September 30, 2021

The K-12 Education Standards Development Committee is responsible for developing recommendations for accessibility standards for publicly funded K-12 schools in Ontario. In September 2021, the Committee was seeking public feedback on their initial recommendations report. The proposed education standards address solutions to identify, remove and prevent accessibility barriers faced by students with disabilities at school.

Based on March of Dimes Canada’s long history as a service provider and advocate in Ontario, we submitted the following response to help make school more accessible for people with disabilities. 

MODC welcomes the opportunity to provide input on the initial recommendations for the development of K-12 education accessibility standards in Ontario. In developing this feedback, we draw on our experience as a major provider of community-based programs for youth and children with disabilities, as well as our experience supporting young people with disabilities to access training and employment opportunities. We have also included the insights of MODC staff who with training and experience as educators in Ontario’s publicly funded K-12 education system.

Overall, MODC broadly supports the initial recommendations put forward by the Standards Development Committee. Adopting the long-term objective that the publicly funded K-12 education system should be fully accessible, equitable, inclusive and learner-centred, we appreciate the Committee’s proposal of robust recommendations to address the multifaceted barriers experienced by students. We also appreciate that the Committee recognizes that access to information about the existing programs, services, supports, accommodations and placements available to students with disabilities is a crucial piece of this puzzle. 

In particular, MODC endorses the recommendations to embed Universal Design for Learning in training for educators and in curriculum development. Taking a Universal Design approach recognizes that it is not enough to accommodate each specific student who has a disability, but that we must provide learning experience using multiple modalities and delivery formats that meet the needs of a diversity of learners. Approaching curriculum and delivery in this way will not only benefit students with disabilities, but students who experience other forms of marginalization as well as able-bodied students who learn in different ways.

In addition, embedding content about accessibility and disability into the curriculum is a crucial component of ensuring that the entire school community – including able-bodied students – works to normalize disability and accessibility, to remove stigmas and create more inclusive environments. 

We also enthusiastically support the following recommendations: 

While MODC is quite pleased with the initial recommendations overall, there are some limitations within the proposed regulations that should be addressed to ensure that the objective of creating an accessible, equitable, inclusive and learner-centred education system is fully realized. Our recommendations for strengthening the regulations are outlined below.

Awareness and training

As stated above, we agree that training for educators is much needed. Currently, much of the focus of training for teachers and school staff is focused on enabling students with disabilities to achieve academically. This is an important skillset for educators to have, but only creates inclusion for students with disabilities within one aspect of their school experience. For example, equipping teachers with the knowledge to provide a large print textbook to a student with sight loss may enable student to follow along in class – but it does not address the other barriers the student faces in feeling valued, included and building the skills to succeed beyond the classroom.

One of the most significant barriers facing students with disability is exclusion and social isolation. Currently, teacher training in our province does not cover how to include students with a disability in the classroom, and even the credentials for special education do not adequately prepare teachers to ensure students with disabilities’ inclusion.

It is important that any disability-related training for teachers and school staff emphasizes addressing students’ holistic needs in terms of inclusion and full participation throughout their school experience. It should not narrowly focus on the specific accommodations required to enable the student’s academic success. For example, growing up with a disability and transitioning to adulthood requires a high level of problem-solving skills; how can training for educators ensure that students with disabilities are being equipped with the soft skills they need to succeed later in life?

Curriculum, assessment and instruction

The focus on Universal Design for Learning is a promising one, as it relates to improving accessibility and inclusion for students with disabilities – and all students – in the classroom. One crucial juncture for accessible curriculum and instruction planning is the teacher’s planning period for the upcoming school year. 

As a default, teachers should be supported to set up the classroom with some basic accommodations and modifications to address Universal Design needs. It is recommended that a checklist or best practices document is created to support educators to incorporate accessibility into their planning and setup of the classroom in September, including:

Digital learning and technology

A number of the recommendations focus on removing digital and technology barriers for students with disabilities, an important consideration as schools move toward becoming increasingly digital. 

We appreciate that the Committee recommends that students who are provided with assistive technology at school should be allowed to take the technology home. However, this recommendation could be strengthened further. Currently, students who require assistive devices or technology receive devices that are funded through the Special Equipment Amount (SEA). Some students can receive equipment as young as kindergarten. This equipment follows them throughout their entire school years, and can be upgraded every four years, as needed. However, when the student leaves the K-12 school system, the equipment which they have used to communicate, self-regulate, read and write must be left with the school board, as the school board’s property. Often this equipment is recycled, stored or disposed of. We recommend that, particularly in situations where the device cannot be used by a future student, the student should be allowed to take the equipment with them in order to continue to succeed and participate as they transition out of the K-12 education setting. 

Also worth noting is that digital lending libraries are often used as a tool for students to access reading materials. However, materials uploaded to digital lending libraries are often photocopied and scanned, resulting in poor readability or incompatibility with assistive technology. We suggest adding a recommendation specific to digital lending libraries, recognizing these unique challenges.

Individual Education Plans (IEPs) 

MODC agrees with the Committee’s recommendations that a number of improvements must be made to Individual Education Plans (IEPs). In addition to the improvements outlined in the report, we suggest that it is important for IEPs to be considered more holistically. Currently, the focus is very academic, outlining the accommodations needed to enable the student’s learning. The IEP could be reconfigured to focus on the holistic school experience for the student, including transition-planning when they change schools or as they prepare for transition out of the K-12 system.

Assessments for students with disabilities’ needs

We appreciate the Committee’s recommendations around improving accessibility and timeliness of professional assessments of disability-related needs. Currently, students typically do not receive an IEP unless they have an official assessment or diagnosis. It is worth noting that diagnosis sometimes comes later in childhood; in the meantime, whatever observations are made regarding accommodations to enable the students’ success must be implemented and documented immediately. Students must be supported to be included, regardless of the existence of an official diagnosis or IEP.

Parent and student participation

There are a number of recommendations regarding improving the participation of parents/guardians and students in the student’s educational plan and accommodation processes. Recognizing the vital role of families as support systems for students with disabilities, we recommend adding some language regarding siblings’ participation and additional support for siblings of students with disabilities, where appropriate. 

Social realms

MODC agrees with the Committee’s statement that social realms are an important part of the educational experience and not to be overlooked. It is important to consider that school-facilitated social events, while easiest to regulate, are only one aspect of the social experience. However, for students with disabilities, being included at school does not always translate into being included after school. Unlike their able-bodied peers, many students with disabilities cannot be spontaneous; they may need to arrange for accessible transportation or care in order to participate. Additional training, funding and awareness among educators and school administration is required in order to reduce social isolation for students among their peers. 

Experiential/co-op learning

As noted by the Committee, experiential and co-op learning opportunities are crucial opportunities for them to gain valuable work experience. It is worth noting that specialized training for co-op educators may be required to properly identify, evaluate and facilitate the placement of students in accessible work environments, and additional staff may be required to provide adequate support in job placement.   

Importantly, experiential and co-op learning programs are also an opportunity to connect dots between systems for students with disabilities. Given that youth with disabilities typically face barriers to employment, it is worth considering how schools might link a co-op placement with other opportunities for a student with a disability. For example, a co-op placement could eventually translate into a summer or post-graduation job, or it could provide an opportunity to connect with a college about their relevant programs. Co-op placements are also a potential partnership opportunity with community agencies with expertise in supporting job seekers with disabilities.  

Transition planning

While transition planning is considered in the Committee’s report, we suggest that transition-planning must be considered more broadly. Transitioning between schools and out of K-12 education are not the only transition points. If the education system aims to prepare students for the future, it is important for schools to support students with disabilities to plan for transitions between life stages as well. Broadly speaking, the K-12 education system should set students with disabilities up for success in adult life and look at their success more holistically. 

Support with postsecondary education planning

Beyond transition-planning, the report does not include recommendations regarding supports for students with disabilities to explore their postsecondary education options. For example, when planning for college and university fairs or career days, schools must consider the specific needs of students with disabilities. 

Similarly, school counselling regarding college and university applications must consider accessibility and disability-related needs. School counsellors should have awareness training to avoid perpetuating barriers or stigma regarding students with disabilities’ postsecondary options. In addition, students with disabilities may require additional support to navigate the process and may need additional information about accessibility and accommodations in different postsecondary institutions, and resources about the full range of programs available to them, including vocational training.

Partnership opportunities

While there is some mention of partnering with community service providers, as well as coordinating services amongst programs funded by different Ministries, there is an opportunity to more clearly articulate the opportunities presented by partnering with community organizations. Many organizations, like March of Dimes Canada, play a significant role in providing programs and services to children and youth with disabilities. In the interest of pursuing a student-centred model without barriers, it is important for schools and school boards to intentionally work in partnership with the community-based organizations serving students with disabilities. 

Episodic disabilities

It is important to address the specific needs of students with episodic disabilities who require accommodations, but not on a full-time basis. For example, some students with episodic disabilities may need to be absent from school periodically. Options for these students to continue their education must be explored, including curriculum being provided at home or virtual learning options.

Educators with disabilities

Lastly, while we appreciate that the mandate of the Committee focused on removing barriers for students with disabilities, we would be remiss not to mention the hiring of teachers and educational staff with disabilities and the employment accommodations they receive. Diversity and representation among educators will impact the experiences of students with disabilities, and so it is important to consider how the publicly funded education system encourages and cultivates diversity, accessibility and inclusion at every level.