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2. Inquiry scope

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The Right to Read inquiry’s terms of reference[11] explain the scope of the inquiry. The inquiry looked into five requirements that are essential to meeting the right to read:

  1. Universal Design for Learning (UDL): Whether Universal Design for Learning, an approach to education that meets the diverse needs of every student, is being applied within Ontario’s reading curriculum and in classroom teaching methods.
  2. Mandatory early screening: Whether all students are being screened for reading difficulties in Kindergarten (or in Grade 1, where a child does not attend public school for Kindergarten) using scientific evidence-based early screening tools.
  3. Evidence-based reading interventions: Whether students who have been identified as having reading difficulties through mandatory early screening or psychoeducational assessment have access to timely, scientific evidence-based reading interventions.
  4. Accommodation: Whether students who have been identified as having reading difficulties through mandatory early screening or psychoeducational assessment have access to timely and effective accommodation and assistive technology.
  5. Psychoeducational assessments: The role of psychoeducational assessments and whether students have access to timely and appropriate psychoeducational assessments where needed (in addition to mandatory early screening for reading difficulties).

The inquiry considered systemic issues that contribute to human rights concerns, including in the areas of teacher training; setting standards, ensuring consistency and monitoring; data collection; and communication and transparency.

The inquiry also considered perspectives on definitions of reading disabilities and dyslexia, including whether these terms are appropriately used and understood.

The inquiry used an intersectional framework to consider how race, gender, identifying as First Nations, Métis or Inuit, lower socio-economic status, co-existing disabilities, being a newcomer, refugee or English language learner (multilingual students who are learning English at the same time as they are learning the curriculum), or being in the child welfare system can combine with a reading disability to create unique and overlapping experiences of disadvantage and discrimination.

There are several reasons why children may struggle with reading. Becoming fully literate requires more than just the ability to read words. The ability to understand the words that are read and the sentences that contain them are important for strong reading comprehension. A comprehensive approach to early literacy recognizes that instruction that focuses on word-reading skills, oral language development, vocabulary and knowledge development, and writing are all important components of literacy.

Word-level reading skills involve learning the correspondence between sounds and letters, and using this knowledge to sound out words and to spell. The inquiry focused on word-level reading difficulties more than difficulties related to reading comprehension. This focus was chosen because of the ongoing struggle for Ontario students with reading disabilities to receive evidence-based instruction in these foundational skills; the difficulty in meeting these early reading outcomes for many more students, often from marginalized or Code-protected groups; research recognizing the importance of instruction in these foundational word-reading skills; and the recognition of the rights of students with dyslexia in the Moore decision. Specifically:

  • Word-level reading difficulties are the most common challenge for students with reading disabilities, learning disabilities and even all young students who struggle to learn to read well.
  • Most students who have issues with reading comprehension have word-level reading difficulties. The reading comprehension difficulties may be caused solely by the time, effort and attention needed to decode the written words. This interferes with the flow of language from the text, and requires students to use limited cognitive resources that cannot then be put toward understanding the texts. A smaller group of students may also have difficulty with language comprehension that impairs reading comprehension. These difficulties are most often compounded by their word-reading impairments. For all these students, effective word-reading instruction and interventions are needed.
  • The solutions for students with word-level reading problems have been extensively researched and are well understood. Responding to students with only reading comprehension difficulties is significantly more variable and complex, with less agreement on effective interventions at this time.
  • The areas identified as the main focus of the inquiry are the most frequent obstacles to developing early reading proficiency.

The OHRC acknowledges the importance of the education system not only teaching all students to read well, but also making sure all students become fully literate. A robust and evidence-based phonics program should take place within a rich evidence-based language arts instructional experience. Modern definitions of literacy include the essential elements of being able to read and write proficiently, and also the ability to access, take in and analyze information. For example, the Alberta Ministry of Education defines literacy as “the ability, confidence and willingness to engage with language to acquire, construct and communicate meaning in all aspects of daily living.”[12] Being able to read and write are fundamental building blocks to becoming fully literate.

While the focus of this report is on teaching students foundational reading skills, there are references to literacy and the importance of enhancing all students’ ability to understand, make meaning out of and analyze what they read. The report also acknowledges the importance of culturally responsive pedagogy, and having students engage with literature and other forms of art and information that reflects their diverse sociocultural backgrounds alongside using scientifically supported, evidence-based methods to teach all students to read. For example, other areas of literacy instruction and engagement will be required to fully meet the needs of Indigenous students.

Early word-reading skills are critical, but they are not the only necessary components in reading outcomes. Robust evidence-based phonics programs should be one part of broader, evidence-based, rich classroom language arts instruction, including but not limited to storytelling, book reading, drama, and text analysis. Evidence-based direct, explicit instruction for spelling and writing are also important to literacy. Many students, including students with reading disabilities, have difficulties with written expression.

Explicit, evidence-based instruction in building background and vocabulary knowledge, and in reading comprehension strategies, are all parts of comprehensive literacy instruction. Although the inquiry focused on one most frequent obstacle to students developing a strong foundation in early reading skills, the report also acknowledges the other elements of a comprehensive approach to literacy. These elements must also be addressed when implementing report recommendations.

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Teachers and other educators

This report focuses on the role of teachers in meeting the right to read, because teachers are responsible for delivering language curriculum to students. However, the OHRC acknowledges that a range of educators play an important role in helping students learn to read. The report discusses different educators’ roles below (see section 4, Context for the inquiry). In short:

  • Principals are responsible for the “quality of instruction” at their school, and assist and supervise teachers and other staff.[13]
  • Early childhood educators who work alongside teachers in Kindergarten classes “have knowledge of early childhood development, observation skills and assessment skills,” and focus on “age-appropriate program planning” that promotes language development. Teachers base their formal reporting to parents on “the teacher-ECE team’s assessment of children’s progress.”[14]
  • Educational assistants act as support staff, and may assist “teachers and other classroom staff in carrying out education plans.”[15]  
  • Literary specialists work with students and other educators on reading and writing processes.
  • Speech-language pathologists, psychologists and other professionals provide advice and support with regard to how a student’s educational and other needs can best be met.

Wherever possible, recommendations in this report should be implemented in a way that empowers educators to be effective reading instruction partners.

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Students with other disabilities

While students with reading disabilities were our focus, the inquiry revealed that many other students are at higher risk of reading failure. The OHRC heard that students with other disabilities such as intellectual disabilities, developmental disabilities, hearing disabilities, vision disabilities, autism spectrum disorder (ASD), and attention deficit hyperactivity disorder (ADHD) also struggle with reading for many of the same reasons as students with reading disabilities. They face many of the barriers identified in this report and will benefit from the report’s recommendations.


Students with ASD, ADHD, intellectual disabilities and developmental disabilities

Students with other disabilities also experience unique challenges that differ from those of students with reading disabilities. Some students are never given the opportunity to learn to read. For example, students with intellectual disabilities are often placed in segregated special education classes that focus on social and life skills with little academic instruction in reading, writing or math. As will be discussed later in greater detail, students with disabilities such as ASD, ADHD, intellectual and developmental disabilities who are behind in reading may not be considered suitable candidates for reading interventions, even though these interventions would help them improve their reading (see section 10, Reading interventions).

ARCH Disability Law Centre’s submission to the inquiry reported that one of the biggest barriers students with ASD and intellectual disability exceptionalities face is being excluded from school (or regular classrooms)[16] due to behaviour or safety issues, or simply due to a lack of accommodations or support services being provided in school.[17] If students are not in school, they can’t be taught reading and other literacy skills. ARCH also raised concerns about students being placed in segregated special education classes where the focus is on social and life skills with little to no academic instruction in reading and math.

In its submission to the inquiry, the Down Syndrome Association of Ontario noted that children with developmental disabilities are assumed to be unable to read and are given no reading instruction. The Association also said that the tendency to modify curriculum expectations to below grade level limits students’ opportunities and life pathways. This report addresses the issue of modifying versus intervening and accommodating (see section 11, Accommodations).

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Students with blindness, low vision or deaf blindness

The OHRC heard that students with blindness, low vision or deaf blindness also face serious barriers in learning to read. The fact these are “low-incidence” disabilities affecting fewer students does not mean that less attention should be paid to meeting their right to read. VIEWS for the Visually Impaired and the CNIB Foundation submitted that school boards across Ontario do not employ enough teachers of the visually impaired (TVI). A TVI provides hands-on direct training to students with vision loss on braille reading and writing where needed, on using assistive technology that is critical to literacy, and on other vital skills relevant to reading. The TVI also supports classroom teachers, special needs and educational assistants and other teaching staff and guides them on how to effectively teach students with vision loss.

VIEWS also outlined concerns with the training requirements for TVIs. VIEWS noted that three or fewer Additional Qualification (AQ) courses are all that is required to be a TVI, and these courses do not need to be delivered through a faculty of education. According to VIEWS, this is inadequate preparation to work with visually impaired students. At least five Canadian provinces and many other jurisdictions have higher training standards for TVIs. VIEWS submits that a qualified teacher should be required to complete a one-year graduate degree specializing in teaching students who are blind, low vision or deafblind and that Ontario should fund that graduate training, just as it now does for the one-year graduate-level program required in Ontario to qualify as a Teacher of the Deaf.

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Deaf and hard of hearing students

The OHRC heard that deaf and hard-of-hearing students[18] also deal with serious challenges when learning to read. For example, the Ontario Cultural Society for the Deaf (OCSD) said that deaf and hard-of-hearing students are prone to experiencing reading difficulties, and many fail to become fluent readers.[19] OCSD also said that deaf and hard-of-hearing students do not get enough access to American Sign Language (ASL) instruction, which it says is required for many deaf students to be able to learn to read. It noted that students who can hear have access to oral language, and that many deaf and hard-of-hearing students who do not have this access find written text foreign and largely inaccessible. It further submitted that the province does not have a well-established and effective reading program for deaf and hard-of-hearing students.

Deaf or hard-of-hearing students whose primary language is not ASL or Langue des signes québécoise, and who primarily use auditory-verbal communication, may require different supports for learning to read.

A significant theme in this report is the concern that teachers are not properly equipped to support all students learning to read. The OHRC’s recommendations here should benefit students with a variety of disability-related needs. Although this report could not address unique barriers for students with other disabilities, those issues merit further consideration by the Ministry, school boards, faculties of education, and the Ontario College of Teachers. All the recommendations in this report should be implemented with proper consideration of intersecting concerns and impacts. All children, regardless of their disability, deserve equal access to a meaningful education, which includes learning to read.

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Other students at risk of reading disabilities

Because few school boards were collecting or analyzing student demographic data at the time of the inquiry, there is limited Ontario data connecting reading achievement with factors such as race, place of origin, gender, LGBTQ2S+ identity, and socio-economic status. However, the Toronto District School Board (TDSB), Ontario’s largest school board, has conducted a student census for several years. It has helpfully analyzed reading and literacy achievement patterns of TDSB students on the Grades 3, 6, and 10 Education Quality and Accountability Office (EQAO) standardized assessments against various demographic and student family background characteristics from the TDSB’s School Information Systems (SIS), Parent Census in 2007–2008 and 2011–2012, and Student Census: Grades 9 to 12 in 2006 and 2011.

The TDSB has found that students from particular identity groups (low socio-economic status; Black, Latin American and Middle Eastern; from the English-speaking Caribbean; with special education needs; male; and not sure of or questioning their sexual orientation) experience significantly lower achievement in reading.[20] This is consistent with data from jurisdictions such as the United States showing that students who are African American, Hispanic, learning English, and/or from low-income homes fall behind and stay behind in reading in far greater proportion than students who are White and middle-class.[21]

While the inquiry focused on students with reading disabilities, it also revealed that many other students are at risk for reading difficulties and the negative outcomes associated with failing to learn to read well. These students do not achieve at the same level as others for many of the same reasons, such as lower phonological awareness at school entry and ineffective curriculum and teaching methods.[22] Instructional approaches that reflect the research science (discussed in greater detail in section 8, Curriculum and instruction) will in fact benefit all students who are at risk. The issues and recommendations identified in this report are matters of overall equity in education.

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First Nations, Métis and Inuit students

The OHRC’s First Nations, Métis and Inuit engagements revealed significant disadvantage experienced by First Nations, Métis and Inuit students attending provincially funded schools, and First Nations students attending federally funded First Nation schools on reserve. As a provincial human rights agency, the OHRC does not have the legal authority to compel federal schools or the federal government to provide documents or data, and cannot enforce their non-compliance with human rights obligations. Nevertheless, this report addresses what the OHRC learned about First Nations, Métis and Inuit students’ experiences in provincially funded schools and First Nations students’ experiences in federally funded schools. We will share this report and recommendations with the Canadian Human Rights Commission and the federal government.

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Students learning in French

The OHRC is aware that issues exist within French-language school boards. Although the OHRC did not select a French school board to be part of the inquiry, we did hear about many of the same concerns exist with the Ontario curriculum and the approach to reading difficulties in French boards.

The inquiry also heard about unique challenges for Francophone students with reading difficulties from a lack of resources, reading interventions and supports in French. We also heard from families of students in French Immersion programs in English-language boards.

Most inquiry findings and recommendations likely apply equally to French-language education, and the Ministry and French boards should work with French reading expert(s) to address and implement the recommendations as appropriate for students learning in French.


[11] Right to Read: Ontario Human Rights Commission inquiry into human rights issues that affect students with reading disabilities in Ontario’s public education system: Terms of reference (3 October 2019), online: Ontario Human Rights Commission

[12] “What is Literacy?” (last visited 9 January 2022), online: Alberta Ministry of Education

[13] “Who’s responsible for your child’s education?” (last modified 31 July 2009), online: Ontario Ministry of Education,

[14] “Full-day kindergarten: Who is working in the classroom?” (last modified 28 February 2019), online: Ontario Ministry of Education, [Ontario Ministry of Education, “Full-day kindergarten”].

[15] “Education/Teaching/Teaching Assistant” (last visited 9 January 2022), online: Ontario Colleges Application Service

[16] For example, through overuse of the sensory room.

[17] See If Inclusion Means Everyone, WHY NOT ME?” (May 2018), online: ARCH Disability Law Centre [ARCH, If Inclusion Means Everyone, WHY NOT ME?].

[18] According to the Canadian Association of the Deaf, “deaf” is “a medical/audiological term referring to those people who have little or no functional hearing [and it may] also be used as a collective noun (“the deaf”) to refer to people who are medically deaf but who do not necessarily identify with the Deaf community.” The Association defines “Deaf (with a capital D)” as “a sociological term referring to those individuals who are medically deaf or hard of hearing who identify with and participate in the culture, society, and language of Deaf people, which is based on Sign language. Their preferred mode of communication is Sign.” See: “Terminology” (last visited 9 January 2022), online: Canadian Association of the Deaf [Canadian Association of the Deaf, “Terminology”].

[19] Robert Hoffmeister & Catherine Caldwell-Harris, "Acquiring English as a second language via print: The task for deaf children" (2014) 132:2 Cognition 229, DOI:; Peter V Paul, Literacy and Deafness: The Development of Reading, Writing, and Literate Thought, (Boston, MA: Allyn and Bacon, 1998); Peter V Paul, Language and Deafness, 4th ed (Sudbury, MA: Jones and Bartlett, 2008).

[20] Toronto District School Board, “Right to Read: Closing Achievement Gaps with Adolescent Learners,” (2019) [TDSB, “Right to Read: Closing Achievement Gaps”].

[21] “The Condition of Education 2020” (May 2020), online: National Centre for Education Statistics [NCES, “The Condition of Education 2020”]; National Assessment of Educational Progress, “Nation’s Report Card: Reading” (2019), online: National Centre for Education Statistics [NAEP, “Nation’s Report Card: Reading”].

[22] Louisa C Moats, Teaching Reading Is Rocket Science (2020), online (pdf): American Federation of Teachers [Moats, Teaching Reading Is Rocket Science].


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