Does anyone know of research that speaks to attrition rates specifically among TVIs?

We are preparing a rebuttal to a state proposal to reduce licensure requirements to become a TVI. One argument we've considered is that untrained TVIs could have higher attrition rates. Anyone know if there is truth to this hypothesis or have something that could support our claim?

Thanks!

Mindy

Mindy S. Ely, Ph.D.
Assistant Professor, Low Vision/Blindness Programs
EL VISTA Project Co-Coordinator
Illinois State University
Department of Special Education
Phone: 217-899-1193
www.eiviprofessionals.comhttp://www.eiviprofessionals.com
http://education.illinoisstate.edu/cert_vision/
Find us on Facebook by searching Illinois State University, EL VISTA

EL VISTA is supported by a grant from the U.S. Department of Education's Office of Special Education (H325K140108).

Good morning, I'm sharing a recent experience from MO b/c I was told the genesis of this proposal is to address the growing personnel shortages due to attrition and growing student/client populations. The Missouri Dept. of Elem and Sec. Education sought feedback to proposed modifications to the State Plan. I'm pasting a copy of a letter submitted by a large group of COMS, TVIs, Agency leadership, employers, etc. to the DESE. The proposed change included not requiring certification of O&Ms working in the school system.
I think some of the comments are applicable for your situation regarding TVIs, especially the fact that 35 other professions require some form of licensure or certification and if the DESE adopts this proposed revision, O&M would quite possibly be the only IDEA related service not requiring it. There were a number of other comments submitted by others which included:  1. Equitable pay for a Master's level O&M and a non-degreed, non-certified O&M; 2. Impact on those OMS who work 100% contratual;  3. trickle effect into other B/VI professions; 4. Should a non-certified B/VI professional be paid on the 'teacher salary schedule' or the 'therapist/consultant' schedule -- a HUGE discussion b/c non-certified staff typically fall into a seperate teacher retirement system often less robust.
Kevin

January 24, 2019

Special Education Compliance

Department of Elementary and Secondary Education    

P. O. Box 480        

Jefferson City, MO 65102-0480

Re: Proposed changes to the Missouri State Regulations Implementing Part B of the Individuals with Disabilities Education Act (IDEA) Regulation VIII – Personnel Standards

Dear Special Education Compliance,

We are writing regarding the proposed changes to the Missouri State Plan regarding Orientation & Mobility (O&M) services and the professionals eligible to provide the services. We oppose the propose change regarding, “Current O&M services contract with Rehabilitation Services for the Blind based on acceptable combination of education, training, and experience to provide services.” Our primary reason for opposing this proposed change is due to the lack of certification required to provide O&M services in Missouri schools. You may have received other versions of this letter from other O&M Specialists, B/VI professionals, and/or parents and we whole-heartedly support the justifications below.

As you refer to Regulation VIII – Personnel Standards located on the DESE State Plan Part B website, you will see the proposed changes in RED print. We are advocating the State Plan require one and/or both of the available certifications in O&M and to eliminate the inclusion of “Current O&M services contract with Rehabilitation Services for the Blind based on acceptable combination of education, training, and experience to provide services.” We believe it is not wise for our students and families nor our profession to support acceptance of non-certified professionals as O&M service providers for the following reasons:

1. The proposed changes do not require certification to work as an O&M Specialist in Missouri schools. Missouri does not offer a license for O&M Specialists, so the requirement of certification is critical. The DESE requires a license or certification for 35 other related professions providing General and/or Special Education to children in Missouri Schools so I ask, “Why should O&M Specialists not be required to seek, gain and maintain one or both available O&M certifications?”

Please refer to pages 99-104 in DESE’s current REGULATION VIII: PERSONNEL STANDARDS in Section A. PERSONNEL QUALIFICATIONS (34 CFR 300.156)https://dese.mo.gov/sites/default/files/RegulationVIIIPersonnelStandards.pdf to confirm how all other titles/professions require licensure and/or certification.

2. We are concerned school districts will recruit and hire non-certified O&M Specialists, which, in time, will likely ‘water down’ our profession. Our students and families deserve services from highly-qualified professionals. Certification ensures professionals meet “entry level” competency standards, ethical service, commitment to consumers and stronger program outcomes. Certification also requires renewal and the renewal process establishes expectations for ongoing professional development through continued education, direct service provision, and a commitment to the field of O&M. Non-certified professionals do not require professional development and their practices are not officially governed by a Code of Ethics nor a governing body of professionals.

3. The State Plan’s proposed changes do not recognize the National O&M Certification (NOMC) as an acceptable certification for service provision. The National Blindness Professional Certification Board (NBPCB) has offered NOMC since 2001 with approximately 150 certified professionals holding the NOMC credential. The ACVREP has offered certification since 2000 with approximately 3,000 certified professionals holding the COMS credential. The combined total of certified O&M Specialists likely exceeds 3,200 professionals. Orientation and Mobility Certification exists. It should be required for hiring.

4. Rehabilitation Services for the Blind (RSB) does not require ACVREP and/or NOMC certification to qualify for employment as an O&M Specialist. A public job posting from Michael St. Julien, Assistant Deputy RSB Director, on 10-04-2018 cites the required qualifications for an O&M Specialist as:

“Graduation from an accredited four-year college or university with specialization in orientation and mobility, teaching the blind and visually impaired, rehabilitation teaching, special education, occupational therapy, physical therapy or closely related areas. (Specialization in other fields of study must be accompanied by a minimum of two years supervised experience in teaching blind and/or visually impaired persons).”

The RSB requires “two years of supervised experience in teaching blind and/or visually impaired persons,” but not only does RSB not require certification to serve clients, they do not stipulate a certified O&M Specialist must provide the supervision during internship. Furthermore, the experience does not stipulate the hours of supervision while other professional certification boards always provide a minimum hour expectation including demonstration of established professional competencies.

We firmly believe professionals working in our schools should hold certification through mastering clinical competencies, passing a comprehensive examination, and completing an internship under an NOMC and/or COMS.
5.  Finally, the proposed change states, “Rehabilitation Services for the Blind conducts a thorough review of potential applicants, which includes a review of educational background and relative experience, prior to issuing a contract to provide services. This change recognizes the legitimacy and benefit to the field of that review process,” and we disagree that this change benefits our field. We think this change minimizes the hard work, commitment and financial investment degreed and certified O&M Specialists make to achieve and maintain professional certification. We do not think “relative experience” should be substituted for enrolling and completing personnel preparation programs and internships supervised by ACVREP and/or NOMC O&M Specialists.

We conclude by stating we do not support the DESE hiring non-certified Math teachers, Chemistry teachers or Teachers of the Visually Impaired so why should we support non-certified O&M Specialists? We request that you reject the proposed change regarding the RSB stipulation and add NOMC as a possible certification required in addition to ACVREP certification.

On Feb 8, 2019, at 2:44 PM, Ely, Mindy <msely@ilstu.edumailto:msely@ilstu.edu> wrote:

Does anyone know of research that speaks to attrition rates specifically among TVIs?

We are preparing a rebuttal to a state proposal to reduce licensure requirements to become a TVI. One argument we've considered is that untrained TVIs could have higher attrition rates. Anyone know if there is truth to this hypothesis or have something that could support our claim?

Thanks!

Mindy

Mindy S. Ely, Ph.D.
Assistant Professor, Low Vision/Blindness Programs
EL VISTA Project Co-Coordinator
Illinois State University
Department of Special Education
Phone: 217-899-1193
www.eiviprofessionals.comhttp://www.eiviprofessionals.com
http://education.illinoisstate.edu/cert_vision/
Find us on Facebook by searching Illinois State University, EL VISTA

EL VISTA is supported by a grant from the U.S. Department of Education's Office of Special Education (H325K140108).

You are subscribed to AERNet, The Association for Education and Rehabilitation of the Blind and Visually Impaired Listserv.

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This e-mail transmission from the Francis Howell School District including any accompanying data or files is confidential and is intended only for the use of the named recipient. If you are not the intended recipient, an addressee, or the person responsible for delivering this to an addressee, you are hereby notified that reading, using, copying, or distributing any part of this message is strictly prohibited. If you receive this message in error, or are not the named recipient(s), please notify the sender at the email address above, delete this email from your computer, and destroy any copies in any form immediately. Improper retention of this e-mail and any attachment(s) to this e-mail could subject you to legal action under pertinent federal and state statutes, and result in civil and criminal penalties.

Kevin, thanks for sharing this letter.  This is such a challenging topic for so many states right now, we can all benefit from sharing information like this.

Michelle Clyne, IL

From: AERNet aernet-bounces@lists.aerbvi.org on behalf of HOLLINGER, KEVIN Kevin.Hollinger@fhsdschools.org
Sent: Sunday, February 10, 2019 9:09 AM
To: Ely, Mindy
Cc: AERNet
Subject: Re: [AERNet] TVI Attrition

Good morning, I'm sharing a recent experience from MO b/c I was told the genesis of this proposal is to address the growing personnel shortages due to attrition and growing student/client populations. The Missouri Dept. of Elem and Sec. Education sought feedback to proposed modifications to the State Plan. I'm pasting a copy of a letter submitted by a large group of COMS, TVIs, Agency leadership, employers, etc. to the DESE. The proposed change included not requiring certification of O&Ms working in the school system.
I think some of the comments are applicable for your situation regarding TVIs, especially the fact that 35 other professions require some form of licensure or certification and if the DESE adopts this proposed revision, O&M would quite possibly be the only IDEA related service not requiring it. There were a number of other comments submitted by others which included:  1. Equitable pay for a Master's level O&M and a non-degreed, non-certified O&M; 2. Impact on those OMS who work 100% contratual;  3. trickle effect into other B/VI professions; 4. Should a non-certified B/VI professional be paid on the 'teacher salary schedule' or the 'therapist/consultant' schedule -- a HUGE discussion b/c non-certified staff typically fall into a seperate teacher retirement system often less robust.
Kevin

January 24, 2019

Special Education Compliance

Department of Elementary and Secondary Education    

P. O. Box 480        

Jefferson City, MO 65102-0480

Re: Proposed changes to the Missouri State Regulations Implementing Part B of the Individuals with Disabilities Education Act (IDEA) Regulation VIII – Personnel Standards

Dear Special Education Compliance,

We are writing regarding the proposed changes to the Missouri State Plan regarding Orientation & Mobility (O&M) services and the professionals eligible to provide the services. We oppose the propose change regarding, “Current O&M services contract with Rehabilitation Services for the Blind based on acceptable combination of education, training, and experience to provide services.” Our primary reason for opposing this proposed change is due to the lack of certification required to provide O&M services in Missouri schools. You may have received other versions of this letter from other O&M Specialists, B/VI professionals, and/or parents and we whole-heartedly support the justifications below.

As you refer to Regulation VIII – Personnel Standards located on the DESE State Plan Part B website, you will see the proposed changes in RED print. We are advocating the State Plan require one and/or both of the available certifications in O&M and to eliminate the inclusion of “Current O&M services contract with Rehabilitation Services for the Blind based on acceptable combination of education, training, and experience to provide services.” We believe it is not wise for our students and families nor our profession to support acceptance of non-certified professionals as O&M service providers for the following reasons:

1. The proposed changes do not require certification to work as an O&M Specialist in Missouri schools. Missouri does not offer a license for O&M Specialists, so the requirement of certification is critical. The DESE requires a license or certification for 35 other related professions providing General and/or Special Education to children in Missouri Schools so I ask, “Why should O&M Specialists not be required to seek, gain and maintain one or both available O&M certifications?”

Please refer to pages 99-104 in DESE’s current REGULATION VIII: PERSONNEL STANDARDS in Section A. PERSONNEL QUALIFICATIONS (34 CFR 300.156)https://dese.mo.gov/sites/default/files/RegulationVIIIPersonnelStandards.pdf to confirm how all other titles/professions require licensure and/or certification.

2. We are concerned school districts will recruit and hire non-certified O&M Specialists, which, in time, will likely ‘water down’ our profession. Our students and families deserve services from highly-qualified professionals. Certification ensures professionals meet “entry level” competency standards, ethical service, commitment to consumers and stronger program outcomes. Certification also requires renewal and the renewal process establishes expectations for ongoing professional development through continued education, direct service provision, and a commitment to the field of O&M. Non-certified professionals do not require professional development and their practices are not officially governed by a Code of Ethics nor a governing body of professionals.

3. The State Plan’s proposed changes do not recognize the National O&M Certification (NOMC) as an acceptable certification for service provision. The National Blindness Professional Certification Board (NBPCB) has offered NOMC since 2001 with approximately 150 certified professionals holding the NOMC credential. The ACVREP has offered certification since 2000 with approximately 3,000 certified professionals holding the COMS credential. The combined total of certified O&M Specialists likely exceeds 3,200 professionals. Orientation and Mobility Certification exists. It should be required for hiring.

4. Rehabilitation Services for the Blind (RSB) does not require ACVREP and/or NOMC certification to qualify for employment as an O&M Specialist. A public job posting from Michael St. Julien, Assistant Deputy RSB Director, on 10-04-2018 cites the required qualifications for an O&M Specialist as:

“Graduation from an accredited four-year college or university with specialization in orientation and mobility, teaching the blind and visually impaired, rehabilitation teaching, special education, occupational therapy, physical therapy or closely related areas. (Specialization in other fields of study must be accompanied by a minimum of two years supervised experience in teaching blind and/or visually impaired persons).”

The RSB requires “two years of supervised experience in teaching blind and/or visually impaired persons,” but not only does RSB not require certification to serve clients, they do not stipulate a certified O&M Specialist must provide the supervision during internship. Furthermore, the experience does not stipulate the hours of supervision while other professional certification boards always provide a minimum hour expectation including demonstration of established professional competencies.

We firmly believe professionals working in our schools should hold certification through mastering clinical competencies, passing a comprehensive examination, and completing an internship under an NOMC and/or COMS.
5.  Finally, the proposed change states, “Rehabilitation Services for the Blind conducts a thorough review of potential applicants, which includes a review of educational background and relative experience, prior to issuing a contract to provide services. This change recognizes the legitimacy and benefit to the field of that review process,” and we disagree that this change benefits our field. We think this change minimizes the hard work, commitment and financial investment degreed and certified O&M Specialists make to achieve and maintain professional certification. We do not think “relative experience” should be substituted for enrolling and completing personnel preparation programs and internships supervised by ACVREP and/or NOMC O&M Specialists.

We conclude by stating we do not support the DESE hiring non-certified Math teachers, Chemistry teachers or Teachers of the Visually Impaired so why should we support non-certified O&M Specialists? We request that you reject the proposed change regarding the RSB stipulation and add NOMC as a possible certification required in addition to ACVREP certification.

On Feb 8, 2019, at 2:44 PM, Ely, Mindy <msely@ilstu.edumailto:msely@ilstu.edu> wrote:

Does anyone know of research that speaks to attrition rates specifically among TVIs?

We are preparing a rebuttal to a state proposal to reduce licensure requirements to become a TVI. One argument we've considered is that untrained TVIs could have higher attrition rates. Anyone know if there is truth to this hypothesis or have something that could support our claim?

Thanks!

Mindy

Mindy S. Ely, Ph.D.
Assistant Professor, Low Vision/Blindness Programs
EL VISTA Project Co-Coordinator
Illinois State University
Department of Special Education
Phone: 217-899-1193
www.eiviprofessionals.comhttp://www.eiviprofessionals.com
http://education.illinoisstate.edu/cert_vision/
Find us on Facebook by searching Illinois State University, EL VISTA

EL VISTA is supported by a grant from the U.S. Department of Education's Office of Special Education (H325K140108).

You are subscribed to AERNet, The Association for Education and Rehabilitation of the Blind and Visually Impaired Listserv.

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This e-mail transmission from the Francis Howell School District including any accompanying data or files is confidential and is intended only for the use of the named recipient. If you are not the intended recipient, an addressee, or the person responsible for delivering this to an addressee, you are hereby notified that reading, using, copying, or distributing any part of this message is strictly prohibited. If you receive this message in error, or are not the named recipient(s), please notify the sender at the email address above, delete this email from your computer, and destroy any copies in any form immediately. Improper retention of this e-mail and any attachment(s) to this e-mail could subject you to legal action under pertinent federal and state statutes, and result in civil and criminal penalties.

Dumbing down standards never improves the profession.  Bill

Sent via the Samsung Galaxy S7 active, an AT&T 4G LTE smartphone

-------- Original message --------
From: Dennis Thurman thurman60@gmail.com
Date: 2/8/19 4:12 PM (GMT-05:00)
To: "Ely, Mindy" msely@ilstu.edu
Cc: AERNet aernet@lists.aerbvi.org
Subject: Re: [AERNet] TVI Attrition

So...if we can’t place qualified professionals to serve our children, lower the qualifications.  I hope
To God these aren’t the same people who license pilots or medical personnel.

Sent from my iPad

On Feb 8, 2019, at 3:43 PM, Ely, Mindy <msely@ilstu.edumailto:msely@ilstu.edu> wrote:

Does anyone know of research that speaks to attrition rates specifically among TVIs?

We are preparing a rebuttal to a state proposal to reduce licensure requirements to become a TVI. One argument we've considered is that untrained TVIs could have higher attrition rates. Anyone know if there is truth to this hypothesis or have something that could support our claim?

Thanks!

Mindy

Mindy S. Ely, Ph.D.
Assistant Professor, Low Vision/Blindness Programs
EL VISTA Project Co-Coordinator
Illinois State University
Department of Special Education
Phone: 217-899-1193
www.eiviprofessionals.comhttp://www.eiviprofessionals.com
http://education.illinoisstate.edu/cert_vision/
Find us on Facebook by searching Illinois State University, EL VISTA

EL VISTA is supported by a grant from the U.S. Department of Education's Office of Special Education (H325K140108).

You are subscribed to AERNet, The Association for Education and Rehabilitation of the Blind and Visually Impaired Listserv.

To post a message to all the list members, send an email to aernet@lists.aerbvi.orgmailto:aernet@lists.aerbvi.org.

Address list requests to:  aernet-request@lists.aerbvi.orgmailto:aernet-request@lists.aerbvi.org

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Thank you for the comments on this thread. We would completely agree. As a state vision group we are preparing a rebuttal that speaks to the various knowledge and skills that an untrained individual is not equipped to provide. This puts the district at risk for not meeting federal mandates, but in the end it is bad for children and families.

Our state AER conference is this week and we will use this platform to make professionals in our states aware. In this way we are hoping to mobilize many voices to speak against the proposed reduction to licensure standards which were put forward by our state board in December.

The proposal will be open to public comment soon. Our vision leadership is writing a letter to the stare board but  we also want to help people prepare to make comments. Your input has been helpful in spurring our thinking as we write this important letter and prepare talking points.

Thank you,
Mindy Ely

On Tue, Feb 12, 2019 at 6:18 AM Dr Denise Robinson yourtechvision@gmail.com wrote:
Dumbing down standards opens districts to more due process and major lawsuits that they will lose. I also feel for the teacher the districts 'made' a TVI who have no experience...what awful pressure.
Just sat in an IEP where at the end of the meeting the director told the parents they put in for emergency TVI status for their special ed teacher who knew nothing about it who was sitting in the meeting also. Teacher was just as stunned as the parents. How long do we think she will last? She is a great special ed teacher but now what....... no support and a huge new blind low vision caseload in the middle of the year....... what about the kids..... are they destined to the 74% unemployment rate now..... I know we have all seen this too many times...does not go well for either kids or teachers and you get very angry parents

Sent from Dr Denise M Robinson

On Feb 11, 2019, at 11:39 AM, a1632287 <a1632287@mail.niu.edumailto:a1632287@mail.niu.edu> wrote:

Dumbing down standards never improves the profession.  Bill

Sent via the Samsung Galaxy S7 active, an AT&T 4G LTE smartphone

-------- Original message --------
From: Dennis Thurman <thurman60@gmail.commailto:thurman60@gmail.com>
Date: 2/8/19 4:12 PM (GMT-05:00)
To: "Ely, Mindy" <msely@ilstu.edumailto:msely@ilstu.edu>
Cc: AERNet <aernet@lists.aerbvi.orgmailto:aernet@lists.aerbvi.org>
Subject: Re: [AERNet] TVI Attrition

So...if we can?t place qualified professionals to serve our children, lower the qualifications.  I hope
To God these aren?t the same people who license pilots or medical personnel.

Sent from my iPad

On Feb 8, 2019, at 3:43 PM, Ely, Mindy <msely@ilstu.edumailto:msely@ilstu.edu> wrote:

Does anyone know of research that speaks to attrition rates specifically among TVIs?

We are preparing a rebuttal to a state proposal to reduce licensure requirements to become a TVI. One argument we've considered is that untrained TVIs could have higher attrition rates. Anyone know if there is truth to this hypothesis or have something that could support our claim?

Thanks!

Mindy

Mindy S. Ely, Ph.D.
Assistant Professor, Low Vision/Blindness Programs
EL VISTA Project Co-Coordinator
Illinois State University
Department of Special Education
Phone: 217-899-1193
www.eiviprofessionals.comhttp://www.eiviprofessionals.com
http://education.illinoisstate.edu/cert_vision/
Find us on Facebook by searching Illinois State University, EL VISTA

EL VISTA is supported by a grant from the U.S. Department of Education's Office of Special Education (H325K140108).

You are subscribed to AERNet, The Association for Education and Rehabilitation of the Blind and Visually Impaired Listserv.

To post a message to all the list members, send an email to aernet@lists.aerbvi.orgmailto:aernet@lists.aerbvi.org.

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