VIEWS calls on ON Ministry of Education to Review Services to BLV/Deaf-blind Students

Brief to the Ministry of Education Calling for a Ministry Review of Services in Ontario for Students Who are Blind, Low Vision or Deaf-blind


Attention: Martyn Beckett, Assistant Deputy Minister of Education for Special Education


Cathy Montreuil, Assistant Deputy Minister of Education for the Student Achievement Division



Mitzie Hunter, Minister of Education


Bruce Rodrigues, Deputy Minister of Education


Submitted by:

Claudine Santos, President of VIEWS for the Visually Impaired


January 25, 2018

1. Introduction

VIEWS for the Visually Impaired hereby asks that Ontario’s Ministry of Education to conduct a full review of services in Ontario for students who are blind, low vision or deaf-blind.

There are substantial and serious gaps in services for these students. There is no comprehensive plan in place to remedy them. Ontario has fallen behind some other jurisdictions, including some other Canadian provinces, in this regard. for example, Ontario’s standards for qualifying a teacher to serve as a “Teacher for the Visually Impaired” (TVI) in Ontario schools is woefully inadequate, and is clearly lower than in some other jurisdictions. Ontario is now not harnessing the amazing potential that new technology offers students with vision loss.

2. Who is Views for the Visually Impaired?

VIEWS for The Visually Impaired is a non-profit provincial support and advocacy organization, which includes parents of children with vision loss. That includes children and youth who are blind, who have low vision, or who have deaf-blindness. VIEWS works with other stakeholders, advocating for and providing opportunities to assist children, youth & young adults who have low vision, who are blind or who have deaf-blindness, in reaching their full potential. VIEWS helps families get the information, resources and support they require.

VIEWS educates and advocates to policy makers, families and the public about the abilities and needs of children, youth & young adults who have low vision, blindness or deaf-blindness.

The Ministry of Education officially recognizes VIEWS as a respected voice for the needs of students with vision loss. We are entitled to representation on the Special Education Advisory Committee at each school board and have had a representative on the Minister’s Advisory Committee on Special Education (MACSE).

3. Why There is a Pressing Need for the Ministry to Launch a Formal Review of Services for Students with Vision Loss in Ontario

A) General

For the reasons set out below, there are significant gaps and inadequacies in services available to and provided to students who are blind, low vision, or deaf-blind in Ontario. This is contrary to the Ministry’s commitment to equity in education. Each school board should not have to re-invent the same wheel to solve this – it requires provincial leadership.

Students with vision loss are far too often below the radar of the Ministry and of individual school boards, when they plan for services for students with disabilities. Vision loss is a low-incidence disability in Ontario. As such, it has garnered far less attention by the Ministry, school boards, and the media, than other important constituencies, such as students with autism or learning disabilities. As VIEWS knows all too well, these children and youth are sprinkled around the province. Their families are too often quite isolated, with minimal contact with families of other students with vision loss.

The vast majority of teachers, whether general education teachers or special education teachers, have received little or no training on working with students with vision loss. For a student with vision loss studying anywhere except the Ross Macdonald School for the Blind, the majority of the time they spend in school will be with teachers and other school staff who have never before worked with a student with significant vision loss.

In recent years, the Ministry has not conducted a comprehensive review of services and supports for students who are blind, low vision, or deaf-blind. The recent review focused on students with hearing loss as well as students with disabilities. As well, major attention has focused recently on services for students with autism.

The time is ripe for such a review. Services and supports for students with vision loss in Ontario schools are inferior to those which are available in the U.S. and in certain other parts of Canada. Ontario Government leadership is needed now to rectify this.

B) Pressing Need to Substantially Increase the Training and Qualifications to Work in an Ontario School as a Teacher of the Visually Impaired (TVI)


VIEWS calls on the Ontario Government to substantially increase the qualifications that are required for a teacher to be permitted to work in an Ontario school as a TVI. TVIs are the itinerant teachers in Ontario schools, including publicly-funded schools who work with blind, low vision, and deaf-blind students on key areas, such as literacy (including Braille literacy), assistive technology, and concept development (developing an understanding of visually-learned concepts such as three dimensional space and colours). They work one on one with students with vision loss during part of the instructional day. For most students with vision loss, most of their school day is, however, spent with other teachers, not TVIs. For this, TVIs play the important role of assisting and supporting the general education teachers and special education teachers who spent most of the school day with students with vision loss. The TVI assists those other teachers in the implementation of instructional strategies and accommodations, with the aim of ensuring full and equal access to the Ontario curriculum. General education teachers and indeed special education teachers are not trained in these specialized areas nor typically know or understand the full impact of vision loss, whether total blindness or low vision, on a child’s learning, development and access.

To qualify to work as a TVI in an Ontario-funded school, certified teachers need only complete the three-session Additional Qualifications courses identified in Schedule D (Teachers’ Qualification Regulation 176/10 sec. 26) according to the instructions from Ontario’s Ministry of Education under the Ontario College of Teachers Act, 1996, S.O. 1996, c. 12 and Policy/Program Memorandum No. 76C

Despite these requirements, in Ontario, teachers can and do begin working as a TVI, teaching students who are blind or low vision in an Ontario-funded classroom, instructing on them such specialized things as braille literacy and numeracy skills, after only completing one of the three part courses. In other words, they may have only completed 125 hours of TVI training. In that course, PPM 76C, which Ontario’s Ministry of Education issued to school boards, contemplates that to become a TVI, a certified teacher completes or be actively engaged in completing the three 125 hour specialist courses, thus teachers need only complete one 120 course, before starting to work in an Ontario-funded class with students with vision loss. There is no reason why a TVI should not have completed all required training before working with students with vision loss, and not merely one third of that required training.

As a result, the teacher, who can be deployed as a TVI to teach a student with vision loss in an Ontario school, need never observe a qualified TVI while he or she is teaching such things as Braille reading to a student with vision loss. There is no requirement that the TVI first complete a formalized practicum, under the direct supervision of a master teacher, who has detailed competencies in the relevant areas, such as learning to read and write in Braille. They may not have ever even met or spoken to a student with vision loss before starting to teach one to read Braille.

As we understand it, there is no provincial or other enforcement that TVIs are actively engaged in completing all three courses. We have no idea how many TVIs in Ontario have in fact completed all three courses. We do not know if the Ministry of Education or any school boards track that information.

Making things worse, these three required 120-hour courses are insufficient, even if completed, to properly train a teacher to meet the unique and highly specialized needs of students with vision loss. Ontario’s inadequate standard for qualifying to work as a TVI stands in striking contrast with Ontario’s requirements for teachers of students who are deaf or hard of hearing. See e.g. the York University accredited program in this area:


A critical part of work with students with vision loss in the 21st century is an ability to effectively work with new and emerging technology which can dramatically assist students with vision loss, such as the range of Apple iOS devices like the iPad and iPhone’s accessibility features. It is our understanding that to work as a TVI in Ontario, one need have no expertise or even familiarity with these. It is also our understanding that many if not most school boards would not be equipped to teach the use of these. In this regard, we lag behind the U.S.


Regarding training requirements for TVI’s, Ontario stands as quite inadequate, in in sharp contrast with certain other Canadian provinces. It is our understanding that BC, Alberta, Quebec, New Brunswick, Nova Scotia, PEI, and Newfoundland/Labrador all require advance training at the masters level, beyond their regular teacher qualifications, including a practicum working with students with vision loss.  We also understand that Saskatchewan is heading in that direction. There are two Universities in Canada that currently offer this level of training: University of British Columbia (, Mount Saint Vincent University in Halifax, Nova Scotia. ( No Ontario university offers this training.


Ontario is also substantially inferior to many of the State Departments of Education in the United States. In the US, to work as a TVI, an extensive curriculum of educator preparation is required. To qualify as a TVI in many states teachers are prepared in recognized and accredited university programs.  Many of these programs are offered at the graduate level, while some programs are at the undergraduate level.  The course of study that a teacher undertakes depends upon the specific states requirements.


“First of all, you need to know that in the United States, state governments license or certify their teachers to work with students with visual impairments.  So, this first link is to the state of Colorado teacher licensing standards:


For a number of years now, TSVIs have to meet basic teacher educator standards, and then the special education core standards, which begin with Section 9.005.  Section 9.02 is specific to the Special Education Specialist: Visually Impaired.  It begins on page 110 and continues through page 117.


Every state has its own set of standards for TSVIs; Wyoming and New Jersey only require three courses to obtain licensure/certification, but most states require much more.


Understand that orientation and mobility have an additional set of standards, but largely adopt the ACVREP certification (at least that’s what we do in Colorado).  But, in Colorado, a professional cannot teach O&M in the schools without the licensure in TSVI as well.


Most states follow professional standards, which come from two sources. CEC and AER.  The Council for Exceptional Children. What Every Special Educator Must Know is now in its 7th printing ( and receives substantial review from educators themselves (in our case, the Division on Visual Impairments and Deafblindness) specifying what the standards should be.  They are arranged similarly to Colorado’s standards, meaning that a teacher has to meet special education core competencies before also meeting the blindness and visual impairment specialty standards.  CEC’s Initial Preparation Standards are found at


Its Specialty Standards for Blind and Visually Impaired are found at


The Council for Accreditation of Educator Preparation (the new NCATE, has adopted the CEC standards.”


Dr. Ferrell noted that things were in some transition or uncertainty towards the end of the Obama administration and with the arrival of the Trump administration. She then continued:


“The Association for Education and Rehabilitation for the Blind and Visually Impaired also approves university TSVI programs.  The standards it uses are very similar to CEC’s; you can link to the Core Standards and the TVI Curricular Standards at  In this case, however, the core standards refer to the university and faculty and administrative type things.  But I think you will find that the TVI standards look very much like the CEC VI Specialty Set.  Remember, AER certifies the program, not the teacher; there has been a lot of debate within AER about whether ACVREP should be certifying teachers, but I don’t think that’s likely given the current political environment.”


VIEWS has no way to know whether and how often any Ontario-funded school boards have chosen to deploy people to work as TVIs in their classroom who have not even met the substandard requirements that Teachers’ Qualification Regulation 176/10 sec. 26 and  PPM 76C require. We are aware of no Ontario Government monitoring, accountability or enforcement, nor any requirement that school boards report to the Province on the qualifications of the TVIs they employ to work in Ontario classrooms which have students with vision loss.


The organization which represents those who teach students with vision loss, the Council for Exceptional Children: Division of Visual Impairment, predominantly a professional organization for Canadian and US TVIs, has issued a Position Paper on TVI qualifications entitled “Professional Preparation and Certification of Teachers of Students With Visual Impairments”

( )


It expresses the importance of specialized properly-trained teachers who work with students with vision loss. It outlines the quality standards needed in their training programs.


Similarly, the “Canadian National Standards for the Education of Children and Youth Who are Blind or Visually Impaired, Including Those with Additional Disabilities” was endorsed by the National Coalition for Vision Health. That coalition included the following organizations and associations across Canada: A.E. Baker Foundation, Canadian National Institute for the Blind, Canadian Ophthalmological Society, Canadian Association of Optometrists, Vision Health Research Council, The Foundation for Fighting Blindness, the Association of Canadian University Professors of Ophthalmology, BC Centre for Epidemiologic & International Ophthalmology UBC, Lions eye Health Program Canada, MEDEC – Medical Devices Canada, School of Optometry University of Montreal, Atlantic Provinces Special Education Authority, Assembly of First Nations, Opticians Association of Canada, Canadian Institute of Health Research, Association for the Education and Rehabilitation of the Blind and Visually Impaired, Alberta Society for the Visually Impaired, Canadian Association for Families of Children with Visual Impairments, VIEWS for the Visually Impaired and the Canadian Deaf Blind and Rubella Association.


Ontario’s practices regarding the qualifications for TVIs permits some of Ontario’s most vulnerable students to receive substandard education, in such critical areas as basic literacy and numeracy. There are many emerging and major changes in adaptive technology for students and adults with vision loss. TVIs that lack sufficient training will be ill-equipped to effectively teach such traditional and vital skills as Braille literacy and numeracy. They will be ill-equipped to harness the power of these new technologies. For students with vision loss, the rapid spread of digital technology in the general education classroom as well as the special education class room will lead to even more exclusion and marginalization from the educational mainstream.


This is made all the worse by the fact that students with vision loss too often arrive at school in kindergarten, already behind in basic literacy compared to their sighted peers. This is, because so many pre-school literacy resources are visually-based (such as Sesame Street videos).


This is not to say that every TVI working in Ontario is operating at a sub-standard level. A handful of Ontario school boards have commendably decided in the past to employ TVIs with higher qualifications than those which the Ontario Government tolerates as sufficient. That additional training was often obtained outside Ontario e.g. if they have obtained a masters degree in this area.

C) Need to Increase the Supply of Teachers of the Visually Impaired and Orientation and Mobility Specialists in Ontario


It is our understanding that Ontario now has a shortage of TVIs. This problem will become more acute as more senior TVIs retire. As noted above, Ontario has no accredited university-level training program for a teacher to get the training they need to serve as a competent and effective TVI.


Compounding this, another key educational professional that students with vision loss need are Orientation and Mobility Specialists. They teach a person with vision loss key skills of being able to independently navigate their environment, e.g. with a white cane. Ontario now has a shortage of these instructors. The only post-secondary program to train them in Ontario closed in recent years. It was offered at Mohawk College. Here again, the training provided should have been more substantial e.g. through an accredited university program.

4. Concluding Thoughts & Calls to Action


The problems that we outline here all fly in the face of major Ontario Government priorities in the area of education. Ontario has commendably made literacy and mathematics major priorities. Yet it has officially permitted and authorized qualifications for TVIs that include no knowledge of basic Braille mathematics code. It continues to tolerate and authorize TVI standards that would never be tolerated for teachers who teach sighted children to read. If parents of sighted children were told that the teacher who teaches them to read has never taught a child to read, nor done a practicum on how to teach that sighted child to read, nor has been in a room when a qualified teacher as they taught a sighted child to read, nor has ever before even met a sighted child, those parents would understandably rise up in mass protest.


Students with vision loss in Ontario deserve much better. We need the Ministry of Education to show leadership on this issue. We know that more than one public sector player may be involved. The College of Teachers may have to be involved (which regulates teachers), as might the Ministry of Advanced Education and Skills Development (which oversees post-secondary education programs). We want the Ministry of Education to lead this effort, for several reasons:


First, if one ministry is not in the lead, we will be left running from pillar to post, in a frustrating effort to try to get coordinated action. Families of students with vision loss should not have to go through that.


Second, a coordinated plan of action is needed. As such, someone has to be in charge.


Third, the ministry of Education is where the buck starts and stops. The Ministry of Education is ultimately responsible for ensuring that student with vision loss have qualified TVIs in the classroom, working with them. It oversees all school boards. It can and should intervene to ensure that no school board employs and deploys any TVI who lacks proper qualifications. It also oversees school curriculum. It needs to ensure that students with vision loss are properly taught all the skills they need, including, for example, in the area of basic iOS and other technology literacy.


We therefore urge the Ontario Government to take immediate action to launch a review of education in Ontario for students with vision loss. It should include the following, but not be limited to these needed actions:


  1. The Ontario Government should publicly acknowledge that the current standards for qualifying to serve as a teacher of the visually impaired (TVI) in Ontario is too low, and needs to be substantially improved.


  1. The Ontario Government should survey publicly-funded school boards, to identify what specific training on working with students with vision loss their current TVIs have completed.


  1. The new standard that the Ontario Government should adopt for qualifying to teach students with vision loss in Ontario schools should at least meet the standard which is in place in provinces like BC and the Maritime provinces. To qualify as a TVI, a certified teacher should be required to complete a Master’s Degree in the Education of Students with Visual Impairments. This can be acquired at either of two well-respected and accredited programs, at (University of British Columbia and Mount Saint Vincent University in Halifax, N.S.) This should include a requirement to complete a practicum with students with vision loss. It should require that the training be provided by instructors with practical experience teaching students with vision loss.


  1. As a transition, those who have already completed the first of the three-part specialist Additional Qualification Courses in Ontario should be required to complete the other two courses to obtain their specialist AQ and should do so within 18 months. Those working as TVIs in Ontario now should also be required to complete supplemental training beyond those three courses, to be mandated and funded by the Government, if they have not obtained masters level TVI training.


  1. The Ontario Government should put in place a strategy to help ensure that there is a sufficient future supply of qualified TVIs who take the needed training, and to encourage teachers to do so. This should include the creation of a qualified accredited university program in Ontario for certified teachers to get the requisite level of training as a TVI.


  1. The Ontario Government needs to put in place effective monitoring and enforcement to ensure that no publicly-funded school board employs any TVIs who lack proper training and certification. This should include public reporting and accountability for this, and effective enforcement of these requirements by the Ontario Government.


  1. The Ontario Government should establish in Ontario an accredit university-level program to train to work as an Orientation and Mobility specialist.


  1. The Ontario Government should institute a program to ensure that a sufficient supply of qualified Orientation and Mobility Specialists are available in Ontario.


  1. The Ontario Government should take action to ensure that Ontario school boards train students with vision loss on current adaptive technology including Apple iOS devices (the iPad and iPhone).


We would welcome the opportunity to work with the Ontario Government to take action on our recommendations.

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