OPVIC Letter to Stephen Lecce

Ontario Parents of Visually Impaired Children (OPVIC)

Also known as Views for The Visually Impaired


April 6, 2021
To: the Hon Stephen Lecce, Minister of Education for Ontario
Via Email: Stephen.lecce@ontario.ca; minister.edu@ontario.ca

Dear Minister,

Re: The Need to Substantially Improve the Number of, Training for and Qualifications of Teachers of the Visually Impaired (TVIs) in Ontario

We urgently seek Government action on a serious, festering problem in Ontario’s education system which has gone unremedied for many years. We need you to protect the rights of students with vision loss to a full and proper education, including literacy. This is a substantially vulnerable and underserved minority. The Ministry of Education has failed to effectively serve these students despite our years of advocacy.

This letter explains the problem. It details how this issue has been neglected by the Ministry of Education and the Ontario College of Teachers. It outlines needed reforms


 1. Summary of the Problem

When students with vision loss reach school, the indispensable school board employee who is vital to their acquiring literacy and other key learning skills is the expert TVI. At school boards, they are itinerant teachers. The TVI goes from school to school, providing the hands-on direct training to individual students with vision loss, one at a time, in specialized areas like braille reading and writing, where needed. They teach blind, low vision and deafblind children how to use rapidly evolving adaptive technology, such as screen-reading and print-enlarging programs. These apps enable them to use a computer, tablet or smart phone, essential to their learning.

The itinerant TVI is also the indispensable expert who educates and supports a student’s classroom teacher, special needs and educational assistant, and other teaching staff on how to effectively teach that student with vision loss. Most of the time that students with vision loss spend in school is with general education or special education teaching staff who have no training in how to teach students with vision loss. Where a TVI is involved, the TVI typically only spends a proportion of the student’s in-school time with a specific student who has vision loss.

Ontario has a growing shortage of TVIs. Even where a properly-trained new TVI is available, they can face unfair roadblocks that impede them from being hired at a school board that needs them.

Ontario’s training requirements to qualify as a TVI are substantially inadequate. They are unjustifiably much lower than in many other jurisdictions. Ontario also lacks a proper training program to train TVIs.

To qualify to start working as a TVI in Ontario, a teacher only needs to complete a grossly-insufficient 125 hour course. It is not taught by a qualified university Faculty of Education. In that course, they will not work with a blind student or see a blind student taught to read braille. In contrast, to become a TVI in at least five Canadian provinces, in much of the US as well as in the UK and New Zealand a teacher must complete a far more extensive and appropriate one year university-taught graduate degree on teaching students with vision loss that includes a properly-supervised practicum.

This is an important issue of equity in education. Its victims are students with vision loss. They are a small, highly vulnerable and chronically underserved population in Ontario’s school system, estimated as numbering around 2,000-2,500.

The solution is known. It is affordable and doable but needs effective Ontario Government leadership. It is a discrete issue you can hive off and readily tackle. Yet despite our pressing for reform for over three years, Ontario has announced no plan or commitment to effectively address this. The Ministry of Education and the Ontario College of Teachers have left this problem with no solution, or with solutions known to be doomed to fail.

Vision loss is a “low incidence” disability among school-age children. The Ministry of Education has a longstanding, entrenched legacy of giving these children far less attention than children with high-incidence disabilities. Your Ministry’s inadequate treatment of our request and its officials over the past three and a quarter years, if not longer, illustrates this.


 2. Who Are We?

I am a member of the board of directors of Ontario Parents of Visually Impaired children (OPVIC). We are Ontario’s officially-recognized volunteer organization of parents of children who are blind, deafblind, or low vision. We advocate for the needs of those children. We are entitled to representation on Special Education Advisory Committees of school boards around Ontario. (Our corporate name remains Views for the Visually Impaired).


 3. The Problem

 a) Ontario’s Inadequate Training Requirements for TVIs

The TVI can make or break the learning experience of students with vision loss. In Ontario’s publicly funded education system, everyone from senior management to the school principal to the classroom teacher all heavily depend on the TVI’s unique expertise. Even teachers with special education specialty qualifications typically do not have expertise or experience with students with vision loss.

Ontario’s current training requirements for TVIs are inadequate. They do not ensure that TVIs have the knowledge, skills and expertise they need to effectively play the pivotal TVI role, serving the needy, highly-vulnerable and chronically underserved population of students with vision loss. In so saying, we are not criticizing the dedication and hard work of Ontario TVIs. Despite their hard work and dedication, they can only accomplish so much when provided grossly insufficient training for their vital role.

Ontario’s required qualifications to serve as a TVI are considerably lower than in any number of other jurisdictions inside Canada and in several other developed countries. No one disputes our concerns about the training and qualifications to work as a TVI in Ontario. They are shared by parents of children with vision loss and by professionals in the blindness rehabilitation field. Our concerns have been endorsed by the CNIB and by the Association for Education and Rehabilitation of the Blind and Visually Impaired (AER). AER is the major international organization of experts doing rehabilitation work in the blindness/low vision field. Our concerns have been echoed by leading faculty members at Canada’s two respected university-based programs for training TVIs, at the Faculties of Education at the University of British Columbia and Nova Scotia’s Mount St. Vincent University. No one at your Ministry or the Ontario College of Teachers has suggested that this long term status quo is justified, or that they know more about how to train TVIs than do all the vision loss experts who have echoed these concerns.

To qualify as a TVI in Ontario, the Ontario College of Teachers and Ministry of Education regulations require a qualified teacher to merely undertake three 125 hour “Additional Qualification” (AQ) courses in the blind/low vision field. In practice, a teacher only needs to take the first of these AQ courses. They can then get a job as a TVI at an Ontario school boards.

Neither the Ministry of Education nor the Ontario College of Teachers appears to monitor or enforce the requirement for a teacher to take the second and third of those AQ courses, once they start to work as a TVI in Ontario. As such, the existing “requirement” of three TVI AQ courses is only a requirement on paper, not in practice.

Even if a teacher takes all three basic TVI AQ courses, the courses are far too short to cover all the content that a TVI needs to learn. In those courses, a teacher need never work with a student with vision loss, or observe a properly trained TVI effectively working with a student with vision loss, or even meet a student with vision loss. These deficiencies were poignantly illustrated at a meeting I attended. A new Ontario TVI, who met Ontario’s minimum requirements to begin working as an Ontario TVI, admitted in the presence of their colleagues that they lack the training they need to competently work as a TVI. None of their colleagues disagreed.

Ontario’s TVI AQ courses, delivered to date, lack the inherent safeguards for quality control that a graduate university program requires. In recent years, the TVI AQ courses have been taught by some TVIs working at the W. Ross Macdonald School. That school’s teachers have years of experience teaching students with vision loss in the residential school setting (but not necessarily in the different itinerant TVI role at a school board).

We have seen no demonstration that the Ontario Government, which operates that school, or the school itself, has the required expertise in teacher training and in the proper design and teaching of a program to train TVIs, equal to a university faculty of education. Just because a teacher has worked in our schools for years alone does not qualify them to design and deliver courses for training others to be a teacher. That is why we have universities, with faculties of education. Those faculties have the rigours of faculty recruitment and promotion, and undertake peer-reviewed research.

As of last spring, none of the TVIs at the W. Ross Macdonald School has a graduate degree in teaching students with vision loss, either a masters or a doctorate. The W. Ross Macdonald School does not appear to require a person to have a TVI graduate degree to teach its students, or to teach one of the TVI AQ courses. Therefore, the teacher who is teaching any of these TVI AQ courses has only themselves completed the demonstrably inadequate existing Ontario TVI AQ courses.

Making this worse, the person who teaches a TVI AQ course has an extremely wide discretion over what to teach in the course, and how to teach it. The Ontario College of Teachers guideline for the three basic TVI AQ courses give the course instructor precious little direction on the specifics to teach in the course and how to cram it all into 125 hours per course, a practical impossibility. There is no assurance that the course content that is taught in a TVI AQ course is kept up-to-date in light of the latest research and scholarship in the area of teaching students with vision loss.

A vital feature for properly training TVIs that is missing from the current regime is a properly constituted, administered and overseen field practicum, working directly with students with vision loss. The current regime has no practicum at all. A properly constituted practicum requires the oversight of an academic program and faculty. Neither the W. Ross Macdonald School nor individual TVIs are qualified to administer this.

The Ontario College of Teachers told us that the current TVI AQ courses are offered through the University of Western Ontario. However, UWO’s involvement is purely administrative. The UWO Faculty of Education does not offer these TVI AQ courses. That Faculty’s professors do not teach these TVI AQ courses, or design or approve their content. We have no information that anyone at the UWO faculty has expertise in the education of students with vision loss, or in how to effectively train TVIs.

It is a cruel irony that while Ontario regulations and the Ontario College of Teachers maintain substandard Ontario TVI training requirements, they also do not properly recognize as sufficient the far-superior TVI training at UBC’s or Mount St. Vincent University’s TVI masters programs. Ontario should respect those graduate TVI degrees as sufficient and as superior to Ontario’s TVI AQ courses.

Instead, if an Ontario teacher gets a TVI masters at UBC or Mount St. Vincent University (for which they must themselves pay), the Ontario starting point is that this training is not recognized. Ontario’s outdated and irrational regulatory starting point is that a UBC or Mount St. Vincent graduate with a TVI masters presumptively must return to Ontario and then undertake Ontario’s inferior TVI AQ courses. The far preferable university TVI graduate programs require more hours of study and a fuller TVI-related curriculum, compared to Ontario’s TVI AQ courses. The university graduate programs are offered by university faculty members, themselves having graduate degrees in this field. Those university graduate programs are part of a university structure that engages research in the field. Those university graduate programs have a clear practicum requirement. Nothing in the inferior Ontario TVI AQ courses requires or assures any such enrichment.

A graduate of the UBC or Mount St. Vincent program can ask the Ontario College of Teachers to grant them an exemption from the inferior Ontario TVI AQ requirements. Yet they should not have to each prove over and over that they deserve an exemption. That the Government and/or the Ontario College of Teachers requires such an exemption to be justified shows the continued disconnect between reality and the Ontario regulatory requirements.

Such exemptions are not automatically granted. We understand that they require supportive justification, beyond proof that the TVI successfully completed their TVI masters. This is an unnecessary and unfair burden. It is an arbitrary regulatory barrier that hurts students with vision loss.

At least one graduate with a TVI masters was not exempted from all three of the current TVI AQ courses. At most, they were only exempted from the first AQ course. Yet that TVI’s training is clearly superior to someone who has no TVI masters degree, but who has completed all three of Ontario’s TVI AQ courses.

In sharp contrast to Ontario’s TVI requirements, the requirements in Ontario to qualify as a Teacher of the Deaf are much higher. A teacher must complete a one year graduate-level program to train as a Teacher of the Deaf at York University’s Faculty of Education. It commendably includes a practicum requirement.

Neither the Ministry of Education nor the Ontario College of Teachers has tried to justify the flagrant discrimination against students with vision loss in this regard as contrasted with the treatment of students who are deaf, deafened or hard of hearing. What’s more, the Ontario Government commendably fully funds the York University Faculty of Education “Teachers of the Deaf” program. A teacher pays no tuition to take that training. In contrast, your Government funds no similar graduate-level university program for training TVIs. This again illustrates inexcusable discrimination against students with vision loss.

 b) Ontario’s Serious and Growing Shortage of TVIs

Ontario has a serious shortage of TVIs. From what we have been able to learn, the vast majority of TVIs working in Ontario do not have a graduate degree in the TVI field. They only have one or more of the inadequate Ontario College of Teachers TVI AQ courses. We also understand that a number of experienced TVIs in Ontario have recently retired or will soon retire.

c) A Disturbing Lack of Ministry Oversight

The Ministry of Education is systematically oblivious to what is happening on the front lines. Its Data Collection officials collect none of the important data needed in this area. They do not collect data on how many TVIs are employed in Ontario, or at each school board. They do not have reliable data on how many students with vision loss are enrolled in Ontario-funded schools, or at each school board, or how many need TVI support. They do not collect data on how many hours of direct TVI service per week each student with vision loss needs or gets, on a province-wide or per school board basis. In striking contrast, the Ministry regularly and systematically gathers and analyzes a great deal of data on other aspects of Ontario’s education system.

d) Wild and Arbitrary Variations in the Support Each Student with Vision Loss Receives in School

The amount of TVI support available to students with vision loss varies wildly and arbitrarily from school board to school board. As a result, we have heard repeated stories of students with vision loss not getting the number of TVI hours per week that the student needs. School boards can respond by saying that they don’t have any more TVI hours to share among their students with vision loss. No one is monitoring how decisions are made over the number of TVI hours a student gets relative to their individual needs. During the COVID-19 pandemic, this plight has become more harmful for students with vision loss in Ontario.

Each school board is free to hire as many or as few TVIs as they wish. Each school board is also free to decide how many or how few hours of TVI support each student with vision loss gets. The Ontario Government sets no requirements for this.

The W. Ross Macdonald School for the Blind in Brantford, which your Ministry operates, endeavours to offer support to school boards around Ontario. However, it has no formal standard-setting, mandatory monitoring or enforcement mandate over school boards across Ontario. Its knowledge about what is going on for students with vision loss on the front lines around Ontario is, ultimately, anecdotal and episodic, not systematic. That is not meant as a criticism of that school. Its role is to teach its own students and to serve as a voluntary resource to Ontario school boards.

e) No Ontario-Based University Program to Train TVIs

Unlike BC and Nova Scotia, Ontario has no university faculty of education that offers a graduate program in the field of teaching TVIs. We have been advocating to the Ontario Government for over three years to have one established. To its great credit, the respected TVI graduate program at UBC has been willing to partner with an Ontario university faculty of education as a satellite campus for UBC’s program. No one has taken UBC up on this offer.

As noted earlier, the Ontario Government fully funds the York University Faculty of education graduate-level program for Teachers of the Deaf. No one in the Ontario Government has given any reason why students with vision loss need or deserve anything less.


4. A Legacy of Protracted Government Neglect

We are enormously frustrated with the Ontario Government’s protracted and ongoing inaction on this issue. We repeatedly brought this problem to the Ontario Government for over three years. Yet nothing has improved. We have received lip service and abject apologies for the Government’s repeated delays. There has been no commitment to fix it nor any plan of action.

Your Government has made announcements about equity in education. Yet this TVI issue has never even been mentioned, much less effectively addressed. We now need concerted Government leadership on this issue before it gets even worse.

We have spoken to a parade of revolving door assistant deputy ministers and directors. We have briefed your office and your Deputy Minister. We have fully briefed the Ontario College of Teachers.

We extensively documented our concerns and offered constructive recommendations for action in writing on several occasions, this being the latest.

We first presented this issue to the Ontario Government over three and a quarter years ago, in our detailed January 25, 2018 brief to your Ministry. We had our first of several meetings with senior Ministry officials in early March 2018.

On June 17, 2019 your then Assistant Deputy Minister Martyn Beckett said that from that point on, he would be our lead contact. He had been fully briefed on this issue over a year earlier. He committed to us that he would let us know by mid-July 2019 what was happening within the Government on our requests. We never heard back from him. We later learned that he retired. Ministry staff later deeply apologized for the ball being dropped yet again on this issue.

We further elaborated on these concerns in writing in our February14, 2020 brief to the Ontario Human Rights Commission’s “Right to Read” inquiry

Last year, we were told that Ms. Demetra Saldaris, Director of the Professionalism, Teaching Policy and Standards Branch, would now have lead responsibility for this issue. We had more than one thorough and helpful discussion with her. We then ran into more radio silence. We have recently stumbled onto the fact that she has left the Ministry. No one had reached out to tell us this, or to offer to take over her lead responsibility for this issue.


5. The Ontario College of Teachers Also Dropped the Ball

Beyond all of our efforts described above, we also repeatedly presented our concerns to the Ontario College of Teachers. It is the self-governing organization that regulates teachers in Ontario.

The College never disputed the problem’s existence. However, its response to the problem has been woefully insufficient.

The Ontario College of Teachers decided to simply improve the curriculum in the TVI AQ courses now required to qualify as a TVI. We have shown the College that their approach is merely a cosmetic action that will not effectively solve this problem. It may lead the College to feel they can claim that they have fixed this problem, without in fact properly solving it. It is akin to laying out nicer plates in the dining room of the Titanic.

6. An Effective Solution is Available

This problem can readily be solved, if the Ontario Government leads the implementation of several coordinated measures:

  1. The Ontario Government should publicly recognize this problem. It should publicly commit to lead the implementation of solutions. It should commit to announce a detailed plan of action.
  2. The mandatory Ontario requirements to qualify as a TVI should be substantially increased. A qualified teacher should be required to successfully complete a one-year graduate masters program delivered by a Faculty of Education, dedicated to training TVIs and that includes a substantial practicum requirement.
  3. A graduate-level university program should be established in Ontario, and fully provincially funded. To save money and time, it should be operated as a satellite of the recognized graduate program offered at UBC, which has graciously offered this support to Ontario. This will speed up reform and substantially reduce costs.
  4. The Ontario Government should incentivize teachers to train as TVIs, and should finance the training of a surge of teachers to undertake this new TVI training, in order to substantially increase the pool of available TVIs in Ontario. After that, a regular flow of new TVIs should be funded through this training to ensure a long-term sufficient supply of qualified TVIs in Ontario.
  5. A provincially-funded program should be established to “retrofit” or upgrade the skills and training of those who are already working as TVIs in Ontario and who did not undertake a graduate-level program in teaching students with vision loss. This should include, for example, effective training in the new adaptive technology that students with vision loss can use as part of their education and activities of daily living.
  6. The Ministry of Education should track, set standards for and make public key data on the numbers of TVIs, their training, and the hours per week of direct TVI support that each school board provides to students with vision loss.

 7. Conclusion — Where You Can Quickly Start

We have repeatedly asked your Ministry and the Ontario College of Teachers to convene a joint roundtable meeting with us, our key supporters such as CNIB, and all other key players. This should include the Ministry, the Ontario College of Teachers, the Ministry of Colleges and Universities and York University’s Faculty of Education and/or another education faculty with whom this topic can be productively discussed. Months ago, your Ministry’s officials indicated that this would be a good idea. Progress can only be made if we are all at the table at the same time, working together. Yet something as simple as that meeting has never been scheduled in months.

Please commit that the Ministry will take swift action to effectively address the issues we are raising and will promptly announce a plan of action with a timetable. Could we please speak to with you to kick-start action?

The Ontario Government publicly committed to leading by example on the issue of accessibility for people with disabilities and that it will take an “all of Government approach” to that important issue. Students with vision loss in Ontario need the Government to lead by example on this issue, rather than continuing to lag far behind so many other jurisdictions inside and outside Canada. We look forward to hearing back from you.


David Lepofsky CM, O. Ont

Member and Director of Government Relations, Board of Directors of OPVIC/Views


Premier Doug Ford, premier@ontario.ca

Raymond Cho, Minister of Seniors and Accessibility, Raymond.cho@ontario.ca

Nancy Naylor, Deputy Minister of Education, nancy.naylor@ontario.ca

Yael Ginsler, Assistant Deputy Minister of Education (Acting) for the Student Achievement Division, yael.ginsler@ontario.ca

Claudine Munroe, Acting Assistant Deputy Minister of the Student Support and Field Services Division, Claudine.Munroe@ontario.ca

Patrick Case, Assistant Deputy Minister, Education Equity Secretariat, Patrick.case@ontario.ca

Rachel Ryerson, Director of the Professionalism, Teaching Policy and Standards Branch, rachel.ryerson@ontario.ca

Denise Cole, Deputy Minister for Seniors and Accessibility, Denise.Cole@ontario.ca

Mary Bartolomucci, Assistant Deputy Minister for the Accessibility Directorate of Ontario Mary.Bartolomucci@ontario.ca

Ena Chadha, Chief Commissioner, Ontario Human Rights Commission cco@ohrc.on.ca

John Rafferty, President, CNIB, john.rafferty@cnib.ca

Suzanne Decary-van den-Broek, CNIB Executive Director, Ontario East & South (GTA), Suzanne.Decary@cnib.ca

Demetra Saldaris, Director of Standards of Practice and Accreditation, Ontario College of Teachers dsaldaris@oct.ca

Prof. Cay Holbrook University of British Columbia cay.holbrook@ubc.ca

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