December 8, 2020

Dear Governor :

This week, as COVID-19 cases in the US reach 200,000 per day, we are deeply concerned about the pandemic’s impact on people who are blind and have low vision. Governors are making difficult decisions about increasing safety protocols to protect citizens, and at the American Foundation for the Blind (AFB), we want to be sure that you have the perspective of individuals with visual impairments as you and others in «State» engage in planning and executing your state’s response to the pandemic. We urge your administration to consider these needs as you work to implement solutions that will benefit not only people with vision loss but all people in your state.

AFB has taken a lead role in bringing together nearly two dozen organizations in two research studies that examined the experiences of people with vision loss during the pandemic. The Flatten Inaccessibility study examined the impact of COVID-19 on 1,921 adults with visual impairments in the United States early in the COVID-19 pandemic. The Access and Engagement study investigated the experiences of 455 families of children with visual impairments and 1,028 teachers of students with visual impairments and orientation and mobility specialists providing education to children from birth to age 21. As our country continues to see case numbers rising, we urge you to meet the needs of people who are blind or have low vision outlined below.

Ensure that digital government services and education are inclusive and accessible. Each state and local government is already obligated to provide accessible digital experiences to people who are blind or have low vision. As our communication, interactions, and transactions increasingly take place online to prevent the spread of the coronavirus, it has never been more important for states to take seriously their obligation to provide accessible digital experiences. The Flatten Inaccessibility study revealed that participants were concerned about the online accessibility of services such as SNAP, WIC, or unemployment insurance applications. Others expressed concern about the accessibility of online job search and hiring processes. One in five participants who had used telehealth reported the telehealth platform was not accessible. Critically, respondents also had difficulty accessing important public health information in accessible formats. During a pandemic, health information, including case statistics or testing locations, must be fully accessible to people with vision loss.

Additionally, the Access and Engagement study revealed significant deficits in the digital accessibility of instructional methods and technology platforms relied upon by schools and classroom teachers. We urge states to evaluate educational tools for accessibility and usability by students who are blind or have low vision, only procure those tools that are fully accessible, and advocate with the developers when inaccessible features are found. Industry standards, such as the Web Content Accessibility Guidelines (WCAG), provide clear guidance for evaluating product accessibility. Students who are blind must have access to the digital classroom just as their peers do. Ensuring accessibility enables all students to benefit from remote learning equally and upholds the civil rights of students with disabilities as guaranteed by the Individuals with Disabilities Education Act.

Support additional resources to fully meet special education needs, including retention and hiring of professionals. AFB recognizes that states and local governments are under unusual budget pressure in the midst of the pandemic. However, we urge states to meet the educational needs of students with disabilities by ensuring that schools and districts have the resources needed to deliver high-quality equitable educational experiences. In many cases, families and professionals reported not having access to the devices or instructional materials needed to participate fully in remote education, including twenty-one percent of families who did not have access to a laptop for school-age children. Schools and teachers need access to funding and resources to provide students the materials they require to learn. We are also very concerned about the pandemic’s worsening impact on the pre-existing shortage of teachers, particularly teachers of students with visual impairments (TVIs), orientation and mobility (O&M) specialists, and other specialized instructional providers. States should take steps to promote the recruitment, hiring, and retention of fully qualified professionals to meet student needs. To meet these needs, we strongly encourage you to provide additional state resources for special education.

Invest in transportation services that support individuals who need them the most while demand is low and plan to restore full service after the pandemic. A common concern articulated by respondents to the Flatten Inaccessibility survey regarded changes to transportation services. As the pandemic has progressed, bus lines have been cut, paratransit service has been modified, and rideshare options have become more limited and more expensive. We understand that many publicly funded transportation providers are facing revenue shortfalls due to lower ridership and that other providers are no longer providing rides because volunteer and paid drivers are either unavailable or at high risk from COVID-19. Nevertheless, many people with disabilities rely solely on public and private transportation services to access employment, health care, education, and food, so we urge states to offset losses where necessary to ensure continued operations and strategize about providing paratransit or other on-demand services to meet the needs of transit-reliant populations, especially people who are blind and have low vision, when cuts are necessary. As local transportation providers begin preparing their FY 2022 budgets, we further encourage states to continue to prioritize continuity of services into the future and to ensure that transit agencies continue to provide sufficient cleaning protocols and PPE for drivers. Permanent cuts to transportation would place significant barriers on all aspects of life for people with vision loss.

Plan now to ensure that testing and vaccination sites are accessible, and that transportation access is not a barrier either to testing or vaccination. One respondent to Flatten Inaccessibility wrote, “I am not sure how I would get to a mobile testing site. I wouldn’t feel comfortable using public transportation or ride-share services for fear of backlash or spreading [COVID-19].” Respondents overwhelmingly expressed significant concern about getting themselves or a family member to a test center. Drive-up only services discriminate against people who cannot drive, and people who are blind continue to face significant discrimination in accessing testing sites. Whether sites are drive-through or located at a health facility, these testing facilities present significant challenges to individuals who cannot drive, may be infected, and do not have a household member able or willing to drive them to a testing site. States must take more proactive steps to identify solutions to transportation barriers, such as providing in-home testing services or local neighborhood-based options, to people without access to a personal vehicle and publicize how individuals can access such accommodations. We have learned that some people with access to alternative testing methods do not know such options exist.

Moreover, with the ongoing difficulty providing accessible testing to individuals who walk, bike, roll, and take transit rather than drive, we are deeply concerned that states have not adequately planned for vaccine distribution accessibility. Among the many considerations that state health officials are evaluating at this time, we urge states to consider how individuals without access to transportation will be able to access the vaccine. Limitations of paratransit scheduling and service areas, the need for super cold storage, and access for rural areas are among the compounding issues that we know will make transportation to vaccination sites more difficult. Vaccinations should be available within easy walking distance of transit lines and at commonly visited health or grocery facilities. States should also consider offering special safe rides to vaccination facilities for people without access to transit. Of course, information about vaccine distribution should also be provided in accessible formats and make use of multiple media, including radio, tv, and internet. We encourage states to consult with local chapters and affiliates of the American Council of the Blind and National Federation of the Blind to promote information about the vaccine and how to receive it. These organizations are also fantastic partners for ensuring that local solutions to unique transportation barriers are available.

As case numbers and hospitalizations rise, ensure that the civil rights of patients with disabilities are protected in healthcare distribution. Disability alone must not be a determinant for rationing care. Numerous survey participants reflected on societal views of disability and how COVID-19 was heightening their concerns. The systemic challenge of people with disabilities being marginalized by many in the general public is not new. One participant wrote, “My concern runs deep relative to persons with disabilities being dismissed, disregarded, and or discarded as persons [who] lack in value when determining the level of attention/care to be given in health settings during the COVID-19 pandemic, especially when having to decide who receives use of limited resources.” These concerns are heightened for Black, Indigenous, and people of color, whose race or ethnicity puts them at higher risk of discrimination. Many states have changed discriminatory crisis standards of care policies to ensure that people with disabilities are not discriminated against in receiving limited health services when demand for care is high and to ensure that people with disabilities have access to needed support providers who can assist and advocate in the hospital if no-visitor policies are in place. We strongly urge states to ensure nondiscriminatory policies are in place, actively enforce nondiscrimination policies, quickly respond to complaints, and communicate appropriate procedures to doctors and hospitals.

At AFB, we are acutely aware that states are facing extraordinary challenges and balancing many competing demands. We appreciate the leadership you provide to your state and support your efforts to make society more inclusive of people who are blind and have low vision. We encourage you to reach out if you have any questions about the concerns we are raising or if we can work together with you to support your plans to ensure people who are blind or have low vision, including those with additional disabilities or deafblindness, have accessible and equitable access to critical services in your state regardless of their age, complexity of their disabilities, or geographic location. Please contact Sarah Malaier, Public Policy and Research Advisor, at


Stephanie Enyart
Chief Public Policy and Research Officer

  1. Rosenblum, L. P., Chanes-Mora, P., McBride, C. R., Flewellen, J., Nagarajan, N., Nave Stawaz, R., & Swenor, B. (2020). Flatten Inaccessibility: Impact of COVID-19 on Adults Who Are Blind or Have Low Vision in the United States. American Foundation for the Blind., page 59-62.
  2. Ibid., page 72-73.
  3. Ibid., page 52.
  4. Ibid., page 22 and 49.
  5. Rosenblum, L. P., Herzberg, T. S., Wild, T., Botsford, K. D., Fast, D., Kaiser, J. T., Cook, L. K., Hicks, M. A. C., DeGrant, J. N., & McBride, C. R. (2020). Access and Engagement: Examining the Impact of COVID-19 on Students Birth-21 with Visual Impairments, Their Families, and Professionals in the United States and Canada. American Foundation for the Blind., page 56.
  6. Ibid., page 30, 37-38, 53, 80, and 83. Examples of other materials that were missing include braille and large print texts, tactile graphics, white canes, Perkins braillewriters, hands-on manipulatives for science or math instruction, computers with screen magnification software, video magnifiers/CCTVs, reading stands, and lighting. The participants surveyed tended to have access to technology and may not be representative of families without access to broadband or other internet access.
  7. Flatten Inaccessibility. Pages 26-33.
  8. A cross-disability letter sent by the Consortium of Citizens with Disabilities Transportation Task Force this summer describes other needs in more detail.
  9. Flatten Inaccessibility. Page 28.
  10. Ibid., page 27-28, 50, 53.
  11. Ibid., page 54.
  12. Ibid.