Library Services for Those with Disabilities: Additional Steps Needed to Ease Access to Services and Modernize Technology
Published: 2016-04-04T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: 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.
section_title: What GAO Found
paragraphs: 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 opportunity to meet its users' needs more efficiently and cost effectively.
section_title: What GAO Recommends
paragraphs: 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.

section_title: Letter
paragraphs: 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. 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 1931, 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,  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.
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  library in Canada for those with visual and other disabilities. 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.
subsections: section_title: Background
paragraphs: 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.  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  service. 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.
subsections: section_title: NLS’s Structure and Administration
paragraphs: 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. 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.
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  preferred reading materials; store, maintain, and circulate NLS books and  machines; and report to NLS on equipment, books, and users. The  operating costs for these activities and services are not funded by NLS  but rather by state, local, and other sources.
section_title: Populations Eligible for NLS
paragraphs: Under LOC regulations, the following four categories of individuals are  eligible to access the NLS program:  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.
This refers to persons whose visual disability with correction prevents  the reading of standard printed material.
This refers to persons who are unable to read or unable to use  standard printed material because of physical limitations.
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  such reading disabilities may include dyslexia, attention deficit  disorder, autism, or developmental disabilities.
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.” 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.”
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  (IDEA) based on learning disabilities, and many of these students had  reading disabilities specifically. 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. 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.
section_title: NLS Users Are Primarily Older Adults with Visual Disabilities, but NLS Efforts Are Not Ensuring Full Access and Awareness
subsections: section_title: Older Adults with Visual Disabilities Make Up the Majority of Users, though an Eligibility Requirement May Limit Access of Potential Users with Reading Disabilities
paragraphs: 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. 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). 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.
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.
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  2010 to more than 20 percent in 2050, which may increase the number of  NLS’s older users.
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.  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  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 non- medical evidence. 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.
section_title: NLS Is Initiating New Outreach Efforts, but Does Not Collect Information Needed to Evaluate Their Effectiveness
paragraphs: 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.  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:  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. However, NLS has not developed a plan for  assessing its outreach efforts, also a best practice we previously  identified. 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.
section_title: NLS Offers Materials in a Range of Formats, but Statutory and Other Limitations Impede Adoption of Potentially Cost- Saving Technologies
subsections: section_title: NLS Provides a Range of Reading Formats, but Most Users Choose to Receive Audio Materials Through the Mail
paragraphs: 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, commercially- available devices. (See fig. 4.) About a third of NLS users continued to  receive cassettes through the mail, although this format is being phased  out. 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. 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.
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  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.
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  disabilities. 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.)
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 Division, 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. 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  to teach braille, into public schools. 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.
section_title: NLS’s Efforts to Adopt New Technologies Are Hampered by Limitations in Its Statutory Authority and Analyses of Alternative Approaches
paragraphs: 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.
subsections: section_title: Refreshable Braille Devices
paragraphs: 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, 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  better employment outcomes if they use braille. 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. (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.)
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. 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.
The current cost of refreshable braille devices makes them cost- prohibitive 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. 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. 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  prototype device in 2016 that could cost as little as $300. 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. 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.
section_title: Audio Player with Wireless Connectivity
paragraphs: 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  considering how it might address another obstacle—lack of Internet  access—by providing not just the audio player but also the required  Internet connectivity. 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  alternatives that best meet mission needs. 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. 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, 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-of- the-art text-to-speech is becoming more natural-sounding, with  appropriate phrasing and pacing. 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  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. Thus,  NLS lacks information about an initiative that has the potential to deliver  content more quickly and cost effectively.
section_title: Conclusions
paragraphs: 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 cost- effective 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 cost- effective 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.
section_title: Matter for Congressional Consideration
paragraphs: 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).
section_title: Recommendations for Executive Action
paragraphs: 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 human- narrated audio materials with text-to-speech materials, NLS should  thoroughly assess the text-to-speech option versus continuing to  provide only human-narrated materials.
section_title: Agency Comments and Our Evaluation
paragraphs: 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 text- to-speech technology as a way to expand its offerings, and NLS will  introduce this technology through a pilot program and solicit feedback  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.
section_title: Appendix I: Comments from the Library of Congress
section_title: Appendix II: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: In addition to the contact named above, individuals who contributed to  this report include Rachel Frisk, Assistant Director; Lorin Obler, Analyst- in-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.
section_title: Related GAO Products
paragraphs: Library of Congress: Strong Leadership Needed to Address Serious  Information Technology Management Weaknesses. GAO-15-315.  Washington, D.C.: March 31, 2015.
High Risk Series: An Update, GAO-15-290. Washington, D.C.: Feb. 11,  2015.
DOD and NNSA Project Management: Analysis of Alternatives Could Be  Improved by Incorporating Best Practices. GAO-15-37. Washington, D.C.:  Dec. 11, 2014.
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.
Talking Books for the Blind. GAO-07-871R. Washington, D.C.: June 12,  2007.