In this paper two models of memory are described and implications for hearing impaired students noted. Research on linguistic encoding in short-term memory is also reviewed. The majority of studies suggest that for hearing/speaking Ss, encoding bases are primarily phonological or sound-based, regardless of presentation mode. For deaf/signing Ss, encoding bases appear to be primarily cherological or sign-based, apparently regardless of presentation mode. However, evidence that hearing signers code signs cherologicaly brings into question the earlier generalizations regarding encoding bases in short-term memory. The need for research on linguistic encoding bases particularly as a function of signed or spoken input to deaf and hearing Ss is noted. (Author/CL)