May 5, 2009

The Honorable Arne Duncan
Secretary of Education
U.S. Department of Education
400 Maryland Avenue, SW
Washington, D.C. 20202

Dear Mr. Secretary:

We are writing to request your attention to a matter affecting students who are visually impaired or blind.

The Federal Child Count, a statutory provision of the Individuals with Disabilities Education Act conducted by the Office of Special Education Programs (OSEP), renders a considerable number of students with educationally significant visual impairments systematically invisible. Because the count is based upon a primary disability category model, students who have disabilities in addition to visual impairment are often not represented as having a visual impairment in OSEP's annual report to Congress.

Using other sources of information, such as the American Printing House for the Blind (APH), the magnitude of the issue is obvious. APH conducts an annual count of students who are legally blind. As such, the APH count is a more restrictive count than the OSEP count. Yet, the APH count consistently reports numbers that are more than twice that of the OSEP count. For example, in 2004, APH reported 56,700 students who were legally blind and receiving services, while the OSEP count reported there were only 25,500 students who were visually impaired and receiving services.

As informative as the APH count is, it is a very restrictive count as it includes only students who meet the legal definition of blindness. In a study based upon epidemiological estimates, the National Plan for Training personnel to Serve Children with Blindness and Low Vision (NPTP), an OSEP-sponsored project, offered a more accurate picture of the numbers of students with educationally significant visual impairments by including those who had additional disability labels. This study, conducted in 1998, estimated there were approximately 93,500 students who were visually impaired, a figure almost four times greater than that of the OSEP count. NPTP recommended that OSEP implement a separate count of students with visual impairments, but that has not occurred.

The impact of OSEP's grossly inaccurate count has many negative and serious repercussions. Some of these repercussions include:

  • This disparity in numbers causes a bias in all research data on student needs and outcomes in this population;

  • The need for teachers certified in visual impairments, orientation and mobility specialists, and teachers for children who are deafblind is underestimated, impacting both teacher preparation programs and educational services;

  • Federal funding provided for vision services is insufficient to meet the need;

  • Children are not being appropriately served based upon educational needs.

We request a set aside of 5 million dollars to develop and implement a yearly "National Census of Students with Visual Impairments" based upon the NPTP model. We believe that subsequent costs can be folded into current operating budgets, but the set aside is necessary to establish the system.

Once accurate numbers are generated for this population of students, many of the impacts stated above can start to be addressed. It is our belief that once appropriate research can be conducted, appropriate numbers of professionals working with these students can be prepared and federal funding is aligned to meet the need, post-school outcomes for students who are blind or visually impaired will mirror those of the nondisabled population.

Thank you for your time and consideration in this matter. As you can see from the list of supporting institutions and organizations, this matter is of great importance to those who educate students who are visually impaired. Please do not hesitate to contact us if you need additional information or wish to discuss the matter further.

CC: Patty Guard, Acting Director, Office of Special Education Programs, OSERS

This letter was endorsed by 160 individuals and organizations across 40 states.