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

Letter

Background

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.

NLS’s Structure and Administration

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.

Populations Eligible for NLS

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.

NLS Users Are Primarily Older Adults with Visual Disabilities, but NLS Efforts Are Not Ensuring Full Access and Awareness

Older Adults with Visual Disabilities Make Up the Majority of Users, though an Eligibility Requirement May Limit Access of Potential Users with Reading 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. 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.

NLS Is Initiating New Outreach Efforts, but Does Not Collect Information Needed to Evaluate Their Effectiveness

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.

NLS Offers Materials in a Range of Formats, but Statutory and Other Limitations Impede Adoption of Potentially Cost- Saving Technologies

NLS Provides a Range of Reading Formats, but Most Users Choose to Receive Audio Materials Through the Mail

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.

NLS’s Efforts to Adopt New Technologies Are Hampered by Limitations in Its Statutory Authority and Analyses of Alternative Approaches

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.

Refreshable Braille Devices

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.

Audio Player with Wireless Connectivity

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.

Conclusions

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.

Matter for Congressional Consideration

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).

Recommendations for Executive Action

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.

Agency Comments and Our Evaluation

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.

Appendix I: Comments from the Library of Congress

Appendix II: GAO Contact and Staff Acknowledgments

GAO Contact

Staff Acknowledgments

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.

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