12. Professional assessments | Ontario Human Rights Commission – Ontario Human Rights Commission |

Many students who are at risk for a word-reading disability will never develop one if they are taught foundational reading skills using curriculum and instruction that reflect the scientific evidence, are properly screened in Kindergarten to Grade 2, and receive early evidence-based tier 2 and tier 3 interventions when screening identifies them as at risk. These students will be less likely to have mental health difficulties, such as depression and anxiety, and behavioural issues that are associated with falling behind in reading. With the changes recommended in this report, fewer students will need referral for professional assessments. This will shorten wait times for students who do need assessments, and free up school board psychology and speech-language pathology staff to support students in other ways. Parents will also be spared the burden of finding and paying for private professional services, assuming they can.
Universal early screening will flag students who need evidence-based structured literacy interventions (explicit and systematic programs that target phonemic awareness, decoding and accurate and quick word reading). If a student is not responding appropriately to such interventions, a professional assessment referral may be appropriate. This can happen as early as Grade 2, or following intense intervention in Grade 1. In the meantime, schools should provide more intensive interventions.
Currently there are long wait times for professional services, particularly psychoeducational assessments, in Ontario school boards. This is in part due to ineffective approaches to teaching reading, failing to identify students who are at risk in Kindergarten or Grade 1, and not providing these students with early, evidence-based interventions.
Some school boards either lack or have problematic criteria for identifying students who are having reading difficulties for board professional assessments. For example, there is a common, but incorrect, belief that a student must be in at least Grade 3 before they should be considered for a psychoeducational assessment for a reading disability. Most inquiry boards do not have centralized, transparent systems for maintaining and managing wait times. The order students are seen in is discretionary and may depend on which school or family of schools the student is in. There is a risk of bias and unfairness in selecting students for a board psychology assessment. Most inquiry boards are not following the Auditor General’s recommendations about how to better manage assessments to ensure timeliness and equity.
Professional assessments should not be required for interventions and accommodations, and all students who are waiting to be assessed should be receiving effective supports. Yet in practice, professional assessments help secure these supports. Because of the long wait for board assessments, parents who can afford to pay get private assessments. This creates a “two-tiered system” in a public education system that should be equitable for all.
Current criteria for a reading disability are also problematic. The Ministry of Education’s Policy/Program Memorandum 8: Identification of and Program Planning for students with Learning Disabilities (PPM 8) says that students must have “academic underachievement that is inconsistent with the intellectual abilities of the student (which are at least in the average range) and/or (b) academic achievement that can be maintained by the student only with extremely high levels of effort and/or with additional support.”[1167] The latest research or principles for diagnosing word-reading disabilities/dyslexia in the DSM-5[1168] do not require students to have “at least average intelligence” or a discrepancy between their ability and achievement. These criteria do not predict whether a student will respond to an evidence-based intervention.
Assessments for suspected reading disabilities do not always need a battery of intelligence and cognitive processing tests. Thoroughly assessing the student’s achievement compared to children of the same age can provide information about whether there is a reading disability/dyslexia, and inform the needed interventions. When a learning disability is identified or diagnosed, the subtype or area of impairment (for example, a learning disability in word reading/dyslexia) should be identified in the assessment and noted by the school board for better planning and tracking. Ontario’s definition of learning disability should recognize “dyslexia,” which is a useful label, and people should be able to self-identify using their preferred terminology.
In addition to assessments by psychologists, speech-language pathologists (SLPs) are integral to supporting the multi-dimensional nature of reading. Boards should use an interprofessional approach (for example, with educators, psychologists and SLPs) to assess and identify learning difficulties. As noted earlier, students need a strong foundation in both word recognition/decoding and language comprehension (oral language) to become skilled readers who understand what they read. Speech-language pathologists have expertise in oral language, evidence-based assessment, screening, and intervention planning in the area of decoding and oral language.
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As discussed in section 9, Early screening, students in Kindergarten to Grade 2 should be regularly screened using evidence-based screening tools that assess their reading accuracy and fluency. Screening in Kindergarten to Grade 1 should also include pre-reading skills that support word reading such as alphabetic knowledge and phonological awareness (with the focus on phonemic awareness).
If a student is flagged by these screening measures, evidence-based explicit and systematic interventions that target phonemic awareness, decoding and word reading should be implemented immediately (no later than Grade 1). These interventions should supplement, rather than replace, similar evidence-based classroom instruction.
This approach will significantly reduce the number of children who will still have reading difficulties. However, if a student is not responding after a period of evidence-based reading interventions, a child in later Grade 1 or in Grade 2 may be referred for a psychoeducational assessment. That is, if a student’s skills compared to others of the same grade and age on word-reading accuracy and fluency measures is not improving, further assessment may be appropriate. At the same time as considering assessments for such a student, interventions should become more intense (for example, more time; smaller group size; and more explicit instruction, cumulative review and supported practice). In other words, schools should not wait for the results of a psychoeducational assessment before providing more intensive intervention.
Example: A student in Grade 1 or 2 is scoring below the 15th percentile on word and/or non-word-reading accuracy and/or fluency at the beginning of a word-reading intervention. They remain at about the same place below the 15th percentile, after receiving the intervention in accordance with the program’s specific requirements, including adequate time and intensity. In other words, the student is not making significant progress compared to same-age peers. This student must receive more intensive intervention, and can be referred for psychoeducational assessment at the same time.
Example: A student in Grade 1 or 2 is scoring below the 15th percentile on word- and/or non-word-reading accuracy and/or fluency at the beginning of a word-reading intervention. The student improves significantly with the intervention. A further period of intervention, or a more intense intervention, may be appropriate before considering referral for psychoeducational assessment. If the student does not continue to improve after this further intervention (for example, if they start at the 5th or 10th percentile and do not move past about the 20th percentile), then a referral for psychoeducational assessment is appropriate. In either case, interventions should continue until the student comes into a solidly average range.
Example: A student in Grade 1 or 2 is scoring below the 15th percentile on word- and/or non-word-reading accuracy and/or fluency, but moves into a solid average range on both word-reading accuracy and fluency (for example, at or above the 25th to 30th percentile). They likely do not need a psychoeducational referral for word-reading difficulties. However, the student should be closely monitored over the next several school years to make sure their reading trajectory remains within the average range for their age and grade.
A student with severe word-reading difficulties who is not responding to appropriate interventions can be diagnosed in late Grade 1 or in Grade 2. If the student has not responded adequately to intensive, evidence-based interventions, it is not necessary or appropriate to wait until Grade 3 to refer them for psychoeducational assessment, although this is a common belief and practice. The student’s lack of response to an intervention, not their age, maturity or developmental level, is the information that should trigger decision-making around assessment. It is important that students waiting for assessment should always receive more intensive intervention immediately, regardless of when the assessment is completed. The critical window for early intervention should not be missed due to delays in being assessed.
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If a student is having, or is suspected of having, difficulty reading words accurately and/or fluently in late Grade 2 or later, it is very concerning as they should have been identified and given interventions sooner. Urgent steps are needed for such students. The student should be immediately tested using tests of word- and/or non-word-reading accuracy and fluency that compare that student’s performance to same-age peers (norm-referenced measures). If the results show the student is at or below about the 25th percentile, they should be immediately given an intense, targeted evidence-based intervention with proven effectiveness. Appropriate accommodations, such as assistive technology, to help the student have equitable access to learning materials and allow them to complete their work, should be provided and supported immediately. Studies have shown that students in late Grade 2 or beyond who are struggling with reading words accurately are much less likely to catch up to their peers in their reading fluency than students who received earlier interventions.[1169]
For children at Grade 3 and beyond, starting an intensive evidence-based intervention immediately is most important. At the same time as starting this intense and targeted evidence-based intervention, the student should be referred for a psychoeducational assessment if they have not been already.
Providing an accurate diagnosis sooner rather than later can provide valuable information for the students and parents. For example, it is often reassuring for them to understand the diagnosis and path forward. This may reduce some of the self-blame and emotional consequences that often accompany reading impairments.
Since there is often a wait for board psychoeducational assessments, if the student responds well to the interventions they are receiving and their reading difficulties, including reading fluency, are resolved, the assessment referral can be withdrawn or the psychologist can conduct the assessment based on simple reading measures alone.
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When a student needs a psychoeducational assessment based on the criteria listed earlier, the primary focus should be to assess the student’s current academic functioning in reading, writing and math.[1170] The assessment should also document the student’s past struggles in these areas and response to interventions, and identify further interventions or accommodations. If parents or educators raise concerns about other issues that are negatively affecting the child’s functioning, a psychologist can also investigate and identify possible co-existing difficulties or disabilities such as attention issues, developmental language disabilities, or mental health issues. However, a student with dyslexia must not be disqualified from receiving reading interventions because of co-existing disabilities (see also section 10, Reading interventions). The assessment could also note the student’s interests or self-reported strengths (for example, other academic areas, art, sports, music, etc.).
Psychoeducational assessments are often used to obtain a formal diagnosis (for example, for the IPRC process). However, under the Code, a professional assessment or diagnosis must not be required for a student to receive interventions or accommodations.[1171] The Ministry of Education (Ministry) has also recognized that a diagnosis is not a pre-requisite for special education supports:
The determining factor for the provision of special education programs or services is not any specific diagnosed or undiagnosed medical condition, but rather the needs of individual students based on the individual assessment of strengths and needs.[1172]
The Ministry’s definition for a learning disability, which includes reading “disorders” such as dyslexia, is set out in PPM 8.[1173] There are several concerns with the definition. First, it states that a student must have “academic underachievement that is inconsistent with the intellectual abilities of the student (which are at least in the average range) and/or (b) academic achievement that can be maintained by the student only with extremely high levels of effort and/or with additional support.”[1174] The Ontario Psychological Association’s (OPA) Guidelines for Diagnosis and Assessment of Learning Disabilities also states that a person must have at least average abilities essential for thinking and reasoning for a psychologist to diagnose a learning disability.[1175]
Similarly, the Association of Psychology Leaders in Ontario Schools includes this criterion in its Recommended Guidelines for the Diagnosis of Children with Specific Learning Disabilities.[1176]
Intelligence and discrepancies or inconsistencies between ability and achievement are not necessary criteria for identifying word-reading disabilities/dyslexia and planning for intervention.[1177] A student’s IQ does not influence their ability to respond positively to structured literacy interventions; that is, IQ test scores do not predict which students will benefit from evidence-based interventions and which will not.[1178]
There is no evidence showing that students with different IQ levels who are having word-reading difficulties use different cognitive processes for reading or have different patterns of errors.[1179] Also, there are no significant differences in the processes involved with reading between students who have a discrepancy between their IQ scores and their achievement, and students who do not.[1180] Nor are there any differences on measures of their brain imaging.[1181]
Leading researchers have known for some time that IQ tests are not necessary in evidence-based criteria for diagnosing learning disabilities in word reading/dyslexia. For example, in 2002, leading U.S. researchers stated:
We propose a rationale and procedures for more efficient approaches to the identification of children as learning disabled in reading or at-risk for these disabilities that are aligned with research on reading disabilities and other forms of LD. This approach emphasizes the assessment of academic skills and their components in an effort to develop intervention plans. Intelligence tests are not necessary for the identification of children as learning disabled and do not contribute to intervention planning. [Emphasis added.][1182]
Some seminal research and highly-cited articles about IQ tests for diagnosing learning disabilities came out of Ontario.[1183] Research has continued to find that using thinking and reasoning (most often measured by scores on IQ tests) and cognitive processing strengths and weaknesses as criteria for diagnosing word-reading disabilities/dyslexia is not necessary.[1184]
Another concern with PPM-8’s criteria is bias. Intelligence test results may be racially and culturally biased and favour upper- and middle-class students.[1185] One study with Canadian First Nations students in Grades 3 and 4 concluded:
Indeed, if a discrepancy definition had been employed for the purposes of identifying serious reading problems, a majority of the children from our sample would not have qualified for special needs funding based on IQ criteria and may not have received help.[1186] 
Indigenous participants also told the inquiry about their concerns that “colonial bias” can subconsciously affect decisions about whether to refer Indigenous students for assessments and the assessment process.
The OPA recognizes that full-scale IQ test scores may not be valid measures of thinking and reasoning for many people with learning disabilities, including people who are culturally and linguistically diverse, have experienced trauma, have minimal or no schooling or who may not have had experience with certain tasks such as two-dimensional puzzles, sorting by shape, and constructing and analyzing patterns.[1187] There are suggested guidelines for psychologists on how to use and interpret tests in a culturally responsive and anti-oppressive way.[1188]  While this is important, even assuming individual psychologists can always address any testing bias, this may be an insufficient response to the risk that using intelligence criteria may fail to identify a reading disability in some students from Code-protected groups.
Concerningly, PPM-8 also says that a student’s learning difficulties should not be “the result of…socioeconomic factors; cultural differences; lack of proficiency in the language of instruction…”[1189] As discussed throughout the report, low socioeconomic status, cultural differences and learning the language of instruction are not acceptable reasons for students to fail academically, although due to a culture of lowered expectations for such students, it may be seen as inevitable or beyond the control of the education system. Any student who is having word-reading difficulties should be given additional supports, and such factors should not be excuses for accepting children’s academic struggles. No student should be disqualified from receiving intensive reading interventions because of a definition of learning disability that excludes them based on cultural differences, low socioeconomic status or learning the language of instruction. If these students do not respond to intensive interventions, just like any other student, a diagnosis of a reading disability/dyslexia may be appropriate.
Another common practice is to administer cognitive processing tests to identify “patterns of strengths and weaknesses” or to look for discrepancies between overall IQ and cognitive processes.[1190] The validity of this approach has also been strongly contested, and the information gathered is not useful for informing a diagnosis of dyslexia or interventions for academic struggles in word-reading accuracy and fluency.[1191] Importantly, a particular cognitive profile or cognitive processing weaknesses do not predict who will benefit from reading interventions or what intervention strategy should be used.[1192] 
As a result of the research on learning disabilities, including dyslexia,[1193] the new edition of the DSM-5, released in 2013, eliminated the need for IQ tests as a routine part of assessments for reading disabilities/dyslexia. The DSM-5 recognizes that IQ tests need only be used where a global intellectual impairment is suspected and needs to be ruled out. The DSM-5 also does not require cognitive processing tests to determine “patterns of strengths and weaknesses” or cognitive processing deficits.[1194]
In the DSM-5, the diagnostic criteria for a “learning disorder” for school-aged children are:
Section 10 of the Ontario Human Rights Code (Code) states that a disability includes a “learning disability or a dysfunction in one or more of the processes involved in understanding or using symbols or spoken language.” A learning “disorder” or potential learning “disorder” triggers the obligation under the Code to provide special education services and supports. Therefore, PPM 8 should not contain additional requirements that students have at least average intelligence before the education system recognizes a learning disability. “At least average intelligence” should not be a criterion for receiving reading interventions or other supports.
Assessing a student for potential dyslexia/word-reading disability can focus on a thorough assessment of reading skills, including: phonemic awareness, decoding accuracy and fluency (for non-words), word-reading accuracy and fluency, spelling, text-reading fluency, reading comprehension, and can include a test of letter-naming fluency. Assessing the student’s understanding of syntax and morphology can also be informative. If academic issues are also present in writing and/or language comprehension, these areas should also be assessed. When there are concerns about a student’s adaptive functioning and global intellectual development, then the referral question is different and an intelligence test may be one of the assessment tools.
With evidence-based classroom instruction and early interventions, fewer students will need psychoeducational assessments for reading difficulties. Eliminating the intelligence criteria in PPM 8 reduces the need for IQ testing and tests of cognitive processes for students referred for evaluation of word-reading difficulties, which can streamline the assessment process. This will allow for more timely assessments of students with suspected reading disabilities who are not responding to interventions (as discussed above) and of students with other difficulties.
One of the inquiry school boards candidly acknowledged that the current approach to teaching reading and responding to reading difficulties unnecessarily contributes to increased demand for assessments by psychologists. The board wants to re-position its four psychologists to offer coaching on evidence-based instruction and intervention, but currently cannot because of the long wait list for psychoeducational assessments its psychologists must get through. This board recognized that some students are on the wait list for an assessment because they did not receive evidence-based classroom instruction and early intervention that would have addressed their reading challenges.
This report’s findings and recommendations should not be the basis for reducing psychology staff or budgets. School psychologists have an important role to play in addition to providing diagnostic assessments, including being available for consultation, counselling students, crisis response, referral to community-based services and providing professional development for staff.[1196]
School psychologists and SLPs can also provide guidance and help interpret school boards’ results on evidence-based early screening and evidence-based interventions; help determine which students need interventions and which interventions would be appropriate; help assess students’ response to intervention and assist with accommodation planning. Psychology staff can also deal with student mental health challenges such as anxiety and depression, and can help students experiencing social and emotional difficulties.
Focusing resources on complex diagnostic processes and separating students who are struggling to acquire academic skills into students with and without a learning disability has limited benefits. An article in the School Psychology Forum, a publication of the U.S. National Association of School Psychologists, noted:
Distinguishing a group of students who truly do have [a specific learning disability] in a stable and predictable way has been a significant hurdle to our field and actually ignores the larger question we should be asking, which is whether doing so actually brings benefit to the children for whom the diagnosis is made. In my view, these questions must be asked and answered in concert. To make the diagnosis when the diagnosis does not convey benefit is a miscarriage of justice as much as failing to make a diagnosis when doing so does convey benefit. Thus, the onus is on all school psychologists to bring improvements to the most vulnerable students, regardless of how they are categorized in our systems. One important reason to limit actions that do not produce a measurable return for their investment is that they carry an opportunity cost of time that could have been spent to benefit child learning.[1197] [Emphasis added.]
The inquiry heard similar concerns about the current focus on assessment and diagnosis. One special education teacher who completed the educator survey said:
I can’t speak for other school boards, but I see that in [my board] the focus for psychological services support has been on assessment. Surely educational psychologists should be able to provide expertise in providing intensive support in remediation of reading difficulties, and not just do assessments? More instruction and less assessment please!
A speech-language pathologist wrote:
I think there needs to be more emphasis on what can be done with screening and intervention without formal reports from professionals. This would allow for more students to be supported and for support to happen earlier. I believe speech-language pathologists and psychologists could help guide teachers with their screening and intervention and that this may be a better use of time. If SLPs and psychologists also employed a tiered approach to our interventions/assessments, this could mean more students getting the supports they need.
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In Ontario’s public education system, the umbrella term “learning disability” is used to identify all forms of learning disability including reading disabilities/dyslexia. Learning disabilities are not categorized by the area that is affected: word reading, reading comprehension, writing or math. The term “dyslexia” is almost never used, even though it is the most common learning disability.
Although PPM 8 notes that learning disabilities include difficulties developing and using skills in one or more of reading, writing, mathematics, and work habits and learning skills,[1198] it does not encourage or require identifying the academic area(s) that is impaired when a learning disability is diagnosed or where a student is identified as having a “learning disability” exceptionality through the IPRC process.
The OHRC asked school boards if they distinguish learning disabilities by subtype, and if they use the term dyslexia. We also asked them to provide information about students with reading disabilities specifically.
The inquiry boards reported that they use the definition of learning disability in PPM 8. However, one board uses the term “learning disorder” and the definition does not align with either PPM 8 or the DSM-5.
The boards reported that they do not identify the type of learning disability or students whose difficulties relate to reading, although they said psychologists’ assessment reports may identify the nature of the learning disability. The boards were not able to provide information about students with reading disabilities specifically, as they do not break down the category of learning disability any further to identify students whose academic difficulties relate to reading. Boards also said they do not use the term dyslexia because it is not used in PPM 8 and they believe that the term is not helpful or is confusing. Some suggested that the term dyslexia is misunderstood by “lay people” or does not provide as much information as the general term learning disability.
Only a few boards appeared to be aware that the DSM-5 does identify dyslexia as a subtype of “learning disorder” and says that “dyslexia is an alternative term used to refer to a pattern of learning difficulties characterized by problems with accurate or fluent word recognition, poor decoding, and poor spelling abilities.” Consistent with the inquiry’s findings, research has shown that teachers often misunderstand dyslexia or are confused by the policies in education systems,[1199] and may believe it is different than a word-reading disability (see also section 4, Context for the inquiry). In Ontario, this may be compounded by the failure to recognize dyslexia in PPM 8 and within Ontario faculties of education (see section 8, Curriculum and instruction).
Parents told the inquiry they often received psychoeducational assessments from school board or private psychologists that were confusing and difficult to understand, or failed to provide a clear diagnosis, indicate the subtype of learning disability, or use the term dyslexia. Parents of children with dyslexia reported that board staff did not believe or accept that dyslexia is a type of disability, and they were often told that the term dyslexia may not be used. For example, one parent said: “We have heard over and over that dyslexia isn’t real and honestly we gave up on our school.”
When a learning disability is diagnosed, there should be a statement of what academic area(s) is affected. For example, a diagnosis should indicate when there is a learning disability in word-reading accuracy or fluency (dyslexia); reading comprehension; written language composition/writing; or mathematics. If several areas are affected, they should all be identified. Further, when the learning disability is in word-reading accuracy and/or fluency, the term dyslexia should also be specified.
Contrary to the prevalent beliefs in Ontario’s education system, including the diagnostic label “dyslexia” is accurate and more specific and descriptive than the umbrella term “learning disability.” When dyslexia is identified, it makes a wealth of information readily accessible to parents, students and teachers. Many useful resources and websites written for families use the term dyslexia,[1200] as do many books, articles and Internet sites for educators within and outside of Canada.[1201] Not providing the “dyslexia” label in assessments and failing to recognize the term within the school system makes it harder for parents and teachers to make the connection and find these resources for supporting their children and students.
Recognizing the term “dyslexia” and ensuring educators know what it means will also reduce disagreements between schools and families. It is also consistent with the requirements of the Code that recognize the importance of people being able to self-identify and have their preferred identity respectfully recognized. Some may choose not to use the term “learning disability” or “learning disorder” due to the socially constructed stigma that can be associated with these terms.
One of the reasons school boards identified for not recognizing subtypes of learning disabilities or using the term “dyslexia” is that students may have impairments in other areas. For example, one board said:
We do not currently use [the term “dyslexia”] as the majority of the students who we diagnose with learning disabilities impacting reading have difficulties not only with accurate/fluent word recognition, decoding and spelling but also have additional issues with reading comprehension. Students with learning disabilities impacting written expression typically have issues not only with spelling but overall written expression skills (grammar, punctuation, clarity or organization of written work). We want to ensure clarity for parents about their child’s profile and its impact on learning. 
In addition to identifying dyslexia, assessment reports can clarify associated difficulties (for example, where the student has difficulties with reading comprehension solely because of their dyslexia) and other academic areas that are impaired (for example, where a student has language difficulties that have an impact on reading comprehension and writing that are separate or in addition to their word-reading difficulties). This is helpful for students, parents and educators.
Categorizing learning disabilities by the area of academic impairment and recognizing and using the diagnostic label “dyslexia” will also facilitate many of the functions of the education system, such as tracking the prevalence of disabilities in each area to inform resource allocation, tracking the effectiveness of interventions for students with dyslexia, and monitoring achievement for these students. This is currently not possible with the general category of “learning disability.” Collecting information on specific learning disability areas, rather than learning disabilities in general, is more useful and will provide more clear and accurate information for students, parents and educators.
There is support for identifying the specific learning disability and using the term “dyslexia” for the specific learning disability in word reading. Organizations such as Yale University’s Center for Dyslexia and Creativity, the International Dyslexia Association, Decoding Dyslexia and Dyslexia Canada call for using the term “dyslexia” within schools and education policies.[1202] In the U.S., the Individuals with Disabilities Education Act (IDEA) uses the term “specific learning disability” and includes dyslexia as one of the possible “disorders.”[1203]
In 2015, the U.S. Department of Education published a letter to address concerns that state and local educational agencies were reluctant to reference the terms dyslexia, dysgraphia and dyscalculia when developing individualized education programs under the IDEA.[1204] The letter clarified that nothing in the IDEA prohibits the use of these terms, and encouraged state and local education agencies to consider situations where it would be appropriate to use them.[1205] The letter stated there may be occasions where having the specific “disorder” (for example, dyslexia) listed in a student’s plan would be helpful for determining learning disability eligibility and program implementation.[1206] There are 47 states with dyslexia-specific laws. Many define dyslexia in their education codes, and 17 states have handbooks and resource guides specific to dyslexia.[1207]
The U.S. National Centre on Learning Disabilities (NCLD) has recognized that it is helpful to use specific terms such as dyslexia to help describe a child’s learning disability and capture and share information about the child’s challenges and needs. The NCLD states:
Appropriately including dyslexia, dyscalculia, and dysgraphia on a student’s IEP will help ensure that the instructional strategies, interventions, goals, and objectives outlined in the IEP match with the students’ specific needs.
That’s why NCLD believes it is appropriate to make specific mention of these subtypes of specific learning disabilities in an IEP.[1208]
The NCLD has emphasized the importance of parents and educators using the same language to reduce confusion and conflict and better support students. It has published a resource guide to facilitate communication between parents and educators about terminology.[1209]
A March 2020 update to the Ontario Psychological Association’s Guidelines for Diagnosis and Assessment of Children, Adolescents, and Adults With Learning Disabilities describes dyslexia as a subset of learning disabilities and states that “when appropriate, psychology practitioners could use the term dyslexia in addition to learning disabilities when providing a diagnostic formulation according to the OPA guidelines,”[1210] and “some individuals with [learning disabilities] may wonder whether they have dyslexia and, when appropriate, may find this diagnosis to be helpful because of the resources available to them in books or on websites.”[1211]
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There have been longstanding issues with board professional assessments. In 2017, the Auditor General of Ontario audited a sample of four school boards: the Toronto Catholic District School Board, Hamilton-Wentworth District School Board, Halton Catholic District School Board, and Hastings and Prince Edward District School Board. The Auditor General found:
The Auditor General reported that nearly one-quarter of students with special education needs in the four boards wait more than a year for psychoeducational assessments.[1213]
People for Education issues an annual report based on survey responses from school principals from English, Catholic and French schools across the province. Year after year, its reports have found issues with assessments. For example, in its 2018 report, People for Education said that based on surveying 1,244 school principals, 93% of elementary and 79% of secondary schools had students on wait lists. In 2018, 66% of elementary schools and 53% of secondary schools reported restrictions on the number of students who can be assessed. The restrictions are worse in rural areas, with 73% of rural elementary schools reporting restrictions, compared to 61% of urban schools. Some schools reported only being permitted to refer two students for assessment per year.[1214] This is an arbitrary cut-off that may not reflect the number of students who need to be assessed. This results in boards having to “triage” and refer only some students deemed to have the greatest needs.
People for Education has also noted that wait times for assessment vary based on the severity of student needs and the school board’s policy for wait lists.[1215]
Long wait times for assessment have also been the subject of media reports.[1216]
The Ministry told the inquiry that in 2018–19, it allocated one-time funding for special education professional assessments for all school boards. Boards had the flexibility to use the funding to:
Therefore, the Ministry has recognized that early intervention can reduce the need for assessments.
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The eight inquiry school boards were asked about their approach to referring students for psychoeducational assessments, and how they maintain and prioritize students who are waiting for assessment. They were asked for:
Based on its analysis of the materials provided and interviews with the boards, the OHRC identified several issues related to school boards’ approaches to psychoeducational assessments.
 
Approaches and criteria for referring students for psychoeducational assessments
In general, when classroom teachers, or sometimes parents or board staff, have concerns about a student’s academic difficulties, the school initiates a series of steps. The degree to which these steps are formalized and written down differs widely by board. For example, some inquiry boards have clearer documented procedures and flow charts or checklists, and identify some specific criteria used in making decisions about professional assessments. Other boards have little or no transparent documentation for the process or factors that are considered. One board only has a brochure for parents explaining psychoeducational assessments, but no written documentation on the process or criteria for considering a student for a psychoeducational assessment. This board’s general, vague criteria for deciding which students to refer for an assessment include “cultural, educational and developmental history; interventions tried; priority of need.”
Most inquiry boards reported that school teams, which often include special education staff and/or school specialists, have initial discussions about the difficulties the classroom teacher has observed, the steps that have already been taken, and other steps that can be tried. Most boards reported having a range of strategies the school team might implement, ranging from differentiated classroom instruction and accommodation to academic achievement assessment and educational assessments to determine if a student should have access to an intervention program. Boards said that as students progress through these steps and strategies, the school team considers whether to refer the student for a psychoeducational assessment. In some cases, board psychology staff are part of these team discussions, but in one board, one school board psychologist makes all the decisions about who will receive a psychoeducational assessment.
A concern with these approaches to determine who qualifies for assessments is the potential for wide differences between schools within a board, and among different school boards. Students with the same pattern of academic functioning may be candidates for an assessment at one school but not at another. This can be compounded when schools have restrictions on the number of students they can recommend. Although the inquiry school boards said that there are no formal restrictions on the number of students a school can put forward for assessment, several boards mentioned that limited resources do affect the number of students who can be assessed, which requires triaging of students based on greatest need. For example, one school board said: “[b]ased on current staffing capacity, there is a general understanding that each school should consider submitting 3 or 4 assessment packages each year.”
Educator survey respondents also confirmed there are limits to how many students per school can be referred for assessment. This is also consistent with People for Education’s finding that most school principals who respond to their yearly survey say there are restrictions on the number of students who can be assessed. Therefore, when students who need assessments are identified using a school-by-school approach, and there are practical limits on how many students each school can put forward, students who are in schools with more students who need assessment may miss out even if they need an assessment and would have been considered higher priority if they attended a different school.
Bias can also come into play when school teams or one or two board psychologists decide who will get an assessment instead of following consistent guidelines from the board or the province. Bias may also result when different factors are considered when deciding who to refer for an assessment. For example, one board reported that students’ poorer eye-tracking and sequencing skills, but good ability to understand spoken language, are considered in referring for psychoeducational assessments. Using these processing criteria (poor eye tracking and sequential skills) is not supported by research, and dyslexia occurs across the range of oral language comprehension abilities.
Other board materials emphasized that to have a learning disability, students must have a discrepancy between their ability and their academic achievement or average to above-average intelligence, and that staff could use informal judgements about whether a student meets these requirements when deciding whether to refer them for assessment. The notion that students must have at least average intelligence for a learning disability may result in students with higher perceived intelligence being more likely referred for assessment. The ability-achievement discrepancy criterion has been discredited.[1217]
Two boards said that cultural factors or cultural bias are relevant considerations without indicating how these factors are considered. One board said “[t]here are factors that might compromise the validity of an assessment, such as student engagement (motivation), mental health challenges, language proficiency, cultural bias,” suggesting that these factors would result in a student being less likely to be referred for assessment. This board did not indicate how it controls for cultural bias. Therefore, students from non-dominant cultures may be less likely to receive needed assessments.
It is also concerning that students who may be showing the common effects of having an unaddressed reading disability, such as decreased motivation or poor mental health, may be denied an assessment for these reasons. If assessments focus on academic skills and identifying the interventions and supports a student needs to increase their academic achievement and eliminate the routine use of IQ tests, it may help alleviate the risk of some of these biases.
The Ontario Association of Speech-Language Pathologists and Audiologists’ inquiry submission noted the importance of reducing bias in the process for selecting students for professional assessments, to make sure students from all equity seeking groups, particularly from intersecting Code-protected groups, have access to them.
Several boards reported delaying considering multilingual students who are learning the language of instruction at the same time as they are learning the curriculum (referred to as English Language Learners or ELLs) for an assessment until the student has at least two to three years of English language instruction. The Ministry’s Policy/Program Memorandum 59: Psychological Testing and Assessment of Pupils states:
If the pupil’s first language is other than English or French and/or the pupil lacks facility in either of these languages consideration should be given to postponing the assessment or, where possible, conducting the assessment in the child’s first language.[1218]
The Ministry’s 2007 Policy and Procedures for English Language Learners and ESL and ELD Programs and Services says that boards must develop a protocol for identifying multilingual students who may also have special education needs. If information from the student’s home country, from initial assessment or from early teacher observation, indicates the student may have special education needs, the student will be referred to the appropriate school team.[1219]
The inquiry heard that in practice, school boards commonly delay assessing multilingual students because they think their struggles are due to a lack of language proficiency or they cannot be assessed.
However, research on how language and reading skills develop shows that the skills that are part of learning to read words are the same for multilingual students as for students whose first language is English, and multilingual students who enter Ontario schools in the primary grades (Kindergarten to Grade 3) who do not have dyslexia quickly develop word-level reading skills.[1220]
Although some period of adjustment and exposure to the language of instruction (English or French) may be appropriate, most multilingual students become reasonably proficient after one year of exposure. If their performance is lagging behind after a year, assessing their academic performance should be considered.
Schools should be alert to the signs of a reading disability in multilingual students, and not delay intervention or assessment unnecessarily. They should not set rigid cut-offs for interventions or assessments, such as requiring a minimum of two to three years of English language schooling. Instead, several factors can be considered:
Multilingual students’ progress should be monitored with regular academic assessment. If they are not learning grapheme-phoneme correspondences to decode words and are not gaining word-reading accuracy and fluency skills, they should immediately receive intervention. If their skills are not improving with appropriately intense and sufficient time in an intervention, then they should be referred for a professional assessment. The inquiry heard that SLPs adopt culturally and linguistically responsive assessment protocols for multilingual students, which can help determine if a learning difficulty is due to a language difference or language disorder. A speech-language pathology referral should be considered for struggling multilingual students to evaluate the underlying language profile and its interplay with reading.
Two Ontario psychologists with expertise in culturally and linguistically diverse children, Dr. Esther Geva and Dr. Judith Wiener, note the importance of providing psychological services to children who face challenges from their cultural and linguistic diversity intersecting with learning difficulties:
Some of the culturally and linguistically diverse children and adolescents who struggle are those who, in addition to being second language learners and culturally different, have significant learning, behavioural, social and emotional difficulties and require the services of psychologists and other mental health professionals.[1222]
Traditional psychological assessments, including assessments that use intelligence testing, “may not be valid for many of these children.”[1223] However, there is research to guide psychologists to collect information that will allow them to assess and diagnose children from culturally and linguistically diverse backgrounds.[1224] 
Many educators and other professionals who work within school boards confirmed the scarcity of assessments and lack of transparent criteria. They noted that parental advocacy is often a factor in which students get referred for an assessment. For example, an educator survey respondent said that there are usually only one to three students per year referred for assessment in a school of 800 students, and the wait list for the school is at least 20 students. This educator noted that parents’ inability to pay for private assessment may be a factor, and parents’ ability to advocate for a board assessment may also help determine whether their child will get one. Many educators described ways schools triage students for assessment and said that students with reading difficulties are rarely identified as a priority:
Students with the highest behavioural needs are placed first. Students with reading challenges are recommended to seek private assessments as the wait is indefinite.
This was consistent with what many parents told the inquiry. They reported being told that their child would not be considered for an assessment, no matter how far behind in reading, as other students would be given priority.
Most inquiry boards reported they will generally not consider a student for a psychoeducational assessment until Grade 3 (or age eight). For example, one board said:
In general, psychoeducational referrals are made for students in [G]rade 3 and older. They are done to rule out the developmental phase or lag that students sometimes have up to age 8…Students must be in [G]rade 4 before we will assess. There are special cases where this might not be the case.
The same board said it requires psychoeducational assessment and diagnosis to provide a student with its most intensive intervention.
Survey responses from students, parents and educators confirmed that Ontario school boards do not consider referring students for psychoeducational assessments until at least Grade 3, and students often do not receive them until Grade 5 or 6. They reported that students must be in at least Grade 3 or 4 and “well below grade level” before referral for a psychoeducational assessment will be considered. This results in students getting assessed far too late.
The OPA has clearly stated that delaying assessment is not necessary or appropriate:
Historically, assessments for considering diagnoses of LD were discouraged until [G]rades three or four. Delaying would account for developmental and environmental variability in the early years, as well as for the lack of tools available to assess young children…The practice of postponing assessments was also influenced by the now highly-discredited ability-achievement discrepancy criteria, and the reality that children had to be a certain age for such discrepancies to be documented…With advances in test construction, knowledge of early risk factors associated with LD, and expertise among clinicians in evaluating young children effectively, there have been many gains in our ability to assess neurocognitive development and learning during the early academic years…While risk factors may be identified at earlier stages of development, once a child is receiving formal schooling, academic difficulties can be reliably assessed and diagnosis of LD may be considered.[1225] [Emphasis added.]
The OPA also recognizes the harm that can result from delaying assessment:
…if a child is struggling academically and has gone unidentified or unsupported during [G]rade one, assessment to indicate the nature of difficulties to guide intervention is essential to emphasize and advocate for the child’s needs. Waiting until the end of grade two misses an evidence-based window of opportunity for intervention and may reduce the effectiveness of future interventions.[1226] [Emphasis added.]
The DSM-5 criteria for diagnosing a learning “disorder,” including in reading, do not require that students be in Grade 3 or older.
Delaying referral for assessment until at least Grade 3 combined with wait times for assessments mean that many students do not get assessed until Grades 4, 5 or later. If students are not receiving evidence-based intervention while waiting, the critical window of opportunity to address their reading skills is missed. As described in this section, students who are not responding to interventions should be considered for assessment as early as late Grade 1 and should receive more intense evidence-based interventions while they are waiting to be assessed.
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Wait list management and wait times for psychoeducational assessments
Consistent with the Auditor General’s 2017 audit findings, the inquiry found that most inquiry boards do not maintain centralized wait lists. Only two of the boards, Hamilton-Wentworth and Thames Valley, reported they maintain a centralized, electronic wait list. London Catholic reported that individual psychology staff members maintain and manage the assessment wait list for their families of schools, but as of June 2019 it has started maintaining a central Excel spreadsheet so it can calculate mean wait times.
The few inquiry school boards that do maintain a central electronic wait list were better able to report on the average number of days students are waiting for an assessment, once referred.
The other inquiry school boards all reported that wait lists are either maintained at the school level or by the psychology staff person responsible for that school or group of schools. One very large school board said:
Each school prioritizes a list of students recommended for assessment. This list can be fluid – as learning needs of students may change over time based on their response to targeted support and intervention. Currently, at the board level, we are not able to identify the date on which students are added to the wait list nor their grade level.
As a result, this board was not able to provide the OHRC with requested information about wait times. Several other boards were also not able to provide any information on students waiting for assessment.
The inquiry boards have limited or no ability to reallocate students between psychology staff to make sure a student does not wait too long for assessment as recommended by the Auditor General.
In 2017, the Auditor General said failing to maintain central wait lists and make sure that students are not waiting too long based on the school or group of schools they are in is an equity issue:
Without a central consolidation of wait lists and reallocation of cases, services related to psychological assessments cannot be provided to students in an equitable and more timely manner.[1227]
Despite this, most of the inquiry boards are not following the Auditor General’s recommendations. They have not addressed the potential for wait times to vary “significantly based on the school the student attends,”[1228] or addressed the Auditor General’s concern that ‘’because the wait-list information is not consolidated, the board cannot properly prioritize students for assessments.”[1229] The boards also lack any data that would allow them to assess whether they are providing this service in a timely and equitable way.
Wait times for psychoeducational assessments
The OHRC asked the school boards to provide data about wait times for psychoeducational assessments. There were significant issues with the information provided.
Students are typically only put on an assessment wait list after the psychology department receives the referral package. However, this does not necessarily reflect how long the entire referral process takes. Board wait lists do not appear to reflect the actual amount a time a student may be waiting for an assessment after concerns about them are identified.
Only six of the eight boards were able to provide a list of students waiting for assessment.[1230] This information was inconsistent and difficult to analyze. Some boards were able to provide the specific date a student was placed on a list, while one board only provided the year. One board was able to provide a list with specific dates for both when a student was put on the list and when they were assigned a psychoeducational assessment (however, this does not mean that the assessment was completed on the day it was assigned). All other school boards provided a list of students waiting for a psychoeducational assessment as of the day the data was retrieved. One board provided the students currently waiting but did not indicate the date the data was retrieved.
Seven out of eight school boards provided an average time for how long students are waiting before receiving a psychoeducational assessment (or before getting assigned to one; this was unclear from the data provided). How boards calculated this was unclear and inconsistent. Most inquiry boards provided a number of months as the average time (for example, six months). These boards did not indicate how they calculated this time (including whether they counted the summer months) and most of these average times seem to be an estimate and not exact values. For example, one board said four to five months; another said two-and-a-half months if a student is placed on the list early in the school year; and another one said the average time was “typically within one year.” However, this board does not maintain a wait list so it was not clear what information it used to generate this estimate.
One school board that reported maintaining a central electronic wait list was able to provide a more precise average time and a median time on the wait list. Another board that also reported maintaining a central wait list provided an average based on the number of calendar days.
Students at several school boards were waiting years for an assessment. In five of the six boards that provided lists, there were students waiting 600 days or more. The OHRC also compared the data provided to the board’s self-reported average wait time and found that many students are waiting longer than the self-reported average wait time. In two of the six boards where data was available, more than half the students waiting for a psychoeducational assessment had been waiting longer than the board’s average reported time for receiving an assessment.
The Ministry told the inquiry that boards’ Special Education Plans are supposed to include information on managing wait times for assessments. However, the Ministry said it “has little information/data on wait times and wait lists in individual boards.” It said that the evidence it has collected to date suggests:
Despite recognizing these issues, it was not clear whether the Ministry has plans to require boards to improve their approaches to managing and collecting data on wait times for professional assessments.
In its inquiry submission, the Ontario English Catholic Teachers’ Association noted persistent issues with students not being able to access professional services and supports.
The Ontario Association of Speech-Language Pathologists and Audiologists emphasized the urgent need to implement the Auditor General’s recommendations about wait lists and wait times. It emphasized the importance of an infrastructure (for example, electronic case management) to manage wait lists, assessments and interventions. It also stressed that boards should remove barriers, such having to travel long distances, for students and families to access professional assessments. It recommended boards consider providing transportation and conducting virtual assessments, as appropriate.
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Professional assessments should not be needed to get supports, but often are
Professional assessments should not be a pre-condition for a student to receive intervention, accommodation or other special education supports. Yet, the inquiry found that they are often required, even if official board policies do not say so. Most inquiry school boards said they do not require a professional assessment such as a psychoeducational assessment or a formal diagnosis for a student to be offered a reading intervention or most forms of accommodation. However, it is concerning that one board said that a psychoeducational assessment with a formal learning disability diagnosis is required to access EmpowerTM Reading. This is even more troubling since students in this board face unique challenges obtaining board or private professional assessments due to geography, and because it is very hard to attract and retain professionals to work in the area. Other boards said students with a diagnosis are more likely to be included in EmpowerTM Reading groups.
Where parents pay for private psychoeducational assessments, some boards require their school board psychologists to vet the assessment before the board will implement recommended interventions and accommodations. Boards said this is to make sure they have the capacity and ability to incorporate the report’s recommendations in the classroom. Parents reported that this can result in delays in obtaining services for students and expressed their frustration that they had to pay for a private assessment because a board assessment was not available, but still faced barriers in having their child’s professionally identified needs addressed. Boards should consider whether it is necessary for board psychologists to routinely review the work of another psychologist who has assessed the student to determine whether the types of interventions and accommodations are available in the board, or if other board staff could fulfill this role.
The inquiry heard that even where boards say assessments are not needed to access supports, the reality is much different. Survey responses from students, parents and educators across Ontario noted that assessments are often required or perceived to be required to receive reading interventions and accommodations.
It is concerning that 41% of respondents to the survey for educators and other professionals said that a psychoeducational assessment should sometimes (37%) or always (4%) be required to receive reading interventions. They said that in practice, they are typically always (6%) or sometimes (37%) required to receive interventions. Many parents (42%) reported that assessments were required for their child to receive reading interventions compared to 45% who said that an assessment was not required, and 13% who said they did not know whether an assessment was required to receive the reading intervention.
A significant proportion (39%) of respondents to the survey for educators and other professionals also said that a psychoeducational assessment should sometimes (35%) or always (4%) be required to receive accommodations. Many (44%) of educator survey respondents said that they are typically required to receive accommodations. A large proportion of parents (72%) reported that a professional assessment was needed for their child to receive accommodations.
 
Lack of interventions and accommodations while waiting
The OHRC asked boards whether students with suspected reading disabilities awaiting assessment had IEPs and were receiving interventions and accommodations. Boards said that most, but not all, students waiting are receiving some form of supports. However, it was not clear if these supports were evidence-based interventions. Only one board clearly stated that it follows an RTI model and identified the interventions it provides while students are waiting for assessment. Every student with a suspected reading disability should be receiving a tier 2 or tier 3 intervention, and any needed accommodations, while they are waiting to be assessed.
Since assessments are often needed to get interventions and accommodations, it is not surprising that the inquiry heard that in practice, many students do not receive interventions and accommodations while awaiting assessment. One parent said:
The system is failing kids. You need the assessment to get resources and accommodations. But no kid is getting put forward for this until Grade three. Dyslexia needs early and consistent intervention. My daughter developed heart-breaking negative self concept and aversion to trying new things in her first years of school. We are lucky to have the knowledge and resources to have somewhat helped her. She still struggles incredibly at school and is still healing from how she sees herself and her learning. It truthfully makes me cry thinking of other kids who are unidentified and ineffectively supported.
The Ontario English Catholic Teachers Association reported that students who have not gone through the IPRC process often do not get special education support:
While the Ontario Human Rights Commission (2018) policy says that schools should provide accommodations for any student with a disability, regardless of whether they meet the Ministry of Education’s definition of “exceptionality,” it is still the prevailing practice that only students with identification through the formal Identification, Placement, and Review Committee (IPRC) process are automatically provided with special education support. Because school boards are struggling to provide supports for the students who have already been identified, they are often reluctant to go through the IPRC process.…As a result, students often go far too long without their learning needs being acknowledged, which means they do not get the proper interventions while they are awaiting identification, and it is more difficult to build new skills or change attitudes when identification finally happens.
Students and parents also reported that an IRPC was required to receive interventions and accommodations. Many students with reading disabilities who have not had a formal assessment will not have gone through the IPRC process. This is more pronounced for multilingual students. Significantly fewer multilingual students in Ontario have an IPRC learning disability identification compared to other students.[1231] Students who have not gone through the IPRC process may be less likely to receive accommodations and interventions than students who have.
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Professional staff shortages
The inquiry heard about challenges finding and maintaining staff to provide services needed to support special education needs. The Ontario Catholic School Trustees’ Association noted that the shortage of speech-language pathologists and psychologists is “a significant challenge to many rural and northern boards across the province. This affects the timeliness of conducting various health and psychological assessments for students.”
People for Education has noted that smaller, rural and northern boards also face challenges due to funding formulas that are tied to enrolment:
Small town/rural boards, which typically have lower enrolment, may be at a disadvantage when it comes to hiring professionals and para-professionals such as psychologists, social workers and child and youth workers. As is the case with most education funding, boards receive funds for these staff based on enrolment. …Boards with lower enrolments may be making decisions about which types of support staff to employ based on finances rather than need.[1232]
In another recent report, People for Education estimated that schools in northern and rural boards have limited access to psychologists compared with schools in the Greater Toronto Area.[1233] This is consistent with what we heard from several inquiry school boards.
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The OHRC makes the following recommendations:
111. The Ministry of Education (Ministry) should work with external expert(s) to immediately revise PPM 8 to align with the research and DSM-5 criteria, and to address any potential biases. This includes:
The Ministry should also work with external expert(s) to re-examine all exceptionality definitions, such as the definition for intellectual disabilities, based on the changes to PPM 8, and should ensure that the criteria for other exceptionalities do not exclude these students from receiving instruction and supports.
 
112. PPM 8 should reflect the current DSM-5 criteria that require showing:
 
113. The Ministry should amend PPM 8 to explicitly state that students do not need to be a certain age or grade level to be considered for assessment. It should direct school boards not to delay identifying learning difficulties and should state that students who are not benefiting from early evidence-based structured literacy interventions should be considered for assessment by end of Grade 1.
 
114. The Ministry should amend PPM 8 to encourage identifying the subtypes of learning disability/academic areas that are impaired, and explicitly recognizing the term “dyslexia” for learning disabilities that affect word reading and spelling.
 
115. School boards should change their definitions of learning disabilities and align their practices for recognizing learning disabilities to be consistent with the revised PPM 8.
 
116. The Ontario Psychological Association’s Guidelines for Diagnosis and Assessment of Learning Disabilities and the Association of Psychology Leaders in Ontario Schools Recommended Guidelines for the Diagnosis of Children with Learning Disabilities should also be updated to make the assessment guidelines for dyslexia/learning disabilities in word reading consistent with current DSM-5 requirements, including by removing the requirement for at least average intelligence (or at least average abilities for thinking and reasoning) or a discrepancy/inconsistency between intellectual abilities and achievement. They should recommend limiting or eliminating the routine use of routine intelligence and cognitive processing tests for assessing students for word-reading disabilities/dyslexia.
 
117. The criteria for identifying students with a learning disability in word reading should apply to students learning in French, and these students should have equitable access to professional assessments.
 
118. The Ministry should revise Policy/Program Memorandum 59: Psychological Testing and Assessment of Pupils, to remove the statement that school boards should consider delaying assessment if the pupil’s first language is other than English or French and/or the pupil lacks facility in either of these languages. Instead, the Ministry should work with external expert(s) to set out factors for determining whether to refer a student whose first language is not English or French for psychoeducational assessment.
 
119. School boards should create clear, transparent, written criteria and formalize their processes for referring students with suspected reading disabilities for psychoeducational assessment based on the young student’s response to intervention (RTI). The criteria should recognize that any young student who has not responded appropriately (based on measures of word and/or non-word-reading accuracy and/or fluency and text-reading fluency and comprehension), after a period of classroom instruction and early evidence-based intervention should be referred for a psychoeducational assessment. Older students (beyond Grade 2) who have word-reading accuracy and fluency difficulties should be referred for assessment immediately. Young and older students should receive more intensive evidence-based interventions while they are waiting to be assessed. Speech-language pathologists can be a resource for assessments for all students with reading difficulties, particularly when there are concerns about language development and to help determine if a student has a language disorder.
 
120. The criteria should account for the risk of bias in the selection process, particularly for students who are culturally and linguistically diverse, racialized, who identify as First Nations, Métis or Inuit, or who come from less economically privileged backgrounds. School boards should regularly assess whether students from Code-protected groups are receiving equal access to professional assessments.
 
121. School boards should remove barriers to students receiving professional assessments, such as by providing transportation and virtual assessments, where appropriate, valid and reliable.
 
122. School boards should eliminate any limits on how many students can be referred for assessment. Any student who meets the criteria should be referred for assessment.
 
123. School boards should stop requiring students be a certain age or grade level before being considered for assessment.
 
124. School boards should stop requiring multilingual students to have a minimum number of years of learning English or French before referring them for assessment. Instead, school boards should regularly monitor the progress of these students, and if a student is having difficulty, consider the relevant factors, based on the guidance in this report and any revisions to PPM 59, in deciding whether to refer for assessment. If the student is still struggling after one year of exposure to English/French, a detailed assessment of reading, spelling, writing and mathematics is appropriate. Special attention should be paid to analyses of successes and errors.
 
125. School boards should immediately stop requiring a psychoeducational assessment for interventions or accommodations.
 
126. School boards should track students by the learning disability/academic area that is impaired, and should explicitly recognize the term dyslexia for learning disabilities that affect word reading and spelling.
 
127. The Ministry of Education (Ministry) should require school boards to implement the recommendations identified in the 2017 Office of the Auditor General of Ontario’s report on School Boards’ Management of Fiscal and Human Resources.[1234] To make sure assessments are completed in an equitable and timely manner, school boards should:
 
128. The Ministry should monitor school boards’ compliance with these requirements.
 
129. The Ministry should adopt the Accessibility for Ontarians with Disabilities Act, 2005 Kindergarten to Grade 12 Education Standards Development Committee’s recommendations related to professional assessments.[1235] For example, the Ministry should implement the recommendation to create a standardized provincial rubric for documenting the number of professional and specialist assessments provided by each school board annually that includes information on the prioritization criteria used in referring students for assessments and the length of time from when the need for assessment is identified to when the assessment is completed.[1236] Boards should implement the recommendation to publicly report on an annual basis data related to professional assessments.[1237]
 
130. The Ministry should provide stable, enveloped yearly funding for professional services that boards can use to develop infrastructure, such as electronic case management information systems; create wait lists where they do not yet exist; manage wait lists and track professional assessments; respond to professional staff shortages; and complete assessments in a timely way.
 
[1167] PPM 8, supra note 209.
[1168] RJ McGill et al, “Cognitive profile analysis in school psychology: History, issues, and continued concerns” (2018) 71 Journal of School Psychology 108 [McGill et al, “Cognitive profile analysis”]; Fletcher et al, “Assessment of reading and learning disabilities,” supra note 1077; RJ McGill et al, “Critical issues in specific learning disability identification: What we need to know about the PSW model” (2016) 39:3 Learning Disability Quarterly 159 [McGill et al, “Critical issues in specific learning disability identification”]; Miciak et al, “Patterns of cognitive strengths and weaknesses,” supra note 1077; RJ McGill & RT Busse, “When theory trumps science: A critique of the PSW model for SLD identification” (2017) 21:1 Contemporary School Psychology 10 [McGill & Busse, “When theory trumps science”]; L S Siegel, “IQ-discrepancy definitions and the diagnosis of LD: Introduction to the special issue” (2003) 36:1 Journal of Learning Disabilities 2 [Siegel, “IQ discrepancy definitions and the diagnosis of LD”]; Linda S Siegel, “IQ is irrelevant to the definition of learning disabilities” (1989) 22:8 Journal of learning disabilities 468 [Siegel, “IQ is irrelevant to the definition of learning disabilities”].
[1169] J K Torgesen et al, “Principles of fluency instruction in reading: Relationships with established empirical outcomes” in M Wolf, ed, Dyslexia, fluency, and the brain (Parkton, MD: York Press, 2001) 333; Metsala & David, “The Effects of Age and Sublexical Automaticity,” supra note 1044; Metsala & David, “Improving English Reading Fluency and Comprehension,” supra note 1044.
[1170] Reading, writing and math are all looked at because it is important to analyze whether the reading difficulties affect other areas, and academic difficulties in writing and math can co-exist with reading disabilities.
[1171] OHRC, Policy on accessible education for students with disabilities, supra note 7 at 25, 78.  For a discussion of the issues with requiring a diagnosis for accommodation in the post-secondary context, see: OHRC, With Learning in Mind, supra note 6.
[1172] PPM 8, supra note 209 at 4.
[1173] PPM 8, supra note 209.
[1174] Ibid at 2.
[1175] OPA, Guidelines for Diagnosis and Assessment of Children, Adolescents and Adults with Learning Difficulties, supra note 35.  The Association of Psychology Leaders in Ontario Schools (APLOS) Recommended Guidelines for the Diagnosis of Children with Learning Disabilities also follow this approach; see: Bill Colvin et al, “Recommended Guidelines for the Diagnosis of Children with Learning Disabilities” (updated September 2017), online (pdf): The Association of Psychology Leaders in Ontario Schools static1.squarespace.com/static/56ba66df62cd9459e3f6a88f/t/59c900298fd4d2c4919234e9/1506345003448/Recommended+Guidelines+for+the+Diagnosis+of+Children+with+Learning+Disabilities-Sept2017.pdf.
[1176] Bill Colvin et al, “Recommended Guidelines for the Diagnosis of Children with Learning Disabilities” (November 2016), online (pdf): The Association of Psychology Leaders in Ontario Schools https://static1.squarespace.com/static/56ba66df62cd9459e3f6a88f/t/585033c4197aea04b25dc1f9/1481651141827/Guidelines+for+the+Diagnosis+of+LD+-+Draft+Nov+23+2016+.pdf [Colvin et al, “Recommended Guidelines – 2016].
[1177] McGill et al, “Cognitive profile analysis,” supra note 1168; Fletcher et al, “Assessment of reading and learning disabilities,” supra note 1077; McGill et al, “Critical issues in specific learning disability identification,” supra note 1168; Miciak et al, “Patterns of cognitive strengths and weaknesses,” supra note 1077; McGill & Busse, “When theory trumps science,” supra note 1168; Siegel, “IQ discrepancy definitions and the diagnosis of LD,” supra note 1168; Siegel, “IQ is irrelevant to the definition of learning disabilities,” supra note 1168.
[1178] K K Stuebing et al, “IQ is not strongly related to response to reading instruction: A meta-analytic interpretation” (2009) 76:1 Exceptional children 31; Morris et al, “Multi-Component Remediation,” supra note 1035; K K Stuebing et al, “Validity of IQ-discrepancy classifications of reading disabilities: A meta-analysis” (2002) 39:2 American Educational Research Journal 469.
[1179] LS Siegel, “Evidence that IQ scores are irrelevant to the definition and analysis of reading disability” (1988) 42:2 Canadian Journal of Psychology/Revue Canadienne de Psychologie 201.
[1180] JM Fletcher, “The validity of discrepancy-based definitions of reading disabilities” (1992) 25 Journal of Learning Disabilities 555; LS Siegel, “An evaluation of the discrepancy definition of dyslexia” (1992) 25:10 Journal of Learning Disabilities 618.
[1181] H Tanaka et al, “The brain basis of the phonological deficit in dyslexia is independent of IQ” (2011) 22:11 Psychological Science 1442.
[1182] Fletcher et al, “Assessment of reading and learning disabilities,” supra note 1077 at 27. For a discussion of how IQ does not seem to be relevant to the definition of a disability in mathematics, see Juan E Jiménez González & Ana I Garcia Espínel, “Is IQ-Achievement Discrepancy Relevant in the Definition of Arithmetic Learning Disabilities?” (1999) 22:4 Learning Disability Quarterly 291, online American Psychological Association APA PsycNet
https://psycnet.apa.org/record/1999-08256-005.
[1183] KE Stanovich & LS Siegel, “Phenotypic performance profile of children with reading disabilities: A regression-based test of the phonological-core variable-difference model” (1994) 86:1 Journal of educational psychology 24; Siegel, “IQ is irrelevant to the definition of learning disabilities,” supra note 1168; KE Stanovich, (1991) “Discrepancy definitions of reading disability: Has intelligence led us astray?” (1991) 26:1 Reading Research Quarterly 7.
[1184] J M Fletcher & J Miciak “Comprehensive cognitive assessments are not necessary for the identification and treatment of learning disabilities” (2017) 32:1 Archives of Clinical Neuropsychology 2 [Fletcher & Miciak, “Comprehensive cognitive assessments”]; J Miciak et al, “Do processing patterns of strengths and weaknesses predict differential treatment response?” (2016) 108:6 Journal of Educational Psychology 898.
[1185] Das et al, “Correlates of Canadian native children’s reading performance,” supra note 615; LS Siegel and N Himel, “Socioeconomic status, age and the classification of dyslexics and poor readers: The dangers of using IQ scores in the definition of reading disability,” (1998) 4:2 Dyslexia 90.
[1186] Das et al, “Correlates of Canadian native children’s reading performance,” supra note 615
[1187] OPA, Guidelines for Diagnosis and Assessment of Children, Adolescents, and Adults with Learning Disabilities, supra note 35 at 14, 28. The OPA Guidelines also state that early assessments of students with reading difficulties “need not involve complex psychoeducational testing such as administration of IQ tests.”
[1188] For example, the following monograph was authorized by the Council of National Psychological Associations for the Advancement of Ethnic Minority Interests (CNPAAEMI) and published by the American Psychological Association: Testing and Assessment with Persons & Communities of Colour (2016), online: American Psychological Association apa.org/pi/oema/resources/testing-assessment-monograph.pdf. See also Guidelines for Diagnosis and Assessment of Children, Adolescents, and Adults with Learning Disabilities, supra note 35, which suggested adaptations for culturally and linguistically diverse individuals.
[1189] PPM 8, supra note 209.
[1190] OHRC, Policy and guidelines on racism and racial discrimination, supra note 246; Colvin et al, “Recommended Guidelines – 2016, supra note 1176.
[1191] Miciak et al, “Patterns of cognitive strengths and weaknesses,” supra note 1077; W P Taylor et al, “Cognitive discrepancy models for specific learning disabilities identification: Simulations of psychometric limitations” (2017) 29:4 Psychological assessment 446; K K Stuebing et al, “Evaluation of the technical adequacy of three methods for identifying specific learning disabilities based on cognitive discrepancies” (2012) 41 School Psychology Review 3 [Stuebing et al, “Evaluation of the technical adequacy of three methods”]; Fletcher & Miciak, “Comprehensive cognitive assessments,” supra note 1184; Fletcher et al, Learning disabilities, supra note 59; McGill et al, “Cognitive profile analysis,” supra note 1168; J H Kranzler et al, “Cross-Battery Assessment pattern of strengths and weaknesses approach to the identification of specific learning disorders: Evidence-based practice or pseudoscience?” (2016) 4:3 International Journal of School & Educational Psychology 146; Fletcher et al, “Assessment of reading and learning disabilities,” supra note 1077; McGill et al, “Critical issues in specific learning disability identification,” supra note 1168; McGill & Busse, “When theory trumps science,” supra note 1168.
[1192] Stuebing et al, “Evaluation of the technical adequacy of three methods,” supra note 1191; J Miciak et al, “The effect of achievement test selection on identification of learning disabilities within a patterns of strengths and weaknesses framework” (2015) 30:3 School Psychology Quarterly 321.
[1193] R Tannock, “Rethinking ADHD and LD in DSM-5: Proposed changes in diagnostic criteria” (2013) 46:1 Journal of learning disabilities 5.
[1194] DSM-5, supra note 32
[1195] Ibid.
[1196] Association of Chief Psychologists with Ontario School Boards’ submission to the inquiry. See also: “What services do School Psychology Professionals offer?” (infographic poster), formerly online (pdf): Ontario Psychological Association.
[1197] A M VanDerHeyden “Why do school psychologists cling to ineffective practices? Let’s do what works” (2018) 12:1 School Psychology Forum 44.  
[1198] PPM 8, supra note 209 at 2.
[1199] C Knight “What is dyslexia? An exploration of the relationship between teachers’ understandings of dyslexia and their training experiences” (2018) 24:3 Dyslexia 207; J Worthy et al, “Teachers’ understandings, perspectives, and experiences of dyslexia” (2016) 65:1 Literacy Research: Theory, Method, and Practice 436.
[1200] See the International Dyslexia Association of Ontario’s website at idaontario.com/; the Dyslexia Canada website: dyslexiacanada.org/; SE Shaywitz, Overcoming dyslexia: A new and complete science-based program for reading problems at any level, (New York: Knopf, 2003).
[1201] A Protopapas, “Evolving concepts of dyslexia and their implications for research and remediation” (2019) 10 Frontiers in psychology 2873; LS Siegel, Understanding Dyslexia and other Learning Disabilities, 1st ed, (Vancouver: Pacific Educational Press, 2013); V Johnston, “Dyslexia: What reading teachers need to know” (2019) 73:3 The Reading Teacher 339.
[1202] “Declaration of Rights: Use the word ‘Dyslexia’” (last visited 2 February 2022), online: The Yale Center for Dyslexia and Creativity dyslexia.yale.edu/dyslexia/declaration-of-rights/use-the-word-dyslexia/; “Use the term ‘Dyslexia’” (last visited 2 February 2022), online: International Dyslexia Association Ontario https://www.idaontario.com/use-the-term-dyslexia/.
[1203] Individuals with Disabilities Education Act, 20 USC § 1400 (2004) s1401(30), online: US Department of Education sites.ed.gov/idea/statute-chapter-33/subchapter-i/1401/30.
[1204] U.S. Department of Education, OSEP Dear Colleague Letter on Individuals with Disabilities Act (IDEA)/Individual Education Program (IEP) Terms, (23 October 2015) at 1, online (pdf): U.S. Department of Education https://sites.ed.gov/idea/files/idea/policy/speced/guid/idea/memosdcltrs/guidance-on-dyslexia-10-2015.pdf  [U.S. Department of Education, OSEP Dear Colleague Letter on Individuals with disabilities Act].
[1205] Ibid at 3.
[1206] Ibid at 1
[1207] “Dyslexia in other countries,” online: International Dyslexia Association Ontario www.idaontario.com/dyslexia-in-other-countries/.
[1208] National Center for Learning Disabilities, “NCLD, 13 Organizations Urge U.S. Department of Education to Tell States: It’s Okay to Use Terms like ‘Dyslexia’ in IEP” (last visited 2 February 2022), online; National Center for Learning Disabilities ncld.org/news/policy-and-advocacy/ncld-13-organizations-urge-u-s-department-of-education-to-tell-states-its-okay-to-use-terms-like-dyslexia-in-iep/.
[1209] National Center for Learning Disabilities, “Getting Specific about SLD: A Conversation Guide for Using Terms like Dyslexia, Dyscalculia, and Dysgraphia” (26 June 2017), online: National Center for Learning Disabilities ncld.org/news/policy-and-advocacy/getting-specific-about-sld-a-conversation-guide-for-using-terms-like-dyslexia-dyscalculia-and-dysgraphia/.
[1210] OPA, Guidelines for Diagnosis and Assessment of Children, Adolescents and Adults with Learning Difficulties, supra note 35 at 37.
[1211] Ibid at 38. Some jurisdictions in Canada use the DSM-5 diagnostic criteria and specify the type of learning disability; see for example “Department of Education Exceptionalities” (last visited 2 February 2022), online: Newfoundland and Labrador https://www.gov.nl.ca/education/k12/studentsupportservices/exceptionalities/; see also: “Learning Disability” (last visited 2 February 2022) online: Newfoundland and Labrador gov.nl.ca/education/k12/studentsupportservices/learning/ which lists four domains of learning disabilities: oral language, reading, written language and mathematics. It also lists four specific learning disabilities: reading disorder, disorder of written expression, mathematics disorder and nonverbal learning disorder.
[1212] For three of the four boards, 24% or more of the students on the psychological services wait lists had been waiting for more than a year. Some students had been on the wait lists for more than two years; see: Auditor General, 2017 Annual Report, supra note 183 at s. 3.12, 617.
[1213] Ibid.
[1214] People for Education, The new basics for public education: People for Education annual report on Ontario’s publicly funded schools 2018 (2018) at 17, online (pdf): People for Education peopleforeducation.ca/wp-content/uploads/2018/06/AnnualReport18_Web.pdf.
[1215] Ibid at 16.
[1216] Adam Carter, “Parents fuming after 2.5 year wait for learning disability test,” CBC News (21 January 2015), online: CBC cbc.ca/news/canada/hamilton/headlines/parents-fuming-after-2-5-year-wait-for-learning-disability-test-1.2918462; Adam Carter, “Hamilton pediatrician says kids ‘sinking’ because of psych test wait times,” CBC News (23 January 2015), online: CBC cbc.ca/news/canada/hamilton/headlines/hamilton-pediatrician-says-kids-sinking-because-of-psych-test-wait-times-1.2928150; Adam Carter, “Province and HWDSB at odds over who needs to fix pscyh test wait times,” CBC News (26 January 2015), online: CBC cbc.ca/news/canada/hamilton/headlines/province-and-hwdsb-at-odds-over-who-needs-to-fix-psych-test-wait-times-1.2930196; Kas Roussy, “Undiagnosed and misunderstood, students with dyslexia face stigma and shame,” CBC News (9 September 2016), online: CBC cbc.ca/news/health/dyslexia-students-ontario-education-ministry-schools-1.3752196.
[1217] OPA, Guidelines for Diagnosis and Assessment of Children, Adolescents, and Adults with Learning Disabilities, supra note 35 at 27.
[1218] Policy/Program Memorandum 59 on the Psychological testing and assessment of pupils (11 October 1982), online: Ontario, Ministry of Education ontario.ca/document/education-ontario-policy-and-program-direction/policyprogram-memorandum-59.
[1219] Ontario Ministry of Education, English Language Learners ESL and ELD Programs and Services at s. 2.3.3, 2.3.4, online: Government of Ontario edu.gov.on.ca/eng/document/esleldprograms/esleldprograms.pdf.
[1220] OHRC, “Policy and guidelines on racism and racial discrimination,” supra note 246 at 29.
[1221] Lesaux & Siegel, “The development of reading in children who speak English as a second language,” supra note 711; see also Geva & Wiener, Psychological assessment of culturally and linguistically diverse children, supra note 455.
[1222] Geva & Wiener, Psychological assessment of culturally and linguistically diverse children, supra note 455 at 2–3.
[1223] Ibid at 3.
[1224] Ibid at 1; OPA, Guidelines for Diagnosis and Assessment of Children, Adolescents, and Adults with Learning Disabilities, supra note 35 at 29–32.
[1225] OPA, Guidelines for Diagnosis and Assessment of Children, Adolescents, and Adults with Learning Disabilities, supra note 35 at 28.
[1226] Ibid.
[1227] Auditor General, 2017 Annual Report, supra note 183, at s. 3.12, 643.
[1228] Ibid.
[1229] Ibid.
[1230] Two large school boards had little information about psychoeducational assessments.
[1231] IDA, Lifting the Curtain on EQAO Scores, supra note 59 at 29.
[1232] The Geography of Opportunity: What’s Needed for Broader Student Success – Annual Report on Ontario’s Publicly Funded Schools 2016 (Toronto: People for Education, 2016) at 6, online (pdf): People for Education peopleforeducation.ca/wp-content/uploads/2017/06/P4E-Annual-Report-2016.pdf [People for Education, The Geography of Opportunity].
[1233] See: “Funding education in Ontario – Time for a review,” (4 February 2020), online: People for Education peopleforeducation.ca/our-work/funding-education-in-ontario-time-for-a-review/.
[1234] Auditor General, 2017 Annual Report, supra note 183 at s. 3.12, 643.
[1235] Education Standards Development Committee, Development of proposed K-12 education standards, supra note 969 at Barrier area narratives and recommendations: s. 3, recommendation 17; s. 5, recommendation 51.7, 51.10.
[1236] Ibid at Barrier area narratives and recommendations: s. 5, recommendation 51.10.
[1237] Ibid at Barrier area narratives and recommendations: s. 5, recommendation 51.7.

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