Letter to OSERS: Concerning Lack of Communication Supports

Earlier this week, TASH sent a letter to the Office of Special Education and Rehabilitative Services (OSERS), Department of Education, expressing concern about the lack of communication supports provided to students with communication disabilities by school districts and seeking clarification of district responsibilities to address a serious national problem. It is clear from recent research that communication instruction, supports and services are not available to a large number of students who do not communicate verbally. Towles-Reeves, Kearns, Flowers, Hart, Kerbel, Kleinert, Quenemoen, and Thurlow (2012) analyzed data from 44,000 students who participated in the alternate assessment based on alternate achievement standards (AA-AAS). This data shows that 20% of students taking the AA-AAS are emerging symbolic language users and 10% do not yet have an identified, consistent communicative output. Approximately 50% of these students do not have access to an Augmentative and Alternative Communication (AAC) system. Their analysis also found there was no statistically significant change in access to AAC or supports from third grade to high school for these students. In other words, if they entered third grade without a communication system, they left school without a communication system.

TASH members were pleased with the release of the Department of Justice’s and Department of Education’s Dear Colleague letter of November 12, 2014 and the Frequently Asked Questions on Effective Communication for Students with Hearing, Vision, or Speech Disabilities in Public Elementary and Secondary Schools. These documents and the relevant federal legislation (the Individuals with Disabilities Education Act (IDEA), the Americans with Disabilities Act of 1990 (Title II), and Section 504 of the Rehabilitation Act of 1973 lay out the importance of communication for all students and set a foundation for meeting the communication needs of all students as a critical component of a Free and Appropriate Public Education.

TASH’s letter, submitted in collaboration with the Council of Parent Attorneys and Advocates (COPAA) and the Autistic Self Advocacy Network (ASAN), seeks clarification of this guidance regarding school district responsibilities to address this urgent national problem.