During the 2021-2022 reporting year, our Board community continued to navigate various facets of accessibility within the meandering landscape of the COVID-19 pandemic. The ongoing impact of periodic shutdowns and closures not only affected student well-being but also presented accessibility challenges associated with remote learning in ensuring that all students had access to online learning tools and technologies. For all students and especially those with special education needs, the world of synchronous and asynchronous learning required consistent planning and engagement by system leaders. With most of our Board community working and learning remotely at various intervals, certain accessibility issues were left until the assurance of certain level of normalcy returned.

Despite the challenges of a pandemic environment, the York Region District School Board remained steadfast in advancing key accessibility-related projects in the virtual world and the Human Rights Commissioner’s Office continued to provide guidance and support in ensuring our continued commitment to complying with (and beyond) the AODA. We also continued the work in bringing together the Accessibility Advisory Committee through meetings during the 2021-2022 school year to discuss ways of ensuring our actions remained aligned with fostering well-being and mental health, championing equity and inclusivity, building collaborative relationships, and empowering ethical leadership.

Notwithstanding the departure of the full-time Human Rights Commissioner at the end of March 2022, the HRCO staff delivered important professional learning through ongoing department-specific accessibility workshop sessions as well as revisions and updates to accessibility compliance training. Despite the ongoing pandemic during the 2021-2022 reporting year, we leaned into challenges with courage as we remained committed to the vital work of embedding accessibility into all aspects of our decision-making as a system.

Sincerely,

Anthony Anirud
Interim Human Rights Commissioner (Consultant)

Legislated Purpose

York Region District School Board (YRDSB or the Board) has prepared this Annual Accessibility Report in accordance with the Integrated Accessibility Standards, Ontario Regulation 191/11 under the Accessibility for Ontarians with Disabilities Act (AODA), 2005.

The Board is defined as a “designated public sector organization” in the AODA. All designated public organizations are required to:

• “prepare an annual status report on the progress of measures taken to implement the [multi-year accessibility plan], including steps taken to comply with this Regulation; and

• post the status report on their website, if any, and provide the report in an accessible format upon request. (O. Reg. 191/11, s. 4).

The Annual Accessibility Report describes the measures that YRDSB has taken in the past school year and the ensuing summer months (September 2020 to August 2021) to identify, remove, and prevent barriers to accessibility for everyone who learns, works and participates in the Board community. The annual status report continues to be prepared as a separate document from the Multi-Year Accessibility Plan 2020 to 2025.

The Annual Accessibility Report is presented to Executive Council and subsequently to the Learning, Equity and Well-Being Standing Committee each fall. For the 2021-2022 reporting period, the Annual Accessibility Report is presented jointly with the HRCO Annual Report. Following approval, this annual report is now posted on the Board’s Accessibility Reports and Plans webpage.

Commitment to Accessibility

The Board’s commitment to accessibility is led by the Human Rights Commissioner’s Office (HRCO). Specifically, the Accessibility Officer within the HRCO is responsible for managing the accessibility portfolio for YRDSB. Accessibility is further guided through the shared responsibilities and collaborative commitments of the Accessibility Advisory Committee.

The Board's commitment to accessibility is aligned with the four priorities of the Board of Trustees’ Multi-Year Strategic Plan (MYSP). Four Multi-Year Accessibility Plan (MYAP) goals have been developed in alignment with the MYSP priorities as well as the Director’s Action Plan goals.

Multi-Year Accessibility Plan (MYAP) Goals

Provide Accessible Customer Service

Provide customer service excellence by promoting accessibility best practices that give meaningful access to all students and staff with and without disabilities.

Understand Accessibility as a Process

Provide accessibility learning, education and outreach to build awareness, knowledge and attitudes to identify, remove and prevent barriers to accessibility.

Engage the Accessibility Advisory Committee

Engage the Accessibility Advisory Committee that operates through shared responsibilities and inter-departmental collaboration, while also engaging people with disabilities.

Publish an Annual Accessibility Report

Complete and publish an Annual Accessibility Report to demonstrate accountability for the Board’s progress in implementing the Multi-Year Accessibility Plan.

1.1 Annual Accessibility Plans and Reports

Accessibility Advisory Committee Meetings

MYAP Goal Alignment: Engage the Accessibility Advisory Committee

• Four Accessibility Advisory Committee meetings were held during the 2021-2022 school year. All approved meeting minutes are available to the public on the Accessibility Advisory Committee web page.

• Professional development and learning was designed and delivered for committee members at each meeting, and included the following:

  • Presentation of YRDSB Feedback Report on the proposed K-12 Education standards
  • Hiawatha (wampum) belt shared learning; and the cost of accessibility renovations and retrofits Q&A
  • Rick Hansen Foundation panel discussion on “The Power of Inclusive Language”; and York Region Inclusive Language Guide shared review and discussion

  • Land Acknowledgment reflection activity; and collaborative review of the K-12 Education Standards - 2022 Final Recommendations Report

• An online feedback form was shared at the end of the school year to allow Accessibility Advisory Committee members to share feedback in order to improve future meetings.

Annual Accessibility Report

MYAP Goal Alignment: Publish an Annual Accessibility Report

• This report is the completed annual status report describing the measures that the YRDSB has taken in the 2021-2022 school year to identify, remove and prevent barriers to accessibility.

• The finalized report will be posted online to the public on the Board’s Accessibility Reports and Plans web page following review and approval by Executive Council and Learning, Equity and Well-Being Standing Committee.

Proposed K-12 Education Standards

MYAP Goal Alignment: Engage the Accessibility Advisory Committee

A YRDSB Feedback Report on the Proposed K-12 Education Standards was completed and submitted to the Education Standards Development Committee on September 22, 2021. The report was based on input from Accessibility Advisory Committee members as well as additional feedback from members of the Board community.

Based on all feedback received from across the province, the Proposed K-12 Education Standards - 2022 Final Recommendations Report was made available to the public on February 23, 2022. The Accessibility Advisory Committee later engaged in focused discussions about select final recommendations.

1.2 Accessibility Learning and Training

There was and continues to be a twofold approach to accessibility learning and training:

1. Accessibility compliance training - mandatory and standardized accessibility training modules as set out under AODA legislation that build accessibility (and human rights) awareness; and

2. Accessibility learning beyond compliance - optional but recommended professional learning sessions and pathways intended to foster accessibility capacity- and knowledge-building.

Accessibility Compliance Training

MYAP Goal Alignment: Understand Accessibility as a Process

There are three separate accessibility compliance training modules that all new employees must complete as a one-time training requirement. The table below outlines each accessibility compliance training module, its previous iteration, and the renewal timelines for updating each module.

*Accessibility and Human Rights 101: This compliance training module was significantly revised to integrate the existing “Introduction to Human Rights” module previously introduced as a one-time completion requirement as part of 2020 compliance training. This renewed compliance training module provides better context for how and why the accessibility portfolio at YRDSB is connected with the Human Rights Office.

**Accessibility, Disability and the AODA: The renewal of the existing “Accessibility Standards for Customer Service” module (originally introduced in 2005) was initiated during the 2021-2022 school year and will incorporate the AODA requirement to “ensure training is provided on the requirements of the accessibility standards and… on the Human Rights Code as it pertains to persons with disabilities” (O. Reg. 191/11, s. 7).

The total completions among active employees for each online module are presented below as of August 31, 2022:

• Accessibility and Human Rights 101: 17, 323
• Accessibility Standards for Customer Service: 16, 190
• Accessibility Awareness for Educators: 12,940

Accessibility Learning (Beyond Compliance)

MYAP Goal Alignment: Understand Accessibility as a Process

The focus of accessibility training at YRDSB has continued to shift towards professional learning beyond compliance through more customized and individualized sessions facilitated by the Accessibility Officer as well as other accessibility champions within different departments.

Accessibility professional learning delivered during the 2021-2022 school year included symposium workshops and department-specific learning sessions, as presented in the following table.

Enterprise Application Support (EAS) also offered virtual Accessible Document Training for YRDSB staff on the following 9 sessions throughout the 2021-2022 school year:

• October 21, 2021
• November 18, 2021
• December 9, 2021
• January 20, 2022
• February 17, 2022
• March 24, 2022
• April 13, 2022
• May 11, 2022
• June 16, 2022

“Customers” within a school board setting refer to all members of the YRDSB community, including: students, employees, trustees, parents/guardians, guests and visitors, permit holders, service providers, and volunteers.

This section outlines the programs and services offered during the 2021-2022 school year that supported more accessible learning or working environments for students, employees and other “customers” with and without disabilities, exceptionalities and/or special education needs.

2.1 Assistive Devices

Special Equipment Amount (SEA)

Accommodations for students with identified special education needs often include access to assistive technology through Special Equipment Amount (SEA) claims.
A Family’s Guide to SEA was updated during the 2021-2022 school year with more inclusive language, less jargon, and embedded QR codes to web-based alternatives.

The Ministry of Education approved over 1,000 SEA claims for the purchase of assistive technology for students with special needs during the 2021-2022 school year.

Additionally, Student Services replaced over 2,000 SEA laptops during the 2021-2022 school year. A group purchase of 700 BoardMaker licenses was purchased and distributed across the Board. SEA approvals included (but was not limited to): hearing assistive technology, vision assistive technology, and software that provides access to curriculum.

Hearing Assistive Technology

Deaf and Hard of Hearing Services for YRDSB has a wide variety of Hearing Assistive Technology that increase auditory access for students when there is personal hearing loss. Some of the devices provided during the 2021-2022 school year included:

• Digital Soundfield Towers - speakers that amplify the voice of educators/peers when wearing a wireless microphone. These can also pair with the digital receivers on the students’ hearing aids or cochlear implants. Everyone benefits from Soundfield as it assists when there is environmental noise.

• Digital transmitters and receivers - use of various microphones for sound amplification. Phonak receivers pair with the personal hearing aid or cochlear implant of the student and the digital transmitter microphone(s) used within the classroom by the educator or student peer(s) in order to amplify their voice.

Vision Assistive Technology

• MacBook accessibility pilot project - MacBooks were explored for students who require the benefits of iOS accessibility features for low vision. The MacBook accessibility pilot project concluded in the 2021-2022 school year, with 8 MacBook users and additional SEA claim orders for these devices.

• PC Windows laptops - Braille users continued to use PC Windows laptops. SEA claims doubled last spring once students returned to in-person learning and Functional Vision Assessments and Learning Media Assessments could be conducted in order to provide appropriate data to support the technology for visual/tactile access.

• Other Hearing Assistive Technology - magnifiers, braille embossers, Braillnote Touch Plus refreshable braille keyboards, large font keyboards, screen reader software, robotics, and more.

Classroom Devices

Student Chromebooks

All student loaner device requests were fulfilled from the local school inventory during the 2021-2022 school year. Schools were supported in making Chromebook purchases for their classrooms using school generated funds. Schools that did not have adequate school generated funds were assisted centrally to purchase devices. Information Technology Services (ITS) facilitated the process by procuring devices and coordinating timely shipments to schools.

A total of 159 school participated with 54 schools obtaining central funding assistance. A total of 8,396 Chromebooks were purchased through this initiative.

During the 2021-2022 school year, the Ontario Secondary School Literacy Test (OSSLT) and Education Quality and Accountability Office (EQAO) Ministry testing were completed online for the first time. Schools were supported centrally with ITS loaning out 2,000 Chromebook devices on an as needed basis throughout the school year.

Headsets and web cameras for educators

At the beginning of 2021-2022 school year, all permanent Teachers, Educational Assistants and Designated Early Childcare Educators were provided with a wireless Bluetooth headset and external web camera to support the hybrid learning model. Long-Term Occasional and Occasional Teachers were also provided a headset and web camera for loan through the school main office.

Additional technology support for teachers

Centrally, teachers were also supported with additional peripheral equipment as identified by Curriculum and Instructional Services. The equipment was procured based on a Hybrid Peripheral School Technology Survey completed by administrators. A total of 189 schools received additional technology, which included the following:

• External speakers (wired and wireless)
• Wireless keyboards/mice
• USB hubs (4 ports)
• Graphic drawing tablets with stylus (secondary math and science program)
• Display monitors
• Document cameras
• Wi-Fi hotspots (outdoor learning)
• HDMI and VGA to HDMI cables

Internet hotspots

Requests for internet hotspots continued to be supported centrally through ITS. Internet hotspot packages were provided to students/families in need as identified/vetted by school administrators throughout the school year. ITS transitioned from cell phones used as an internet hotspot to stand-alone hotspot devices.

For information on assistive devices provided to YRDSB employees with disabilities, refer to Assistive Devices as Workplace Accommodations under Section 5.1 Accessible Employment.

2.2 Student Services and Supports

Blind and Low Vision (BLV) Services

• Provincial school partnerships - Provincial school consultants continued to provide in-school assessments for students who meet the criteria for Deafblindness. During the 2021-2022 school year, a percentage of students opted to enroll at W Ross MacDonald School for the Blind as a result of the COVID-19 pandemic and issues with accessing remote learning in a meaningful way.

• Accommodating medically fragile students - a small number of students continue to learn remotely due to medical fragility. They are supported both virtually and in-person at their residence by Deafblind Interveners and Teachers of Students with Visual Impairments.

Deaf and Hard of Hearing (DHH) Services

• New DHH program - a new DHH program was launched in September 2021 to support communication and access needs for new grade 9 DHH students. Learners who are profoundly deaf engaged in mostly credit-bearing courses and interval assessments with consultants from a partnership school for the Deaf.

• ASL Interpreters - within the specialized DHH program, three ASL Interpreters and one Assistant for Sign Language Support meet the demands of different timetables for DHH students, in order to ensure meaningful access to curriculum that is comparable to their hearing peers.

• Provincial school partnership - A provincial school consultant from EC Drury School for the Deaf provided direct instruction in the development of ASL skills with profoundly deaf learners through weekly virtual sessions.

3.1 Accessible Web Content

YRDSB Website

The Board continued to monitor and approve web content to ensure AODA compliance. Content Contributors continued to receive support and training in order to publish more accessible web content/copy.

Accessibility Resource Hub

The YRDSB Accessibility Resource Hub is an open-access and centralized web space that continued to be updated with best practice resources and guidelines to educate and support the system in making learning and working environments more accessible.

In particular, the previous Remote Learning and Training Guidelines were refreshed and retitled as the Accessible Video Conferencing Guidelines. This update expanded the guidelines to provide accessibility best practices and considerations for virtual conferences and events in addition to accessible remote learning and training.

3.2 Accessible Formats and Communication Supports

Accessible Board Videos

All Board-approved prerecorded videos produced by Corporate Communications and/or Learning Design and Development continued to include open captions in meeting WCAG 2.1 Level AA requirements.

The HRCO was approved to purchase a series of licenses for automatic transcription software, Otter.ai. The transcription software continued to support a more efficient process for captioning Board videos as a regular practice.

A total of 3,165 minutes of audio and video data were transcribed through Otter.ai during the 2021-2022 school year.

Accessible Document Remediation

The Accessibility Officer as well as other accessibility champions within YRDSB remediated countless documents throughout the 2021-2022 school year, including (but not limited to):

• Board memorandums,
• Board Policy and Procedure documents,
• Parent, Family and Community Engagement Advisory Committee (PEAC) newsletters,
• Research and Assessment Services reports,
• Mental Health flyers, and
• Other Board communications.

4.1 Scheduled Accessibility Projects

MYAP Goal Alignment: Provide Accessible Customer Service

Plant Services completes accessibility projects to update, modify and retrofit existing buildings as part of its multi-year plan. A complete list of accessibility projects started and/or completed on YRDSB facilities during the 2021-2022 school year is presented in the table below.

Total cost of accessibility projects in 2021-2022 school year: $1,842,214

All Access Washroom Project

MYAP Goal Alignment: Provide Accessible Customer Service

During the 2021-2022 school year, Plant Services continued with the full-scale implementation phase of the Board's All Access Washrooms Project. All access washrooms have now been installed across all Category 1 to 3 schools, which have one all access (or all gender) washroom per floor. The way all access washrooms are accessed (unlocked or by card reader) is at the discretion of each school administrator and how they identify issues/needs specific to their school community.

Plant Services began working on Category 4 schools that require significant renovations and costs in order create an all access washroom. Schools included as part of the 2021-2022 accessibility project budget include Charles Howitt Public School and Wellington Public School.

Braille Signage Project

MYAP Goal Alignment: Provide Accessible Customer Service

Blind / Low Vision (BLV) Services continued to identify and update a priority list of YRDSB schools with students who require Braille signage to access their school environment in a meaningful way. The priority schools requiring and installed with Braille signage are listed below:

Priority schools

1. Beckett Farms Public School
2. Doncrest Public School
3. Hodan Nalayeh Secondary School
4. Newmarket High School

Completed schools in 2021-2022

• H.G. Bernard Public School
• Maple High School
• Wilshire Public School

5.1 Accessible Employment

Disability Management

MYAP Goal Alignment: Provide Accessible Customer Service

The Disability Management (DM) team within Human Resources Services supported 3,952 employees on DM during the 2021-2022 school year.

• DM files carried over from the 2020-2021 school year: 1,731
• New DM files opened in 2021-2022: 2,221
• DM files closed in 2021-2022: 1,980

Assistive Devices as Workplace Accommodations

Assistive devices that were provided by HRS for workplace accommodations are listed below:

• Air cleaners and humidifiers for scent sensitivities / allergies,
• American Sign Language (ASL) interpreters,
• Arranging worksite ergonomic assessments,
• Communication Access Realtime Translation (CART) and/or computerized notetaker services,
• Custom noise cancelling ear plugs,
• Document cameras,
• Mobility devices (scooters, wheelchairs, wheeled carts, stools),
• Modified work stations (special chairs, desks, keyboards, monitors and lighting),
• Specialized phones and headsets,
• Speech to text software,
• Voice amplification and hearing systems (FM transmitters, receivers, microphones, and sound barrier devices)
• Zoomtext Plus technology.

Candidate Support

MYAP Goal Alignment: Provide Accessible Customer Service

• Human Resource Services (HRS) will be transitioning from Zoom to Microsoft Teams as the primary video conferencing platform for virtual interviews. The Recruitment and Promotion team continued to include the Accessible Video Conferencing Guidelines in the Administrator Toolkit for use with school-based interviews.

• Human Resource Services continued to review all job postings to ensure only bona fide occupational requirements and educational credentials are included to reduce barriers to entry, consistent with Recommendations 14 and 15 of the Employment Equity Plan.

The accessibility portfolio for York Region District School Board (YRDSB or the Board) is a mandate of the Human Rights Commissioner’s Office (HRCO), which provides leadership over the Board’s AODA Advisory Committee. Accessibility at YRDSB is guided through the shared responsibilities and collaborative commitments of the AODA Advisory Committee. The HRCO has worked with AODA Advisory Committee members to review the Proposed Kindergarten to Grade 12 (K-12) Education Standards - 2021 Initial Recommendations Report, and to request additional feedback from members of the Board community at large.

Synthesizing the Report for Internal Use

The proposed K-12 Education standards and recommendations were initially reviewed and synthesized by the Accessibility Officer into Shared Google Docs based on the seven barrier areas. The K-12 Education Standards Development Committee (SDC) executive summary report was also integrated into the shared Google Docs. The synthesized Google Docs were created to chunk the contents of the initial recommendations in order to provide an easier way for AODA Advisory Committee members and other Board staff members to review and comment directly on specific recommendations related to their respective areas of work.

Meetings were held with various subcommittees and working groups under the AODA Advisory Committee in order to collaboratively review specific barriers recommendations. For example, the Accessibility Officer met with the Barrier Buster and Built Environment Subcommittee on several occasions to review the barrier seven recommendations on physical and architectural barriers.

Communication to the System

Following a meeting with members of YRDSB’s senior leadership team, a series of system memos were shared internally via the Board’s “News Digest” email. The memos included four different options for reviewing the recommendations:

1. Summary of the recommendations posted on the YRDSB accessibility web page under Accessibility Reports and Plans;
2. Full initial recommendations report available online to the public;
3. Executive summary report from the K-12 Education Standards Development Committee; or
4. Video summary by David Lepofsky, Chair of the AODA Alliance.

The proposed the K-12 Education standards were also shared through social media postings on the Board’s Instagram and Twitter pages. All staff and community members who reviewed the recommendations were asked to complete the YRDSB Review and Feedback Form by Friday, September 17, 2021. The completed Google Forms (19 in total), in addition to the AODA Advisory subcommittee and working group meetings, were used to draft this feedback report. The majority of the feedback forms were completed by YRDSB teachers, with the remaining forms completed by a combination of administrators, school-based support staff, non-school based staff, consultants and parent/guardians or community members.

All feedback received on the proposed K-12 Education standards was reviewed by the Accessibility Officer and grouped into themes. General feedback themes are presented first, followed by the main themes that emerged for each barrier area, which comprise the remaining sections of this feedback report.

General Feedback

Ease of Reading and Understanding

The majority of survey respondents, as educated school board employees, agreed that “overall, the report was easy to read and understand.” From a more critical accessibility lens however, we need to recognize that some YRDSB community members can better understand more plain language writing, particularly for English language learners or individuals with learning disabilities.

A primary example of the need for simplified language is the report’s 12 guiding principals. Despite drawing out the key idea in each guiding principle, there was notable overlap between the guiding principles in terms of some phrases and “key words” (e.g., dignity, equality, equity, inclusion, human rights, etc.). As a result, the 12 guiding principles were synthesized before being shared internally.

As we continue to adopt more inclusive language in education, it has become clear that words matter. There should be a conscious consideration for the words, language and sentence structure of the final report, as well as throughout the process of passing the proposed K-12 Education standards into law under the AODA. Traditional legislative language is a barrier to accessibility. Plain language alternative formats should accompany any current and new accessibility standards.

Consistency of Recommendations

The methodology section outlined how all initial recommendations were discussed and reviewed by the full committee through a collaborative and engaged process. However, it was clear that the different barrier areas of the recommendations report were drafted by different individuals/small groups from the SDC. In addition to different writing styles, the recommendations were not formatted consistently across the different sections or barriers areas of the report.

Some recommendations included up to 20 sub-recommendations presented as numbered lists (e.g., 49.1 - 49.20 parent and student participation recommendations), lettered lists (e.g., 92a - 92m elevator recommendations), or separate recommendations (e.g., recommendations 43 - 48 all relate to IEPs, but are short and separate recommendations instead of sub-recommendations). The recommendations and respective sub-recommendations should be formatted and presented with consistency in the final report.

All YRDSB survey respondents agreed with the barrier one recommendations, with one respondent adding the following comment:

• “It is my experience that Special Education & ELL supports are the first to be reduced when schools attempt to balance their budgets at the grassroots level. This sends a message.”

Overlapping Barrier Areas

It is not clear why the barrier one and two recommendations were presented as separate barriers areas in the initial recommendations report. Two of the five barrier one recommendations relate to accessibility training (or “in-servicing”), which is also the focus of the three awareness and training recommendations. Awareness and training are often the first steps to addressing and changing attitudes, behaviours, perceptions and assumptions about people with disabilities.

Undervalued Impact of Ableism and Attitudes

Attitudinal barriers are the most pervasive barriers to accessibility, with ableism still very prevalent throughout education. The initial recommendations reports does address ableism in the guiding principles statement and recognizes that “attitudes, behaviours, perceptions and assumptions underpin the work of all other small groups”. However, only five of the 184 total recommendations are focused on addressing attitudes, behaviours, perceptions and assumptions. The undervalued impact of ableism and attitudes in this report is particularly clear when compared to the 50 physical and architectural barriers recommendations (with hundreds of sub-recommendations).

Out of the five barriers one recommendations, the training recommendations should be expanded to include, where possible, experiential learning and working with students with disabilities. Case in point recommendation 3 on training for teacher candidates:

• “Pre-service teacher education needs to have much more theoretical and practical experience working with students with disabilities. [Co-op] teaching opportunities should expand to special education placements, including self-contained programs. Secondary teaching qualifications needs to expand to include those with experience working with students with complex and special education needs.”

A major attitudinal and systemic barrier in education continues to be the socially acceptable discomfort level when it comes to teaching or engaging with students from community classrooms. Teaching in a community classroom should not be accepted as a “stepping stone” or “checkbox” to teaching in mainstream or advancement with the Board. Teachers and support staff should not be considered “brave” or “patient” for wanting to work in community classrooms; in fact, it is quite frankly ableist for any teacher who does not want to teacher in a community classroom. This systemic ableism needs to be more purposefully challenged in the barrier one recommendations.

A much larger focus on the attitudes, behaviours, perceptions and assumptions recommendations is the need to establish a proper foundation for affecting a meaningful and lasting cultural shift in education towards accessibility and acceptance of differences as part of life.

Limitations of Universal Design for Learning

Recognizing the value of Universal Design for Learning (UDL), a few survey respondents were quick to note some of its limitations. UDL is a good and essential starting point for building a culture of accessibility, but we must also ensure the diversity of disabilities are recognized and supported.

• “It is critical that UDL encompass the invisible disabilities in addition to the visible (often physical).” These are often harder to measure, and more difficult for people to understand because they are unable to 'see' the result of the UDL measure or accommodation. Often one can appear to be doing fine but the underlying effort and stress of managing in an environment goes undetected in a classroom setting.”

• “… sometimes the concept of UDL can be used to exclude those on the far margin or disability. Those with severe disabilities are often not served. Also, recognize that it is nearly impossible to know what the needs are until you have lived with or cared for someone with a disability. Assumption of need(s) is a danger here. We must gather input from multiple stakeholders to ensure the full picture is being gathered and even the rarer needs are being considered. Don't act on the "stereotype" version of disability.”

Recommendation 6 to standardize UDL training should be elaborated to include more specific recommendations on the extent to which the concept of UDL should be covered in the UDL training. For example, is the recommendation to address the UDL contents from the Ministry’s 2013 Learning for All resource guide (Learning for All - A Guide to Effective Assessment and Instruction for All Students, Kindergarten to Grade 12)? Or is it to go more in depth into the concept of UDL? What are the recommended resources and research to support this recommendation?

Anti-Oppressive Curriculum Reforms

The curriculum, assessment and instruction recommendations essentially calls for substantial reforms to Ontario curriculum in recommendation 9. These significant reviews and renewals of curriculum should seek community participation, as expressed by a member of the AODA Advisory Committee’s Curriculum Working Group:

• “This review must include community, particularly communities who have been marginalized so that they are centred in the review; continue to work with community when making changes, and when monitoring for impact. This would be an anti-racist, anti-oppressive approach.”

One survey respondent shared their thoughts on how to reform curriculum and assessment practices:

• "Curriculum needs an overhaul to make these changes work in a meaningful way. Curriculum must come away from grade-specific, and be outlined as a continuum. Curriculum should be more skill-based than content-based (i.e., science - skills of inquiry, hypothesis, testing/experiment; in history - skills/ concepts of chronology, critical analysis, perspective-taking) as opposed to specific units to be done in each grade."

• "Assessment needs an overhaul as well. Remove grades/leveling for up to grade 6; reporting should be clear and easy for students and families to understand; what has the student learned? What can they do? What can they work on next?"

Physical Health and Wellness, Mental Health and Well-Being

The Board’s mental health leads were consulted directly on recommendation 25, and shared feedback and questions regarding three main themes: terminology, related research and resources, and evaluation concerns.

Clarify Terminology

“Wellness” and “well-being” are terms that are often used interchangeably. Are these recommendations associating physical health specifically with wellness? And mental health specifically with well-being? If so, recommendation 25 that “the ministry develop a Health and Well-being strategy and action plan…” suggests it is a mental health action plan, yet the recommendation mentions physical health as well as sexual health? Sub-recommendation 25.1 also references “inclusive design” without context:

• “Elsewhere in the document, Universal Design is referenced, [but] here, inclusive design is referenced. Both hold value and promise. However, I do not believe Inclusive design has been defined here.”

Clarification with respect to the terminology used throughout recommendation 25 is needed.

Align Research and Resources

What role, if any, does the Ontario Health and Physical Education Curriculum play in this proposed Health and Well-being strategy and action plan? Additionally, it was noted that the concept of social-emotional learning (SEL) is currently under review by School Mental Health Ontario (SMHO) alongside the Equity Secretariat with a view towards equity and an anti-oppressive practice approach.” The K-12 Education standards need to be aligned with existing and new research and resources as they relate to mental health and well-being.

Evaluating / Measuring Recommendation 25

Concerns were raised about how the Ministry will evaluate and measure the implementation of recommendation 25 and its many sub-recommendations that include (but are not limited to):

• coordinated resources,
• guidelines,
• materials,
• programming, 
• beyond the school environment,
• sexual health education,
• incorporating training for educators, and
• awareness and lived experience of disabilities are part of the overall learning opportunities.

“How are guidelines different from materials versus resources in this context?” It was also noted that educators cannot be equipped to measure or “assess the resiliency needs of all students” (recommendation 25.6):

• “Teachers are not able to ‘assess’ resiliency. Resilience is a factor both informed by the individual and system elements”

A recommendation such as this cannot be appropriately implemented and supported with so many moving parts in one recommendation. Concerns with proper implementation and evaluation also applies to the other lengthy recommendations in this report (i.e., that include 6 to 20 sub-recommendations). The proposed timelines also need to better reflect and respond to competing priorities and the amount of dedicated time and system learning necessary.

Indigenous Education

In consulting a number of the Board’s Indigenous consultants and lead staff, it was questioned whether recommendation 26 was made in consultation with Indigenous communities. It was specifically noted that:

• “[sub-recommendation 26.1] is infringing on the two row wampum teachings (treaty agreements) and Indigenous sovereignty... which will create issues at the board level for learning on the land. One does not supersede the other.”

The sub-recommendation should be revised to express that the ministry will work in collaboration with Indigenous communities/partners to support “curriculum design and content including Indigenous curriculum is accessible and available for students with disabilities.” The following sub-recommendation 26.2 raised implementation concerns regarding Indigenous pedagogy, ways of knowing and experiences.

• “Is this an expectation for classroom teachers? How will teachers be provided with cultural competency training needed to understand what Indigenous pedagogies are? How will cultural appropriation be avoided?”

Accessible Procurement Limitations

YRDSB adopted a statement of accessible procurement that is now included in all Purchasing Services contracts and Requests for Proposals. However, ensuring “that all technology purchased by a school board ensures full digital accessibility” (recommendation 35.1) is not always possible. Many of the major digital tools/resources procured by YRDSB (and most school boards) are US-based vendors, such as Google and Microsoft. Increasingly more and improved accessibility features have become available in Google Workspace for Education (formerly Google Apps or GAPPS) and Microsoft Office 365 over the past 18 months. However, software updates are beyond the control of school boards, and can often present new learning curves for staff to refamiliarize themselves with new interfaces.

Long-Term Funding Commitments

Consistent with recommendation 36 regarding long-term funding for assistive technologies and related hardware, one survey respondent believed that:

“All school boards should ensure full, open access to web applications for education (e.g., Google Apps for Education, TextHelp Read & Write) to provide universal access to assistive technology (e.g. text-to-speech, speech-to-text, screen reading, masking and organization) for all students, staff and employees. This will reduce barriers for students or employees with non-identified barriers. Setting minimum standards for access would ensure equal access to all stakeholders in Ontario.

Virtual Meeting Platform Flexibility

Recommendations 39.1 reads that “only accessible virtual platforms shall be used by a school board…” This fails to recognize other factors that are considered in procuring and supporting certain web conferencing platforms, including: privacy and confidentiality, the need to restrict access at times, internal capacity and know-how, as well as cost. The recommendation should have allowances for web conferencing platforms that are not “fully accessible” if the virtual environment is still accessible. For example, GoToWebinar is one of the only web conferencing platforms with a built-in feature that requires all attendees to pre-register (i.e., pre-event registration). However, GoToWebinar does not have an integrated automatic captions or transcripts feature, but can be made available through different ways (e.g., CART or Google Live Captions).

Recommendation 39 should instead support accessible online or virtual learning environments as a whole, rather than narrowly recommending that “only the most accessible virtual meeting platforms should be used...” The individual hosting the virtual meeting needs to know how to foster an accessible virtual learning and/or working environment for all participants.

Digital Accessibility Capacity Building

Consistent with the previous feedback theme, the barrier four recommendations on digital learning and technology should, in general, consider strategies that build staff capacity to better support and implement the proposed the Digital and Technology Action Plan. Learning and training sessions need to be made available and mandatory for all staff to develop the core competencies needed to host an accessible online learning or working environment.

Format of Recommendations

As mentioned in the “consistency of recommendations” general feedback, recommendations 43 to 48 all relate to IEPs and are presented as separate recommendations. This format is easier to follow compared to the recommendations with up to 20 sub-recommendations. Using recommendations 43 to 48 as the example, all recommendations should be concise where possible, and split into separate recommendations if more than five sub-recommendations are included.

IEP-specific Feedback

A number of Student Services staff reviewed the barrier five recommendations and provided feedback related to the Individual Education Plan (IEP) process:

Simplify IEPs

• “IEPs should be simplified/shortened. Ensure they are true working documents, focused on a few key learning objectives at a time and updated regularly.

Standardize IEPs

One survey respondent provided feedback that expands on recommendations 44 to revise the format and content of IEPs:

• “The IEP format should be designed centrally within the Ministry of Ed. to present the same information in a way that is easily shared between school boards. This should be reviewed regularly, to ensure they can capture all necessary and relevant details. Consider providing access to all IEPs through a coordinated platform that allows for common access to staff between boards as well as parents from home. Using a common platform would allow programming goals, transition plans and SEA equipment to be tracked, monitored and shared between boards more easily. The OCT should establish standards that allow for alternative training to serve as teaching qualifications (working with students with complex needs), rather than traditional subject areas to ensure that the most qualified teachers are teaching the high-needs populations.”

Another survey respondent suggested a standardized model for IEPs:

• “Even though IEP is very personalized, due to its complication, it is still preferred to have a universal model with SMART goal examples. It can be designed on school board level, Ministry of Education level, or a federal based body level. Parents need shared information in a central place to access IEP knowledge. Besides being classified as different disorders, the model can also find the common ground. For example, many students have behavioral, executive functioning, social and self-advocacy concerns. The model can break down each executive functional skills and give guidance.”

IEP Accountability

• “All staff teaching/supporting a student with an IEP must sign the IEP, acknowledging that they are legally obliged to implement it. This legal obligation needs to be enforced; it is currently not and more often than not, IEPs are written that do not reflect what is actually happening in the classroom. Families must be able to rely on the IEP; they need to feel confident that it is being implemented.”

IEP Access for All

One Board community member shared their child’s IEP journey, highlighting the importance of recommendation 46 to make IEPs more accessible to all students:

• “I would like to share my child's IEP journey. One of my children was referred to a specialist by the school when he was in JK. Even though nothing was diagnosed, he got an IEP for behavioural/social concerns. In grade 1, the school recommended that we withdrew from the IEP since his hitting issues were gone. In grade 4, another school referred my son to a specialist, and ADHD was diagnosed. With my constant request, my child got his IEP in grade 7. In between, I learned bunch of educational courses regarding special needs. And then I found out that my child may be twice exceptional. I shared my thoughts that my child may be twice exceptional two years ago. However, my child's case was considered lower priority for school psychological assessment. I had to arrange a private assessment and confirmed 4 exceptionalities when my child is 12. We are heading another journey to update the IEP. My child is lucky and unlucky at the same time. His exceptional identification was missed by parents, educational professionals, or health specialists for many years. I recommend that the school board provide universal guidance for interventions/strategies for all the students, even if they don't have a chance to get a formal diagnosis, or missed their identifications. Not every student will go through the formal IPRC/IEP process. For most students, it is very obvious to be seen who may need further interventions with SMART goals. Don’t wait for a formal diagnosis. Make those strategies available for every student. Share the best practices and resources in a central place for teachers, school staff, students and parents.”

Social Isolation

Recommendation 67 that proposes staff assistance for social interaction and play should be moved to the IEP-related recommendations given that its implementation would carried out through a student’s IEP. One survey respondent was echoed the importance of creating school support teams to promote social inclusion:

• “For social isolation, I recommend a school support team actively monitoring social interactions. A student’s social life will change his view in his classwork, school and life. It is one of the most important aspects at school. Recess time is a great time to detect social concerns as well.”

Inter-Ministry Collaboration

One survey respondent shared feedback and questions specifically in response to recommendation 41:

• “Effective intersectoral collaboration is a huge barrier (Ministry of Health, Social Services). How will the Ontario Health Teams be leveraged to support his recommendation? We are seeing now Ontario Health Teams collaborate across siloed care in health and leaning into the need to effectively collaborate with social service agencies at the local level. How might the ministry of education and boards be involved in this work?”

Accessible Field Trips and Transportation

Similar to the feedback regarding "virtual meeting platform flexibility", there should be flexibility with the educational and online events recommendation 57. The recommendation should ensure an accessible overall experience for students and staff with disabilities during field trips, rather than to “only hold educational events at venues whose built environment is accessible to students and staff with disabilities”.

A narrow recommendation to only hold educational events at accessible venues shifts the responsibility for accessibility almost entirely on the venue. The teacher(s), staff or school board department organizing the event would only have to ask if the venue is accessible or not. However, accessibility is a shared responsibility. The person or group organizing the educational event should know to ask about different accessibility features (refer to AODA.ca Accessible School Field Trips article) at the venue, including:

• Ramps, lifts or elevators whenever there are stairs,
• Automatic doors and wide doorways into buildings and common areas,
• Accessible public washrooms,
• Accessible seating areas (in auditoriums, arenas or picnic areas),
• Accessible pools and change rooms; and
• Whether support persons or staff are required to pay entrance fees.

The event organizer(s) should have a basic understanding of how to make the event experience accessible for all, which includes proactively supporting accommodations including transportation considerations. One survey participant shared their thoughts on how legislating accessible transportation on field trips without any understanding may in fact perpetuate ableism:

• “While I agree with the need to facilitate inclusiveness in the social realm like field trips, the fact is that [accessible] busing and transportation will likely mean students needing that transportation travel separately... Also, specialized services cost more. Will there be a plan to subsidize specialized transport? Otherwise, I foresee an issue with ableist and reactionary thinking if this leads to fewer or cancelled or more expensive trips and events… "because we need a wheelchair bus" or whatever the issue. Careful attention needs to be paid to ensure we do not inadvertently worsen relationships and perpetuate negative thinking towards those with disabilities.”

Recommendation 57 should be expanded to include some of the elements of recommendation 65, including establishing a process to affirmatively reach out to potential venues (adapted from 65.2), ensuring the venue is informed of their duty to accommodate (adapted from 65.3), sharing supports and advice for venues who need assistance (adapted from 65.4), and surveying students with disabilities at the end of any educational event or field trip (adapted from 65.6).

Transitions Facilitator/Navigator

One survey respondent supported the proposed transition facilitator/navigator in recommendation 58:

• “For the transitional plan, I recommend making the transitional support available and automatically for every student, especially for students with autism. A model with different levels of support can be designed. Current teachers may assess the transitional support needs and record the suggestions for the next teacher/school. The communication channel needs to be opened to parents and students before the end of the school/transition time to determine who needs transitional support for the next transition.”

Bullying/Cyberbullying Workshops

One survey respondent supported recommendation 64, while urging earlier interventions for anti-bullying workshops and learning:

• “Early work on respect, bullying and consent are needed to proactively mitigate exclusion and combat self-esteem and mental wellness deterioration at the elementary level, where identities and feelings of self-worth are largely shaped. It is my experience that peer responses to individuals with disabilities have the greatest impact on their development and performance.”

Access to Co-op Education and Employment Opportunities

Related to recommendation 65 on experiential/co-op learning opportunities, one survey participant suggested school boards explore internal placement opportunities within schools as well as in Board administrative positions:

• “School boards should work with unions to expand and standardize access to in-school placement opportunities (with custodians, office staff and food service providers). School boards should be compelled to use their administrative sites to support co-op placements; it's an opportunity to demonstrate the success of co-op partnerships with neurodiverse students. Opportunities should be available at all post-secondary institutions for students who don't graduate with an OSSD. Community Integration through Co-operative Education (CICE) and vocational-type programs should be available at all institutions to provide social, employment and academic opportunities. Post-secondary institutions are like small, self-contained towns. Within each, are opportunities to work in almost every employment sector, as well as opportunities to socialize and build community. Students who graduate with fewer than 30-credits should be eligible to access a CICE or vocational-type program at any institution.”

The Built Environment and Barrier Buster subcommittee under the AODA Advisory Committee, in addition to members of the Board’s Plant Services, were directly consulted on the proposed recommendations specific to the physical and architectural barriers. Additional feedback was provided through the internal review and feedback form.

Ministry Funding

The vast majority of the recommendations intended to remove physical and architectural barriers in school boards is dependent on substantially increased capital funding from the Ministry of Education, as alluded to in recommendation 77. In fact, recommendation 77 to revise the funding formula for school construction should be the first and foremost recommendation to remove physical and architectural barriers.

The School Condition Improvement (SCI) allocation would need to be increased in particular given that the “Beyond Building Code accessibility requirements” (recommendations 81 to 119) are being proposed for existing schools and other educational facilities in addition to new school builds. It is well documented that retrofit requirements for existing buildings are substantially more costly than incorporating accessibility into new construction.

Members of Plant and Planning Services were quick to point out how quiet rooms and sensory rooms, referred to as “unloaded rooms” (that do not count towards the student capacity of the school), are often the first to go when asked by the Ministry “how can you reduce capital costs?” upon reviewing new school plans. It is important to note that capital funding constraints not only perpetuate physical barriers, but are also a function of systemic barriers related to the absence of meaningful accessibility considerations in the Ministry of Education funding formula.

Competing Priorities

It was also noted by members of Plant and Planning Services that many of the technical accessibility requirements are very prescriptive and appear to have been included without consideration for competing operational, safety and/or financial priorities. Specific examples of overly prescriptive and competing priorities are provided below:

• Recommendation 81 to install heated paths of travel to the entrances of schools. Heated floors or pathways are considered a luxury item in private homes let alone for public schools. The operational implications for removing existing pathways, installing heated paths and repaving pathways across 222 YRDSB schools would be considerable. The increased financial implications become even more evident in doing a cost analysis between the installation, maintenance and hydro costs associated with heated paths compared to the cost of salt and human resources required to shovel and/or snowplow paths of travel during winter months.

• Recommendation 95h that requires at least two accessible stalls in each washroom to avoid long wait times. YRDSB is currently implementing its all-access washroom initiative whereby 36 schools were identified as requiring major renovations in order to accommodate an all-access washroom. A requirement to add two accessible stalls in every washroom would essentially require major renovations to now every YRDSB school, including moving walls, plumbing, doorways, etc. The financial implications of this beyond Code recommendation would, again, be considerable.

• Recommendation 102e regarding weighted blankets is too prescriptive and can present safety issues. Weighted blankets are only one example of a sensory accommodation for some people with disabilities, such as Autism Spectrum Disorder (ASD). Additionally, a suitable weighted blankets has to be approved through a Board Occupational Therapist to meet specific requirements (usually 10% of the person’s body weight). Sensory elements or objects should be recommended in general, rather than just the specific weighted blankets recommendation.

• Recommendation 104b regarding outdoor spaces. This sub-recommendation does not take into consideration that parcels of land for new YRDSB school builds are often inherited by the York Region municipality or township. The inherited lots have often been rejected by private builders due to large slopes, flood plains or other limitations with the land. School properties with large slopes between the school and school yard or playground are extremely difficult to make fully accessible (as noted in some existing YRDSB schools). Naturalization efforts for outdoor spaces is another competing interest that needs to be considered if major leveling or infrastructure is needed to make outdoor spaces fully accessible to everyone.

Accessibility Design Experts and Consultants

Feedback from the Plant and Planning Service also raised the following questions related to accessibility design experts and consultants referenced in recommendations 71, 72 and 79:

• Who would be considered to “have sufficient demonstrated expertise in accessibility design” as per recommendation 71?

• Similarly, who would be considered a “properly qualified and experienced accessibility consultant” as per recommendation 72?

• What are the industry and/or ministry standards for being considered an accessibility design experts or consultant?

• Given that the Rick Hansen Foundation Accessibility Certification (RHFAC) was highlighted as “substantially inadequate and has significant problems”, what are the alternative accessibility design standards or qualifications?

• Is there any sort of existing database of accessibility design experts and accessibility consultants available?

For consistency with implementation of the recommendations, it was suggested that a list or database of accessibility design experts and accessibility consultants be made available to school boards.

Additionally, assuming criteria for accessibility design experts are established, they should further have “sufficient demonstrated expertise in accessibility design” specific to school built environments. The Built Environment and Barrier Buster subcommittee are considered subject matter experts of school built environments, and noted how a number of recommendations appeared to be based on accessibility design in public settings (e.g., recessed fountains, floor mountain urinals, no labyrinth entrances into washrooms, tactile attention indicators, etc.). As outlined in the Education Act, a school is a highly regulated space and is not generally accessible to the public. There are unique considerations and competing proprieties that differ between school built environments and public spaces, such as shopping malls or restaurants.

Assistance Listening

A staff member of the Board’s Deaf and Hearing department shared comprehensive feedback related to various references to assistive listening in the specific room requirements recommendations 101 through 112:

• “There was a great deal of reference to assistive listening, such as hearing loops. There are a variety of SEA tools used by students in the Board already. I have not encountered a hearing loop in any school thus far. Having assistive listening does not preclude that fact that some people with hearing loss will not hear a public address or speaking regardless of the technology or reduced background noise. Visual reinforcement is often necessary (e.g., school announcements that are visible on a screen as well as over PA system). Assistive listening is referenced often but never defined [in the recommendations]. Hearing loops are one very finite example. Not all of those with hearing loss use hearing loops. Many use other strategies or technologies… Also many of the built environment recommendations address physical needs. Only in some cases was the acoustic environment of a space even mentioned. There are strategies that can be implemented at the building stage that can improve the acoustics and sound to noise ratio of a room. This should be considered at the building stage. Improved acoustics in rooms benefits all kinds of learners. There was also no mention of accessibility of portables. The acoustics of portables, regardless of mitigation factors, are abysmal. Some of the equipment students use through SEA is not as effective in portables due to reverberation and background noise from ventilation systems and thin walls.”

It has often being stated that education is the great equalizer. Our schools are the place where we first develop an understanding of the societal value placed on individuals. To this end, the concept of accessibility in education must embrace a human rights based approach in which we recognize that all students will have different needs at different times and in different circumstances. Students with disabilities are part of human diversity and humanity.

We commend the K-12 Education Standards Development Committee on completing the vital first phase in the work towards the development of new accessibility standards for K-12 education. The removal of barriers, both visible and invisible, that impede and marginalize K-12 students with disabilities in Ontario schools is critical to fostering inclusion so that students are able to fully benefit from Ontario’s education system. The YRDSB’s position, as expressed by the HRCO, is that accessibility can best be understood as a process of proactively identifying, removing and preventing barriers to people with and without disabilities. Indeed, this must be a student-centred approach where we actively consider and think about accessibility from the outset to ensure that nobody is excluded.

Meaningful accessibility can only be realized through a human rights based approach that recognizes the integral relationship between rights-holders and duty-bearers:

1. Right-holders are students with disabilities (those we serve in education) who need to be empowered to claim and exercise their rights; and

2. Duty-bearers are the educational system in general (and our Board in particular) which need to build capacity in order to fulfill our obligation to respect, protect, promote, and fulfil human rights, including disability rights.

While the proposed K-12 Education standards are an important first step, only recommendation 22 embodies a human rights based approach. A consistent theme throughout the report is the overly prescriptive nature of many recommendations, which overlook the core need for ongoing capacity building and addressing the fact that systemic ableism and attitudinal barriers continue to present the greatest obstacles for full participation and inclusion. Rather, many recommendations continue to perpetuate the compliance culture that is apparent throughout the other accessibility standards under the AODA.

To foster a culture of accessibility, the K-12 Education standards need to be more intentional and purposeful in drafting recommendations that promote a respect for dignity, difference and acceptance of disabilities as part of human diversity and humanity. It is our hope that greater attention will be accorded to the approach articulated in UN Convention on the Rights of Persons with Disabilities in the eventual drafting of the K-12 Educational standards.

Sincerely,

Anthony Anirud
Human Rights Commissioner