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AFBAmerican Foundation®
for the Blind

Expanding possibilities for people with vision loss

Response from the Field to OSEP Memo on Eligibility

for further information, please contact:
Rebecca Sheffield, Ph.D.
Senior Policy Researcher,
American Foundation for the Blind
rsheffield@afb.net

July 26, 2017

Ruth E. Ryder
Acting Director
Office of Special Education Programs
U.S. Department of Education
400 Maryland Avenue, SW
Washington, D.C. 20202

Dear Ms. Ryder,

We, the undersigned individuals and organizations, write to thank you and the Office of Special Education Programs for issuing the May 22, 2017, memorandum entitled "Eligibility Determinations for Children Suspected of Having a Visual Impairment Including Blindness under the Individuals with Disabilities Education Act." We also urge the Department to recognize the expertise of our field and are requesting the Department to actively collaborate with us in future discussions about challenges and solutions in serving students who are blind or visually impaired.

The guidance provided by this memo asserts what professionals in the field of blindness and visual impairments know and have always advocated for - that the federal definition of "students with visual impairment including blindness" in the Individuals with Disabilities Education Act (IDEA) is inclusive of all students with impairments in vision that, even with correction, impact their access and participation in school, including children who need supports related to progressive visual conditions. We are pleased to have access to this memorandum to share its important message with state and local school districts and school administrators. Hopefully, this will lead to greater consistency in eligibility determinations among and between states and school districts.

In reading the memorandum, we are reminded of two basic principles of IDEA:

  1. Eligibility for special education is individualized and based on evaluation of educational need, not diagnoses or medical conditions.
  2. Services and supports for students in special education are individualized and based on evaluation and assessment, not diagnoses or medical conditions nor the categories or labels used to determine eligibility.

As recommended in this memo, we will continue to support the individualized provision of a range of special education services for children with all types of educationally significant visual conditions, regardless of diagnoses, including children with neurological, cortical, and/or cerebral visual impairments, as well as children with issues of binocularity and convergence, which, even after correction, adversely impact their access to education.

We support thorough, individualized evaluations using a range of tools to assess eligibility, as well as (often simultaneous) thorough evaluations to determine the best supports and services to be provided to students deemed eligible based on state and federal criteria. Where an evaluation determines that any student - regardless of eligibility category - needs supports and services that fall within the scope of training and expertise of teachers of students with visual impairments (defined differently from state to state but commonly known as TVIs), we know that the professionals in our field stand ready to support and serve these students. TVIs are also prepared to actively collaborate with multidisciplinary special education teams whenever needed, so that if an evaluation determines that a student needs supports or services which are outside the scope of TVI training and expertise, teams can identify and coordinate with the best trained professionals to provide needed services.

We realize that the recent memorandum is likely to generate discussions among states and school districts about students with binocular vision disorders (including convergence insufficiency), and we know that discussions will continue to arise about the provision of vision therapy, a treatment which is sometimes medically prescribed for conditions including binocular vision disorders. As clearly described in a recent position paper [1] from the Low Vision Rehabilitation Division of the Association for the Education and Rehabilitation of the Blind and Visually Impaired, TVIs are educational professionals and not therapists; the provision of vision therapy should be supervised by a doctor and further, is outside the TVIs' scope of professional practice.

Knowing that eligibility does not determine services, should a student with a binocular vision disorder be evaluated and found eligible for special education, TVIs already provide and will continue to provide important evaluation and supports, including classroom accommodations and direct instruction if necessary. TVIs are often the "vision experts" within a school system, and they will continue to work with the multidisciplinary teams to identify additional experts and professional service providers should information and/or supports be needed which are beyond the TVIs' professional expertise.

The professionals and organizations in the field of blindness and visual impairment are eager and ready to share our knowledge and experience with, and to learn from, the experts and leaders at the Office of Special Education Programs. We were disappointed not to have been consulted in advance of this memorandum, as we are very familiar with the issues discussed and could have provided context and expertise to reduce the potential for confusion from school districts and parents. We encourage the Office to actively involve us as a resource and seek our input as stakeholders in future conversations and considerations related to students who are blind or visually impaired. We know that by working together, we can help to further shape a system of education and special education which will achieve the greatest outcomes and future quality of life for students and families.

Thank you again for your thoughtful guidance and support.

Sincerely,

Organizations:

American Council of the Blind

American Council of the Blind of New York, Inc.

American Foundation for the Blind

Association for the Education and Rehabilitation of the Blind and Visually Impaired (AER)

Central Texas Professionals for the Visually Impaired

Conference of Educational Administrators of Schools and Programs for the Deaf

Hadley Institute for the Blind and Visually Impaired

National Family Association for Deaf-Blind

New Jersey Consortium on Deaf-blindness

New York Institute for Special Education (NYISE)

Pennsylvania Partnership for the Deafblind (PPDB)

Perkins School for the Blind

St. Joseph's School for the Blind

Texas School for the Blind and Visually Impaired

University of Arizona, Visual Impairments Specialization Program

Virginia AER

VISIONS/Services for the Blind and Visually Impaired

Individuals:

Susan E. Allen , ECSE, Teacher of Students with Visual Impairments - Prescott Valley, Arizona

Betsy Bentrup Armstrong, COMS, Certified Teacher of Students with Visual Impairments, Retired from the NYC Department of Education - Surry, Maine

Carol Beal , Ph.D., Professor of Education at the University of Florida - Gainesville, Florida

Luz E. Robles Bermudez, Ed. D, Visual impairment Facilitator, Puerto Rico Department of Education - San Juan, Puerto Rico

Tracy C. Blackford , M.Ed., Teacher of Students with Visual Impairments - Cottonwood, Arizona

Laura Bozeman , Ph.D., COMS, CLVT, Associate Professor/Director: Vision Studies School for Global Inclusion and Social Development UMass Boston - Boston, Massachusetts

Sara Burch , COMS, Teacher of Students with Visually Impairments - Boulder, Colorado

Patricia Marie Camarillo, M.A., Education Specialist - Visual Impairment and Early Childhood Special Education - Fresno, California

Anthony R. Candela , M.A., CRC, Certified Teacher of Students with Visual Impairments, Orientation and Mobility Specialist - New York, New York

Martha Aldana Castiglia , M.A., Teacher of Students with Visual Impairments- Escondido, California

Carolyn Chenault , M. Ed., Certified Teacher of Students with Visual Impairments - Phoenix, Arizona

Mehitabel Chiott, Teacher of the Visually Impaired for Winston-Salem/ Forsyth County Schools - Pfafftown, North Carolina

Amy Colaizzi , M.Ed., Certified Teacher of Students with Visual Impairments - Norfolk, Virginia

Krista Collins, TVI Intern, Graduate Student at CSULA in the Education Specialist for VI and Blindness Program - San Luis Obispo, California

Christine Cowan , M.Ed., TVI, Mentor Coordinator, Texas School for the Blind and Visually Impaired - Austin, Texas

Adele Crudden , Ph.D., LMSW, LPC, CRCC, Professor, Mississippi State University - Starkville, Mississippi

Frances Mary D'Andrea , Ph.D., Educational Consultant in Literacy for Students with Visual Impairments - Pittsburg, Pennsylvania

Jacqulyn Daniels, M.Ed., Teacher of Students with Visual Impairments - Portland, Oregon

Melinda Demaris , M.Ed., TVI/COMS, Wicomico County Public Schools - Salisbury, Maryland

Jennifer Edwards , M.S.Ed., COMS, Teacher of Students with Visual Impairments - Plainfield, Illinois

Jane Erin , Ph.D., Professor Emerita, The University of Arizona - Tucson, Arizona

Carol Anne Evans , Ph.D., Certified Teacher of Students with Visual Impairments, School Psychologist specializing in Visual Impairment - Taylorsville, Utah

Ardell Fiedler , M.S., CRC, COMS - Aberdeen, South Dakota

Genevieve Francoeur-Anderson , M.A., COMS, Doctoral Student at the University of Northern Colorado, NLCSD Scholar - Lakewood, Colorado

Michele Germany , M.A., TVI, COMS, Fremont Unified School District - Fermont, California

Susan Chatterley Greer , M.Ed., Supervisor and Certified Teacher of the Visually Impaired and Certified Early Childhood Teacher, Early Childhood and Family Education, Arizona State Schools for the Deaf and the Blind - Tucson, Arizona

Joyelle Harris , Ph.D., Executive Director, Council of Schools and Services for the Blind - Atlanta, Georgia

Carrie Hauptli , M.A., COMS, San Luis Obispo County Office of Education, Teacher of Students with Visual Impairments, Orientation and Mobility Instructor - San Luis Obispo, California

Vicki Herrin , M. Ed., Certified Orientation and Mobility Specialist - San Antonio, Texas

Kathleen Mary Huebner , Ph.D., Professor Emerita, Salus University - Elkins Park, Pennsylvania

Linda Jordan , Ed.S., TVI, COMS, LVT - Helotes, Texas

Cheryl Kamei-Hannan , Ph.D., Professor, Coordinator of the Education Specialist Credential in Visual Impairment and Blindness, Division of Special Education and Counseling, Charter College of Education, California State University, Los Angeles - Los Angeles, California

Bernadette Kappen , Ph.D., Executive Director, New York Institute for Special Education - Bronx, New York

Gaylen Kapperman , Ed.D., Visual Disabilities Program, Northern Illinois University - Dekalb, Illinois

Nikiesha Kirkpatrick, M.A. Behavior Disorders; M.Ed. Special Education- Deaf Education; M.A. Marriage and Family Therapy - Brooklyn, New York

Olaya Landa-Vialard , Ph.D., Assistant Professor and Coordinator, Low Vision Blindness Program, Department of Special Education, Illinois State University - Normal, Illinois

Holly Lawson, Ph.D., CVLT, COMS, Coordinator of the Visually Impaired Learner Program at Portland State University - Portland, Oregon

Jill Lenihan , Instructional Assistant for the Visually Impaired - Santee, California

Sandra Lewis , Ed.D., Professor and Coordinator of the Visual Disabilities Program in the School of Teacher Education - Tallahassee, Florida

Amanda Lueck , Ph.D., Professor Emerita, Department of Special Education, Program in Visual Impairments, San Francisco State University - San Francisco, California

Jo Ann Malone , M.Ed., Certified Teacher of the Visually Impaired - Flora, Mississippi

Gina Michell, M.A., Teacher of Students with Visual Impairments - Huntington Beach, California

Cyral Miller , Teacher of Students with Visual Impairments - Austin, Texas

Nancy D. Miller , LMSW, Executive Director/CEO, VISIONS/Services for the Blind and Visually Impaired - New York, New York

Pamela Mohn, M.A., Certified Teacher of Students with Visual Impairments - Phoenix, Arizona

Mary T. Morse , Ph.D., TVI, Special Education Consultant - Nashua, New Hampshire

Vicki Numkena , M.A., TVI, Another Choice Vision Services, LLC - Dolores, Colorado

Alberta Orr, M.S.W., Ph.D., Adjunct Professor in the College of Education and Rehabilitation at Salus University - Elkins Park, Pennsylvania

Margie Owens , M.Ed., Retired Teacher of the Visually Impaired - Jackson, Mississippi

William M. Penrod, Ed.D, TVI, COMS, Associate Professor of Special Education at Northern Illinois University - Dekalb, Illinois

Angeli Persaud , Parent - Queens, New York

Jeane Petree, M.A., Teacher of Students with Visual Impairments - LaMesa, California

Ann Pilewskie, M.A., Teacher of Students with Severe Disabilities, Special Education Consultant, Doctoral Student at The Ohio State University in the Blind and Visually Impaired Program, NLCSD Scholar - Columbus, Ohio

Stephanie Pizza , B.S., M.S., Ed.S, Certified Teacher of Students with Visual Impairments, Director of Children and Youth Services at the Center for the Visually Impaired - Atlanta, Georgia

Carlie Rhoads, M.Ed., TVI, Doctoral Student in the Visual Disabilities Program at Peabody College of Vanderbilt, NLCSD Scholar - Nashville, Tennessee

Alena Roberts, M.S., Certified Teacher of Students with Visual Impairments - Seattle, Washington

L. Penny Rosenblum , Ph.D., Professor of Practice University of Arizona - Tucson, Arizona

Wendy Sapp , Ph.D., COMS, TVI, Consultant at Visual Impairment Education Services - Cohutta, Georgia

Amy J. Scepaniak , M.A., COMS/CLVT, SDSBVI North Central Outreach Vision Consultant - Aberdeen, South Dakota

Lori Scharff , President, American Council of the Blind of New York - Malverne, New York

Sheryl Schmidt, Teacher of Students with Visual Impairments - Highland, California

Ian Shadrick, Ed.D.(c), CVRT, CRC - Jefferson City, Missouri

Rebecca M. Sheffield , Ph.D., TVI, Senior Policy Researcher, American Foundation for the Blind - Arlington, VA

Nancy Shephard, M. Ed., Teacher of the Visually Impaired - Gilbert, Arizona

Irene Topor , Ph.D., TVI, CLVT, Associate Professor of Practice, University of Arizona, Tucson - Tucson, Arizona

Hilary Travers, M.Ed., Teacher of Students with Severe Special Needs, Doctoral Student in the Visual Disabilities Program at Peabody College of Vanderbilt, NLCSD Scholar - Nashville, Tennessee

Erica Vandeven , M.Ed., Teacher of Students with Visual Impairments - Tucson, Arizona

Hermila Varela , B.A., Certified Teacher of Students with Visual Impairments - El Paso, Texas

Annette Vinding , B.A., M.A., Certified Teacher of Students with Visual Impairments - Fleetwood, North Carolina

Karen Wolffe , Ph.D., Career Counseling & Consultation, LLC - Austin, Texas

Diane P. Wormsley , Ph.D., Author, Educational Consultant - Pittsburgh, Pennsylvania



[1] The Role and Training of Teachers of Students with Visual Impairment (TSVIs) as a Special Educator and Why TSVIs Do Not Provide Vision Therapy Services. https://aerbvi.org/resources/publications/position-papers/

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