase access to auditory information.
Some learners use assistive technology to access braille. Braille note takers or electronic braille displays have multiple functions so that a learner can write, manage a calendar, and access online materials. Note takers and electronic braille displays can connect to a handheld device or a computer to give learners access to additional content.
Whether or not the technology is a built-in feature or a separate device, the IEP or 504 team needs to determine if it is required for the learner to receive a free and appropriate public education (FAPE). If the feature or device increases, maintains or improves the functional capabilities of the learner with a disability then it would be considered assistive technology and would be documented as such on the IEP or 504 plan.