ELA/ELD FW Public Comments - Instructional Quality Commission (CA Dept of Education)

Item 2.C.2. Public Comment Attachment 2 ELA/ELD SMC April 21, 2014 Public Comment Attachment 2 (from March 28, 2014 Meeting, Item 4.A.2.)

From: Pam Ormsby Sent: Wednesday, March 19, 2014 4:48 PM To: Tom Adams Subject: Re: AB455-Common Core Curriculum-D/HH students

Dear Mr. Adams,

I understand that today is the last day to respond to the "Chapter Nine -Access and Equity" draft.

Line 366-370"Although deaf and hard-of-hearing students constitute a small percentage of California's school population, teachers must consider their unique visual linguistic and learning needs when designing and providing instruction and assessment. For example, the acquisition of written English cannot rely on letter-sound correspondences for these students.

I would say, "Although deaf and hard of hearing students constitute a low incidence within the group of California's school population, their unique visual and linguistic needs must be considered. Deaf students whose first language is ASL may not be able to rely on letter-sound correspondence for the acquisition of written English. When providing assessment and designing instruction, their visual language needs must be considered."

Line 373-374 "The linguistic outcome of Deaf students in bilingual ASL/English programs is to become proficient in both ASL and printed English." footnote 1 at bottom of page following line 355 Some deaf and hard-of-hearing students are able to learn to understand and use spoken English considering their level of residual hearing and age of identification and intervention. Deaf students in bilingual ASL/written English programs may most easily learn English after acquiring written English skills.

388-390 Research has shown that native users of ASL demonstrate higher proficiency levels in English than non- native users. (This is an over application of one research study. This study has been controversial in relation to the demographics and the prompts used to solicit ASL/English responses from Deaf students while at School for the Deaf.(an ASL environment). (Avoid controversy while getting to the idea-ASL programs-L! or L2 for those for whom it's appropriate. Avoid the wars.)

I would either eliminate lines 387 to 393 or substitute "Native users of ASL have been shown to be able to acquire high proficiency levels in written English. In school, they are building a second language, written English on a strong first language base of ASL. (May need to be re-worded). or just start "Schools with 393-397. eliminating lines 387-393.

399-403 I would change to say- The type of primary language support provided may vary with the student's level of residual hearing, language and learning style needs. In schools where students are placed in the mainstream classroom or regional/center SDC for D/HH , students may access the curriculum through using hearing aids and other asisstive listening devices, using spoken-only or spoken/signed English , with or without the assistance of appropriate interpreters or note-takers.as determined in a student's I.E.P. Some dead and hard of hearing students speak Spanish as a first language. Those students' ELD needs must also be considered.

-Pam Ormsby Item 2.C.2. Public Comment Attachment 2 ELA/ELD SMC April 21, 2014

From: Pam Ormsby Sent: Tuesday, March 18, 2014 6:14 PM To: William Ellerbee Cc: Tom Adams Subject: AB455-Common Core Curriculum-D/HH students

Dear Dr. Ellerbee and Director Thomas Adams,

It has recently come to my attention that you are working on including special accommodations for deaf and hard of hearing students in regard to the new Common Core Standards. I am happy to hear that D/HH students will be provided with accommodations and modifications per their special needs.

I have been a California credentialed teacher since 1967. I have been a teacher of the D/HH since 1986.I have used ASL/PSE/SEE. I am a parent of a 35 year old deaf son. I have taught ages 3-18. I have taught students in the mainstream, SDC. and am currently working with Latino students from Spanish speaking families in public charter schools in East Oakland. I feel that my long and varied experience qualifies me to address students' needs.

I support students who use ASL as their first language as their way of accessing instruction. I do feel it is important to document the %age of D/HH students in the State of California, for whom this is the case. Data must precede and inform planning.Teachers from the range of placement settings must be involved.

I would venture to estimate that 90% of students in California who have I.E.P.s with D/HH listed, do not fall within this ASL-first language category. I am concerned that administrators, unfamiliar with the continuum of communication modes used by D/HH students, may be confused by the proposed language for AB455 and specifically "Chapter 9-Access and Equity"-Core Curriculum.

I would like to propose that in addition to defining Deaf students-"Bilingual in ASL and Printed English" that a footnote is added stating that: There exists a continuum of communication modes used by dead/hard of hearing students. Many deaf/hard of hearing students access the core curriculum through audition and speech assisted by amplification, signed English, cued speech, and written English. Their special needs for accessing the core curriculum will be addressed in their I.E.P.

I support the use of ASL for students who use ASL as their communication mode. I am not comfortable with some of the statements used to justify this recommendation. They fly in the face of my own experience where students of a range of hearing have consistently learned to read though using a phonetic code in addition to the use of other reading strategies.

I support the use of many visual supports and teaching strategies to assist D/HH students in developing cognitive academic language proficiency.

I recognize the range of hearing ability in the deaf/hard of hearing population and the use of residual hearing and speech reading as ways to access instruction as a tool for many D/HH students.

All these tools must be recognized and be available to our students as appropriate per their Individual Educational Plans. Language and support must be appropriate to each student.

I would appreciate your assistance in clarifying the proposed language in AB455 and in Chapter 9- "Access and Equality"-addressing the Common Core Curriculum.

If you have any further questions, please feel free to contact me.

Pam Ormsby, M.A. Teacher of the Deaf / Hard of Hearing

2 Item 2.C.2. Public Comment Attachment 2 ELA/ELD SMC April 21, 2014

Attachment 4 from March 28, 2014 Meeting Item 4.A.2.

March 20, 2014

MEMORANDUM

TO: Tom Adams California Department of Education

FM: California Coalition of Options Schools (CCOS) Center for Early Intervention on Deafness (CEID)

RE: Comments to the 2014 ELA/ELD Framework

Chapter 1 Introduction to the Framework

 Amend Footnote 1 (page 3 of 19) to read: As noted throughout this framework, speaking and listening should be broadly interpreted. There exists a continuum of communication modes used by students who are Deaf and/or Hard of Hearing to access the core curriculum. Speaking and listening should include Deaf and/or Hard of Hearing students using American Sign Language (ASL) as their primary language, or Deaf and/or Hard of Hearing students assisted by amplification, cochlear implants, simultaneous communication that includes sign supported speech, cued speech, and written English. Each student’s special needs for accessing the core curriculum will be addressed in his or her Individualized Educational Program (IEP).

Chapter 9 Access and Equity

 Amend all references, including footnotes within the Section “Deaf Students Bilingual in ASL and Printed English” to read: Deaf and/or Hard-of-Hearing

 Add an additional Section Deaf Students with Hearing Loss Who Communicate with Spoken English or Simultaneous Communication, including Sign Supported Speech to read:

To participate in the general education curriculum, students who are Deaf and/or Hard of Hearing who communicate with spoken language or a form of total communication (sign supported speech, cued speech, Signing Exact English, etc.) need individualized supports and services which will enable them to access the curriculum and achieve the same high standards required of their peers who have normal hearing.

These supports and services may include instructional and classroom modifications and accommodations (including sophisticated personal and classroom technology, acoustic environments, special seating and lighting) to ensure access to classroom instruction and 3 Item 2.C.2. Public Comment Attachment 2 ELA/ELD SMC April 21, 2014 curriculum.

Students who are Deaf and/or Hard of Hearing often also require related services in areas of speaking and listening, language, communication, reading, social, and self-advocacy skills.

Linking the Individualized Education Program (IEP) activities to content standards helps ensure students who are Deaf and/or Hard of Hearing the opportunities to fully access and reinforce the common core content standards addressed in their education settings.

Determining services, placements, and accommodations for students who are Deaf and/or Hard of Hearing requires a comprehensive review of students' needs. Some examples of the areas the IEP team should consider including for students who are Deaf and/or Hard of Hearing and who communicate with spoken English or a form of simultaneous communication with sign supported speech include:

 Need for related services and supports (e.g., speech-language, educational audiology, English language learning, occupational therapy, sensorimotor integration, physical therapy, counseling, parent training)  Language level  Communication mode (e.g., spoken English or simultaneous communication including sign-supported speech)  Personal hearing technology (e.g., hearing aids, cochlear implants)  Need for other hearing assistive technology (e.g., FM system, classroom assistive listening devices)  Need for interpreter services  Classroom environment (e.g., acoustics, size, lighting, special seating)  Instructional accommodations (e.g., teacher speaking style, language models, use of visual information, classroom technology)  Specialized academic instruction by a credentialed teacher of the deaf trained and experienced to provide instruction in the mode of communication used by the student to access the curriculum.

The efforts of the IEP team need to be guided by a complete understanding of the child's hearing loss and overall developmental and social needs. This knowledge must, in turn, be coordinated with and integrated into ongoing classroom instruction and extracurricular activities. Comprehensive assessment, direct/indirect services, in-service activities, and public information efforts that can significantly enhance the intervention efforts of the education team should be considered for the student.

It is vital that all service providers work collaboratively to support the student and address his or her individual needs.

Attachment 9 from March 28, 2014 Meeting Item 4.A.2.

Response to Attachments 3 and 4 Regarding Language Addressing Deaf and Hard-of-Hearing Students Submitted by Janice Orton, ELA/ELD CFCC Member, and Rory Osbrink

Edits to the ELA/ELD Framework recommended by Pam Ormsby (Item 4.A.2, Attachment 3) are italicized.

Our responses to her suggestions are highlighted in gray.

Line 366-370"Although deaf and hard-of-hearing students constitute a small percentage of California's school population, teachers must consider their unique visual linguistic and learning needs when designing and providing instruction and assessment. For example, the acquisition of written English cannot rely on letter-sound correspondences for these students.

I would say, "Although deaf and hard of hearing students constitute a low incidence within the group of California's school population, their unique visual and linguistic needs must be considered. Deaf students whose first language is ASL may not be able to rely on letter-sound correspondence for the acquisition of written English. When providing assessment and designing instruction, their visual language needs must be considered."

Response: Letter-sound correspondences are not completely accessible to most deaf and hard-of hearing students regardless of their primary language. The above comment makes it seem as if only those deaf and hard of hearing children who use ASL as their primary language cannot fully access sound. In reality, it is often through ASL that Deaf children learn about phonics. By understanding their own phonological system in ASL, then they have comparison to draw from to support their letter-sound correspondence. Deaf children learn through phonics, orthography, and fingerspelling which provides them with more readily accessible tools to learn how to read.

Line 373-374 "The linguistic outcome of Deaf (hard-of-hearing deleted) students in bilingual ASL/English programs is to become proficient in both ASL and printed English."

Response: The removal of hard-of-hearing from this sentence does not recognize the fact that hard-of- hearing students enroll in bilingual settings and do become bilingual in ASL and English. In fact, hard-of- hearing children who are proficient in ASL and printed English often have higher proficiency levels in Spoken English as well. footnote 1 at bottom of page following line 355 Some deaf and hard-of-hearing students are able to learn to understand and use spoken English considering their level of residual hearing and age of identification and intervention. Deaf students in bilingual ASL/written English programs may most easily learn English after acquiring written English skills.

Response: We recommend leaving as was originally written. This terminology leads to the medical model of Deaf people as opposed to a cultural model. Because this section is discussing Deaf students who are bilingual, we believe it best to support the cultural model of Deaf people.

388-390 Research has shown that native users of ASL demonstrate higher proficiency levels in English than non- native users. (This is an over application of one research study, This study has been controversial in 5 Item 2.C.2. Public Comment Attachment 2 ELA/ELD SMC April 21, 2014 relation to the demographics and the prompts used to solicit ASL/English responses from Deaf students while at School for the Deaf.(an ASL environment). (Avoid controversy while getting to the idea-ASL programs-L! or L2 for those for whom it's appropriate. Avoid the wars.)

I would either eliminate lines 387 to 393 or substitute "Native users of ASL have been shown to be able to acquire high proficiency levels in written English. In school, they are building a second language, written English on a strong first language base of ASL. (May need to be re-worded). or just start "Schools with 393-397. eliminating lines 387-393.

Response: We agree to remove the sentence “Research has shown that native users . . . (Strong and Prinze) to what Ms. Ormsby recommended - Native users of ASL have been shown to be able to acquire high proficiency levels in written English. In school, they are building a second language, written English on a strong first language base of ASL. Also, eliminate “Children who are born to hearing parents may start learning ASL at a later age.” Keep the rest. Please note, we can provide more than one research study.

Lines 390-401 are taken from SBAC’s Signing Guidelines. These lines should be cited as such.

399-403 I would change to say- The type of primary language support provided may vary with the student's level of residual hearing, language and learning style needs. In schools where students are placed in the mainstream classroom or regional/center SDC for D/HH , students may access the curriculum through using hearing aids and other assistive listening devices, using spoken-only or spoken/signed English , with or without the assistance of appropriate interpreters or note-takers.as determined in a student's I.E.P. Some dead and hard of hearing students speak Spanish as a first language. Those students' ELD needs must also be considered.

Response: The topic of this section of the framework is bilingual deaf students (see page 15). Bilingual means two languages (English and ASL). Ways in which monolingual deaf students access English are not applicable here. IEP’s are discussed on page 28.

Response to Item 4.A.2 Part II

I support students who use ASL as their first language as their way of accessing instruction. I do feel it is important to document the %age of D/HH students in the State of California, for whom this is the case. Data must precede and inform planning.

Response: ASL is not just a means of accessing instruction, ASL provides Deaf and hard-of-hearing students a linguistic base from which to interact, encounter, and process the world around them.

Teachers from the range of placement settings must be involved.

I would venture to estimate that 90% of students in California who have I.E.P.s with D/HH listed, do not fall within this ASL-first language category. I am concerned that administrators, unfamiliar with the continuum of communication modes used by D/HH students, may be confused by the proposed language for AB455 and specifically "Chapter 9-Access and Equity"-Core Curriculum.

I would like to propose that in addition to defining Deaf students-"Bilingual in ASL and Printed English" that a footnote is added stating that: There exists a continuum of communication modes used by dead/hard of hearing students. Many deaf/hard of hearing students access the core curriculum through audition and speech assisted by amplification, signed English, cued speech, and written English. Their special needs for accessing the core curriculum will be addressed in their I.E.P.

Response: While this may be true, this does not mean that is the best practice for deaf and hard-of- hearing children in California. Communication modes cause confusion, by encouraging ASL as the primary language of communication in the classroom, we can standardize how we teach our students. Research shows that through ASL, deaf and hard-of-hearing children can succeed in core curriculum, Spoken English, and as a whole child. There is no disagreement that some children can access English through audition and speech; however, this is a small percentage (and we know this because we receive these students or requests for support for these students after they’ve struggled at other schools. Signed English has no research supporting its success nor do they have any standardized training provided in California. Cued Speech does have some research supporting its success but the community of users is too small and virtually nonexistent in California so it would not be a feasible option.

Edits to the ELA/ELD Framework recommended by CCOS (Item 4.A.2, Attachment 4) are italicized.

Our responses to these suggestions are highlighted in gray.

Chapter 1 Introduction to the Framework  Amend Footnote 1 (page 3 of 19) to read: As noted throughout this framework, speaking and listening should be broadly interpreted. There exists a continuum of communication modes used by students who are Deaf and/or Hard of Hearing to access the core curriculum. Speaking and listening should include Deaf and/or Hard of Hearing students using American Sign Language (ASL) as their primary language, or Deaf and/or Hard of Hearing students assisted by amplification, cochlear implants, simultaneous communication that includes sign supported speech, cued speech, and written English. Each student’s special needs for accessing the core curriculum will be addressed in his or her Individualized Educational Program (IEP).

Response: This footnote is written for bilingual Deaf students. It is adapted from SBAC and directly states “for those students whose primary language is ASL.” This footnote does not refer to students whose primary language is English and the alternate methods used to access English.

Chapter 9 Access and Equity

 Amend all references, including footnotes within the Section “Deaf Students Bilingual in ASL and Printed English” to read: Deaf and/or Hard-of-Hearing

Response: Hard-of-hearing people are not considered a cultural group but rather a sub-group in Deaf Culture under the main label of Deaf (much like late-deafened).

 Add an additional Section Deaf Students with Hearing Loss Who Communicate with Spoken English or Simultaneous Communication, including Sign Supported Speech to read:

To participate in the general education curriculum, students who are Deaf and/or Hard of Hearing who communicate with spoken language or a form of total communication (sign supported speech, cued speech, Signing Exact English, etc.) need individualized supports and services which will enable them to access the curriculum and achieve the same high standards required of their peers who have normal hearing. 7 Item 2.C.2. Public Comment Attachment 2 ELA/ELD SMC April 21, 2014

Response: The term “Normal” hearing is again fostering the medical model and disregarding the cultural model of Deaf individuals.

These supports and services may include instructional and classroom modifications and accommodations (including sophisticated personal and classroom technology, acoustic environments, special seating and lighting) to ensure access to classroom instruction and curriculum.

Response: Modifications and accommodations are listed on pages 29-32 in Chapter 9.

Students who are Deaf and/or Hard of Hearing often also require related services in areas of speaking and listening, language, communication, reading, social, and self-advocacy skills.

Linking the Individualized Education Program (IEP) activities to content standards helps ensure students who are Deaf and/or Hard of Hearing the opportunities to fully access and reinforce the common core content standards addressed in their education settings.

Determining services, placements, and accommodations for students who are Deaf and/or Hard of Hearing requires a comprehensive review of students' needs. Some examples of the areas the IEP team should consider including for students who are Deaf and/or Hard of Hearing and who communicate with spoken English or a form of simultaneous communication with sign supported speech include:

 Need for related services and supports (e.g., speech-language, educational audiology, English language learning, occupational therapy, sensorimotor integration, physical therapy, counseling, parent training)  Language level  Communication mode (e.g., spoken English or simultaneous communication including sign-supported speech)  Personal hearing technology (e.g., hearing aids, cochlear implants)  Need for other hearing assistive technology (e.g., FM system, classroom assistive listening devices)  Need for interpreter services  Classroom environment (e.g., acoustics, size, lighting, special seating)  Instructional accommodations (e.g., teacher speaking style, language models, use of visual information, classroom technology)  Specialized academic instruction by a credentialed teacher of the deaf trained and experienced to provide instruction in the mode of communication used by the student to access the curriculum.

Response: Many students need a variety of services and supports, Chapter 9 in this framework document provides a general overview on pages 25-33.

The efforts of the IEP team need to be guided by a complete understanding of the child's hearing loss and overall developmental and social needs. This knowledge must, in turn, be coordinated with and integrated into ongoing classroom instruction and extracurricular

activities. Comprehensive assessment, direct/indirect services, in-service activities, and public information efforts that can significantly enhance the intervention efforts of the education team should be considered for the student.

It is vital that all service providers work collaboratively to support the student and address his or her individual needs.

Response: The IEP is discussed in the framework, Chapter 9, on page 28.