Minutes: NIMAS Development Committee Meeting, January 2005

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Minutes: NIMAS Development Committee Meeting, January 2005

CAST, Inc.
40 Harvard Mills Square, Suite 3
Wakefield MA 01880-3233
Voice 781-245-2212
TTY 781 245 9320
Fax 781 245 5212
Scribe: Jennifer Sutton
DATE: January 18 – January 19, 2005
LOCATION: Caribe Royale, Orlando, Florida (pre-conference related to the Assistive Technology Industry Association Conference)

Two links to aid in navigating the Web version of this document are:
  1. Skip the Table of Contents and go to the list of attendees, or
  2. Skip the Table of Contents and list of attendees to go to the first day's activities.

Table of Contents


Attendees

Committee Members

  • Jose Blackorby, Program Manager, Disability Policy Program, Stanford Research International, Menlo Park, CA (National Center for Learning Disabilities)
  • Frederick (Rick) Bowes, III, Electronic Publishing Associates, Consultant, American Foundation for the Blind, Duxbury, MA
  • Janice Carter, Manager, The Benetech Initiative/BookShare.org, Palo Alto, CA
  • David Dikter, Executive Director, Assistive Technology Industry Association, Jamaica Plain, MA
  • Steve Driesler, Executive Director, School Division, Association of American Publishers (AAP), Washington, DC.
  • Bill East, Executive Director, National Association of State Directors of Special Education, Alexandria, VA
  • Rick Ferrie, Scott Foresman/Pearson Learning, Pearson Education, Glenview, IL
  • Jim Fruchterman, President & CEO, The Benetech Initiative/Bookshare.org, Palo Alto, CA
  • Chuck Hitchcock, Project Director, NIMAS Technical Assistance Center, CAST, Wakefield, MA
  • George Kerscher, Senior Officer, Accessible Information Recording For the Blind & Dyslexic (RFB&D), Secretary General, DAISY Consortium, Co-chair Web Accessibility Initiative (WAI), a division of the W3C, Chairperson, Open eBook Forum (OeBF), Missoula, MT (Co-chair, ANSI/NISO Z39.86 Maintenance Committee)
  • Steve Noble, Policy Analyst, Kentucky Assistive Technology Service Network, Louisville, KY (Learning Disabilities Association of America)
  • Mary Platner, Teacher Scottsdale Elementary School, Scottsdale, AZ (Council for Exceptional Children)
  • James Pritchett, Project Manager, Technology Development Recording for the Blind & Dyslexic, Princeton, NJ (ANSI/NISO Z39.86 Maintenance Committee)
  • Richard Robison, Executive Director, Federation for Children with Special Needs, Boston MA
  • David Rose, Principal Investigator, CAST, Wakefield, MA
  • Dave Schleppenbach, CEO, gh LLC, West Lafayette, IN (Assistive Technology Industry Association)
  • Mary Ann Siller, Director, National Education Program, American Foundation for the Blind, Dallas, TX
  • Larry Skutchan, Technology Project Leader, American Printing House for the Blind, Louisville, KY
  • Chris Wilder-Smith, Principal Technical Architect, CAST, Wakefield, MA
  • Skip Stahl, Project Director, NIMAS Development Center, CAST, Wakefield, MA
  • Ron Stewart, Director, Technology Access Program, Oregon State University, Corvallis, OR (Association of Higher Education and Disability)
  • Jennifer Sutton, Consultant, CAST, Silver Spring, MD

Regrets: Committee Members

  • Frank Bowe, Professor, Hofstra University, Hempstead, NY (National Association of the Deaf)
  • Donald Deshler, Director, Center for Research on Learning, University of Kansas, Lawrence, KS (National Center for Learning Disabilities)
  • Bonnie Jones, Education Program Specialist, Office of Special Education Programs, United States Department of Education, Washington, DC
  • Chuck Mayo, Assistant Director, Textbook Administration Division, Texas Education Agency, Austin, TX (National Association of State Textbook Administrators)
  • Martha Minow, Professor, Harvard Children's Initiative, Harvard Law School, Cambridge, MA
  • Michael Wehmeyer, Associate Professor, Special Education, University of Kansas, Lawrence, KS (Association of Retarded Citizens)

Additional CAST Attendees

  • Rebecca Beck, Director of Instructional Development
  • Linda Encarnacao, Executive Assistant

Regrets: CAST Representatives

  • Aubrey Francois, Technology Development Manager
  • Jennifer Jude, Research Assistant

Contributing Experts and Interested Visitors

  • Chris Arthur, Don Johnston Inc.
  • Stephen Baum, Kurzweil Educational Systems, Inc.
  • Bill Beavin, American Printing House for the Blind
  • Bob Brasher, American Printing House for the Blind
  • Jessica Brodey, Assistive Technology Industry Association
  • Froma Cummings, Arizona Department of Education
  • Blake Erickson, Telex
  • Bridget Herd, Telex
  • Dominic Labbé, VisuAide
  • Ivan Lagacé, VisuAide
  • Randy Marsden, Madentec
  • Karen McCall, Karlen Communications
  • Martin McKay, Texthelp
  • Julia Myers, American Printing House for the Blind
  • Gary Mudd, American Printing House for the Blind
  • Sara B. Nerlove, National Science Foundation
  • Rick Osterhaus, AbleNet
  • Fred Ross-Perry, IntelliTools
  • Mark Richert, Association for Education and Rehabilitation of the Blind and Visually Impaired
  • Cyndi Rowland, WebAIM
  • Paul Schroeder, American Foundation for the Blind
  • Diane Schuch, Talking Tapes Textbooks
  • Jared Smith, WebAIM
  • Neil Soiffer, Design Science
  • Phil Steele, gh
  • Tuck Tinssley, American Printing House for the Blind
  • Ruth Ziolkowski, Don Johnston Inc.

Tuesday, January 18, 2005

CAST and the Committee members wish to express their appreciation to the Assistive Technology Industry Association (ATIA) for hosting this meeting. David Dikter deserves special recognition and thanks for his assistance with making the meeting such a success. The facilities and service were excellent.

Continental breakfast; introductions, overview of the day

Note: Although Bonnie Jones was unable to attend, her greetings were expressed by various individuals on her behalf.

Others who welcomed the group and set the tone for the meeting included:
  • David Dikter – Assistive Technology Industry Association
  • Greetings from CAST – Chuck Hitchcock, David Rose, and Skip Stahl

Opening remarks highlighted the enthusiasm for the work ahead – the result of which will be to have accessible textbooks in the hands of students in a timely manner.

The NIMAS Centers: Goals, Objectives & Desired Outcomes

Skip Stahl and Chuck Hitchcock each provided an overview of the two centers. Two centers are being joined together in order to establish a functional entity for operational purposes. Among the goals will be to implement the NIMAS, assure that it remains current and comprehensive, and improve it. The Committee has five governing Principles for the National Instructional Materials Access Standard which will direct its activities and the outcomes of the two centers.

The two cooperative agreements have been awarded for five years, but there will be a three-year review. An evaluation plan will be established for both centers.

Background

The Office of Special Education Programs (OSEP) endorsed NIMAS 1.0, but at the same time, it recognized that the standard would require ongoing maintenance to meet the needs of students.

CAST responded to OSEP's Requests for Proposals and was awarded the cooperative agreements. IDEA 2004 was signed by the President, but some of the language in the final law will need to be clarified via regulations. Some of the Committee's work, as well as that of CAST and its subcontractors, will be affected by how OSEP interprets the law and when it promulgates the regulations. Recently, CAST briefed OSEP staff, along with staff of the Office of Special Education and Rehabilitative Services, and this meeting gave CAST an opportunity to explain the consensus that had been reached in order to put forward NIMAS 1.0.

The work of the Digital Accessible Information SYstem (DAISY) Consortium and the American Foundation for the Blind (AFB) Textbooks and Instructional Materials Solutions Forum preceeds the work of the Technical Panel that helped to develop the NIMAS 1.0.

NIMAS Development Center – Skip Stahl
Highlights included:
  • Development Committee
  • Development Center Goals
  • Activities and Subcontracts

A list of those serving on the Development Committee may be found by visiting http://nimas.cast.org. An abstract describing this center was distributed to the group prior to the meeting.

With the Committee's help, the Development Center will work toward defining and expanding the populations served. Ideally, content provided will expand beyond print textbooks to include additional content that supports learning. Basic access to content will remain the primary goal, but electronic content can be enhanced to support pedagogical aims. Technological advances will be identified and monitored with an eye toward how those technological advances can benefit teachers and teaching methods.

A market-based distribution model is likely to be the most effective approach.

NIMAS Technical Assistance Center – Chuck Hitchcock
Highlights included:
  • Technical Maintenance Committee
  • Technical Assistance Center Goals
  • Activities and Subcontracts

A list of those serving on the Technical Assistance Committee may be found by visiting http://nimas.cast.org. An abstract describing this center was distributed to the group prior to the meeting.

The Technical Assistance Center will address the implementation of the standard in reality. It will support publishers, the National Instructional Materials Access Center (NIMAC), states, districts, schools, etc.

Universal Design is the overarching principle, and Universal Design involves various paths to access.

The Technical Assistance Center will be responsible for promoting awareness of the NIMAS, taking publishers' concerns into account (such as supporting them as they develop appropriate work flows), and creating sample content. Authorized entities will be assisted as they develop the capabilities to convert and transform NIMAS files into enhanced content such as braille or synchronized text and audio.

The help of appropriate Committee members will be required to assess the current availability of tools. Then, those interested will strategize about how to put other necessary tools in place for automating production and assuring the provision of high-quality products.

CAST will work with a few states that have different laws and have a variety of capabilities in place. CAST will be establishing the selection criteria for these few states, publishers, and other entities such as conversion houses.

ACTION 1: CAST will work with the Association of American Publishers (AAP), AFB, and others who may have data to update the 50-state survey. Data from the various research projects needs to be reconciled.

Subcontracts with organizations such as AFB and the Assistive Technology Industry Association (ATIA) have been established. In addition, CAST staff is working with the DAISY Consortium and the Z39.86 Advisory Committee. It may also be helpful to work with the American Institutes of Research, including the technical assistance centers.

ACTION 2: Develop strategies to assist the Department of Education to promote the NIMAS in its press releases and other relevant communications about IDEA.

It was noted that this Committee has a high profile, as far as the Department of Education is concerned. As a result, the Committee can make formal requests.

ACTION 3: Raise awareness of the NIMAS among publishers, in states, and among parents and teachers.

Future Scenarios

Committee members introduced themselves and mentioned their hopes for the Committee's work. Visitors in attendance also introduced themselves and briefly indicated why their organizations or companies are interested in the NIMAS. Each attendee mentioned an optimal long-term future outcome.

Future outcomes were wide ranging, but increasing access to texts in a transparent, accurate, and consistent way that would promote interoperability was stressed. The goal is a uniform system to permit timely access to textbooks.

Specific scenarios were not proposed at this time.

IDEA Mandates: NIMAS and the National Instructional Materials Access Center – Mary Ann Siller, David Dikter, and Jessica Brodey

David Dikter and Mary Ann Siller helped to frame the discussion of IDEA mandates by raising questions and providing background information. The points they raised are summarized here, and in some cases, they were explored in more detail during other discussions.

The support of AAP representatives in developing NIMAS 1.0 was acknowledged and appreciated. Because of the work of the Technical Panel, including these AAP representatives, there is now a U.S. National File Format.

With input from Mary Ann and David, Jessica Brodey discussed a PowerPoint presentation with a focus on sections 612, 613, and 674 of IDEA. This presentation contained a section enumerating "outstanding questions," and this list of questions has been reproduced in this document.

Issues that were highlighted during the group's discussion include:
  • What are print instructional materials?
  • What is the impact of the ability of SEAs and LEAs to "opt out" of participation in the NIMAC?
  • How is copyright affected, given the paragraph added to the Chafee Amendment? This question relates to "TITLE III – MISCELLANEOUS PROVISIONS, SEC. 306. COPYRIGHT" in which Section 121 of title 17, United States Code, is amended. See http://nimas.cast.org/idea2004 for more details.
  • What will be the impact of the expansion of the definition of "print instructional materials," as that relates to large print production?
  • How will accessible texts of dramatic works be made available since the Chafee Amendment pertains only to non-dramatic works?
  • How will those using the NIMAS files assure that only the students who are qualified to use them will do so?
  • How will access to older materials be handled?
  • If a publisher provides content directly to a state, what will be the impact on that publisher, other publishers, the NIMAC, and other states?
  • How are math and science handled? What about trade books that are required reading?

The law was signed on December 3, 2004, so the first deadline, related to the establishment of the NIMAC, will be on this date in 2005.

Some funds are available under Educational Media Services.

One area that will need to be monitored involves the potential ability to purchase a digital textbook directly from a publisher in, for example, a proprietary format. Will it be possible to render other specialized formats from that file set? If so, then the publisher might not be required to submit content to the NIMAC since it will already have fulfilled the goal.

There was some discussion of Web sites since, sometimes, the content on them supplements print instructional materials. Web sites are not considered to be print instructional materials at this time. Do the Americans with Disabilities Act and Section 508 come into play? What about Internet-based textbooks?

Outstanding Questions from the PowerPoint Presentation Provided to CAST by Jessica Brodey
  • What does "adopt" really mean?
  • What will the final NIMAS format look like?
  • How often will the NIMAS be updated?
  • What impact will changes to the NIMAS have on state adoptions?
  • What actions must the NIMAC take to coordinate with the producers and distributors of technologies that render the NIMAS usable for individual students?
  • What role will AT vendors play in the distribution and use of the NIMAS files to students with disabilities?
  • Nothing in IDEA addresses or explicitly enumerates where LD students fit into the Chafee definition of Blind or other persons with print disabilities.
  • If states choose not to coordinate with the NIMAC, are they required to use NIMAS?
  • What will be the impact of the NIMAS "loophole?"
  • Copyright exception does not explicitly protect publishers if states require the NIMAS format but choose not to coordinate with the NIMAC.
  • What policies and procedures will the NIMAC establish to ensure compliance with Chafee?

Standards Update: ANSI/NISO Z39.86 – George Kerscher

George Kerscher gave an overview of the Opens new windowDAISY Consortium and its activities. He indicated that over 100 organizations around the world are represented.

The DAISY Consortium has a continuing commitment to the World Wide Web Consortium and open standards. It is also committed to moving the DAISY standard into the mainstream. One of the projects that the Consortium has underway is the development of a Knowledge Network to provide training in content production. A presentation on the Knowledge Network is scheduled to be held at CSUN in March of 2005.

George indicated that the ANSI/NISO Z39.86 Advisory Committee Chair passed from Michael Moodie of the National Library Service for the Blind and Physically Handicapped (NLS) to him in September of 2004. The ANSI/NISO Committees are currently voting on the Z39.86-2005 revision, and voting is expected to close on February 11, 2005. There are some changes to DTBook in this revision, but the changes should not significantly impact NIMAS in the short-term.

The Advisory Committee now has a number of invited experts who will be assisting the core Committee members. These include representatives from VisuAide, Design Science, and CAST. Minutes from the Advisory Committee's conference calls and face-to-face meetings will be made publicly available on the Opens new windowANSI-NISO Z39.86, Advisory Committee Minutes Page.

A process was approved by the Advisory Committee to extend the Z39.86 standard. See the outline of this process at Opens new windowhttp://www.daisy.org/download/download.asp?Cat=guide. Organizations will be encouraged to collaborate, develop plans for work and maintenance, establish usage guidelines, provide training materials and sample content, make necessary updates to the validator, and generally demonstrate a commitment to maintaining the extension as the core standard evolves. Extensions must be comprehensive. For example, a simple change to DTBook is not the desired approach. The DAISY Consortium will provide support services including list-management and a location on the DAISY Consortium's Web site for posting relevant documents.

There was discussion of the DAISY 3 Validator, known as Opens new windowZedVal. The current software could be modified to become a NIMAS-only validator. In addition, Opens new windowthe DAISY Multi-Format Converter was mentioned. This project will support the upgrading and validation of existing content.

A few companies, such as Microsoft and Adobe, have been approached about the possibility of a "save as" DAISY feature.

Some conversion vendors are expected to announce support for DAISY and NIMAS shortly.

ACTION 4: CAST may wish to consider developing a section of content for the DAISY Knowledge Network that would specifically address NIMAS.

Development Center Subgroup Breakout

Three groups broke out and developed a list of issues, goals, action steps, and challenges. The groups were:
  • Technology – Skip Stahl, Facilitator, Dave Schleppenbach, Scribe and Presenter
  • Pedagogy – David Rose, facilitator, Jose Blackorby, Presenter, and Ivan Lagacé, Scribe
  • Production & Distribution – Chuck Hitchcock, Facilitator, Steve Driesler, Presenter, and Janice Carter, Scribe

The Technology group had the most participants, especially since many visitors joined the group. The group concerned with Pedagogy was the smallest since a number of the Committee members who could not attend would have been in this group.

Reconvene for Issue Identification

The groups reconvened and each of the three presenters outlined the results of the discussions. CAST will maintain the background files for reference. Only highlights of the presentations are included.

Pedagogy

1. Broaden the range of students who can legally receive NIMAS files. Consider and define best practices for curriculum design and instructional materials, building upon NIMAS to enhance functionality. It may take some effort to reach consensus on this point. Cost may be an issue. Groups to be engaged would include content providers, assistive technology vendors, parents, teachers, etc.

2. Broaden the range of materials to be provided so that core materials include more than textbooks. Workbooks, teacher editions, and assessment tools are examples that were mentioned. Math and science are content areas that must be addressed. Costs, technology, production complexities, and the need to modify the language in the regulations are challenges.

Production & Distribution
This group's goals were:
  • Goal 1 – Provide clarification guidance for the generation of regulations and procedures regarding production and distribution.
  • Goal 2 – Create exemplary work flow that will point out the efficiency of an XML production system. (Guidelines document that smaller publishers can use with their contractors.)
  • Goal 3 – Initiate outreach to educate publishers and state agencies about the benefits of "opting in" to the access center. Create a FAQ that explains the benefits of NIMAS files? This goal is dependent upon Goal 1.

Discussion in this group was limited to the NIMAS file itself, rather than an end-product or an alternate format. Would files be distributed only through the NIMAC, and if not, how would states achieve the goals?

Technology

This group documented a significant number of issues. Some of them related to multimedia content and how it can work with the basic NIMAS files. Most of the focus was on quality control.

How much of the markup can be reliably done automatically with authoring tools?

A process for validation must be established. NIMAS files could be valid, but validity does not necessarily mean that they would be usable, i.e. valid XML tables may not be accessible. A validator needs to be in place, and the timing of human intervention should be clarified.

Evaluation issues may be market-driven. Who will fund evaluation, and which entities will do it? Will the entities that evaluate need quality control checks, too, and if so, by whom? How will NIMAS-compliance be certified?

Interoperability will need to be addressed, especially as it relates to semantics vs. presentation.

How will multiple versions of a book be handled, i.e. if there are state-specific books with only some content changes? At what stage would validation be done?

It will be important to balance quality control with the need to provide content promptly and efficiently.

The production of textbooks today focuses on printing and involves issues of presentation. NIMAS, on the other hand, requires content and structure.

How can publishers gradually shift their work flow but meet with success, in terms of XML production, relatively soon?

Future Meetings of Note

As the day concluded, two meetings were noted.

The AFB's 19th Annual Josephine L. Taylor Leadership Institute will be held from March 11-13 in Boston, MA. AFB and CAST will showcase a special pre-meeting on March 10 from 1:00 5:30 at the Boston Marriott Long Wharf Hotel aimed for publishers, state directors of special education, braille transcribers, assistive technology specialists, etc. The title is What is NIMAS? A New File Format for Developing Textbooks and Instructional Materials for Students K-12 with Visual or Print Disabilities. A half-day seminar will be devoted to defining, discussing and demonstrating the impact of the new provisions in IDEA surrounding the National Instructional Materials Accessibility Standard (NIMAS) and the central repository or National Instructional Materials Access Center (NIMAC) that will provide for the storage and distribution of electronic textbook source files from publishers. For more information go to Opens new windowhttp://www.afb.org or contact Mary Ann Siller at siller@afb.net

Opens new windowA meeting of the Open eBook Forum's Education Special Interest Group is to be held on April 14, 2005

Wednesday, January 19, 2005

NIMAS Center Evaluation Plan – David Rose

David Rose presented an overview of the mission and the kinds of evaluation requirements that CAST anticipates addressing in order to demonstrate that the goals of the two cooperative agreements are being met. The current status regarding the provision of accessible textbooks needs to be established. Then progress must be monitored over the next several years to determine whether the provision of NIMAS content is improving the timely access to textbooks for students.

A variety of standards will be taken into account including technical, educational, and accessibility standards. Among the goals of the cooperative agreements is to make NIMAS more comprehensive with respect to the range of students with print disabilities served and the kinds of content that can be made available. As the research to maintain and develop the standard is conducted, it will be important to take various stakeholders into account including publishers, conversion houses, authorized entities, state and local education agencies, teachers, teacher education programs, and students.

Is the standard valuable to those who need it, and can it be reliably implemented? Is there a streamlined process for receiving and distributing files via the NIMAC? Can the NIMAC reliably evaluate, categorize and manipulate the NIMAS files it receives?

The goal will be to measure whether there is progress with respect to developing and distributing accessible textbooks, along the continuum of stakeholders, ranging from publishers to students. Tuck Tinsley stressed the importance of keeping students' needs in focus during the research process. As an example, it may be important to assess when books are reaching students today and to demonstrate that content is gradually becoming available more promptly. Surveying Instructional Materials Centers was one approach the American Printing House for the Blind (APH) took to collecting this kind of data.

Initially, CAST will be focusing its attention on a core group of states in various stages of readiness to take advantage of the benefits of access to NIMAS content. It could prove valuable to seek additional funding in order to conduct more comprehensive research to establish the base lines for evaluation and improvement.

Clearly, students who are blind or visually impaired will benefit from textbooks and core instructional materials being developed with NIMAS files. To some extent, some infrastructure to identify and serve these students is in place, but identifying and supporting students with learning disabilities will require some additional effort. Is the learning facilitated by electronic content considered accommodation or remediation? As mainstream teachers see the value and flexibility of electronic content, including multimedia, it is very likely that the benefits to all students, including those without print disabilities, is expected to become more obvious.

Three national surveys were initiated by the AFB Solutions Forum to look at the production of textbooks and instructional materials, how students access multimedia textbooks, and the training and availability of braille transcribers. An assessment of which states have braille bills was also included. In 2004, a national survey was conducted in all fifty states which looked at the manner in which school districts manage access to textbooks and educational materials. The National Center on Accessing the General Curriculum at CAST completed the 50 State Accessible Curriculum Policy Survey.

Sampling may be a more effective way to obtain data, rather than conducting a national survey of students.

ACTION 5: CAST and APH will continue discussions regarding research related to assessing whether students' needs are being met since this outcome is critical.

ACTION 6: CAST will be soliciting ideas from Jose Blackorby, representatives of the AFB Solutions Forum, perhaps the Association of Technology Assistance Programs, and others familiar with existing research in order to capitalize on their knowledge and experience. Committee members are welcome to provide input regarding research, as well as offering references for CAST's review.

Provision of Comments to the Department of Education – Jessica Brodey and Paul Schroeder

To avoid a conflict of interest, NIMAS Centers' employees and Committee Members, in their NIMAS capacities, cannot be involved in developing, collecting, or submitting comments to the Department of Education. As a result, information provided during this meeting and included in these minutes is offered for reference in order to support those in attendance at the meeting. Nothing in this section should be construed as endorsing a particular position. The Committee, itself, cannot submit comments as a whole, but individual organizations may submit comments.

Jessica Brodey and Paul Schroeder discussed the current language in IDEA as that relates to the NIMAS. Particular issues that were raised included:
  • What does the term "adopt" mean?
  • Can the establishment of the NIMAC simplify for all stakeholders the process of providing accessible textbooks both in states that have textbook adoption policies, as well as in those states that are "open territories?"
  • Can the desired outcome be clarified? It would be ideal if NIMAS files were placed in the NIMAC repository, rather than publishers distributing files directly. The use of a repository, containing at least metadata for files, will prove cheaper, will offer better results to students, and will make the location of and distribution of the files faster. It will be important to have a "critical mass" of publishers participating, as well as to avoid publishers being required to provide multiple file types.
  • Which students are qualified to receive accessible textbooks developed as a result of having the NIMAS files? Will students benefit by receiving "raw" NIMAS files? Organizations that are authorized entities and provide "value added" to the NIMAS files will be determining qualifications under the Chafee amendment. Who is qualified under Chafee will become critical as NIMAS files are made more available to students. Today, NLS is responsible for regulating the Chafee Amendment. See a fact sheet at Opens new windowhttp://www.loc.gov/nls/reference/factsheets/copyright.html. The general consensus of the group is that NIMAS is focused on those that qualify under Chafee.
  • What is the definition of an "authorized entity?" Will classroom teachers be considered to be authorized entities? Distributing NIMAS files directly to teachers could cause both quality control issues, as well as concerns about security. Authorized entities serving students who are blind or visually impaired are clearly defined, but what about those that specifically serve students with a broader range of learning disabilities?
  • How will the decision-makers on different levels throughout the textbook adoption and ordering process be affected?
  • How will State and Local Education Authorities be affected? If a state does not "opt in" to ordering from the NIMAC, it could increase security issues in terms of who will have access to the files. The NIMAC and authorized entities offer a level of assurance that qualified students will receive the files.
  • What specific assurance will a state have to provide to the Secretary of Education if it does not choose to "opt in" to the NIMAC? What will the state's duties and responsibilities be in order to comply?
  • How will existing state laws that specify files to be provided from publishers be affected?
  • What will be the requirements for the NIMAC with respect to distribution, cataloging, quality control, Digital Rights Management, etc.?
  • What is the definition of "timely manner?" How will success be measured?
  • How will NIMAS remain in alignment with the ANSI/NISO Z39.86-2005 revision which is to be released soon? The newer version (dated 2005) of the Z39.86 standard will make it easier to produce NIMAS files, so the sooner they can align, the better. The key to alignment will be the use of the correct Document Type Definition. The efforts of all those involved with content production should not be doubled as a result of the existence of Z39.86 and NIMAS. NIMAS is the minimum subset of the Z39.86 standard; rather than being the real goal of a final file format. NIMAS is a method to establish requirements for a National File Format for the United States.
  • How will images be addressed with respect to the rights-holders of those images? Is PDF offered simply for extracting the images to accompany the NIMAS file set? Will PDFs actually be distributed to end-users?
  • How will braille production be improved using NIMAS files as the single source file?
  • How will students obtain the assistive technology they need in order to access the content they receive from the authorized entities? This issue will become especially important when organizations that qualify as authorized entities begin to provide "scaffolds" to expand the functionality of NIMAS files. Expanding functionality will impact the playback technology students have, the need to extend NIMAS according to standards to assure interoperability, etc.
  • Will the need to offer students accessible electronic content be written into IEPs? Should NIMAS be specified since raw NIMAS files may not be directly distributed to students? The National Association of State Directors of Special Education is developing forms to support the writing of IEPs.
  • What is the definition of "core materials?"
  • When specifics are "to be determined," comments should suggest how.

Interested organizations are encouraged to present comments at the upcoming hearings to be held by the Department of Education. Locations and dates include:
  • Newark, DE, January 28
  • Columbus, OH, February 3, 2005
  • Boston, MA, February 7, 2005
  • San Diego, CA, February 11, 2005
  • Atlanta, GA, February 15, 2005
  • Laramie, WY, February 18, 2005
  • Washington, DC, February 24, 2005

Specific addresses for these meetings will be published in the Federal Register.

Oral comments should, of course, be followed up by written comments. Jessica Brodey offered to collect comments in order to submit them as a package. This approach could assist with flagging these comments for emphasis. Bill East of the National Association of State Directors of Special Education indicated a willingness to help diseminate a unified message about NIMAS since this organization will be participating in all of the hearings.

Because NIMAS will not be commented upon as much as many other issues, it is especially important that those who care about the implementation and maintenance of the standard make their views known.

ACTION 7: Develop some general draft language for the National Association of State Directors of Special Education to present in its comments.

ACTION 8: AFB will make an effort to distribute, via its Web site, some guidance and possible draft language to assist those who are interested in providing comments.

Generally, the group seems to favor a market-based approach for providing NIMAS content.

NIMAS and the National Instructional Materials Access Center: Collaboration and Support Needs – Mary Ann Siller, facilitator

Mary Ann Siller facilitated this discussion using information that was collected from the AFB Solutions Forum in preparation for the repository meeting sponsored by Recording for the Blind & Dyslexic and the Open eBook Forum in October, 2004. The key areas for consideration included:
  • Distribution
  • File structure
  • The definition of an access center (repository), or, in this case, the NIMAC

The focus of discussion was section 674 of IDEA in which duties of the Access Center are described.

One approach to be considered may be a yearly subscription fee. How would a NIMAC subscription model, or other pricing models, affect the membership-fee models employed by authorized entities today?

What will be the impact if the population being served grows? Eventually, a non-compensation approach may become unacceptable to publishers. How can the charge to expand access be reconciled with publishers' needs? Market-based alternatives will need to be explored.

How will states, such as KY and CA, that require the purchase of the textbook be affected?

Ideally, publishers will not be in a position in which they "opt in" to use the NIMAC for some states, but not for others. A situation like this one would not resolve either accessibility issues or meet publishers' needs.

Will the NIMAC contain publishers' files or only the metadata related to those files? Will the NIMAC be involved in file transformation? Will schools be directed, via the NIMAC, to obtain the files from the authorized entities after the files have been upgraded/transformed from the raw NIMAS files? Which organization(s) will schools contact to obtain the files they need? If states customize raw NIMAS files for their needs, how will the resulting products be handled and by whom?

If raw NIMAS files are downloaded into school settings, how will copyright issues and content protection be addressed? Are written agreements sufficient, and who would receive these agreements? Will the states be responsible for establishing the process for identifying who is trusted to obtain and distribute content? The Committee will need to consider the complexities of the states and each of the school districts.

How will ancillary files be handled, such as workbooks and testing materials, that are important to augment the reading and understanding of the textbook content? How is the term "core materials" defined?

The general idea may be to build upon APH's existing Louis Database. It should be noted that sometimes, publishers have requested files that they have donated to Louis. Via Louis, today, publishers are able to track where their files are distributed.

The NIMAC will need to address quality control. How will electronic and human validation be handled? How will the possible conflict between quickly making the files available, while at the same time, assuring that they are of high quality, be addressed? What about human and financial resources? Will independent evaluators be required?

The NIMAC will also need to consider the collection of metadata and the development of listings of books for searching. Will the NIMAC be required to serve as an information resource, such as by tracking content available from authorized entities, too?

How will the stakeholders address the distinction between simply providing access to content vs. making that electronic content truly usable to the students who need it?

ACTION 9: CAST, APH, AFB, and others on the Committee should collaborate to articulate how the NIMAC is expected to function, develop a project plan, and identify timelines. It will be important to include an evaluation component so that APH can document and report the success of the NIMAC.

ACTION 10: Clearly identify the quality control requirements including the process for electronic and human validation. Consider using the "package file" and "checksum." These are two technical options for assuring that the NIMAS file set for content, such as a book, is complete.

Working Lunch (Public Comment Period)

Neil Soiffer of Design Science and Stephen Baum of Kurzweil Educational Systems, Inc. both made brief comments to the group.

Neil described Design Science's work on the implementation of MathML and the development of the company's Math Player. He stressed that there are both semantic and presentational aspects to the markup for math. A second math player is available from gh. Ideally, the two companies will collaborate in order to extend the Z39.86 standard, which will, in turn, support the extension of NIMAS. Some technical issues related to implementation remain to be addressed, but there has been considerable progress. One of the most important issues, from gh's perspective, relates to pedagogical needs that arise when teaching math to students with print disabilities.

Stephen Baum mentioned the need for a mechanism to address digital rights protection. Will users be able to extract and copy content, and if so, how much? George Kerscher indicated that the DAISY Consortium is currently working on a new Digital Rights Management specification, and AAP was requested to comment on the proposed requirements.

Stephen also suggested the need for expanding the capabilities of NIMAS files, while at the same time, keeping the NIMAS neutral with respect to playback technology. There is an expected need for interactivity with the content. Assessment components may also be important.

Finally, Stephen raised the question of how images will be handled. If they are excluded, this lack may render the content useless to some groups. If images are distributed, will they only be offered to authorized entities or to end-users? Do images qualify under the Chafee Amendment as "digital text?" Will the image availability be determined by the needs of the user? Do publishers have the rights to distribute images? What will be the standards for validating their accessibility and usability? How is the large print exemption addressed if images are not made available? Images with more instructive abilities, beyond just the images included in the print textbooks, will become important to a wide range of students.

ACTION 11: The issue of how images may be used and by whom should be brought to the attention of the Department of Education. This issue should be considered by those who are writing comments.

Expansion of the Committee

There are a few more seats open on the Committee. At the moment, students with physical disabilities, cognitive disabilities, teachers and other educators, a representative from the Association of Educational Publishers, are either not represented, or they are underrepresented. There are between six and eight seats available.

ACTION 12: For reference, CAST will develop a list of the Committee members re-categorized into the constituant groups they represent. This new version will be distributed to the current Committee.

Committee members will be encouraged to nominate individuals or organization representatives, and CAST will present those nominations to the Department of Education.

Ongoing Communications

The priority is to draft, present when possible, and submit comments from individual organizations. CAST will not represent the NIMAS centers in this activity.

Some Committee members specifically wanted to see AFB's and AAP's comments as examples, in order to assist in drafting their comments. There was a request for a listserv to permit the sharing of drafts.

When work plans are being developed, it will be helpful to organize them around the obvious time milestones as outlined in IDEA. Once work groups are established, designated representatives will need to develop work plans and guide each group. Establishing action steps, deliverables, timelines, and a work plan is essential.

ACTION 13: CAST plans to establish listservs to continue the work of the Committee.

ACTION 14: CAST and APH will be meeting again shortly to continue their dialogue about the establishment of the NIMAC.

ACTION 15: CAST will develop and distribute a work plan to the Committee. Then, the group will review and provide comments on that plan.

As the meeting concluded, Committee members expressed their thanks for the meeting, reflected positively on the consensus in place to date, emphasized their willingness to offer methods to assist in commenting, etc. The general feeling was that much had been accomplished to date. The Committee affirmed its commitment to supporting the ongoing work to assure that the provisions in IDEA would be implemented effectively.

Next Face-to-face Meeting

The next face-to-face meeting is proposed for September in Dallas, TX. It will be arranged by CAST with the assistance of AFB. Additional details will be forthcoming.

Action Items: Summary

ACTION 1: CAST will work with the Association of American Publishers (AAP), AFB, and others who may have data to update the 50-state survey. Data from the various research projects needs to be reconciled.

ACTION 2: Develop strategies to assist the Department of Education to promote the NIMAS in its press releases and other relevant communications about IDEA.

ACTION 3: Raise awareness of the NIMAS among publishers, in states, and among parents and teachers.

ACTION 4: CAST may wish to consider developing a section of content for the DAISY Knowledge Network that would specifically address NIMAS.

ACTION 5: CAST and APH will continue discussions regarding research related to assessing whether students' needs are being met since this outcome is critical.

ACTION 6: CAST will be soliciting ideas from Jose Blackorby, representatives of the AFB Solutions Forum, perhaps the Association of Technology Assistance Programs, and others familiar with existing research in order to capitalize on their knowledge and experience. Committee members are welcome to provide input regarding research, as well as offering references for CAST's review.

ACTION 7: Develop some general draft language for the National Association of State Directors of Special Education to present in its comments.

ACTION 8: AFB will make an effort to distribute, via its Web site, some guidance and possible draft language to assist those who are interested in providing comments.

ACTION 9: CAST, APH, AFB, and others on the Committee should collaborate to articulate how the NIMAC is expected to function, develop a project plan, and identify timelines. It will be important to include an evaluation component so that APH can document and report the success of the NIMAC.

ACTION 10: Clearly identify the quality control requirements including the process for electronic and human validation. Consider using the "package file" and "checksum." These are two technical options for assuring that the NIMAS file set for content, such as a book, is complete.

ACTION 11: The issue of how images may be used and by whom should be brought to the attention of the Department of Education. This issue should be considered by those who are writing comments.

ACTION 12: For reference, CAST will develop a list of the Committee members re-categorized into the constituant groups they represent. This new version will be distributed to the current Committee.

ACTION 13: CAST plans to establish listservs to continue the work of the Committee.

ACTION 14: CAST and APH will be meeting again shortly to continue their dialogue about the establishment of the NIMAC.

ACTION 15: CAST will develop and distribute a work plan to the Committee. Then, the group will review and provide comments on that plan.


Last Updated :July 8, 2008