A Call to Action: Are We Ready for Related Services? Do We Want to Be?
We are proud to call ourselves teachers. Since 1921, when the Perkins School for the Blind and the Harvard Graduate School of Education first developed a specialized training program for teachers of children with visual impairments, university-based personnel preparation programs have prepared teachers who are skilled at addressing the unique learning needs of students with visual impairments. We teach reading, writing, and mathematics in braille, and we provide access to the general curriculum by adapting and modifying materials and environments. The work that we do clearly fits the federal definition of special education, as set out in the recently published regulations implementing the 2004 Individuals with Disabilities Education Improvement Act (IDEA), as "specially designed instruction, at no cost to the parents, to meet the unique needs of a child with a disability" (34 C.F.R.§300.39). "Specially designed instruction" is further defined as
adapting, as appropriate to the needs of an eligible child under this part, the content, methodology, or delivery of instruction-(i) To address the unique needs of the child that result from the child's disability; and (ii) To ensure access of the child to the general curriculum, so that the child can meet the educational standards within the jurisdiction of the public agency that apply to all children (34 C.F.R. §300.39[b]).
This is what we do. But the "highly qualified" teacher standards promulgated by the No Child Left Behind Act of 2001 and IDEA as amended in 2004 threaten our existence as teachers and special educators. For example, these two laws, taken together, mandate that the persons teaching all children be qualified in the subject area they teach by the end of the 2006-07 school year. We have no problem with this; we want the teachers teaching children and youths with visual impairments to be highly qualified, too. However, if interpreted literally, this means that teachers of students with visual impairments should at least be qualified in reading or language arts and mathematics, and carried to its natural consequence, should also be qualified in all elementary content areas. Because itinerant teachers and teachers in specialized schools are usually assigned caseloads ranging from pre-kindergarten to grade 12, they might also need to be qualified in history, geometry, physics, calculus, trigonometry, biology, chemistry, and foreign languages as well. If these teachers are working with children who are educated in a specialized school, they would need content-area qualifications for each age level they teach! We fear that these requirements:
- Will exacerbate an already large teacher shortage by discouraging new personnel from entering the field and pushing large numbers of existing teachers into retirement or another field; and
- May force specialized schools into new roles that either absolve them from the highly qualified teacher requirements entirely or radically change their staffing patterns in such a way that they more closely resemble a local school, with a classroom staff of general education teachers and resource rooms staffed by teachers of students with visual impairments.
Some of these issues regarding the highly qualified teacher regulations were raised during the public comment period for the IDEA Part B regulations that were issued in final form on August 14, 2006. The response from the U.S. Department of Education was strong and unwavering:
The highly qualified special education teacher requirements apply to all public school special education teachers. There are no separate or special provisions for special education teachers who teach in specialized schools, for teachers of children who are blind and visually impaired, or for teachers of children with other low incidence disabilities and we do not believe there should be because these children should receive the same high quality instruction from teachers who meet the same high standards as all other teachers and who have the subject matter knowledge and teaching skills necessary to assist these children to achieve to high academic standards (Federal Register, 71, 46555 [August 14, 2006]).
In response to a comment requesting clarification of the roles of special education teachers who do not directly instruct in any core academic subject, the preamble analysis states:
Special education teachers who do not directly instruct children in any core academic subject or who provide only consultation to highly qualified teachers of core academic subjects do not need to demonstrate subject-matter competency in those subjects. These special educators could provide consultation services to other teachers, such as adapting curricula, using behavioral supports and interventions, or selecting appropriate accommodations for children with disabilities. They could also assist children with study skills or organizational skills and reinforce instruction that the child has already received from a highly qualified teacher in that core academic subject (Federal Register, 71, 46557-8 [August 14, 2006]).
Special education versus related services
Each state will determine how it meets the regulations, and whether it views the work of teachers of students with visual impairments as "special education" or, alternatively, as "related services." The definition of related services in the regulations provided by the federal government is "transportation and such developmental, corrective, and other supportive services as are required to assist a child with a disability to benefit from special education" (34 C.F.R. §300.34[a]). In addition, the new Part B regulations of IDEA define supplementary aids and services as: "aids, services, and other supports that are provided in regular education classes, other education-related settings, and in extracurricular and nonacademic settings, to enable children with disabilities to be educated with nondisabled children to the maximum extent appropriate " (34 C.F.R. §300.42), which would seem to cover most areas of the expanded core curriculum. Some states already classify teachers of students with visual impairments as providers of related services. Other states may follow suit, simply because they may be unable to hire special educators with dual qualifications in visual impairment and content subject areas, or because reclassification might help to circumvent the highly qualified teacher mandates of NCLB and IDEA.
Our question is: Do we want to hold on to our identity as special educators? We fear that we will be unable to do so, as the realities of addressing the accountability and assessment mandates of No Child Left Behind become more burdensome to school districts and specialized schools. Should we enter a paradigm shift, in which we view ourselves as providing related services? Our knee-jerk response to this is, "No. Our services are not ancillary or related. They are essential."
However, we have never had the debate. It is possible that, as with orientation and mobility services, identifying our teaching and services as related services may make our services more available to children and youths with visual impairments. It might also (a) more appropriately reflect what we do as itinerant teachers (but not as specialized school teachers, where we are teachers of record, providing instruction in core academic subjects as well as areas of the expanded core curriculum); (b) help promulgate the importance of the expanded core curriculum; (c) allow the field to monitor itself, by establishing national professional standards that are independent of state teacher certification and licensing (much as the American Speech and Hearing Association [ASHA] does); and (d) (dare we say?) raise the salaries of educational specialists in visual impairments (as has been done for speech and hearing professionals and with other related services, such as occupational and physical therapy).
We do not have the answers. But we would prefer to be proactive about the elephant in the room before it steps on us.
Kay Alicyn Ferrell, Ph.D., professor, School of Special Education, executive director, National Center on Low-Incidence Disabilities, University of Northern Colorado, McKee Hall 007, Campus Box 141, Greeley, CO 80639; e-mail: <email@example.com>. Sharon Zell Sacks, Ph.D., director of curriculum and staff development, California School for the Blind, 500 Walnut Avenue, Fremont, CA 94536; e-mail: <firstname.lastname@example.org> or <email@example.com>.
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