LIBRARY SERVICES 

FOR THOSE WITH 

DISABILITIES

Additional Steps 

Needed to Ease 

Access to Services 

and Modernize 

Technology

Report to Congressional Committees

April 2016

GAO-16-355

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-16-355, a report to 

congressional committees 

April 2016

LIBRARY SERVICES FOR THOSE WITH 

DISABILITIES

Additional Steps Needed to Ease Access to Services 

and Modernize Technology

Why GAO Did This Study

NLS, within the Library of Congress 

(LOC), provides free audio and braille 

materials for U.S. citizens and 

residents who cannot read standard 

print due to visual and other 

disabilities. In fiscal year 2016, the 

NLS program received about $50 

million in federal funds to provide these 

materials through a national network of 

libraries. The House report 

accompanying the fiscal year 2016 

legislative branch appropriations bill 

included a provision for GAO to review 

NLS’s users and the technology it 

employs to meet their needs.

GAO examined (1) the characteristics 

of NLS users and the steps NLS is 

taking to ensure eligible individuals’ 

access and awareness, and (2) how 

NLS provides materials and the extent 

to which it is considering emerging 

trends in technology. GAO reviewed 

relevant federal laws and regulations, 

NLS documents, and administrative 

data; interviewed NLS officials, 

librarians from 8 of the 101 network 

libraries selected for geographic 

diversity and a range in the number of 

users, and officials from research and 

advocacy groups and assistive 

technology companies; and reviewed 

literature on NLS-eligible populations 

and trends in assistive technologies. 

What GAO Recommends

Congress should consider authorizing 

NLS to provide its users devices for 

reading electronic braille files. In 

addition, GAO recommends that NLS 

re-examine its eligibility certification 

requirements, evaluate its outreach, 

and assess alternative approaches to 

delivering audio content. LOC 

generally agreed with these

recommendations. 

What GAO Found

The National Library Service for the Blind and Physically Handicapped (NLS) is 

primarily used by older adults with visual disabilities, and NLS has taken some 

steps to ensure eligible users’ access to and awareness of available services. In 

fiscal year 2014, about 70 percent of the program’s 430,000 users were age 60 

and older and almost 85 percent had visual disabilities, according to the most 

recent NLS data available at the time of GAO’s review. Federal regulations 

establish eligibility for NLS services for people with a range of disabilities. 

However, medical doctors must certify eligibility for people with reading 

disabilities such as dyslexia, which is not required for those with visual or 

physical disabilities. According to officials from network libraries and other 

stakeholder groups, the requirement for a doctor’s certification is an obstacle to 

accessing services because of additional steps and costs to the individual. These 

officials and stakeholders said other professionals, such as special education 

teachers, are also positioned to certify eligibility for applicants with reading 

disabilities. GAO has previously noted the importance of disability programs 

keeping pace with scientific and medical advances. However, the certification 

requirement has remained largely unchanged for more than 40 years. NLS has 

taken steps to inform eligible groups about its services, such as partnering with 

other organizations that serve these groups, developing a new website, and 

distributing an outreach toolkit to network libraries. However, NLS has no plans 

to evaluate which outreach efforts have resulted in new users in order to ensure 

resources are used effectively—a key practice identified previously by GAO. 

NLS offers materials to its users in a range of formats, but its efforts to adopt 

new, potentially cost-saving technologies are hampered by limitations in both its 

statutory authority and its analyses of alternatives. Users may choose to receive, 

through the mail, audio materials on digital cartridges or hard copy braille 

documents. Users may also choose to download audio and braille files from an 

NLS-supported website. During fiscal year 2014, 86 percent of users chose to 

receive audio materials on digital cartridges, according to NLS data. NLS officials 

said they would like to provide users with devices for reading electronic braille 

files, a faster and less bulky approach than braille documents, and per the 

agency’s July 2015 analysis, could become more cost effective with 

technological advances. However, federal statute does not authorize NLS to use 

program funds to acquire and provide braille devices as it does for audio devices, 

which prevents the agency from taking advantage of technology that has the 

potential to reduce costs. NLS is also examining new technologies for audio 

materials but has not fully assessed available alternatives. For example, NLS is 

considering supplementing its collection of human-narrated audio materials with 

text-to-speech (i.e., synthetic speech) materials, which some evidence suggests 

could be produced more quickly and at a lower cost. However, NLS has not 

comprehensively compared the text-to-speech option to its current approach in 

order to make a decision on whether to move forward, as called for by GAO best 

practices for alternatives analysis. Without this analysis, NLS may miss an 

View GAO-16-355. For more information, opportunity to meet its users’ needs more efficiently and cost effectively.

contact Daniel Bertoni at (202) 512-7215 or 

bertonid@gao.gov. 
Page i GAO-16-355 Library Services for Those with Disabilities

Letter 1

Background 3

NLS Users Are Primarily Older Adults with Visual Disabilities, but 

NLS Efforts Are Not Ensuring Full Access and Awareness 8

NLS Offers Materials in a Range of Formats, but Statutory and 

Other Limitations Impede Adoption of Potentially Cost-Saving 

Technologies 15

Conclusions 28

Matter for Congressional Consideration 28

Recommendations for Executive Action 29

Agency Comments and Our Evaluation 29

Appendix I Comments from the Library of Congress 31

Appendix II GAO Contact and Staff Acknowledgments 35

Related GAO Products 36

Figures

Figure 1: Organizational Structure of the Library of Congress 5

Figure 2: Age of NLS Users, on September 30, 2014 10

Figure 3: Distribution of Disabilities among NLS Users, on 

September 30, 2014 11

Figure 4: Percentage of NLS Users Accessing Reading Materials, 

by Format, Fiscal Year 2014 17

Figure 5: Number of NLS Reading Materials Circulated to Users, 

by Format, Fiscal Years 2010-2014 18

Figure 6: NLS Specialized Audio Players and a Commercially 

Available Audio Device 19

Figure 7: Hard Copy Braille Book and a Refreshable Braille 

Device 22

Contents
Page ii GAO-16-355 Library Services for Those with Disabilities

Abbreviations

ACS American Community Survey 

BARD Braille and Audio Reading Download system 

IDEA Individuals with Disabilities Education Act 

LOC Library of Congress 

NCLD National Center for Learning Disabilities 

NFB National Federation of the Blind 

NHIS National Health Interview Survey 

NLS National Library Service for the Blind and Physically 

 Handicapped 

USPS United States Postal Service

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. The published product may be reproduced and distributed in its entirety 

without further permission from GAO. However, because this work may contain 

copyrighted images or other material, permission from the copyright holder may be 

necessary if you wish to reproduce this material separately.
Page 1 GAO-16-355 Library Services for Those with Disabilities

441 G St. N.W.

Washington, DC 20548

April 4, 2016

The Honorable Shelley Moore Capito

Chairman

The Honorable Brian Schatz

Ranking Member

Subcommittee on Legislative Branch

Committee on Appropriations

United States Senate

The Honorable Tom Graves

Chairman

The Honorable Debbie Wasserman Schultz

Ranking Member

Subcommittee on Legislative Branch

Committee on Appropriations

House of Representatives

The National Library Service for the Blind and Physically Handicapped 

(NLS), within the Library of Congress (LOC), provides free, accessible 

reading materials for those who cannot read standard print. A substantial 

number of Americans have difficulty reading standard printed material 

due to visual and other types of disabilities. For example, according to 

one estimate, nearly 21 million Americans are blind or have visual 

disabilities.1 Others may have trouble holding or handling a book due to 

conditions such as quadriplegia or paper allergies. The inability to read 

can have a significant impact on an individual’s education, work capacity, 

and full integration in society. The program was authorized in 19312

, and 

it received about $50 million in federal funding in fiscal year 2016. U.S. 

citizens and residents with sufficiently severe visual or physical disabilities 

or reading disabilities resulting from organic dysfunction such as dyslexia 

and other learning disabilities are eligible for the NLS program. 

Headquartered in Washington, D.C., NLS operates in conjunction with a 

national network of state and local libraries that conduct outreach, 

 1

Centers for Disease Control and Prevention, Summary Health Statistics for U.S. Adults: 

National Health Interview Survey, 2012 (Hyattsville, MD: February 2014).

2

Pub. L. No. 71-787, 46 Stat. 1487.

Letter
Page 2 GAO-16-355 Library Services for Those with Disabilities

determine eligibility, and distribute reading materials. In addition, the 

United States Postal Service (USPS) receives funds to cover the costs of 

mailing these materials. The House report accompanying the fiscal year 

2016 legislative branch appropriations bill included a provision for GAO to 

review NLS’s services, including its user base and the technologies it has 

in place to meet users’ needs.3

We examined: (1) the characteristics of NLS’s users and the steps NLS is 

taking to ensure those eligible are aware of and have access to its 

services, and (2) how NLS provides materials to users and the extent to 

which it is considering emerging trends in technology.

To address these objectives, we reviewed relevant federal laws and

regulations, as well as NLS documents including procedures, strategic 

planning documents, studies by external contractors on NLS’s outreach 

and its braille program, and assessments of network library performance. 

We reviewed NLS administrative data for fiscal years 2010 through 2014, 

the most recent available at the time of our review, on the number of 

users, user demographics, and formats in which materials were provided. 

We assessed the reliability of these data by interviewing cognizant NLS 

officials and reviewing related documentation, and found the data to be 

sufficiently reliable for our reporting objectives. Additionally, we 

interviewed officials from NLS, LOC, and USPS. We also interviewed staff 

at 8 of NLS’s 101 network libraries about topics including user 

demographics and NLS technologies. We interviewed librarians in the 

District of Columbia, Georgia, Illinois (two libraries), Massachusetts (two 

libraries), Oklahoma, and Washington state. We selected these libraries 

to achieve diversity in geographic location, number of users, and outreach 

practices. For example, we included some libraries that had piloted new 

outreach materials from NLS or changed their organizational structure in 

recent years. We also interviewed officials from a number of external 

stakeholder groups, including research and advocacy organizations for 

relevant disabled populations; other organizations that provide accessible 

reading materials; private companies that produce assistive technology 

for those with visual disabilities; and the CNIB Library, a private non-profit 

 3

See H.R. Rep. No. 114-110 (2015), which accompanied H.R. 2250, 114th Cong.
Page 3 GAO-16-355 Library Services for Those with Disabilities

library in Canada for those with visual and other disabilities.4 Finally, we 

reviewed select articles and reports on the demographics of NLS-eligible 

populations and trends in assistive technologies for these populations. To 

assess NLS’s efforts to ensure access to its services and consider 

technological trends, we used criteria previously identified by GAO in the 

areas of disability evaluation, outreach, and alternatives analysis, as well 

as criteria for internal controls in the federal government.

We conducted this performance audit from June 2015 through April 2016 

in accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

NLS operates a program that provides free reading materials for residents 

and citizens of the United States and its territories as well as U.S. citizens 

residing abroad who are generally unable to read standard print because 

of a visual or physical disability. Under its authorizing statute, the program 

may provide reading materials in braille, audio, and other formats, and 

since the 1940s, may provide devices for reproducing audio recordings.5

The types of materials that NLS provides include books, magazines, 

music scores and materials for music instruction. In addition, NLS users 

have access to over 400 state, national, and international audio and 

braille newspapers through Newsline, a telephone and internet-based 

 4 Specifically, we interviewed officials from these research and advocacy organizations: 

American Council of the Blind, American Foundation for the Blind, National Federation of 

the Blind (NFB), Blinded Veterans Association, National Center for Learning Disabilities 

(NCLD), and the Center for Applied Special Technology. We also interviewed officials 

from these organizations that provide accessible reading materials: American Printing 

House for the Blind, Bookshare, Learning Ally, and National Braille Press. We also 

interviewed officials from the private sector technology companies HIMS, Inc. and 

HumanWare.

5

Under federal law, it is not an infringement of copyright for authorized entities, including 

NLS, to reproduce and distribute certain published literary works in specialized formats for 

the use of blind and other persons with disabilities. 17 U.S.C. § 121.

Background
Page 4 GAO-16-355 Library Services for Those with Disabilities

service.6 The Free Matter for the Blind and Other Physically Handicapped 

Persons program, administered by USPS, assists NLS in circulating 

materials to its users. In fiscal year 2016, USPS had a budget of 

approximately $55.1 million for free delivery of mail in the NLS program

and certain other purposes. USPS delivered 43.9 million pieces of mail 

through the program during fiscal year 2015.

NLS is within the LOC’s Office of National and International Outreach, 

under LOC’s organizational structure effective Oct. 1, 2015 (see fig. 1). 

NLS receives its own congressional appropriation; however, LOC 

oversees the budget and activities of NLS and approves its budgeting 

decisions. For instance, if NLS’s budgetary plan includes investing in a 

new technology initiative, it must submit a proposal for approval by LOC’s 

Information Technology Steering Committee. LOC also oversees NLS’s 

strategic planning process. NLS is currently in the process of developing 

its first comprehensive strategic plan, which NLS officials stated will be 

completed in fiscal year 2016.7 LOC will review this plan to ensure it 

aligns with LOC’s overall strategic plan. In addition, LOC has oversight of 

NLS through processes such as monitoring, checks of internal control 

procedures, and performance management.

 6

In fiscal year 2016, the Library of Congress (LOC) received federal funding of 

approximately $50.2 million for the program operated by NLS, which included $650,000 

that was specified to support a free newspaper service to blind and physically disabled 

residents. Regarding this latter amount, LOC has contracted with NFB, which operates 

Newsline with a combination of federal and state funds, to have NFB utilize those funds. 

According to NLS officials, NLS users qualify for the Newsline service because the 

qualification standards for both NLS and Newsline are identical, and eligible users can 

sign up for both services simultaneously. 

7

In the draft of this strategic plan, several broad priorities have already been identified, 

including increasing public awareness of the NLS program, increasing the quantity and 

variety of the materials available to users, and making options for the delivery of NLS 

reading materials more timely and user-friendly.

NLS’s Structure and 

Administration
Page 5 GAO-16-355 Library Services for Those with Disabilities

Figure 1: Organizational Structure of the Library of Congress

Note: This figure is a simplified depiction of the relevant components of the Library of Congress’s 

organizational chart.

Administration of the NLS program is shared between NLS headquarters 

and a national network of libraries and outreach centers. Headquarters is 

located in Washington, D.C., and its staff’s functions and responsibilities 

include selection and production of reading materials, procurement of 

playback equipment, establishment of standards and assurance of quality 

products and services, and development, maintenance, and circulation of 

the specialized music collection. In addition, NLS relies on a network of 

101 regional and sub-regional libraries and outreach centers to implement 

the program. Most states have one regional library participating in the 

network that is operated by the state or other entity. Some states also 

have sub-regional libraries that coordinate with the regional libraries to 

serve a specific geographical area, and are generally operated by public 

libraries. NLS network libraries conduct outreach to potential users; 

screen applicants for eligibility; provide customer service to users such as 

assistance with selecting an appropriate NLS device and identifying 
Page 6 GAO-16-355 Library Services for Those with Disabilities

preferred reading materials; store, maintain, and circulate NLS books and 

machines; and report to NLS on equipment, books, and users.8 The 

operating costs for these activities and services are not funded by NLS 

but rather by state, local, and other sources.

Under LOC regulations, the following four categories of individuals are 

eligible to access the NLS program:9

• Blind

This refers to persons whose visual acuity is 20/200 or less in the 

better eye with correcting glasses or who have a restricted field of 

vision.10

• Visual Disability

This refers to persons whose visual disability with correction prevents 

the reading of standard printed material.

• Physical Limitation

This refers to persons who are unable to read or unable to use 

standard printed material because of physical limitations.11

• Reading Disability Resulting From Organic Dysfunction

This refers to persons who have a reading disability resulting from 

organic dysfunction that is severe enough to prevent them from 

reading printed material in a normal manner. An NLS factsheet states 

 8

Additionally, there are Advisory and Outreach Centers that assist with outreach efforts on 

behalf of NLS and provide connectivity to the NLS automated circulation system; 

independent machine-lending agencies designated by NLS to circulate NLS devices; and 

two multistate centers that store and distribute playback equipment and supplies, 

specialized collections of materials, and back-up copies of the NLS collection.

9

36 C.F.R. § 701.6.

10This category includes people whose wide diameter of visual field subtends an angular 

distance no greater than 20 degrees.

11The term “physical limitation” is used in LOC’s regulatory language. For the remainder of 

this report, all the disabilities in this category will be referred to as “physical disability.”

Populations Eligible for 

NLS
Page 7 GAO-16-355 Library Services for Those with Disabilities

such reading disabilities may include dyslexia, attention deficit 

disorder, autism, or developmental disabilities.12

Under the LOC regulations, a competent authority is required to 

determine the eligibility of all potential users. In cases of blindness, or 

visual or physical disabilities, a variety of professionals are permitted to 

certify an individual’s eligibility, including doctors of medicine, registered 

nurses, therapists, social workers, and certain hospital staff, among 

others. In the absence of any of the competent authorities listed in the 

regulation, a professional librarian may approve eligibility. By contrast, in 

the case of those with a reading disability, the competent authority must 

be a doctor of medicine who may consult with colleagues in associated 

disciplines.

Estimates of the blind and visually disabled population vary widely, and 

the precise number who may be eligible for NLS is unknown. Estimates 

for this population are often based on self-reported information and rely 

on different definitions of blindness and visual disability. For example, 

according to the National Health Interview Survey (NHIS), in 2012 there 

were approximately 21 million adults ages 18 and older who reported that 

they had “trouble seeing.”13 However, according to the American 

Community Survey (ACS), in 2013 there were approximately 7 million 

adults ages 18 and older who reported that they were blind or

experienced “serious difficulty seeing.”14

It is also difficult to estimate the number of people who would potentially 

qualify for the NLS program based on reading and physical disabilities. 

With regard to reading disabilities, a National Center for Learning 

Disabilities (NCLD) report estimated that in 2012 there were 

approximately 2.4 million public school students who qualified for special 

education programs under the Individuals with Disabilities Education Act 

 12The term “reading disability resulting from organic dysfunction” is used in LOC’s 

regulatory language. For the remainder of this report, all the disabilities in this category will 

be referred to as “reading disability.”

13Centers for Disease Control and Prevention, National Health Interview Survey, 2012.

14U.S. Census Bureau. American Community Survey 2013, 1-Year Estimates (figure 

C18103). (Washington D.C.: 2015). Both the NHIS and ACS estimates report only 

numbers for non-institutionalized civilian adults and exclude those in long-term care 

facilities or prisons.
Page 8 GAO-16-355 Library Services for Those with Disabilities

(IDEA) based on learning disabilities, and many of these students had 

reading disabilities specifically.15 In addition, according to the Survey of 

Income and Program Participation in 2010, there were at least 3.5 million 

adults ages 18 and older with learning disabilities, including reading 

disabilities such as dyslexia.16 Regarding physical disabilities, NLS 

officials said that the wide range in the types and severity of potentially 

qualifying conditions and the lack of centralized data make it difficult to 

estimate the population of potentially eligible users of the NLS program.

 15Candace Cortiella and Sheldon Horowitz, The State of Learning Disabilities Report: 

Facts, Trends and Emerging Issues (New York: National Center for Learning Disabilities, 

2014).

16NCLD officials estimate that a much larger number of Americans—20 percent of adults 

and children—may have a learning disability. This estimate is based on a review of a 

number of research studies on this population.

NLS Users Are 

Primarily Older Adults 

with Visual 

Disabilities, but NLS 

Efforts Are Not 

Ensuring Full Access 

and Awareness
Page 9 GAO-16-355 Library Services for Those with Disabilities

In fiscal year 2014, about 430,000 individuals used the NLS program, with 

the majority being older individuals who were blind or had other visual 

disabilities.17 The majority of NLS users were aged 60 and over (about 70 

percent), with almost 20 percent at least 90 years of age (see fig. 2). In 

addition, almost 85 percent of NLS users were either blind or had other 

visual disabilities resulting in their inability to read standard print (see fig. 

3).18 NLS officials told us that the majority of users have age-related 

vision loss and therefore did not qualify for services until later in life. 

About 6 percent of NLS users had physical disabilities, which include 

multiple sclerosis and Parkinson’s disease, according to officials we 

spoke with from network libraries. Another nearly 6 percent of users had 

reading disabilities. NLS guidance explains, and network library officials 

corroborated, that users’ reading disabilities generally include dyslexia, 

autism, and traumatic brain injuries. In part because of their older age, 

many users have physical dexterity issues which compound their other 

disabilities, according to NLS officials. Although NLS does not track users’

mobility or dexterity limitations as part of its annual data collection efforts, 

a survey of users and non-users NLS contracted for in 2013 indicated that 

almost half of users had limited mobility, and about a third had problems 

with manual dexterity.19

 17NLS officials estimate that almost 200,000 additional people used the NLS program in 

fiscal year 2014 through loans to institutions such as nursing homes, schools, and 

hospitals. 

18The specific types of disabilities that made users eligible for the NLS program remained 

consistent, with no type fluctuating more than 2 percent across the five fiscal years we 

reviewed (2010 through 2014).

19NLS contracted with ICF International to conduct a survey of current NLS users, former 

NLS users, and eligible non-users. The survey was conducted from March 11th to May 

10th, 2013 and was offered in both web and telephone modes. Sample users were 

selected using a stratified random sampling approach and ICF determined that the results 

were generalizable to the full NLS user population. Completed responses were obtained 

from 2,517 individuals and the response rate for the sample of current NLS users was 

28.9 percent (response rates could not be calculated for the other groups). See ICF 

Incorporated, L.L.C., National Library Service for the Blind and Physically Handicapped 

(NLS) Talking Book and Braille Program Evaluation and Recommendations for Increased 

Patronage (Virginia: June 28, 2013).

Older Adults with Visual 

Disabilities Make Up the 

Majority of Users, though 

an Eligibility Requirement 

May Limit Access of 

Potential Users with 

Reading Disabilities
Page 10 GAO-16-355 Library Services for Those with Disabilities

Figure 2: Age of NLS Users, on September 30, 2014 

Note: These data are based on the number of users on Sept. 30, 2014, rather than a cumulative total 

for fiscal year 2014.
Page 11 GAO-16-355 Library Services for Those with Disabilities

Figure 3: Distribution of Disabilities among NLS Users, on September 30, 2014

Note: These data are based on the number of users on Sept. 30, 2014, rather than a cumulative total 

for fiscal year 2014.

NLS’s 2013 survey of users and non-users indicated that NLS users 

generally have retired from employment or are unemployed, have low or 

fixed incomes, and are more likely to live alone than non-users. In 

addition, 13 percent of the user respondents reported having served in 

the military.20

The number of NLS users remained stable from fiscal year 2010 through 

fiscal year 2014, according to NLS data. NLS officials said they estimated

about 10 percent turnover in their users each year. While they recruit new 

users, they said the number of older users who die each year generally 

results in the number of users staying about the same. Although NLS 

does not project user estimates for future years, the proportion of the U.S. 

population age 65 and older is expected to increase from 13 percent in 

 20These data are not available over time as NLS does not conduct user surveys regularly. 

Although NLS inquires if applicants are veterans of U.S. military service, they do not track 

this data. Under LOC regulation, preference in providing reading materials and equipment 

must be given to the needs of the blind and other persons with disabilities who have been 

honorably discharged from the Armed Forces of the United States. 36 C.F.R. § 701.6(g).
Page 12 GAO-16-355 Library Services for Those with Disabilities

2010 to more than 20 percent in 2050, which may increase the number of 

NLS’s older users.21

While NLS serves individuals with a range of disabilities, an eligibility 

requirement specific to individuals with reading disabilities may hinder this 

group of potentially eligible users from accessing services. Specifically, 

the regulatory requirement that only doctors of medicine may certify a 

reading disability was cited as a barrier to services by staff with whom we 

spoke at 5 of the 8 network libraries, 2 organizations that provide similar 

services to NLS, and 2 organizations specializing in learning disabilities.22

This eligibility requirement, which originated in 1974 and has remained 

largely unchanged since, creates additional steps and costs for applicants 

with reading disabilities in comparison to other groups, and may hinder 

some individuals’ access to services. For example, officials we spoke with 

from a network library said that many of their potential users have little 

money and live in rural areas that are far from doctors, which limits their 

ability to get the necessary certification.

Furthermore, a medical diagnosis is not necessary to determine if an 

individual has a reading disability, according to a number of groups we 

interviewed and the policies of other organizations that support people 

with these disabilities. According to staff we spoke with at two 

organizations specializing in learning disabilities, and 6 of the 8 network 

libraries, special education teachers and school staff are typically also 

knowledgeable about reading disabilities. Recognizing this, certification of 

reading disabilities is conducted by non-medical personnel for other 

disability services. For example, under IDEA educational services are 

provided to eligible children with disabilities, including learning disabilities, 

which may affect reading. However, IDEA does not require a doctor’s 

certification of eligibility; this determination is instead made by the child’s 

parents and a special education team generally comprised of the child’s 

teacher and at least one other person qualified to conduct diagnostic 

examinations of children, such as a school psychologist or remedial 

reading teacher. In addition, two private organizations that, similar to 

NLS, provide individuals with alternatives to standard print materials, use 

 21GAO, Older Adults: Federal Strategy Needed to Help Ensure Efficient and Effective 

Delivery of Home and Community-Based Services and Supports, GAO-15-190

(Washington, D.C.: May 20, 2015).

22See 36 C.F.R. § 701.6(b)(2)(ii).
Page 13 GAO-16-355 Library Services for Those with Disabilities

LOC regulations as guidance to determine the eligibility of individuals with 

disabilities except for reading disabilities. These organizations instead 

allow individuals who are deemed competent authorities for the other 

LOC eligibility categories by the organizations to certify for reading 

disabilities.

Although the eligibility requirement for those with reading disabilities may 

be inconsistent with other federal policies and with some entities’ current 

practices, and potentially hinder access to services, NLS does not plan 

any modifications. Network libraries have formally recommended to NLS 

that it re-visit the requirement that a doctor certify the eligibility of those 

with reading disabilities. This is also consistent with our previous 

recommendations that agencies providing disability benefits and services 

should ensure they use up-to-date medical criteria, which reflect 

advances in medicine and technology and include consideration of nonmedical evidence.23 NLS officials said that changing the eligibility 

requirement for reading disabilities may lead to more users and increased 

costs. Two other organizations that provide similar services saw an 

increase in the number of users after they changed their certification 

requirements so non-medical personnel could certify eligibility. NLS has 

not estimated the potential demand for its services by those with reading 

disabilities, and so the actual effect on NLS services from revising the 

eligibility requirement is unknown.

NLS’s current users likely represent a small percentage of those eligible, 

but NLS has initiated new efforts to increase awareness and usage of its 

services. In 2014, NLS developed a plan for improving and expanding its 

outreach efforts. This plan is based, at least in part, on the 

recommendations from the 2013 survey of NLS users and non-users.24

The efforts may help address outreach challenges reported to us by staff 

at the eight network libraries, including limited nationwide awareness, a 

lack of information in accessible formats, difficulty reaching the wide 

variety of potentially eligible populations, and a lack of guidance provided 

network libraries. NLS’s efforts to improve outreach include:

 23GAO, High Risk Series: An Update, GAO-15-290 (Washington, D.C.: Feb. 11, 2015). 

24ICF Incorporated, L.L.C., Talking Book and Braille Program Evaluation and 

Recommendations for Increased Patronage.

NLS Is Initiating New 

Outreach Efforts, but Does 

Not Collect Information 

Needed to Evaluate Their 

Effectiveness
Page 14 GAO-16-355 Library Services for Those with Disabilities

• Increasing electronic recruitment methods: NLS has established 

additional electronic resources, including website announcements and 

advertisements through social media. For example, NLS developed a 

Facebook page and is developing a new website. These changes 

may increase nationwide awareness of services, which staff at 5 of 

the 8 libraries told us was needed.

• Producing more information in accessible formats: NLS is developing 

videos for its website as well as talking guides on how to use its 

services. These guides are being developed specifically for older 

individuals to explain processes step by step. Previously, information 

on services was mostly provided via brochures and posters.

• Fostering more partnerships: NLS is increasing communications with 

other organizations that serve its eligible populations. In October 

2014, NLS sent e-mails to 300 organizations identified as serving 

people who may be eligible for its services, with the goal of partnering 

with these organizations and conducting outreach through them. 

According to officials, 150 organizations responded to this email and 

agreed to work with NLS. For example, veterans service organizations 

agreed to ensure veterans are informed about the program and 

encouraged to take advantage of its services.

• Providing an outreach toolkit for network libraries: NLS recently 

released a toolkit providing guidance and materials such as 

customized posters and a webinar for librarians on how to effectively 

conduct outreach through partnerships, media, social media, and 

events. Staff at 6 of the 8 network libraries told us they wanted more 

guidance and assistance from NLS on outreach efforts such as these.

While NLS is making efforts to improve outreach, it has not collected 

information necessary to evaluate these efforts. NLS’s plan and ongoing 

efforts to improve outreach address a number of best practices for 

outreach that we have previously identified, such as researching the 

target audience, identifying stakeholders, obtaining feedback, and using 

multiple approaches.25 However, NLS has not developed a plan for 

assessing its outreach efforts, also a best practice we previously 

 25GAO, Social Security Disability: Additional Outreach and Collaboration on Sharing 

Medical Records Would Improve Wounded Warriors’ Access to Benefits, GAO-09-762

(Washington, D.C.: Sept. 16, 2009).
Page 15 GAO-16-355 Library Services for Those with Disabilities

identified.26 Generally, NLS officials told us they will judge the success of 

these new outreach efforts by determining whether there have been 

increases in the overall number of users, the number of users in particular 

target categories, and the number of visits to their website. However, 

these measures will not inform NLS as to which efforts directly resulted in 

new NLS users, which would help NLS allocate resources to those that 

are most cost-effective. Although staff we interviewed at 3 of the 8 

network libraries said they have tracked how users heard about their 

services for this purpose, NLS does not obtain such data centrally.

NLS offers its users several options for receiving both audio and braille 

reading materials, and the vast majority of NLS users choose to receive 

audio materials, primarily in the form of digital cartridges sent through the 

mail. NLS users may receive audio materials through the mail on digital 

cartridges or cassettes, download audio files from the Internet, receive 

hard copy braille documents through the mail, or download braille files 

from the Internet. According to NLS administrative data, almost 90 

percent of NLS users received digital cartridges during fiscal year 2014, 

with the majority playing these cartridges on specialized audio devices 

provided by NLS, and a much smaller number using other, commerciallyavailable devices.27 (See fig. 4.) About a third of NLS users continued to 

 26Such a plan would be consistent with best practices and communication strategies 

recommended to NLS as part of a market research study issued in 2014.

27NLS only provides users its own specialized players, not commercially-available 

devices, according to agency officials.

NLS Offers Materials 

in a Range of 

Formats, but 

Statutory and Other 

Limitations Impede 

Adoption of 

Potentially CostSaving Technologies

NLS Provides a Range of 

Reading Formats, but 

Most Users Choose to 

Receive Audio Materials 

Through the Mail
Page 16 GAO-16-355 Library Services for Those with Disabilities

receive cassettes through the mail, although this format is being phased 

out.28 Downloading from the Internet was less popular than receiving 

materials through the mail, with only about 10 percent of NLS users 

downloading audio materials through NLS’s online Braille and Audio 

Reading Download (BARD) system.29 BARD enables eligible users to 

search for and select audio files for immediate download rather than wait 

to receive materials through the mail. These files may be transferred to a 

digital cartridge and played on NLS’s specialized device, or downloaded 

directly to and played on a variety of commercially available devices, such 

as smartphones. A much smaller proportion of NLS users chose to 

receive braille materials, whether in hard copy or downloaded from BARD 

and read on a refreshable braille device that converts an electronic text 

file into braille characters.30

 28Before moving to its digital cartridges and players starting in 2009, NLS provided analog 

cassettes and cassette players. NLS is phasing out this technology and converting analog 

recordings to digital, but some users still listen to cassettes for certain content that is not 

yet available digitally.

29BARD was introduced in 2007, and was upgraded in 2013 to consolidate two separate 

systems for downloading braille and audio materials. We do not report data for fiscal years 

prior to 2014 due to a change in how NLS reports data on downloads. According to NLS 

officials, prior to fiscal year 2014, NLS’s data for audio downloads through BARD 

represented the number of users with BARD accounts who could potentially download 

materials. Starting with fiscal year 2014, according to NLS officials, the agency reported 

the number of users who actually downloaded audio materials. As a result of this change, 

trend data on the percentage of NLS users downloading materials through BARD are 

misleading.

30Refreshable braille devices, currently available commercially, rely on piezoelectric 

technology, meaning electric currents raise and lower plastic pins that form braille 

characters. After one line has been read, the display is refreshed to provide the next line 

of characters. As discussed later in this report, NLS does not provide its users with such 

devices.
Page 17 GAO-16-355 Library Services for Those with Disabilities

Figure 4: Percentage of NLS Users Accessing Reading Materials, by Format, Fiscal 

Year 2014

Note: Percentages do not add to 100 because NLS users may access reading materials through 

multiple formats during a fiscal year. This figure includes only users who were served in the United 

States by regional and sub-regional libraries. It excludes miscellaneous services, musical materials, 

and any materials sent to U.S. citizens living in another country.

Over the last 5 years, the majority of materials circulated to NLS users 

each year have been either digital cartridges or cassettes, although the 

number of items downloaded through BARD has been gradually 

increasing (see fig. 5). The number of digital cartridges has increased 

substantially since they were introduced in 2009, while the number of 

cassettes has declined as they are phased out. Meanwhile, the number of 
Page 18 GAO-16-355 Library Services for Those with Disabilities

audio files downloaded annually from BARD more than doubled between 

fiscal years 2010 and 2014. Among braille materials, there has been a 

shift away from hard copy to electronic braille.

Figure 5: Number of NLS Reading Materials Circulated to Users, by Format, Fiscal Years 2010-2014

Note: This figure includes only users who were served in the United States by regional and subregional libraries. It excludes miscellaneous services, musical materials, and any materials sent to 

U.S. citizens living in another country. Also, this figure does not include analog discs, as fewer than 

100 discs were circulated annually to users in recent years.

Most users’ preference for receiving materials through the mail and 

playing them on an NLS-provided specialized audio device appears to be 

linked to their level of comfort with technology and their access to the 

Internet, according to interviews and survey data. NLS designed the 

digital cartridges and players that provide users with audio books and 

magazines to be easy to see and handle for those with visual and other 
Page 19 GAO-16-355 Library Services for Those with Disabilities

disabilities.31 The program’s mainly older users feel comfortable with 

NLS’s specialized audio player because it is user friendly, according to 

staff at all 8 network libraries we contacted. For example, librarians in one 

state said many users like NLS’s player because it is durable and easy to 

use, and many—especially those who lost their vision later in life—do not 

feel as comfortable using commercially available audio devices. At the 

same time, younger NLS users—a minority of the customer base—may 

prefer to use other devices, such as smartphones, to access NLS audio 

materials, according to staff we spoke with at 6 of the 8 network libraries. 

Staff in one library said younger users tend to be more sophisticated in 

their use of technology, and prefer to use smaller, mainstream devices 

rather than the NLS player. (See fig. 6 for an image of NLS’s standard 

and advanced players and the commercial audio device which as of 

August 2015 had more registered NLS users than any other commercially 

available device.)

Figure 6: NLS Specialized Audio Players and a Commercially Available Audio 

Device

 31For example, the NLS player has no functions other than playing digital cartridges and 

has built-in audio instructions. NLS offers both a standard and an advanced version of the 

device; the advanced version has some additional features, such as bookmarking and 

navigating, which allow users to skip to different parts of an audio book.
Page 20 GAO-16-355 Library Services for Those with Disabilities

Furthermore, some users lack Internet access or do not feel comfortable 

downloading files from the Internet. According to NLS’s 2013 user survey, 

about 40 percent of those not using BARD cited lack of Internet access as 

a reason. Staff at all 8 network libraries told us that many of their NLS 

users lack access either to the Internet or a computer. For example, staff 

in one library told us many of their NLS users have low incomes, or are 

older with fixed incomes, and many, especially in more rural areas, lack 

the high-speed Internet connection needed for BARD. According to NLS’s 

2013 user survey, about 50 percent of sampled users who do not use 

BARD said they lacked the computer skills to do so. Similarly, staff in all 8 

network libraries we contacted said the process of downloading files from 

BARD onto a computer, and then transferring them to a cartridge that can 

be played on an audio device, is challenging for some users. For 

example, staff in one library said users have difficulty figuring out which 

folder to save downloaded files into on their computers. Recognizing this, 

NLS officials told us they expect in summer 2016 to introduce a new 

software application known as Media Manager intended to simplify the 

process of downloading from BARD onto a computer by handling a 

number of the steps automatically.

Meanwhile, the much lower use of braille compared to audio among 

NLS’s customer base may, in part, reflect the rate of braille use among 

blind people in the United States overall as well as characteristics of NLS 

users. The precise number of blind and visually impaired people who use 

braille in the United States is not known, according to a study on braille by 

LOC’s Federal Research Division32, as well as officials from two national 

organizations that produce braille materials and an assistive technology 

company we contacted. However, according to the LOC study, several 

estimates suggest that the proportion of blind and visually impaired 

Americans who use braille may be about 10 percent.33 According to a 

research and advocacy group for the blind and an organization that 

produces braille materials, braille use declined after many blind students 

were moved from specialized schools for the blind, which are more likely 

 32LOC Federal Research Division, The Current State of Braille Literacy and Electronic 

Assistive Braille Technologies (Washington, D.C: September 2014).

33The study cites, for example, data indicating that approximately 14 percent of visually 

impaired students used braille as their primary or secondary form of reading during fiscal 

year 2014, and a study from the 1990s that found less than 10 percent of blind and 

visually impaired adults used braille.
Page 21 GAO-16-355 Library Services for Those with Disabilities

to teach braille, into public schools.34 Another factor that has impeded the 

wider use of braille, according to an organization that provides braille 

materials and an assistive technology company we contacted, has been 

the high cost of refreshable braille devices, which sell for $1,000 to 

$2,000 at a minimum. Beyond reflecting braille use in the wider 

population, NLS users’ low use of braille may also reflect the specific 

demographics of the NLS population. Individuals who lose their vision 

later in life may be less likely to learn braille than those who were blind at 

an early age, according to staff from one library we contacted and a 2012 

NLS report.35

NLS is considering whether to adopt several new technologies for 

delivering braille and audio content to its users which have the potential to 

improve services and reduce costs. However, in one case—providing 

refreshable braille devices to its users—NLS’s efforts are hampered by 

limitations in its authorizing statute, among other factors. In two other 

cases—developing an audio player with Internet connectivity and adding 

synthetic speech materials to its audio collection—the agency has not 

taken steps to assess the potential cost savings resulting from alternative 

approaches.

Promoting braille is one of the broad goals included in NLS’s draft 

strategic plan for 2016 to 2020, and the agency believes providing braille 

electronically will help achieve that goal. According to a 2012 NLS 

report,36 braille is the literacy medium for those who are blind and visually 

impaired, as unlike audio, it is a direct corollary to print and displays 

features of print, such as capitalization and punctuation. This view is 

consistent with those of several other organizations we contacted, 

including a research and advocacy organization serving people who are 

blind. There is also some evidence suggesting that blind people have 

 34According to the U.S. Department of Education, as a result of IDEA—the precursor to 

which was enacted in 1970—the majority of children with disabilities are now educated in 

neighborhood classrooms with peers who do not have disabilities. 

35Library of Congress, Report of the National Library Service for the Blind and Physically 

Handicapped (Washington, D.C.: September 2012).

36LOC, Report of the National Library Service for the Blind and Physically Handicapped.

NLS’s Efforts to Adopt 

New Technologies Are 

Hampered by Limitations 

in Its Statutory Authority 

and Analyses of 

Alternative Approaches

Refreshable Braille Devices
Page 22 GAO-16-355 Library Services for Those with Disabilities

better employment outcomes if they use braille.37 NLS officials told us 

they believe that the ability to loan refreshable braille devices could attract 

more users to NLS. The agency has cited several advantages of this 

technology compared to hard copy braille, including that it is less bulky to

store and transport and can be delivered more quickly to users.38 (See 

fig.7 for images of a 13-volume hard copy braille book in NLS’s collection 

and an example of a refreshable braille device.)

Figure 7: Hard Copy Braille Book and a Refreshable Braille Device

 37LOC Federal Research Division, The Current State of Braille Literacy and Electronic 

Assistive Braille Technologies.

38LOC, Report of the National Library Service for the Blind and Physically Handicapped.
Page 23 GAO-16-355 Library Services for Those with Disabilities

However, NLS is currently unable to provide refreshable braille devices to 

its users due to statutory language that limits its use of appropriated 

funds. Since the 1930s, the statute has authorized NLS to use 

appropriated funds to provide braille materials to its users. However, the 

statute does not allow NLS to use such funds to provide users with 

devices for reading electronic braille files.39 Although the statute did not 

originally allow NLS to provide users with any playback equipment, in the 

1940s it was amended to allow NLS to provide devices for playing audio 

materials. In 2015, the LOC submitted a request to the Committee on 

House Administration and the Senate Committee on Rules and 

Administration to amend the law to allow it to use appropriated funds to 

provide playback equipment for formats in addition to audio recordings, 

including refreshable braille devices. In November 2015, legislation was 

introduced in the House of Representatives that would amend the law to 

allow NLS to use appropriated funds to purchase and provide to its users 

playback equipment for braille materials, among other things.40

The current cost of refreshable braille devices makes them costprohibitive for NLS; however, emerging technology may soon change 

that. As previously noted, several sources indicate that the current cost 

for these devices is about $1,000 to $2,000 at a minimum.41 According to 

one study we reviewed, the current technology used in these devices is 

effective, but it is also expensive to produce, in part because it relies 

heavily on manual assembly.42 However, efforts are underway to develop 

new refreshable braille technology that could significantly reduce the cost 

of these devices. For example, a consortium of organizations has 

supported research on refreshable braille technology and, according to 

one organization that has been involved in the effort, plans to unveil a 

 39The statute authorizes the use of appropriated funds for the provision of “books 

published either in raised characters, on sound-reproduction recordings, or in any other 

form,” and for “reproducers for such sound-reproduction recordings” (i.e., audio playback 

equipment), but contains no such authorization for the use of appropriated funds for the 

provision of other types of reproducers, such as refreshable braille devices. 2 U.S.C. § 

135a.

40H.R. 4093, 114th Cong.

41For example, the LOC Federal Research Division study examined several devices that 

ranged in cost from about $1,500 to about $3,600.

42Graham Bogda, Brendan Vishoot, Carl Grider, and David Schroeder, “Design and 

Testing of a Low-Cost Refreshable Braille Actuation Technology,” Journal of Engineering 

Technology (Spring 2011).
Page 24 GAO-16-355 Library Services for Those with Disabilities

prototype device in 2016 that could cost as little as $300.43 NLS hired a 

consultant to examine the potential costs and benefits associated with 

providing braille through lower-cost refreshable braille devices rather than 

hard copy. The resulting report, delivered in July 2015, found that the total 

annual cost of NLS’s current approach—including the costs for NLS to 

produce hard copy braille documents, for network libraries to store them, 

and for USPS to deliver them—is about $17 million. It found that if the 

cost of refreshable braille devices were to come down to about $400, then 

the total annual cost of an alternate approach in which NLS loans these 

devices to its users, and hard copy braille is largely replaced by electronic 

braille, could be about $7 million—a savings of almost $10 million per 

year compared to the current approach. According to standards for 

internal control in the federal government, agencies should identify, 

analyze, and respond to changes that may create the risk of not 

successfully fulfilling their missions, including changes in the 

technological environment.44 As long as its statute does not allow NLS to 

use appropriated funds to provide refreshable braille devices, NLS will not 

be able to take advantage of technological advances that could potentially 

help it fulfill its mission more cost efficiently.

NLS is in the preliminary stages of developing an audio player with 

wireless connectivity that could download audio directly from BARD, an 

approach that it believes would improve services for users and potentially 

reduce overall costs to the federal government. NLS officials said users 

would benefit from a device capable of downloading audio materials 

directly from the Internet because they would receive content faster than 

receiving digital cartridges through the mail. As noted above, there are 

obstacles to the wider use of BARD among NLS’s customer base, but an 

NLS-provided audio player with wireless connectivity could mitigate some 

of these issues. Specifically, such a device would eliminate the multi-step 

process now required to download BARD files to a computer and then 

transfer them onto NLS’s audio player. Staff we spoke with in 5 of the 8 

network libraries commented that downloading audio files directly to an 

NLS player would be simpler than the current process. In addition, NLS is 

 43An organization that produces braille materials told us new technologies being 

considered to bring down the cost of refreshable braille include pneumatics—i.e., pushing 

air through bendable tubes to raise braille characters—and ceramic materials that change 

shape.

44GAO, Standards for Internal Control in the Federal Government, GAO-14-704G

(Washington, D.C.: September 2014).

Audio Player with Wireless 

Connectivity
Page 25 GAO-16-355 Library Services for Those with Disabilities

considering how it might address another obstacle—lack of Internet 

access—by providing not just the audio player but also the required 

Internet connectivity.45 At the time of our review, the goal of providing 

users with a device capable of connecting directly to the Internet was 

included in NLS’s draft strategic plan, and NLS officials said they were in 

the process of hiring a business analyst and project manager to more fully 

assess the business case for moving forward with this effort. LOC officials 

told us they expect NLS to submit a proposal for this initiative to LOC’s 

Information Technology Steering Committee during fiscal year 2016.

As it considers moving forward with this effort, NLS is leaning toward 

designing its own next generation, specialized player, but it has not fully 

assessed the costs and benefits of designing its own player versus using 

a commercially available player. NLS officials said that, in their 

experience, the existing commercially-available players lack the durability 

needed for NLS’s purposes, may not be suitable for users with physical 

disabilities, and are expensive. Libraries for those with visual impairments 

in some other countries, meanwhile, have found that commercially 

available audio players can meet their users’ needs. For example, the 

CNIB Library, which provides free reading materials to those with visual 

and other disabilities in Canada, does not provide its own specialized 

device to users but instead helps them acquire commercially-available 

devices when they cannot afford to do so. CNIB officials said they chose 

this approach because it was less expensive than developing their own 

player, and also commented that it offers users a range of choices to 

meet their needs. Some libraries for the blind in Europe and Asia also 

purchase commercially-available audio players for library users, 

according to two assistive technology companies we contacted. NLS 

officials told us they have not ruled out using a commercially-available 

device as their next generation player, and while they have not yet 

analyzed this option, they plan to explore it further through requests for 

information and market research. We have previously found it is important 

for agencies to thoroughly analyze alternatives, including their relative 

costs and benefits, so they consistently and reliably select the project 

 45NLS has started to examine the costs of its current approach versus supporting wireless 

delivery for its users, and officials believe that wireless delivery may be less expensive 

than mail delivery through the Free Matter for the Blind and Other Physically Handicapped 

Persons program. NLS officials estimate that the majority of the cost of the Free Matter for 

the Blind program is associated with distribution of NLS materials. 
Page 26 GAO-16-355 Library Services for Those with Disabilities

alternatives that best meet mission needs.46 In a 2007 report, we found 

that when NLS developed its current digital audio player, it did not 

sufficiently consider the option of acquiring a commercially-available 

device designed specifically for those who are blind or have physical 

disabilities, and we recommended that NLS develop and document 

analyses of alternatives including commercial products.47 At that time, 

NLS did not act on our recommendation and take steps to consider 

commercial products. We continue to believe that without such an 

assessment, NLS runs the risk of not choosing the most cost-effective 

approach for providing its next generation of audio players.

Although NLS has relied exclusively on human narration to provide audio 

materials,48 text-to-speech—i.e., synthetic, computer-generated speech—

may be acceptable to many NLS users, according to interviews and 

survey data. According to several organizations we contacted that serve 

those with visual impairments and two studies we reviewed, the sound 

quality of text-to-speech has improved over time. For example, one study 

found that while not quite equivalent to natural human speech, state-ofthe-art text-to-speech is becoming more natural-sounding, with 

appropriate phrasing and pacing.49 In addition, evidence suggests that 

many NLS users may be willing to listen to text-to-speech materials. 

According to NLS’s 2013 user survey, almost 80 percent of sampled NLS 

users were willing to listen to text-to-speech audio materials. While staff 

at 4 of 8 network libraries we contacted said NLS users prefer human 

narration, staff in all 8 libraries said using text-to-speech is a viable option 

 46GAO, DOE and NNSA Project Management: Analysis of Alternatives Could Be 

Improved by Incorporating Best Practices, GAO-15-37 (Washington, D.C.: Dec. 11, 2014).

47GAO, Talking Books for the Blind, GAO-07-871R (Washington, D.C.: June 12, 2007).

48NLS uses recording studios to produce about two-thirds of the new audio books it adds 

to its collection each year, according to NLS officials. The other one-third are obtained free 

of charge from commercial publishers of audio books. NLS has agreements with several 

publishing houses to receive their new audio books. 

49David Evans and John Reichenbach, “Need for Automatically Generated Narration,”

BooksOnline ‘12 (October 2012). Another study found that people with visual impairments 

were more likely to accurately comprehend text-to-speech than sighted people, probably 

because those with visual impairments—especially older people—have more experience 

with text-to-speech. Konstantinos Papadopoulos, Evangelia Katemidou, Athanasios 

Koutsoklenis, and Eirini Mouratidou, “Differences Among Sighted Individuals and 

Individuals with Visual Impairments in Word Intelligibility Presented via Synthetic and 

Natural Speech,” Augmentative and Alternative Communication, Vol. 26(4) (December

2010).

Text-to-speech
Page 27 GAO-16-355 Library Services for Those with Disabilities

for certain types of NLS reading materials. In Canada, the CNIB uses 

text-to-speech for the front and back matter of the books it produces, and 

expects to incorporate more text-to-speech into its collection in the future. 

The CNIB website also has a link to a nonprofit organization that provides 

audio books primarily in text-to-speech format to those with visual and 

other disabilities, helping its users gain access to a collection of over 

250,000 audio books. In addition, one assistive technology company told 

us that libraries for the blind in Europe regularly use text-to-speech for 

newspapers and magazines, and they often use it initially for best-selling 

novels so they can provide these quickly to their users.

NLS officials are considering whether to supplement NLS’s audio 

collection with text-to-speech materials, but they have not assessed the 

costs and benefits of doing so, nor have they included moving forward 

with text-to-speech content as an objective in the agency’s draft strategic 

plan. NLS officials told us they might in the future use text-to-speech for 

certain types of reading materials for which human narration is less 

critical, such as reference materials, cookbooks, bibliographies, and 

endnotes. They said an advantage of text-to-speech materials is that they 

can be produced more quickly than human-narrated materials: Officials 

said it takes 3 to 4 months to record a book with human narration. Also, it 

may be less expensive to produce text-to-speech materials. Officials said 

it costs, on average, about $3,600 to record a book with a human 

narrator, and in fiscal year 2014 the agency spent $10.5 million on such 

recording. In contrast, they said it costs $75 to convert an audio book 

provided by a commercial publisher to NLS’s format, and they estimated 

that producing text-to-speech books might cost about the same. However, 

although NLS officials said they have done some preliminary 

experimentation to understand the high-level challenges of producing 

text-to-speech materials, and have hired a contractor to develop software 

for converting digital text files to text-to-speech files that meet NLS’s 

specifications, they have not made a decision about whether to move 

forward with text-to-speech. Furthermore, they have not yet 

comprehensively assessed the option of incorporating text-to-speech 

compared to relying solely on human narration, an assessment called for 

by best practices we previously identified for alternatives analysis.50 Thus, 

NLS lacks information about an initiative that has the potential to deliver 

content more quickly and cost effectively.

 50GAO-15-37.
Page 28 GAO-16-355 Library Services for Those with Disabilities

The NLS program provides accessible reading materials to those who 

cannot read standard print due to visual, physical, and other disabilities. 

Eighty-five years after the program was established, NLS is providing an 

important service to many older and visually-disabled adults, but it is also 

missing opportunities to meet the needs of all groups eligible for services. 

For example, the regulatory requirement that a medical doctor must 

certify eligibility for individuals with reading disabilities treats this group 

differently than other populations and creates an obstacle to receiving 

services. Likely because this requirement has remained largely 

unchanged for the past 40 years, it is inconsistent with currently accepted 

practices. Additionally, while NLS’s new outreach efforts have the 

potential to enhance awareness of its services among some eligible 

groups, NLS’s failure to evaluate these efforts means officials are unable 

to target funds to those efforts determined to be the most cost-effective, 

or make adjustments to those that are less effective.

Looking ahead, NLS is considering emerging technologies to meet user 

needs. Yet there are factors both beyond and within NLS’s control that 

may prevent the adoption of potentially cost-saving alternatives. For 

example, without a change in federal law, NLS will have to forego the 

opportunity to provide braille in a more modern and potentially costeffective manner by distributing refreshable braille devices to its users. 

Further, in the area of audio materials, NLS lacks the information it needs 

to make informed choices about whether and how to proceed with 

adopting certain new technologies. For example, if NLS continues its plan 

to design a specialized audio player that connects to the Internet, without 

assessing the alternative of instead providing commercially available 

devices to its users, the agency may potentially invest in a less costeffective option. Similarly, absent a comprehensive comparison of adding 

text-to-speech materials to its audio collection versus continuing to rely 

only on human narration, NLS may not make an informed decision about 

whether to move forward with a technology that has the potential to 

decrease the time and costs of providing new materials to users.

To give NLS the opportunity to provide braille in a modernized format and 

potentially achieve cost savings, Congress should consider amending the 

law to allow the agency to use federal funds to provide its users playback 

equipment for electronic braille files (i.e., refreshable braille devices).

Conclusions

Matter for 

Congressional 

Consideration
Page 29 GAO-16-355 Library Services for Those with Disabilities

1. To ensure that it provides all eligible populations access to its services 

and that its eligibility requirements are consistent with currently 

accepted practices, the Library of Congress should re-examine and 

potentially revise its requirement that medical doctors must certify 

eligibility for the NLS program for those with a reading disability 

caused by organic dysfunction.

2. To ensure funds are directed to the most cost-effective outreach 

efforts, NLS should evaluate the effectiveness of its outreach efforts, 

including the extent to which different outreach efforts have resulted in 

new users.

3. To help it determine the most cost-effective approach for its next 

audio player, NLS should comprehensively assess the alternatives of 

designing its own specialized audio player versus providing 

commercially available players to its users.

4. To help it determine whether to supplement its collection of humannarrated audio materials with text-to-speech materials, NLS should 

thoroughly assess the text-to-speech option versus continuing to 

provide only human-narrated materials.

We provided a draft of this report to LOC for its review and comment, and 

also provided relevant excerpts to USPS. In its written comments, 

included in our report as appendix I, LOC generally agreed with our 

recommendations and noted steps it plans to take to address them. For 

example, LOC agreed to reexamine and potentially revise its requirement 

that only medical doctors may certify NLS eligibility for people with 

reading disabilities to authorize other qualified persons to make such a 

certification. NLS has not predicted the increase in its users that may 

result from such a change, but it is exploring enhancements to its 

technological infrastructure that would support the increased demand for 

services that may result. With regard to our recommendation to evaluate 

its outreach efforts, LOC said it will look into implementing a new process 

for collecting data from network libraries on how NLS program users were 

referred to the program, as well as other ways of measuring the efficacy 

of various outreach approaches. Regarding our recommendations related 

to exploring new technologies, LOC indicated that NLS will thoroughly 

study various alternatives as it begins the process of developing the next 

generation of audio players, including the advantages and disadvantages 

of designing an NLS-specific player compared to using a commercially 

available player. LOC also indicated that NLS is exploring the use of textto-speech technology as a way to expand its offerings, and NLS will 

introduce this technology through a pilot program and solicit feedback 

Recommendations for 

Executive Action

Agency Comments 

and Our Evaluation
Page 30 GAO-16-355 Library Services for Those with Disabilities

from users and network libraries to assess their acceptance of this 

approach. LOC and USPS also provided technical comments, which we 

incorporated as appropriate. 

We are sending copies of this report to appropriate congressional 

committees, the Librarian of Congress, the Director of NLS, and other 

interested parties. In addition, this report will also be available at no 

charge on GAO’s website at http://www.gao.gov.

If you or your staff have any questions about this report, please contact 

me at 202-512-7215 or bertonid@gao.gov. Contact points for our Offices 

of Congressional Relations and Public Affairs may be found on the last 

page of this report. GAO staff members who made key contributions to 

this report are listed in appendix II.

Daniel Bertoni

Director, Education, Workforce, and Income Security Issues
Appendix I: Comments from the Library of 

Congress

Page 31 GAO-16-355 Library Services for Those with Disabilities

Appendix I: Comments from the Library of 

Congress
Appendix I: Comments from the Library of 

Congress

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Appendix I: Comments from the Library of 

Congress

Page 33 GAO-16-355 Library Services for Those with Disabilities
Appendix I: Comments from the Library of 

Congress

Page 34 GAO-16-355 Library Services for Those with Disabilities
Appendix II: GAO Contact and Staff 

Acknowledgments

Page 35 GAO-16-355 Library Services for Those with Disabilities

Daniel Bertoni, 202-512-7215 or bertonid@gao.gov

In addition to the contact named above, individuals who contributed to 

this report include Rachel Frisk, Assistant Director; Lorin Obler, Analystin-Charge; Nora Boretti, Leia Dickerson, Holly Dye, Alexander Galuten, 

Melissa Jaynes, Tammi Kalugdan, Bob Kenyon; Kaelin Kuhn, Dainia 

Lawes, Sheila McCoy, Almeta Spencer, and Walter Vance.

Appendix II: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments
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High Risk Series: An Update, GAO-15-290. Washington, D.C.: Feb. 11, 

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Talking Books for the Blind. GAO-07-871R. Washington, D.C.: June 12, 

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