Memorandum submitted by RNIB


1. Introduction


1.1 RNIB is the UK's leading charity offering information, advice and guidance to over two million people with sight problems, with a national Children's Services team concerned with the interests of blind and partially sighted children and young people, including those with additional needs. RNIB is in a strong position to maintain an overview of educational provision for visually impaired pupils at a local and national level. In the area of testing and assessment we work closely with QCA and awarding bodies to ensure equal access but are keenly aware of tensions inherent within the system which makes this hard to achieve. We are pleased, therefore, to have this opportunity to submit evidence to the Select Committee on Testing and Assessment and would welcome the opportunity to supplement this information with oral evidence


1.2 The submission begins with background information, which is intended to inform members about the population of children and young people with visual impairment and the context in which they are educated. This is followed by RNIB's overall policy position on testing and assessment. The remainder of the submission identifies specific areas of concern around the existing provision for learners with visual impairment.


2. Background


2.1 Visual impairment, which includes both blindness and partial sight, is a low incidence impairment. It is estimated that there are around 17,500 children in England between the ages of five and 16 with a visual impairment of sufficient severity to require specialist support. Approximately 50 percent of the children have a single impairment, 20 percent have some additional need or needs and 30 percent have profound or complex needs with associated learning difficulties. Out of all pupils with a visual impairment only around 4 percent use braille.


2.2 Fifty nine percent of blind or partially sighted children are educated in mainstream schools. This number has remained static for a number of years. Pupils attending mainstream schools may attend their local school with support provided by the local authority specialist support service or a school that is specifically resourced for blind and partially sighted pupils where specialist support forms part of the permanent school staffing. Just over three in ten visually impaired pupils attend maintained special schools for pupils with learning and/or physical disabilities, while only one in 20 attend special schools for pupils who are blind or partially sighted (Keil and Clunies-Ross, 2003). In the latter, most class or subject teachers will hold an additional qualification in visual impairment. The number of schools that exist specifically for visually impaired children has fallen significantly in recent years as increasing numbers are included in the mainstream. Those that remain are educating pupils with increasingly complex needs.


2.3 Depending upon the degree and nature of their visual impairment, a pupil may use non-sighted or sighted methods, or a combination of both, to access the curriculum. Examples of non-sighted methods are braille, audio-tape, and computer with speech software. Sighted methods include enlarged or modified print, low vision devices such as magnifiers and computers with large screen monitor and/or enlarged text on screen. Some environmental adaptations may also be necessary, for example increasing or decreasing the level of illumination in the pupil's work space. The class or subject teacher plays a crucial role in ensuring that the range of strategies or approaches used enable the pupil with visual impairment to be fully included in the class.


2.4 In addition to requiring equal access to the mainstream curriculum, many visually impaired children also learn disability specific skills such as braille, mobility and independence skills, which are an essential aspect of their journey towards adulthood. Pressure of time within the normal school day frequently involves juggling the competing priorities of these specialist activities with the demands of National Curriculum subjects.


3. RNIB's policy on testing and assessment


3.1 RNIB is committed to a social model of disability, one where we all share a collective responsibility towards disabled individuals by identifying and responding to their needs from the outset. The fact that 75% of blind and partially sighted people are unemployed indicates clearly that we have some way to go before we achieve a society where disability does not create barriers to achievement and fulfilment. In the specific area of testing and assessment, the government''s own research ('Improving the Life Chances of Disabled People' 2005) demonstrates that over 40% of disabled people suffer some form of labour market disadvantage because they have no qualifications.


3.2 RNIB believes that the interests of visually impaired learners are not well served by current testing and assessment structures because these have not been designed with the needs of disabled learners in mind. Our highly centralised and bureaucratic assessment system is as much about measuring the standards of schools as it is about recognising and accrediting the achievement of individual learners. While we believe this to be inappropriate for all learners, the tensions are inevitably greater for disabled learners whose skills and aptitudes cannot be readily measured against simple summative standards. In short, we believe that in the name of inclusion many disabled learners are being shoehorned into a system which does not fully understand their needs or recognise their achievements. This is particularly true of children with visual impairment and additional disabilities, whose progress and achievement is almost entirely overlooked by the current external assessment model. However, even those with visual impairment alone have to work harder to demonstrate the same level of achievement as their peers, often in the context of being required to complete assessment tasks that assume visual knowledge and experience.


3.3 We believe that the emphasis on external summative assessment should be changed in favour of a holistic assessment process which evaluates children's progress against individually negotiated targets. Assessment should be fit for purpose not just in relation to the task but also the individual, focusing on what learners can do rather than grading them according to what they cannot. Such an assessment system would be capable of recognising a wider range of achievement than at present, including for example visually impaired children's ability in braille, mobility or independent living skills.


3.4 We also believe that the achievements of disabled pupils should be recorded so that these can be compared against national standards. Currently there is no way of judging whether their overall level of achievement is above, in line or below that of other learners. We believe that recording and making this data publicy available should form part of QCA's impact assessment of its Disability Equality Scheme.


4. Specific concerns


Even taken on its own terms, RNIB is concerned that the current testing and assessment system denies some visually impaired pupils the opportunity to demonstrate their full knowledge, skills and understanding. Many of these weaknesses are historic but the introduction of disability discrimination legislation into the area of general qualifications from September 2007 has placed them in a new light. In particular:


4.1 There are significant differences in the reasonable adjustments for National Curriculum tests and for GCSE and other examinations at Key Stage 4 and above. For example, National Curriculum papers can be opened with approval one day or more in advance, allowing time to modify the papers to make them more accessible to individual needs. For GCSE papers the maximum time allowed is one hour, which is an inadequate amount of time to make most papers more accessible.


4.2 Modified papers for partially sighted candidates are produced in a single standard size of 18 point print. This excludes a growing number of candidates who need a larger size of print but do not read braille. RNIB is currently working with the awarding bodies to develop a software tool which will enable schools to produce papers in house in a range of formats to suit pupils' individual access needs. This work urgently needs funding to enable it to be rolled out to all paper-based tests and examinations in future.


4.3 We believe that the system for the production of papers in alternative formats at Key Stage 4 and above falls short of the quality standards expected for standard papers. Many papers are produced at short notice, which allows insufficient time for modification and proof-reading. The quality of diagrams, especially in braille papers, is often poor. Some awarding bodies struggle to produce papers across the full range of subjects. Paradoxically, the system for producing braille and large print papers for National Curriculum tests is much more rigorous although the tests themselves are less important to the individual learners concerned.


4.4 Past papers in alternative formats are often in limited supply and do not exist at all for some courses. On the basis that past papers form an essential part of the revision programme for many learners, we believe that this disadvantages candidates with visual impairment who are unable to obtain them.


4.5 We are concerned that the growing move towards e-assessment may create new barriers for visually impaired learners if the software systems adopted are not tested to ensure they are fully compatible with the access technology used by many visually impaired people. We are particularly concerned that learners with visual impairment are not forced to acquire new IT skills to demonstrate their ability for reasons which are primarily to do with saving awarding bodies time and money.


4.6 We believe that assessment criteria for tests and qualifications should be designed to reflect the actual working methods of all learners. RNIB has recently been involved in protracted discussions with QCA and the awarding bodies about the nature of reading, to avoid a situation where some visually impaired children may be denied the opportunity to take English GCSE because they are unable to read the paper independently.


4.7 We believe that the emphasis on timed tests and examinations disadvantages learners with visual impairment, for whom the ability to access and process written information often takes longer than those with full sight. The common practice of providing compensatory time allowances does not address this issue adequately because it increases the workload and fatigue of the learner concerned. At A-level, for example, it can result in some 3 hour papers becoming 6 hours in length.


5. Conclusion and recommendations


5.1 If qualifications are intended to meet the needs of all learners, there must be dialogue to ensure that the interests of minority groups are included from the outset. RNIB believes that the system for the current system for the testing and assessment of learners with visual impairment is unacceptable because it operates largely on a post hoc basis, with assessment materials and tasks being modified after they have been set and approved for the sighted majority. Under the DDA 2005, QCA is required to ensure that the assessment criteria for all qualifications are drawn up with the needs of disabled learners in mind. However, experience to date suggests that QCA does not recognise the need to involve disabled groups fully in this process. We are also concerned that communication between QCA and the awarding bodies is often not as effective as it should be.


5.2 Our recommendations are as follows:

A major review of the whole purpose of testing and assessment for all learners, with a view to dismantling the centralised summative model currently in place and placing more reliance on teacher assessment.

Research into the impact of National Curriculum tests and public examinations on the education of disabled children, with special emphasis on their relevance to these children's futures.

A commitment to government funding of all reasonable adjustments required for children in statutory education to gain equal access to national tests and qualifications.

The establishment of a steering group representing disabled learners to meet on a regular basis with officers of QCA and the awarding bodies, to address the many complex issues which arise in trying to separate children's ability from their disability.


June 2007