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by Marty Murrell

QUESTION: Could you tell us what "not functionally blind" means to you? For example, a severely impaired student who is totally blind or has light perception (LP) who will never be a tactual learner because of severe cognitive and physical issues.

RESPONSE: The term "functionally blind" has a generalized meaning in the field of visual impairments. It is usually related to the fact that a child, even those with some vision, functions as someone who is blind, that is, primarily receives sensory input. However, in Texas, it is a term defined in commissioner rule and it is tied to braille reading and writing. When a child is determined to be functionally blind through the learning media assessment, there are additional requirements and rights for that child related to Braille reading and writing. (See cites below.) In Texas, a child is NOT functionally blind if he is primarily a visual learner and will not need Braille now or in the future.

The primary intent of the rule was to ensure that children who needed braille and braille related instruction, were appropriately identified and received appropriate IEP goals and services related to braille. This includes pre-braille activities, braille readiness activities, or braille reading and writing instruction. However, it became evident that there were a very small number of children who are primarily tactual/auditory, but, because of significant cognitive/developmental issues, will not become readers in any medium. They will not be able to use even Braille labels/symbols in such devices as calendar boxes. To continue to discuss the benefits of Braille and other Braille related topics with the parents and other IEP team members seems to be unnecessary, and in some cases, insensitive.

To reduce this non-productive exercise, a group of stakeholders suggested a third option which recognizes that the child is primarily a tactual learner, but instruction related to braille, including pre-braille activities, was inappropriate at the time of the evaluation and the ARD meeting because of significant cognitive issues. The label of "functionally blind" is not applied so that the braille related requirements attached to the label will not apply. But it would be inappropriate to say that the child was "not functionally blind." This is an option that should be used judiciously and infrequently. It is not a permanent determination. If the child progresses to the point where even minimal braille usage is a possibility, then the term functionally blind should be applied. (Within the vision profession, these children typically would be considered functionally blind, but again, the term in Texas law and Commissioner rules has different implications specific to braille literacy.)

In some situations, it is very difficult to determine through a typical learning media assessment, if the child is functionally blind or not, and if there is or will be a need for braille. In those cases, it is better to err on the side of caution and apply the functionally blind label, but indicate that more ling-term, on-going assessment is necessary before a final decision is made. This will ensure that the ARD committee will have the information about the benefits of braille which are particularly critical when making difficult decisions. It is important to note that when this option is used, the ARD committee should set a reasonable deadline for the ongoing assessment to be completed and decisions are made.

Related References:
TEC 30.002 (f)
In the development of the individualized education program for a functionally blind student, proficiency in Braille reading and writing is presumed to be essential for the student’s satisfactory educational progress. Each functionally blind student is entitled to Braille reading and writing instruction that is sufficient to enable the student to communicate with the same level of proficiency as other students of comparable ability who are at the same grade level. Braille instruction may be used in combination with other special education services appropriate to the student’s educational needs. The assessment of each functionally blind student’s educational needs. The assessment of each functionally blind student for the purpose of developing the student’s individualized education program must include documentation of the student’s strengths and weaknesses in Braille skills. Each person assisting in the development of a functionally blind student’s individualized education program shall receive information describing the benefits of braille instruction. Each functionally blind student’s individualized education program must specify the appropriate learning medium based on the assessment report and ensure that instruction in braille will be provided by a teacher certified to teach students with visual impairments. For purpose of this subsection, the agency shall determine the criteria for a student to be classified as functionally blind.

TAC 89.1040 (12) (B)
A student with a visual impairment is functionally blind if, based on the preceding evaluations, the student will use tactual media (which includes braille) as a primary tool for learning to be able to communicate in both reading and writing at the same level of proficiency as other students of comparable ability.