Two links to aid in navigating the Web version of this document are:
The group gathered for a continental breakfast beginning at 7:30. The meeting opened at approximately 8:00 and concluded around 5:00. Tentative times were included in the agenda, but times have been removed from the minutes since topics and the length of discussion shifted throughout Thursday and Friday.
Welcoming comments were made by Bonnie Jones, NIMAS Centers Project Officer, Office of Special Education Programs, United States Department of Education. Dr. Jones noted that the Committee has an awesome charge to move the NIMAS initiative forward. With reference to the publication of the final NIMAS-related IDEA regulations, Dr. Jones anticipated that it might be late 2005 or early 2006 before the regulations were finalized.
Chuck Hitchcock, Project Director of the NIMAS Technical Assistance Center, reviewed work completed since the January meeting, and referenced the posting of the details of many NIMAS-related presentations on the NIMAS Web site at http://nimas.cast.org. Chuck Hitchcock also noted that CAST has been receiving an increasing number of questions from states, publishers, and conversion services related to NIMAS implementation. He mentioned that the NIMAS Web site is the central location to access the most up-to-date activities and information about CAST's efforts.
Chuck Hitchcock also reported that CAST is in the process of finalizing a set of NIMAS exemplars, which will be made available for download from the NIMAS Web site. These exemplars will include NIMAS-conformant XML file, a package file, a PDF rendering of the print work, and a number of "student ready" versions created from these source materials in a variety of file formats (MS Word, accessible HTML, DTB 2.02, and DTB 3.0). Chuck Hitchcock also noted that a NIMAS listserv has been established but had had little active communication to date. He explained that it was the intent of the NIMAS Centers to post NIMAS exemplars from any organization, conversion house, or publisher that was willing to create them and make them publicly available.
George Kerscher (DAISY Consortium, RFB&D) and James Pritchett (RFB&D) both offered some suggestions for exemplars and agreed to re-initiate that topic in the Technical Subgroup meeting. Jim Fruchterman (The Benetech Initiative/Bookshare.org) said that he has taken a science fiction novel and is in the process of converting it so that its markup is NIMAS-conformant. He will investigate the potential of making the volume and its associated source files available as an exemplar.
The NIMAS Centers will explore the possibility of posting the NIMAS-related pages from CAST's recently published book on the NIMAS Web site. The bibliographic citation for this work is "Rose, D., Meyer, A., and Hitchcock, C., (2005). The Universally Designed Classroom: Accessible Curriculum and Digital Technologies. Cambridge, MA: Harvard Education Press."
Skip Stahl, Project Director of the NIMAS Development Center, briefly mentioned some of his activities, including two recently published articles for a National Association of State Directors of Special Education (NASDSE) publication with which Bill East is affiliated.
David Rose, Principal Investigator the NIMAS Development and NIMAS Technical Assistance Centers, reminded the group that NIMAS is not simply a book standard and that the charge from the U. S. Department of Education is also to change learning and the way that students with print disabilities are defined. He commented that ultimately NIMAS would provide the foundation for an analysis of the accessibility and appropriateness of media types beyond print—graphics, for example. He noted that he was recently asked to deliver a keynote presentation on Universal Design for Learning at a National Science Foundation conference. Beyond accessible materials, David Rose commented that NIMAS should provide a heightened emphasis on all aspects of learning, including instructional strategies and assessments. He noted that the "I" in NIMAS stood for "instruction" and that the Committee needed to attend to that.
Jessica Brodey, Policy Consultant with the Assistive Technology Industry Association (ATIA), presented an overview of ATIA's response to the recent Notices of Proposed Rulemaking (NPRMs) published by the U.S. Department of Education. She highlighted a number of issues about which many in the assistive technology industry are seeking clarification. ATIA focused their comments on "non-visually-impaired students with disabilities" (NVIPDs) and posed the following questions:
The assistive technology industry is quite interested in extending the standard to offer more functionality to a wider range of students. As a result, procedures for the standard's alignment will need to be put in place to ensure innovation in terms of content creation and playback.
During the discussion following Jessica's presentation, issues regarding the limitations of the standard were raised. Shah Karim (Saferock) mentioned private schools and inquired about whether the Section 508 standard was applicable. Committee members emphasized the need for intelligent reading systems to accommodate more students—beyond those defined by Chafee. Vendors are likely to become concerned, and have difficulty supporting it if the standard changes too frequently. These and other issues are presently holding up contractual arrangements and state adoptions.
ATIA also requested additional clarification about the envisioned DRM and package file protocols, and inquired about the metadata protocols for the package file.
Dave Schleppenbach (gh, ATIA) also noted that the NIMAS specification offered only limited guidance regarding visual rendering and as such did not address the needs of NVIPDs. For example, a switch user may not go through word-by-word and sentence-by-sentence. An additional question involved the application of modular extensions to the NIMAS specification (synthetic speech, for example) and how these might be incorporated into the specification in the future. Dave Schleppenbach noted that the specification could support richer options in audio output in SSML, multiple speakers, prosodic, and multiple languages.
George Kerscher commented that a (DAISY) player or playing system can deal with switches and such, but noted that the standard is silent on visual rendering, and that, at present, SSML is not used to enhance the content for commercial presentation. Jessica Brodey commented that in order to maintain consistency of markup such as tags, maybe it shouldn't be in the standard.
Ron Stewart (Association of Higher Education and Disability) commented that the specification does present some limits based on the preferred means of consumption, and Jessica Brodey agreed that that was the case with respect to certain types of content—dramatic works and poetry, for example. She also noted that attempts to expand the base of qualifying students would cause problems with copyright holders and publishers. Jessica Brodey also cautioned that an ever-evolving standard would wreak havoc in the development cycle of the assistive technology industry.
Dave Schleppenbach questioned how the NIMAS specification would keep up with the changes in the DAISY specification on which it is based. This concern was echoed by Jessica Brodey. Chuck Hitchcock suggested that the NIMAS Centers need to work with the DAISY Consortium to align messaging and public awareness-building.
Jessica Brodey also noted that publishers and vendors alike needed guidance on how to handle large files and what exactly the conversion process would involve.
James Pritchett commented that additional NIMAS conversion was the responsibility of the value add vendors (Authorized Entities). Jessica Brodey countered that, hypothetically, the Authorized Entities could use NIMAS-conformant files if a teacher is considered to be an Authorized Entity.
Jennifer Sutton, the NIMAS Technical Assistant Center Consultant, asked if indeed a classroom teacher would be considered an Authorized Entity. [The legal consensus on this question is "no"].
Chuck Mayo (Texas Education Agency, National Association of State Textbook Administrators) suggested that perhaps a teacher would be with specific regard to braille.
Mary Ann Siller, Director of the National Education Programs for the American Foundation for the Blind (AFB), presented an overview of AFB's present NIMAS-related concerns and activities. She noted that there are forty-six national organizations represented in the AFB Solutions Forum. She also commented that a number of AFB's questions mirrored those of ATIA, e.g. what does "timely" mean with respect to the adoption of NIMAS by SEAs and LEAs? AFB believes this means that alternate format materials should be provided to qualifying students with print disabilities at the same time as non-disabled peers receive their print materials. Mary Ann Siller emphasized that how this is achieved is important, and that a best practice model is needed for official state-wide approach. The AFB Solutions Forum has produced a guidelines document (checklist) to facilitate the process along with CAST and NASDSE. It will be made available on the NIMAS Web site.
Mary Ann Siller also noted that communication with SEAs and LEAs was an ongoing issue. LEAs need to help them get up to speed. What does "adoption" of NIMAS mean at the LEA level? She commented that the production capacity of braille, Digital Talking Books, etc., was an open, often uncoordinated, system, and she noted that the Committee needed to be informed about what braille producers are capable of doing or how they might borrow from other resources in order to facilitate production. AFB and the NIMAS Centers were in the process of gathering baseline data regarding the production of braille today in order to determine if progress is being made.
Mary Ann Siller also raised a question about what would happen to the national unified approach envisioned by NIMAS if SEAs or LEAs "opt out" as allowed for in IDEA 2004. Specifically, AFB recommended to the U.S. Department of Education that (1) assistive technology professionals should coordinate with state textbook adoption agencies or state departments of education, and that (2) a NIMAS (or accessible, alternate format materials) consideration should be in every IEP. Mary Ann Siller further commented that NIMAS impact assessments should be a part of the U.S. Department of Education's data gathering.
Additional questions and concerns raised by AFB included asking how and by whom NIMAS-conformant files would be validated, and what the timeline was for receipt of NIMAS-conformant files by the NIMAC. Mary Ann Siller also recommended that organizations and individuals expert in braille creation needed to be a part of the NIMAS process since there were features and aspects of braille transcription and braille production software that would be dependent on NIMAS-conformant file elements and attributes. Mary Ann Siller thanked Bob Stepp from Braille2000 and Joe Sullivan from Duxbury Systems for attending the NIMAS Committee meeting.
Mary Ann Siller recommended that the NIMAS Committee incorporate braille expertise and work with publishers to make certain that NIMAS tags supported braille production as much as possible, and to build awareness.
Steve Noble (Kentucky Department of Education, Learning Disabilities Association of America) commented that the Committee's work could be furthered by involving membership from the Association of Technology Act Programs (ATAP) via its Executive Director, Deborah Buck. Steve noted that by involving ATAP the Committee could leverage that organization's existing infrastructure to help move everyone's agenda forward.
Mary Platner (Teacher, Scottsdale Elementary School) suggested that in states like Arizona and Kentucky, a broader application of NIMAS through 504 or IEPs established which students were qualified to receive accessible versions created from NIMAS-conformant source files. She asked if there was such a thing as a LOUIS (American Printing House for the Blind database) list for a broader range of students beyond the blind and visually-impaired—something with an accessible files K-12 focus? If this does not already exist, Mary Platner suggested a front-loading of effort to coordinate this.
Jennifer Sutton commented that it would take considerable time and effort to create, coordinate, and maintain another database.
Ron Stewart commented that braille-ready files, those created from NIMAS or braille-ready not from a publisher, were difficult to acquire. That, at least in Oregon, mechanisms for doing this don't really exist in a systematic way. Oregon would need an incentive, an impetus, to buy in.
Rick Ferrie (Pearson Education) emphasized that publishers needed to fine tune the basics of the present before they'd be ready to address the future.
Steve Driesler, Executive Director of the School Division of the Association of American Publishers (AAP), said that the K-12 publishing community has some minor questions related to the standard, many of which matched the questions already raised by ATIA and AFB. What are the NIMAC requirements and what will the NIMAC do with the files it receives? Obviously, the safeguarding of intellectual property and adherence to copyright are of prime importance. NIMAS-conformant files from the NIMAC should only go to the Authorized Entities, and only be used for print-disabled students as defined by law. The AAP has been in communication with the American Printing House for the Blind to provide input to APH as it envisions the operational structure of the NIMAC.
Steve Driesler quoted Jim Fruchterman's earlier comment about "the 'perfect' being the enemy of the 'good'" and added that the only way you can eat an elephant is one bite at a time. NIMAS is not yet an accessibility solution for all students with disabilities, and, by law, was intended to be limited to a set of qualifying students. There is apparently still a lack of knowledge about the entire process—the benefits of the standard, the function of the NIMAC, where to go to get information—and there's a lot of misinformation. A knowledge gap and a misinformation gap. The publishers want action steps that we can agree on to close these gaps.
Steve Driesler noted that the publishing community is concerned that since there is "opting in" and "opting out" (for SEAs and LEAs) and there are challenges, when an agency (SEAs or LEAs) is not well informed, it's becomes easier to opt out. Texas was noted as an exception rather than a rule. One question (among many) arises: in an adoption state that does not opt in, can an LEA opt in? The AAP had a discussion with Tuck Tinsley of APH about this as well.
The publishing community agrees that there is a need to keep the standard current, but there is also concern that that the NIMAS standard was a carefully negotiated compromise and there is still a need for, via public discussion, substantive changes, and those should be accepted or rejected as a part of a consensus process as well.
Rick Ferrie noted that addressing the handling of math textbooks was a high priority, since both California and Texas will have statewide adoptions in the next three to five years. Steve Driesler commented that math brought science along with it as well.
Skip Stahl asked what the ideal time frame was for this information. Rick Ferrie noted that most publishers were going into production for these adoptions by January of 2006, and as they go through the development process they could be making some modifications.
George Kerscher commented that the MathML working group (of the DAISY Consortium) was addressing the issue, and that while MathML is fine, how to have it read is the harder part. But once it's out, the inclusion of it in the DTB elements set should help clarify these issues.
Dave Schleppenbach noted that math notation (e.g. division) is complicated and even MathML has limitations in terms of coding and rendering—that there may be holes, difficulty of rendering math by speech, and that these were questions both technical and pedagogical. Chuck Hitchcock commented that the technical subgroup acknowledges there's a problem and knows what the issues are. Dave Schleppenbach noted that it was not reasonable to expect publishers to produce in MathML, since it was not a part of their workflow, and even if they were ready, would they be willing to accept it?
Steve Driesler asked what states have to do to adopt the NIMAS.
Bill East, Director of the National Association of State Directors of Special Education (NASDSE), reported that he sent a series of questions to state directors and that he 48 total responses: 16 in reaction to questions about the IDEA and its regulations, 15 about NIMAS processes, 10 about NIMAS resources, and 7 about training. The respondents indicated that, in general, NIMAS is not yet a priority for state directors. In general, the questions were not technical in nature. Special education is not traditionally involved in textbook acquisition. The state directors need a step-by-step guide. Mary Ann Siller commented that she hoped the AFB checklist would go a long way toward helping them.
Bill East noted that the NASDSE annual meeting is next month (October 2005) and that, there's not a whole lot of talk among state directors about the law. Other questions from state directors included:
Chuck Hitchcock commented that many of the state's questions mirrored those of the publishers. If publishers want to stay in business they will be producing NIMAS-conformant files of their textbooks. The way the IDEA mandate is written, if there's no contract, there's no purchase, and if there's no purchase, there's no business. Why would a state opt out?
Steve Driesler said we should remember that the NIMAS is a requirement, while the NIMAC is an option. What's needed is a simple, straightforward, and clear FAQ for states.
Julia Myers, Director of Resource Services at the American Printing House for the Blind (APH), explained that APH has recently received planning funding from the U.S. Department of Education and is beginning to work with a nationally recognized consultant in this field. A Request for Proposal is being developed to solicit the support of vendors to assist with the development of the NIMAC. APH also intends to form an advisory council. The NIMAC is expected to be functioning by December of 2006. APH imagines that a pilot project may be launched beforehand.
A discussion of the availability of image files, via PDF, took place since the NIMAC needs to understand what kinds of PDFs it will be receiving. Though the issue of images was addressed at various points during the two days of the meeting, a summary of the remaining points is provided here.
There seemed to be some confusion as to whether PDFs of full pages would be submitted by the publishers. In the end, it seems that the publishers will only be providing images to support the provision of alternative attributes to describe those images (alt text).
Generally, there appeared to be a preference for having the images extracted by the publishers and to have them included in a separate folder. The provision of image descriptions is considered to be part of the value-added process. [Note: Upon review of these one committee member remarked, "Actually, I had the opposite impression. I thought that there was a significant preference for full-page PDF images."]
For the creation of tactile graphics, images may be helpful, depending upon the tools available to the Authorized Entity doing production. Images with a resolution of 72 dots per inch (dpi) seem to be considered adequate for presentation on screen or for editing.
Scalable Vector Graphics (SVG), for which there is a W3C recommendation, were discussed as one method for providing images. However, tools and knowledge of how to work with this format seemed to be somewhat limited, given the wide range of technical skills to be found among those who create tactile graphics.
Skip Stahl discussed the schedule for the remainder of the day: the Committee would divide into its three subgroups and those in the audience were encouraged to join any subgroup. The Committee was reminded of the items summary that was included in the original agenda. Skip Stahl indicated that these items might be useful to generate discussion. Other issues could, of course, be raised and brought back to the group, as a whole. Chuck Hitchcock reviewed the Committee members' group assignments. The groups met briefly, prior to lunch, and then met for several hours in the afternoon.
See the attendees list to see the committee members in each subgroup.
David Rose said that we want to universally designed the money flow. A market workflow model provides incentives for publishers. CAST/NIMAS favors a market model for longevity. There will probably not be another federal legislative solution (legally mandated).
The topic of pedagogy group: What do students need? Set of students? Set of topics?
Ron Stewart mentioned the there is case law on instructional materials issues at the postsecondary level. If you cannot provide curriculum for students with disabilities at the same time as for other students, then you will not provide any curriculum (postsecondary level governed by 504, not IDEA).
Jose Blackorby (SRI International) inquired about the frame for this discussion. David Rose suggested starting with the general education curriculum. It's not just about the materials—teachers need to know how to use materials. How do you build teacher education into students' educative materials? If you don't know what your material is capable of, you won't use it to its full capacity. Let's think of this as a hierarchy (pyramid) from general education classroom level, to small group, to highly individualized instruction. Move from top to bottom. Jose Blackorby said that whole class and whole school instruction is not designed with students with disabilities in mind.
Michael Wehmeyer (University of Kansas) said that trying to get materials universally designed means taking into account all students. We're thinking much broader than Chafee. NIMAS's thinking depends on a middleman that converts instructional materials into alternate formats. For many students there is no such middle system. Constraints on the NIMAS. NIMAS not being able to go further is a function of copyright law, and who has the legal right to access those files. NIMAS has pieces of what we want for all kids. We should come at this from both sides—continue with this process, while simultaneously thinking about the ideal situation. We must take advantage of publishers' interest in market model. Schleppenbach's gh Braille reader is a good example of reader from which kids with cognitive impairments can benefit.
Mary Platner said that publishers do not want this to be free and that piracy issues are big.
David Rose said that after lunch the group should think about this from a UDL perspective, not a policy perspective.
After the lunch break, David Rose passed out his Universal Design for Learning Guidelines document. He asked the group, even with fully accessible instructional materials, how do we use the materials (teaching methods, assessment methods, etc.)? Are assessments included in NIMAS? If assessment is an element of instruction, then it should be part of NIMAS, right? Workbooks and practice books go hand-in-hand with textbooks, especially in early grades.
Ron Stewart said that there is a competency model in Oregon. Materials are bundled by core competency. David Rose said that we must start with good objectives that are UDL. Core competencies are driven by the goals. That matters more than whether or not it is considered supplementary or primary instructional material. Rich Robison (Federation for Children with Special Needs) said that "core" subjects are enumerated in IDEA 2004. Ron Stewart said that on the IEP you must justify how your teaching points to core curriculum. Rich Robison replied that in 1997 objectives/benchmarks were a key feature of the IEP. Now they've moved back to measurable goals; You may use objectives/benchmarks but don't have to. Only students with significant disabilities who are taking alternate assessments must continue to receive them.
David Rose said that NIMAS does not define "instructional materials." The IEP should determine what must be provided to the NIMAC. Any content area that is addressed by the educational standard set in a state would fall into the category of required instructional materials.
Rich Robison said that it's a multi-step process. Just trying to meet the minimum. SPED directors are going to be thinking about this differently than us.
Mary Platner said that Arizona law does define "instructional materials" as "required by SEA or LEA for use by teachers in classrooms."
Roberta Brosnahan (Freedom Scientific) said that AEP does not think that supplementary materials fall under NIMAS.
Michael Wehmeyer said that he thought the only thing that was excluded was teacher guides, because teachers do not need access (that's what NFF agreed upon). NIMAS 2.0 should define this better. Whatever other students are using to learn should be covered by NIMAS.
David Rose said that if the school purchases materials to meet their goals, then it is core for them and should apply. The requirement is created/defined by the school, not the publisher. He summarized the discussion so far: yes assessment is part of NIMAS. You can't teach without it. Materials are defined by the school system and its goals.
Mary Platner mentioned that Arizona law stipulates accessibility requirements for online curricula as well.
Michael Wehmeyer stated that in NFF there was an agreement by publishers (included on panel) that supplementary workbooks were to be included under NIMAS. That was the intent.
David Rose asked, what about the non-book curricular materials? Videos, manipulatives, etc. What is our posture on this? Do we think that things like captioning are part of NIMAS? NIMAS-conformant videos? (Is NIMAS just about print?) Michael Wehmeyer replied that NFF is a first step to creating UDL materials. Videos ought to be included if part of the core curriculum. Ron Stewart added that the DAISY standard speaks to video files as well.
Froma Cummings (Arizona Department of Education) asked, how are we going to do manipulatives? Hard to envision, but very necessary—some work with some kids and other don't.
Michael Wehmeyer queried, is NIMAS broader than NFF? NFF was very firmly just linked to print materials.
Jen Jude (NIMAS Research Assistant) mentioned that there are references "print disabilities" throughout NIMAS statute.
David Rose said that he wants to change "print disabilities" to "curriculum disabilities."
Froma Cummings said that we're trying to target the needs of all students who aren't visual learners.
David Rose said that we want the pedagogy to be included in curricular materials (especially for home-schooled children and those with teachers who don't have time for individual instruction). Students could use guided learning. He asked the group, what do we not include in NIMAS as part of instructional materials?
Ron Stewart replied that individualized curricula specifically designed to meet the needs of an individual student should not be included. It is designed to be special and we'll give them license to specialize that way and not be UDL. Example: orientation and mobility content for blind/visually impaired students. Very unique curriculum that is considered to be outside of UDL. Froma Cummings was unsure about including life skills, saying that she'd use ASL as an example instead.
Rich Robison warned that there is a danger of defining materials that do not need to be UDL, of splintering off such a group. There is potential for cross-application of these materials (i.e. the hearing person who wants to use the ASL materials, the use of Velcro in the mainstream).
Michael Wehmeyer said that the discussion shouldn't start with the outliers, but should start with the largest group and move down (top down).
David Rose asked, what are our priorities for teaching methods? Mary Platner answered that we want publishers to advertise their textbooks as having varied teaching methods (e.g. concept maps). Say that it is "research-supported." David Rose wondered how can we find research-proven methods without spending $30M. Jose Blackorby replied that that isn't our burden. Publishers should be doing this research.
Michael Wehmeyer added that the research is often very disability-specific. For example, research on advance organizers. They have been validated with one population and could be good for another population, we just don't know. David Rose said that he thought that was a great idea. He added that we can justify using a method because of one population and then let the marketplace figure our whether the research supports it for other populations. We have to make sure that the method (e.g. advance organizer) is universally designed. It needs to be highly customizable as well.
Jose Blackorby said that basal textbooks make the mistake of introducing several concepts at the same time.
David Rose stated that selection/choice is part of UDL and that one can also individualize the order that things happen (i.e. organizer first or last).
Jose Blackorby said that you must have different research designs for studies with low incidence populations, because it is too expensive to do randomized studies, etc. Do single-subject studies instead. Michael Wehmeyer remarked that the U.S. DOE is moving in the direction of allowing different research designs, realizing that the questions you ask must be related to the study you do. Bonnie Hill (Freedom Scientific) added that there is also the possibility of comparing two classrooms—one using digital technologies and one not. Teacher-run research, that's not statistical.
Mary Platner said that the average special education teacher spends one day of teaching per week doing paperwork. The general education teacher is spending the equivalent amount of time developing materials and assessing student reactions.
David Rose wondered it we can ask a certain community (i.e. MR) what they need most and what is most important for us to do? That could create constituent groups that care about and are invested in NIMAS. Mary Platner said that if you could get funding, it's a good idea. Froma Cummings added that you could go to those group's conferences and have post-session meetings for all those interested. Jose Blackorby said that such meetings are tricky because they must be at the right level of detail. Michael Wehmeyer concurred, saying that many people don't know the possibilities that UDL represents and don't have the background to understand what NIMAS needs.
Ron Stewart said that you have to show them the features of UDL that are exciting and effective and then ask them what NIMAS needs. Mary Platner said that you have to target the right people in these groups and the right number of people.
Rich Robison said that he can describe things from the student with MR's vantage point, rather than from the policy vantage point. Consumer/family-friendly focus groups might be a good idea.
Mary Platner wondered if we could ask organizations to ask for feedback through their publications. Froma Cummings said that she thought we could get a lot of information from attending current conferences and having a second session for interested people—that will attract the passionate people.
Rich Robison said we should use the Web as a companion piece. Must repackage specifically for these groups and have this material ready so as to not lose momentum.
David Rose said that getting really interested (and uppity) people involved is much more effective than a mass mailing.
Jose Blackorby added that we want to train the trainer.
Michael Wehmeyer said that a lot of research is missing on these issues.
Mary Platner said that in open territory states, such as Arizona, there are lots of small school districts that are making purchasing decisions. It would be nice to have a NIMAS stamp of approval to prevent schools from buying from imitators and make sure they get real NIMAS-compliant materials. We need to brand NIMAS. Rich Robison said that we need to give it a language or a brand (like Bobby) that assures that the right message gets across. Keep "UDL" and "NIMAS" symbols separate.
Michael Wehmeyer stated that we need to have a market solution. Publishers need to become more successful because they do UDL right and because more schools buy their stuff.
David Rose said that there is a case for UDL in emotional scaffolding of students. Must use teaching technique that appeals to both shy and outspoken students.
Michael Wehmeyer said that we need something that is truly universally designed and accessible to use as an example. gh Braille media player has the potential. Until teachers actually see this they won't get it.
David Rose said we should start thinking about the action steps and ways to maintain momentum.
George Kerscher announced that the DAISY/NISO Structure Guidelines has been upgraded for 2005 and is available online at http://www.daisy.org/z3986/structure/structguide.htm. The "World Cultures and Geography" exemplar has also been upgraded to correspond to the 2005 specification. He noted that an issues tracking procedure had been initiated via the DAISY Z39.86 site and every issue was now being logged in a database. "Issues" are comprised of errors in training materials, in the specification itself, in the errata, etc.; to date six have been logged in reference to DTBook 2005 (such as you can't have bridgehead in a div, for example).
Skip Stahl noted that the touchy part is between "required" and "optional" in the NIMAS, and that problems will arise with respect to modular extensions that may lead to new versions of the specification—how to address the need to remain current while continuing the consensus process.
George Kerscher noted that a drama module would be very easy to do, and that the protocol for adding modules to the NIMAS already existed: new modules, if appropriate to textbooks and related instructional materials, would automatically become part of the "optional" element set. Chris von See (TechAdapt) commented that as a content transformation organization, TechAdapt would be concerned about new or removed elements in the vocabulary.
Skip Stahl noted that the addition of any modular extension to the baseline (required) NIMAS element set would require Committee approval, but by having modular extensions appear as optional elements once approved by DAISY/NISO, it would make them eligible for inclusion in the next revision. Through the consensus process, they may come into the standard, but the process gives flexibility in the interim. Some folks may want video and music, as examples, or math, which will not be part of the standard right away.
James Pritchett commented that the entire communications process (between NIMAS and DAISY) when things are happening with DAISY needs to be solid.
George Kerscher noted the DAISY Consortium could use some more participation in the Math Working Group, but perhaps both the NIMAS Web site and the DAISY Web site need to provide some direction in their respective FAQs as to what happens in the interim. For example, sometimes all the marginalia is marked as a sidebar and annotations not marked correctly. We need exemplars to help others produce it the right way. James Pritchett noted that exemplars should use the optional elements, not just the baseline set, in order to encourage extended best practice. And exemplars should be reviewed and vetted for accuracy and usefulness.
Dave Schleppenbach commented that there had been additional problems, for example some files wouldn't validate due to missing or inaccurate elements, and also the NFF compromise may have bartered away things that may not be important, but also some things that may be important. James Pritchett noted that the tension was between those groups who wanted the minimum number of elements and those who wanted the maximum. Dave Schleppenbach stated that the compromise was the minimum (NIMAS) and maximum (DAISY).
Jennifer Sutton asked if people would automatically go to the DAISY site for the "maximum" (or how to produce it), and wouldn't states be looking at the outcomes, not the XML?
James Pritchett asked if the CAST exemplars included the outcomes (student-ready examples) and noted that student-ready versions should not be presented as NIMAS-conformant file set exemplars, but as additional resources.
Dave Schleppenbach asked if the issue of PDFs had been resolved. Was the agreement that publishers would provide the full page layout or extracted images? It was his recollection that images would be extracted with some (to be established) reference to the image in the XML. George Kerscher and Skip Stahl commented that they recalled that the PDFs would be full-page layout.
Dave Schleppenbach noted that if the images were to be extracted and referenced he'd like to see them placed in a folder, but obviously the manner of how the images were to be provided needed to be resolved. There was also the issue of image resolution, since the publisher PDFs were huge files with very high resolution images designed for print publication.
George Kerscher asked about the capability of assistive technology software to render or process 72 dpi images—was this something that software like Wynn and Kurzweil could manage? George Kerscher also noted that large print wasn't on the table when the PDF and the availability of images were being discussed, so the discussion should focus on what resolution of images would be appropriate for both onscreen and hard copy print?
Bob Stepp (Computer Application Specialties) began a discussion of the challenges he perceived to exist with respect to the production of high-quality contracted braille from NIMAS-conformant source files. He raised the issue of text units and semantics and the fact that considerable human judgment was required when using NIMAS-conformant files, at least the early version for which he had access. He noted that, in his experience, NIMAS-conformant files, while syntactically valid, do not adequately describe the layout of the document.
Bob Stepp had access to a Pearson grade 4 reading textbook. He noted that all the separate stories contained in the book were subordinate to the vocabulary drill, and that while the words were in the NIMAS XML, the file itself was not an accurate representation of the book. Bob Stepp indicated that he felt that the difficulty was not with the specification itself (full DAISY markup) but with its limited application in NIMAS.
George Kerscher suggested that there were significant training needs with respect to how transcribers actually used either DAISY or NIMAS-conformant XML files, noting that XML was markedly different from the RTF and Word documents with which that transcribers were used to dealing.
Bob Stepp, acknowledging that training was an issue, returned to the question of markup. For example, the NIMAS-conformant file did not contain a table of contents (TOC), so the TOC had to re-created manually by comparing the NIMAS XML with the print version. George Kerscher noted that TOC and index were part of the NIMAS optional tag set and present in full DAISY mark up.
Bob Stepp noted that it was very difficult to write an XSLT (transform) since the standard appears to be evolving and that some elements were required while others were optional. As a consequence, the transcribers that he has heard from feel that NIMAS is no better than RTF, and in many cases, not as usable. He noted that he has been asked to create RTF file from NIMAS-conformant files so that transcribers could have familiar files to work with. He also commented that for accurate braille production, layout decision-making needs to be postponed until the very final stages. Both the braille translation software and the transcribers working with it want source files that are as descriptive as possible. Additional elements and their associated attributes are necessary to efficiently create braille. For example, the baseline NIMAS doesn't require class attributes, which would provide additional style information, and trying to globally script a NIMAS-conformant file is a challenge since every publisher may apply a different approach.
Dave Schleppenbach suggested that perhaps creating a Name Space for publishers would alleviate that confusion.
George Kerscher noted that class attributes were recommended practice for full DAISY markup.
Bob Stepp stated that he would want uniformity throughout the book with class attributes as an expected, rather than excepted, norm. Then he could include them in an update to Braille2000. That would also help transcribers since they sometimes change their minds about layout at the last minute once they see how the book actually works.
Bob Stepp reiterated that he did not believe the NIMAS baseline set is not rich enough to facilitate braille production because it doesn't have class attributes present.
George Kerscher and Skip Stahl noted that NIMAS was always meant to serve as a baseline and that NIMAS-conformant files would always require additional tagging in order to produce the student-ready versions, including braille.
Bob Stepp noted that exemplars of both baseline and augmented NIMAS-conformant files showing consistent class attribute usage would be very helpful, but the challenge still remained because these elements were optional. As a consequence, decisions like how and when to assign indented and unindented paragraphs in braille were next to impossible without significant additional work. Further, the creation of glossary terms, first word instance, and the subsequent usage also posed a challenge since the word was not stylized in NIMAS XML.
George Kerscher noted that this type of distinction was addressed in the dictionary modular extension to the DAISY/NISO standard, and that would guide the production of the pronunciation.
James Pritchett commented that the immediate challenge seemed to be who's going to do it, how will they do it, and when will they do it (in order to make NIMAS-conformant files "braille ready"). At the moment the creation of braille files from RTF is familiar and cheaper, but even though NIMAS is not the full DAISY element set, it does establish a precedent that will be far more beneficial in the future.
Jennifer Sutton asked what about what's going on around the world. George Kerscher explained at some point that some organizations are actually creating the content and then selling it back to the publishers—serving as the conversion services and then, at the same time, getting the kind of single source file that both the organization and publisher want/need—and that class attributes are being used by other countries.
Joe Sullivan commented that the prodnotes element was not necessarily wanted as a transcriber's note. In addition, there was the use of definition lists in glossaries versus different kinds of definitions, conditional ones; and then there was the challenge of glossaries versus sidebars and sidenotes.
George Kerscher asked "didn't the characters come out right with Unicode and UTF 8?" Bob Stepp agreed that the content was much better with both named entities and UTF 8. Joe Sullivan added that that was with an XSLT on the front end to aid the transformation.
Bob Stepp continued that he was developing administration tools—a heading extractor, for example—so he can easily do something like map down headings from six to three class attributes and try to get the unit broken up into chunks of similar things that might be fixed later in the game. Hopefully an automation of the concepts would help and facilitate several dozen globally resolved issues.
George Kerscher noted that the DAISY Multi-Format Converter (DMFC) work has some potential to provide transformation tools, and that a first release was expected around the end of the year.
Skip Stahl suggested that the Technology Subgroup could indicate a priority of optional elements (or attributes) that would facilitate braille transformation and transcription. He also noted that the legal mandate is that states adopt NIMAS, and that the baseline element set was the agreed to consensus of the NFF Technical Panel. One way to facilitate state "adoption" of NIMAS would be to encourage states to include a "consideration" of alternate format materials on a student's IEP. He also noted that one additional means for meeting the NIMAS mandate in IDEA 2004 was that publishers could sell accessible student-ready versions directly to states.
The question of file validation was also raised. Bob Stepp noted that the use of XML schema for validation would be the most effective. Dave Schleppenbach noted that whomever was validating NIMAS-conformant files needed some understanding of the content. Chris von See added that, in that case, the person would function like an instructional designer.
Another question was raised about the certification of conversion houses, i.e. some way of indicating that they were competent to manage NIMAS content. Would this be something like "DAISY OK" or "DAISY Certified?" George Kerscher said that "okayness" can work for products and services and that this issue had been discussed at the DAISY Consortium a few times. Jennifer Sutton wondered whether or not the DAISY Consortium actually had the resources to go down this road, posing "what happens within the NIMAC in terms of kicking quality control problems back?"
An additional suggestion was that a voluntary product accessibility model like the Section 508 VPAT (Voluntary Product Accessibility Template) be considered for NIMAS-conformant files. Along with a NIMAS VPAT (or, as Steve Noble suggested, a Voluntary Instructional Materials Accessibility Template or VIMAT) there is a pressing need to develop training that is appropriate for publishers and conversion houses as well as the transcriber community.
This group has convened to expose critical issues pertaining NIMAS policies and commerce and to provide suggestions to the NIMAS Technical Assistance Center as it attempts to provide guidance, establish best practices, and disseminate information to others responsible for implementing IDEA 2004, the standard, and associated regulations published by the U.S. Department of Education regarding the NIMAS.
The discussion began with the question of how best to identify Authorized Entities. It was suggested that user agreements should be provided to the NIMAC but that this operational process should be left to APH and the NIMAC advisory committee to work out. It was thought that a registration and vetting process might be needed to cut down on legal liability and that such a process would be based on Chafee requirements.
Julia Myers, representing the NIMAC at APH, expressed the opinion that APH will not decide who are Authorized Entities, but that SEAs and LEAs will be the ones defining which, in their groups, are authorized. It was suggested this working group might provide a list as recommendation to APH. It was further suggested that states will need to accept the liability regarding the appropriate use of files based on what was intended. Regarding the NIMAC and contracts, consider the needs of nonprofit agencies, go back to the law to review Authorized Entity definitions. "Primary mission" is the key. States may need to recommend a single contact and then work with the other agencies to do the work.
Chuck Hitchcock suggested that this group author statements that might provide guidance to NIMAC and perhaps recommend a process that this group may agree upon.
Jim Fruchterman noted that the problem is that to get the file you have to go back to a state if you are not on the list. This would be restraining based on where the book goes. Shouldn't national nonprofits that qualify as Authorized Entities be able to sign a contract with the NIMAC to receive files directly? The consensus of the group was that such national Authorized Entities should have direct access to the NIMAC.
Steve Driesler indicated that liability is assumed at the nonprofit or agency level, not the NIMAC. He thought that a policy should be developed to deal with possible abuses. The NIMAC does not want to be in a policing role.
There was a related question about expanding the definition to include a larger population of students with "print disabilities." If Chafee does not require buying a book then publishers will want to control the size of the qualifying population. It is hoped that there will be a viable market solution for other student populations who may not seem to fit neatly within the Chafee exemption.
The question of homeschooling was raised. How does it relate to access to materials in NIMAS or through the NIMAC? There is a question regarding the federal law concerning the responsibility of the school if a child is enrolled in the school and then home schooled. This is not really in our focus at this time but those children are likely still the responsibility of the local education agency.
Steve Driesler mentioned the movement to a market model that will serve the Chafee group and others? He suggested that we narrow the population to Chafee for now in order to avoid undermining the viability of a market model for a larger group later.
The group was reminded that final regulations regarding NIMAS and the NIMAC have not yet been issued so one or more of the topics being discussed might be influenced by that development in late 2005 or early 2006.
It was mentioned that the NIMAC will have no control over when the files come in, if they are fully validated, what the files will look like, or what SEAs and LEAs need to know about them. Some information may be saved with the NIMAS-conformant files. It was also stated that a quality review will be done on NIMAS-conformant files, a searchable record of information of the file will be created, descriptive information will be provided, who asked for the files to go to the NIMAC will be tracked, and perhaps a record of the contract from the state or LEA with the publisher will be created.
Workflow has to be well defined about the validity of files. There was a question about whether the NIMAC would have the authority to ask the publisher to fix a file if it has problems. You can reject the files at the NIMAC, they think.
The question of unfinished books being submitted was also raised. Although this is a common occurrence in Texas with follow-up submissions of tear sheets for completion, this approach is thought to be unique and not applicable to the NIMAC. Most states accept the file complete when it is done. Not all the books will need to be brailled (the question is how is this happening with communication among groups). It was noted that publishers will not be providing braille files, nor will the NIMAC.
Jim Fruchterman raised the question of this group's purpose and noted that the U.S. Department of Education was unlikely to provide additional guidance by regulation. It was agreed that we should attempt to track issues and make recommendations as a working group in order to provide guidance to others.
Steve Driesler wanted to confirm that the education of publishers does not require a listing of the benefits of opting in to NIMAC. They already accept the idea. He suggested educating publishers on tagging with NIMAS and help to facilitate a market solution. He also suggested the creation of documents to move this work forward.
Chuck Hitchcock raised the question regarding what needed to be included in a contract or purchase order with a publisher. This language will be proposed a bit later. It was emphasized that the group needs to address the question of why opting in is critical and then, perhaps, provide examples of contract language.
The question of what "adopt" means was raised and the issue of opting in or out at the state or local level was discussed. People may not opt in if they think that they are putting themselves at risk. Guidelines may be needed and a process may need to be developed and disseminated. A starter list was discussed and it was stated that the NIMAS Technical Assistance Center would attempt to complete this list and distribute it for accuracy and completeness.
Reasons some states and local education agencies might not choose to opt in:It was noted that the NIMAC will be a key player regarding the critical mass issue. If people begin checking and don't find what they are looking for, they may not come back to check again. Then have to go to other solutions. A rapid population of the NIMAS was deemed important.
Steve Driesler also suggested that ideally it would be good to have one stop in each state no matter if of an adoption or open territory state, that would be the focus for coordination with the NIMAC. Suggested a model with a manageable number of contact points in each state. Perhaps this will require a set of criteria that establishes who is the contact to make it manageable.
It was suggested that there may be a need for guidance to determine which students qualify under the Chafee Amendment and who gets to decide this.
After breakfast the second day of the conference began at approximately 9:00 am and concluded at noon, at which point lunch was served. Much of the discussion focused on topics that had been brought up during the previous day's subgroup sessions.
Chuck Hitchcock mentioned a summary document being developed that compared the tags for PDF, NISO 2002, and NISO 2005, and the NIMAS baseline (required) elements. Chuck Hitchcock noted that this document was in the process of revision and had not yet been publicly released, and questioned the extent to which the document might prove useful, and to whom. The consensus was that the actual infrequency of overlap between the NIMAS/DAISY tag set and tagged PDF meant that a comparison might not be all that helpful. The decision was not to post the document at this time.
George Kerscher introduced the topic of best practices for NIMAS markup by suggesting that a part III be added to the DAISY Structure Guidelines that would list all the elements and their associated semantics. This suggestion was made to provide a quick reference, with semantics (what they mean), all in a single resource (at the DAISY/NISO Web site).
Chuck Hitchcock commented that the NIMAS Web site will be posting a collection of papers, and that from the NIMAS homepage one can access info about NIMAS that is presented in an educational way as opposed to a technical way.
Bonnie Jones expressed concern about how the endorsement of resources might impede their availability.
Bob Stepp introduced concerns about the "baseline" (mandated) NIMAS-conformant file set being insufficient for meaningful braille translation. [This issue was also raised in some detail in the Technical Subgroup breakout session]. Bob Stepp commented that while he has had access to only one NIMAS-conformant XML file, it does not seem to provide sufficient tags to allow his Braille2000 software to convert it into something that will be useful to braille transcribers. He noted that transcribers are used to working with RTF documents that provide far more style and structure information than the baseline NIMAS apparently does, and, consequently, he was being asked if there was a way to convert NIMAS XML "back" into RTF for braille transcription purposes.
George Kerscher noted that when this issue arose in the Technical Subgroup meeting he had suggested the use of "class attributes" as a solution to the style concerns, since they add richer semantic information to the content. He also noted that the use of class attributes was not required in the baseline DAISY XML. This suggestion resulted in the thought that the optimal solution would be to request NIMAS-plus (aka "NIMAX," full DAISY-conformant XML markup) rather than the NIMAS, the agreed-upon and mandated tag set.
Steve Driesler reacted strongly, noting that this was not the time to be extending the publisher's mark up responsibility beyond the mandated NIMAS tag set, and that representatives from the braille community had been active and contributory members of the original NFF Panel that created the NIMAS consensus.
Skip Stahl commented that it was clear that there were some outstanding issues, and that the Committee needed to meet people where they were, however, the NIMAS version 1.0 tag set did indeed exist as the agreed-upon mandate.
Mary Ann Siller suggested that a partial fix would involve the collaboration of technical experts, transcribers, and states, not that states should not go back and change their laws, but that the AFB online course would need to be added to address these new issues. In addition, it was apparent that the transcriber community would need to retool and reorient themselves in order to work with XML.
Chris von See asked for clarification of exactly what the "value-add" (i.e. Authorized Entity) process was envisioned to entail. A number of respondents noted that NIMAS was developed as an "intermediate" format that contained "baseline" elements, and that the Authorized Entities would be responsible for subsequent markup that would facilitate the conversion of these files into student-ready versions.
Bob Stepp commented that braille transcribers are older women, generally, and not that technical. The baseline set lumps textual units together that don't belong together, so XSLT can't really fix things. In addition, transcribers aren't thinking of turning to commercial companies for value-added support, so a significant challenge exists. Bob Stepp also noted that large states with existing braille production know-how (e.g. Texas and California) will likely ask for more than NIMAS provides.
Chuck Hitchcock shifted the conversation towards a discussion of an aspect of the Chafee Amendment by asking "who is an Authorized Entity?" He elaborated by thinking about how national organizations like Recording for the Blind & Dyslexic and Bookshare.org will get access to NIMAS-conformant files—directly, or only through the request of an SEA or LEA?
Skip Stahl suggested that state-level instructional materials centers might function as satellite NIMACs since the publishers were only protected under Chafee if they provided files to the NIMAC, not directly to states.
James Pritchett suggested that NIMAC distribution probably should not be thought of as a request-driven process, since publishers would likely just create NIMAS-conformant files and deposit them in the NIMAC well before the demand. Steve Driesler and Rick Ferrie agreed.
Chris von See asked if value-add companies would be required to resubmit "expanded" NIMAS-conformant files back to the NIMAC. Since APH is still in the process of determining file submission protocols, no definitive answer was forthcoming.
Jennifer Sutton suggested that an investigation of the interface between the LOUIS Database at APH and the Union catalog could yield some important information. Did searches occur concurrently or in parallel?
Jim Fruchterman commented that he envisioned Bookshare.org serving as a sort of vacuum cleaner to bring all of the NIMAS-conformant files to various states.
Mary Platner opined that a state-by-state approach did not seem very practical since it would result in the segmentation that already existed.
Skip Stahl reminded the group that, at least as far as the legal mandate went, the buck stops with SEAs and LEAS for acquiring accessible alternate format version created from NIMAS-conformant source files, so ultimately they would be the drivers.
Ron Stewart commented that the Badger Center at the post-secondary level exists for book location, but it's not free of charge.
Chuck Hitchcock suggested the NIMAS Centers may wish to propose language that states can use that would show that they have adopted NIMAS, and make sample language available on the NIMAS Web site. Chuck Mayo stated that Texas would need language fairly quickly, and needs it too.
Steve Driesler requested an a FAQ, perhaps more than one, for various constituent groups, like publishers, SEAs, LEAs, etc.
Chuck Mayo stated that, at least in Texas, the powers that be may opt out of the NIMAC since they already get parts of books along the way. It seems that if they opt in, they'll have to wait.
Steve Driesler commented that for Texas, the textbooks are Texas-specific and the state does get files along the way (while they are in the process of creating the complete file). Even using the NIMAC it might be possible to file in parts, and not be breaking their system; they could opt in without breaking their system. Opting in is not forcing exclusivity; opting in means getting resources, depositing.
Rick Ferrie suggested that there was a need to separate technical issues (and jargon) from regular things. Doing this would enfranchise contributors who glaze over with all the tech-speak.
George Kerscher noted that it's clear that end-users are asking for full DAISY markup.
Rick Ferrie noted that as soon as a preliminary math specification is available, the Committee needs to start working on tools and other supports, so who else should be invited to participate?
Chris von See recommended that it would be very important to show (with the NIMAS exemplars on the Web site) how braille could be addressed.
Chris von See asked Julia Myers if the NIMAC would stock hard-copy books? Julia said no. Julia agreed that some Authorized Entities and others probably need printed books (like RFB&D and maybe even Bookshare.org for their brailing activities). The question of whether or not a full-page PDF rendering could effect the same support was raised, but remained unresolved.
The NIMAS Development Committee fully supports the creation of a NIMAC Advisory Group to support APH's development of the NIMAC.
The NIMAS Development Committee agreed that the development of a "VIMAT" for detailing the content of NIMAS-conformant files is a very good idea, and should be considered as part of the file set metadata.
James Pritchett recommended linking the VIMAT (demonstrating it) to the NIMAS exemplars to document and model its use.
Rick Ferrie agreed, stating that larger publishers are going to out-source a lot of this work and a VIMAT would help in the contract negotiations.
Rick Bowes (Consultant, AFB) noted that many folks in higher education are looking at this where 508 (and the VPAT) becomes more of a factor.
Jim Fructerman said that Benetech had made proposals for funding an open source tool to do NIMAS-conformant file quality evaluation.
ACTION: CAST will streamline the posting of the exemplars and announce their availability to the Committee and other interested parties. A strategy to differentiate between exemplars and other possible file-type outcomes, as these are posted on the Web site, will be devised.
ACTION: CAST will post the NIMAS-related excerpt from The Universally Designed Classroom on the NIMAS Web site, if possible.
ACTION: CAST and AFB will work together to post the checklist on the NIMAS site and publicize its availability among relevant stakeholders.
ACTION: AFB should work with the community to outline effective strategies and work with CAST to publicize when relevant updates have been made to the training course.
ACTION: A FAQ, or a set of FAQs, should be created to educate stakeholders, such as publishers, Authorized Entities, states, and LEAs, so that everyone is familiar with expectations and process. CAST's currently available FAQ provides the basics, but FAQs that present specific steps and definitions from different audiences' perspectives will be helpful.
ACTION: The NIMAS Centers' Directors will develop some possible scenarios for Committee consensus.
ACTION: The NIMAS Centers' Directors, with Committee input, will identify what elements would be required.
The NIMAS Development and Technical Assistance Center, supported by the U.S. Department of Education, Office of Special Education Programs (OSEP), works with states, TA systems, disability advocates, national associations, technology experts, publishers and content conversion houses to improve the timely delivery of high quality accessible educational materials to students with disabilities.The NIMAS Center was launched on October 1, 2004.The project officer for both the Development and TA Centers is Bonnie Jones, Ed.D. Opinions expressed herein do not necessarily represent the Department of Education's position or policy.
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