OPVIC Brief on TVI Qualifications to the Ontario College of Teachers

Ontario Parents of Visually Impaired Children — Views for the Visually Impaired

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Brief to the Ontario College of Teachers in Response to Its Two Surveys on Strengthening Required Qualifications for Teachers of the Visually Impaired (TVIs)

June 25, 2020

1. Introduction

This brief is submitted to the Ontario College of Teachers by OPVIC (Ontario Parents of Visually Impaired Children). Our organization now uses the name OPVIC in our daily activity. Our corporate name remains Views for the Visually Impaired. The name OPVIC more effectively explains who we are.

We are provincially recognized as the organized non-profit, non-partisan advocacy voice of parents and guardians of children with vision loss in Ontario. That includes children and youth who are blind, or who have low vision, deaf blindness or vision loss combined with another disability or disabilities. As the parents of children with vision loss, our role every day is, in our own ways, to teach our children. We bring that perspective to bear in this brief.

OPVIC advocates at the provincial and local levels on behalf of the needs of students with vision loss. For example, OPVIC has representatives on several Special Education Advisory Committees around Ontario. It is entitled to be represented on those committees, as the grassroots voice advocating for the needs of children with vision loss. OPVIC is also a supporter of the Accessibility for Ontarians with Disabilities Act Alliance.

We have only been able to submit this brief after the College’s time line for receiving feedback. We appreciate the College giving us additional time to respond. With the COVID-19 crisis, OPVIC and its members, like all others, have been struggling to deal with a myriad of unprecedented challenges.

We thank the Ontario College of Teachers (OCT) for looking into the current requirements to qualify in Ontario to serve as a teacher of the visually impaired (TVI). We welcome this opportunity to provide our input into the College’s two surveys on this topic.

 

 2. The Bottom Line – Summary of This Brief

1. Instead of responding on a question by question basis to the College’s two surveys, this brief’s detailed analysis is our comprehensive answer to those surveys and this consultation. We offer a thoroughly-researched brief to support our position.
2. By this consultation and these surveys, the Ontario College of Teachers recognizes that there is a need to improve the required training in Ontario to qualify to serve as a Teacher of the Visually Impaired (TVI). OPVIC has for quite some time, most recently over the past two and a half years, spearheaded efforts to get these requirements substantially strengthened. In this we have been joined, encouraged and supported by key vision loss professionals.
3. It is beyond dispute that Ontario’s current training requirements for TVIs is substantially inadequate. They do not ensure that TVIs have the knowledge, skills and expertise they need to effectively play the pivotal TVI role in our schools, serving the needy, highly-vulnerable and chronically underserved population of students with vision loss in Ontario schools.
4. The appropriate reform needed is for Ontario to require a teacher to obtain a masters degree in the field of teaching students with vision loss, with a substantial practicum component, offered by a university’s faculty of education, and taught by qualified university faculty members who have the needed expertise in and who conduct research on teaching students with vision loss. In early 2018, our call for reform was unanimously supported by OPVIC on behalf of parents of students with vision loss in Ontario, by AER, the Association for Education and Rehabilitation of the Blind (representing vision loss rehabilitation professionals and vision loss education professionals), and by the Canadian National Institute for the Blind/Vision Loss Rehabilitation Ontario Canada’s National provider of Advocacy, Support and Vision Loss Rehabilitation.
5. One option for reform that the Ontario College of Teachers is actively considering is continuing to deliver TVI training through some form of revised or expanded Ontario “Additional Qualification (AQ) courses. That option is inappropriate. This is so, whether they are in the form of the current AQ courses for TVIs, or in the form of the revised courses that the Ontario College of Teachers is now considering and seeming to favour. Such a strategy would deliver a mirage of needed reform. It would not deliver the actual improvements that are needed.
6. The required curriculum for TVIs cannot all fit within such AQ courses. The venue and manner of delivery of such AQ courses does not ensure the proper quality and comprehensiveness of the program. It does not assure the sufficient qualification of those who teach the AQ courses.
7. The Ontario College of Teachers has sought input on proposed revised guidelines for the three TVI AQ courses now in operation. Even if revised as proposed, those courses suffer from substantial deficiencies. They will not provide the training that TVIs need. As well, the draft revised guidelines for those courses are woefully insufficient. They largely talk in extremely vague generalities about teaching. They only include brief elements relevant to teaching students with vision loss. Those elements are also extremely general and high-level. Those guidelines provide exceedingly little direction or guidance to an instructor who would teach any of those courses. The proposed addition of a proper and much-needed practicum requirement, now missing from the Ontario College of Teachers’ AQ requirements for TVI training, requires proper oversight under a university’s faculty of education, not the oversight of those whom the College now permits to teach TVI AQ courses.
8. The College’s list of five possible new optional courses does not cover all the content that proper TVI training should include. They were not designed by experts in the field of designing curriculum for teachers of students with vision loss. The College is proposing optional courses in areas like adaptive technology. Such content should be mandatory, not optional.
9. OPVIC calls upon the Ontario College of Teachers to actively support OPVIC’s proposal that a graduate TVI masters degree be required, taught in a university faculty of education, including a substantial practicum requirement. We urge the College to support our request that the Ontario Government fund the establishment and operation of such a program in Ontario.
10. At least five other Canadian provinces require a masters TVI degree. Two Canadian universities offer just such a degree, the University of British Columbia and Mount St. Vincent University. Ontario should do and require nothing less. The Ontario College of Teachers and its survey has produced no convincing policy justification for Ontario requiring anything less.
11. It would be inappropriate and unjustified for the Ontario College of Teachers to instead try to squeeze such a requirement into the ill-suited and ill-fitting framework of a series of AQ courses akin to what the College has decades ago approved for Teachers of the Deaf. That York University program should be treated as a masters program, to which it is the functional equivalent, not as at present, as a certificate or diploma program. The fact that it is not is an arbitrary and unwarranted quirk of history, unjustified by any compelling policy rationale. That arbitrary and unjustified quirk of history should not be repeated and superimposed on students with vision loss and those who teach them. If it is agreed that the current TVI AQ regime as is or with refinements is insufficient, then the expanded program that is needed, and that is twice proven in Canada to be amenable to a university faculty of education’s masters program, should in Ontario be just that. It should not artificially be diluted or downgraded to something less. The fact that the Ontario College of Teachers ordinarily operates in the realm of AQ courses should not be the tail that arbitrarily and unjustifiably wags the needed reforms here.
12. There are serious and substantial problems with the two surveys that the Ontario College of Teachers has been conducting, and its related process for developing reforms. The design of a proper Ontario program for training teachers to become qualified TVIs should be left to those with actual proven qualifications and expertise in this area, namely those delivering graduate-level university programs for TVIs.

3. The Pressing Need for Substantial Reform to and Upgrade of Ontario’s Required Qualifications to Serve as a TVI in Ontario

a) The Proper Starting Point

A proper consideration of this issue should begin with a clear understanding of what is wrong with the current training requirements for Ontario TVIs. In recent years, OPVIC has led the public campaign in Ontario to get the Ontario Government and the Ontario College of Teachers to substantially strengthen the required training and qualifications to serve as a TVI in Ontario. We believe that it is due to our advocacy efforts that the College has recently started to take some preliminary consultative action on this issue. The current College consultation and two surveys are part of that action.

In all of our advocacy efforts and discussions with the Ontario Government and the Ontario College of Teachers, with university education faculties and with TVIs themselves, no one has disagreed with our position that the current training requirements to qualify to serve as a TVI in Ontario are out-dated, inadequate and unjustified. No one has publicly opposed the reforms we seek. In over two years of our advocacy efforts on this issue, no one has tried to justify them as sufficient.

The Ontario College of Teachers’ current consultation on TVI training carries with it a recognition that Ontario’s TVI training requirements need to be improved. The only live question is how to improve them.

OPVIC earlier documented substantial deficiencies with Ontario’s current TVI training requirements in four briefs and submissions. All of them have been shared with the Ontario College of Teachers and with the Ontario Government. All have been made public. We ask the Ontario College of Teachers to treat those briefs and submissions as part of this submission. We here supplement them. These include:

1. OPVIC’s January 25, 2018 brief to the Minister of Education. We then had not started using the name OPVIC.
2. OPVIC’s February 14, 2010 brief to the Ontario Human Rights Commission’s “Right to Read” inquiry..
3. OPVIC’s May 1, 2020 letter to Assistant Deputy Minister of Education Jeff Butler, and
4. OPVIC’s June 18, 2020 brief to the Ontario Government’s consultation on plans to transition to school re-opening during the COVID-19pandemic.

The critical role of the TVI in the education of students with vision loss underpins our concern. In OPVIC’s February 14, 2020 brief to the Ontario Human Rights Commission’s “Right to Read” Inquiry, we explained:

“When students with vision loss reach school, the pivotal and indispensable school board employee who is vital to their acquiring literacy is the teacher of the visually impaired (TVI). The TVI provides the hands-on direct training to students with vision loss on braille reading and writing where needed, on the use of adaptive technology that is critical to literacy, and on other vital skills relevant to reading.

The TVI is also the indispensable person who educated and supports the student’s classroom teacher, special needs and education assistant (if any) and other teaching staff on how to effectively teach students with vision loss. Most of the facetime that students with vision loss spend in school is with teaching staff who have no training or experience in how to teach students with vision loss. Where a TVI is involved, they typically only spend a small proportion of the student’s in-school face-to-face time with the student with vision loss.

In Ontario’s publicly funded education system, everyone from senior management through 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 with students with vision loss.”

Despite the TVI’s vital role for students with vision loss, Ontario’s training requirements for TVIs have for years fallen substantially below the requirements in at least five other Canadian provinces, in much of the US, and in certain other developed countries such as the UK and New Zealand. Vision loss professionals have for years tried to get the Ontario Government and the Ontario College of Teachers to rectify this, without success. It appears, as is too often the case, that the vocal and public voices of parents of students with disabilities is needed to get major institutions to initiate needed action towards reform, like the Ontario Government and the Ontario College of Teachers.

 b) The College’s entire Model of “Additional Qualifications” (AQ) courses Is Inherently Insufficient to Meet the Needs of Students with Vision Loss

The entire focus of the first of the two Ontario College of Teachers surveys is on what might be included in new “Additional Qualification” or AQ courses for TVIs. We address the details of that option in detail further later in this brief.

As an overarching concern, our earlier briefs and submissions, listed above, together demonstrate extremely serious problems with the TVI AQ courses. Those courses are too short to cover all the content that a TVI needs to learn. They include no practicum requirement. A teacher can complete all those courses and never even meet a student with vision loss, much less work with a student with vision loss or observe a trained TVI properly working with a student with vision loss. These deficiencies were poignantly illustrated when a new Ontario TVI, who met the College’s minimum requirements to begin working as an Ontario TVI, candidly admitted in the presence of their colleagues and an OPVIC member that they don’t consider themselves to have the training they need to work as a TVI.

As we understand it, Ontario College of Teachers and Ministry of Education regulations require a qualified teacher to undertake three AQ courses in the blind/low vision field, each about 125 hours, to be qualified to work as a TVI in Ontario. Yet in practice, a teacher can take only the first of these AQ courses and then get a job as a TVI at one of Ontario’s 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. In practice, only the first of those requirements is actually needed and required to get and keep a job as a TVI in an Ontario school. No one appears to effectively police whom an Ontario publicly-funded school board employs to work as a TVI.

The deficiencies with the existing TVI training requirements that we identified in our four earlier briefs and submissions cry out for the major reform we seek. Yet, we here identify additional serious problems with the College’s model of TVI AQ courses. These additional deficiencies make the case for the reform we seek even more urgent and overwhelming.

AQ courses in this area, delivered to date, do not have the inherent safeguards for quality control that a graduate university program requires. Information we have acquired from the W. Ross Macdonald School for the Blind in Brantford ((which the Ontario Government directly operates and which the Ontario College of Teachers has consulted in its recent efforts in this area) revealed the following.

Staff at the Ontario College of Teachers have told us that the current TVI AQ courses are offered through the University of Western Ontario. To uninformed observers hearing this, it can seem that because these courses are offered through UWO, this provides some quality assurance for these courses. Yet, we understand UWO’s involvement provides no such safeguards. It may deliver to some an illusion of quality control or assurance but does not deliver the reality of quality control or assurance.

From information we obtained from the W. Ross Macdonald School, UWO’s involvement in those TVI AQ courses is purely administrative. It is our understanding that these AQ courses are not offered by the UWO Faculty of Education. They are not taught by professors at the UWO Faculty of Education. Their substantive curriculum is not set by or approved by the UWO Faculty of Education. Even if, despite all this, UWO had provided some oversight of the College’s TVI AQ courses, we have no information that anyone on the UWO faculty or staff have any expertise in the education of students with vision loss, or in how to effectively train TVIs. It would therefore be wrong to treat UWO’s purely administrative involvement as lending any quality control or credibility to the TVI AQ courses.

We understand that in recent years, the TVI AQ courses have been taught by some TVIs who work at the W. Ross Macdonald School. This might at first suggest to some that there is sufficient expertise brought to bear in the design, teaching and evaluation of these courses. The W. Ross Macdonald School’s teaching staff of course has years of experience teaching students with vision loss in the residential school setting. It is the only residential school for students with vision loss in Ontario.

We have, however, seen no demonstration that the Ontario Government, which operates that school, or that the school itself, has any expertise akin to a university faculty of education in teacher training, and in the proper design and teaching of a program to train TVIs. Just because someone is a teacher and has worked in our schools for years, that alone does not qualify them to design and deliver courses for training someone to be a teacher. That is why to train people to become qualified teachers in Ontario, we have universities, with faculties of education whose faculties are subject to the rigours of faculty recruitment and promotions, and that undertake peer-reviewed research. In so stating, we do not in any way doubt the knowledge, hard work, dedication or passion for students of the W. Ross Macdonald School’s staff.

Reinforcing this concern, we understand that none of the TVIs at the W. Ross Macdonald School have a graduate degree in teaching students with vision loss, whether a masters or a doctorate. The W. Ross Macdonald School does not appear to require a person to have such a graduate degree to teach its students, or to teach one of the TVI AQ courses. That means that the teacher who is teaching any of these TVI AQ courses only has their Ontario TVI training, i.e. they have completed the demonstrably inadequate existing Ontario TVI AQ courses that lie at the core of this entire issue.

The W. Ross Macdonald School advised that to teach one of these AQ courses, an Ontario TVI must have had some designated number of years working as a TVI, possibly 15 years. It can of course be helpful to have had such experience teaching students with vision loss. However, without the proper expertise and academic training in how to train TVIs based on work and graduate-level research, and without a better training foundation in teaching students with vision loss than is obtained from Ontario’s current TVI AQ courses, simply being an experienced W. Ross Macdonald TVI with a number of years in the classroom is not sufficient. At a human level, it is entirely understandable that those teachers have tried to fill the void, no doubt out of the best of intentions, so that TVIs get trained in Ontario. However, that does not reduce the serious problems with the TVI AQ system.

We have also learned that the person or persons who teach a TVI AQ course in any year has an extremely wide discretion over what to actually teach in the course, and how to teach it. The Ontario College of Teachers has set some extremely general guidelines possibly supplemented by suggested curriculum that was designed some years ago. However, as a practical matter, the TVI AQ course instructor retains a very wide choice over how to shape the course and its delivery. As addressed further later in this brief, it appears that the College’s guideline for the three basic TVI AQ courses, appear, even if reformed as the College is proposing, to give the course’s instructor precious little direction on the specifics to teach in the course and how to fit it all into 125 hours per course.

We are not aware that either the College or UWO provides any effective expert oversight of the choices that a TVI AQ instructor makes over what to teach in the TVI AQ courses. Moreover, we are not aware that the Ontario College of Teachers or UWO has any expertise in teaching students with vision loss, or in training TVIs, by which to provide the needed effective oversight. We are not aware of any 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.

In addition, a vital feature for properly training TVIs that is missing from the current regime is a properly constituted, administered and overseen field practicum with students with vision loss. The current regime has no practicum at all. The College appears to confirm that one is needed, since it has included one in proposed course revisions, address further later in this brief.

The AQ course format would not effectively provide for this. As addressed later in this brief, a properly constituted practicum requires the oversight of an academic program that a faculty of education can provide. Neither the W. Ross Macdonald School nor individual TVIs are qualified to administer this. As noted earlier, the UWO’s involvement in TVI training through AQ courses training has been purely administrative.

Based on all of these concerns, the entire option of improving or expanding the existing regime of TVI AQ courses is a non-starter. As we have often said, it is akin to laying out nicer china on the tables of the dining room of the Titanic, as if that would solve the impending problem facing the Titanic’s passengers and crew. It fails to address the core problem. If anything, it seriously risks becoming a distraction and a diversion from measures that are needed to truly fix the problems from which students with vision loss now suffer in Ontario. Updating or expanding upon the existing TVI AQ courses risks create a superficial impression that the College is genuinely acting to make things better, without actually delivering the improvements that students with vision loss need and deserve.

c) Current Ontario College of Teachers Requirements and Practices Don’t Properly Recognize the Superior TVI Training Provided at UBC and Mount St. Vincent Graduate University Programs

It is a stunning and cruel irony that Ontario regulations and the Ontario College of Teachers enforce substandard Ontario TVI training requirements. At the same time, they do not properly recognize as sufficient the superior TVI training at UBC’s or Mount St. Vincent University’s TVI masters programs. If an Ontario teacher gets a TVI masters at UBC or Mount St. Vincent University, the Ontario starting point is that this training is not recognized in Ontario. Yet those degrees should instead be respected as sufficient and as superior to Ontario’s TVI AQ courses. Ontario’s erroneous 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.

This is indefensible. Those university TVI graduate programs require more hours of study and a fuller TVI-related curriculum, compared to Ontario’s TVI AQ courses. Those university graduate programs are offered by university faculty members, themselves having graduate degrees in this field. Ontario’s AQ courses are taught by TVIs with no graduate degree in the field. Those university graduate programs are part of a university structure that engages research in the field. Nothing in the AQ courses requires or assures any such academic enrichment. Those university graduate programs have a clear practicum requirement. Ontario’s AQ courses have no practicum component and have no capacity to provide a properly-overseen practicum component.

In the face of this serious concern, Ontario College of Teachers officials have told OPVIC that a graduate of the UBC or Mount St. Vincent program can ask the College to grant them an exemption from the AQ requirements. The College told OPVIC that of the several most recent graduates who sought that exemption, all were granted exemptions.

Based on feedback we have subsequently received from the field, our concerns in this regard are undiminished. First, those with a masters from a graduate TVI program should simply be recognized in Ontario as qualified. They should not have to each prove 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 Ontario requirements.

Second, we have received feedback indicating that such exemptions are not automatic. We understand they require supportive justification, beyond proof that the TVI successfully completed their masters. This is an unnecessary and unfair burden. If anything, it is an arbitrary regulatory barrier that can only hurt students with vision loss.

Third, we understand from feedback received that at least one graduate with a TVI masters did not get exempted from all three of the current TVI AQ courses. At most, they only got exempted from the first AQ course. Yet that TVI’s training is clearly superior to someone who has no masters but who has completed all three of Ontario’s TVI AQ courses.

Finally, we have no information or indication that Ontario College of Teachers officials who assess and decide upon individual applications for these exemptions have the needed expertise in the area of teaching students with vision loss or in the design and operation of proper training of TVIs.

 

4. Response to the Options for Reform that the College Has Presented

a) Problems with The Ontario College of Teachers’ Proposal to Create Five New TVI AQ Courses

The foregoing problems amply show that there is no merit to the option that the Ontario College of Teachers’ first survey exclusively addresses as a solution, namely creating five new TVI AQ courses, from which a candidate may select three to take. Those five courses would be:

“Cortical Vision Impairment (125 Hours)

Technology for Learners who are Blind/Low Vision (125 hours)

Braille (125 hours)

Supporting Learners who have Low Vision (125 hours)

Supporting Learners who are Blind (125 hours)”

These general course titles are some of the relevant areas that a TVI needs to know. We have been given no specifics on the content, objectives, requirements or assessment in any of these courses. We do not know if The College has any such information and if so, if it made any of that information public. As far as we have seen, the College has simply circulated these five course titles for comment.

Later in this brief, we address the confusion in the College’s survey over whether these five new courses are meant as an addition to or replacement of the current three TVI AQ courses. In either event, there is no assurance that any or all of these new AQ courses can or would have any better quality assurance or quality control than has been the case for the three existing AQ courses. To the contrary, the same problems with the current courses would be replicated in these new courses.

As well, a closer look at the proposal of these five new courses quickly reveals even more concerns. The Ontario College of Teachers’ first survey contemplates that one would only be expected to complete, at most, only three of the five new AQ courses. There is no assurance that the three courses, even if taken, will adequately cover the training requirements that a properly-trained TVI needs.

For example, the College’s first survey contemplates that one of the new courses, addressing adaptive technology, yet proficiency with rapidly-changing adaptive technology for students with vision loss is an absolute necessity for TVIs. It is a current major deficiency in current Ontario TVI training. Nothing about it should be optional.

Moreover none of those new courses is entitled to address the needs of students with vision loss who also have another disability. Yet a significant proportion of students with vision loss have an additional disability or disabilities. Nothing in what the Ontario College of Teachers has made public to us suggests that this would receive appropriate coverage.

As noted later in this brief, it is not clear from the survey whether the Ontario College of Teachers means these five new courses as an addition to the three existing TVI AQ courses, or as a replacement for them. If they are meant only as an optional addition to the three pre-existing TVI AQ courses, then no one need ever take them. Why should a TVI spend all the time and money needed to undertake them, if they are not required. If a person, wanting to be a TVI, and wants quality training for it, it would be preferable for them to undertake a masters TVI program which provides better quality training, and which results in a masters degree.

The Ontario College of Teachers might aspire to eventually issue a news release, proudly announcing a major step to improve training of TVIs, namely the creation of these new AQ courses. Yet creating these new courses could well end up accomplishing nothing for students with vision loss. It risks having the College and the Government use the creation of those new courses as an excuse for moving on to other issues, and again wrongly leaving behind the pressing unmet needs of students with vision loss.

 b) Problems with The Ontario College of Teachers’ Plans to Update Some or All of the Existing Required TVI AQ Courses

Though not addressed in either of the two Ontario College of Teachers surveys, we understand that the College is also considering possible changes to the three existing TVI AQ courses. We first review the April 23, 2019 document from the College which appears to be a proposed revision to the College’s guideline for Part 1 of the current TVI AQ courses. That is the first of the three current TVI AQ courses. We here provide key points in response to it, as concerns this brief’s core topic.

The College’s proposed revised guideline for the TVI AQ Part 1 course suffers from the problems with the current TVI AQ courses that we have identified in our four earlier briefs and submissions, and elaborated upon in this brief, subject to our comments below about its addition of a practicum requirement.

That 34 page guideline is not easy to read. The vast majority of it is extremely general, talking about very broad and basic principles of teaching, unrelated to the specific needs of students with vision loss. Indeed, the vast majority of it says nothing specific about training TVIs or about teaching students with vision loss.

We suspect that those extensive high-level generalities are likely the College’s boiler plate language for AQ courses more generally. There is an indication that this is older College boilerplate language for AQ courses. Among the legislation to which it refers is the Ontarians with Disabilities Act 2001. That law was repealed years ago.

Amidst that general language, several mentions of learners with vision loss appear to be cut and pasted into the document’s lofty generalities about teaching where they are grammatically and contextually appropriate. The first reference to any teaching content specific to students with vision loss appears almost halfway through the 34 page document.

This document provides exceedingly little direction or guidance on what is to be taught in this course. Only about one or two pages or so of this document speak about substantive content that is specific to teaching students with vision loss. Those items are scattered through the latter half of the document. We excerpt those passages in Appendix 2 to this brief. Even those passages are expressed in very vague and general terms. They give a course instructor very little direction or guidance.

As well, we have seen no information from the College establishing that those who recently revised this document have the qualifications required to teach in a university’s faculty of education specialty graduate program for TVIs. Indeed there is no indication that those with proper expertise in the design of university graduate programs for TVIs had meaningful or decisive input into the proposed revisions to this guideline, or the five proposed new TVI AQ courses addressed in the preceding section of this brief.

This proposed revised TVI AQ course guideline proposes to add a practicum requirement to this course, as a form of experiential learning. It provides only very general content regarding this practicum. It does not specify what must be covered, or how it is to be administered, or who is to supervise a practicum placement, or how this can properly be done in the context of a non-university AQ course.

An AQ course such as this is entirely ill-suited to include a practicum requirement. As noted earlier, a proper practicum requirement should be designed, administered and overseen by a properly-qualified university faculty of education’s graduate TVI degree program. For example, the W. Ross Macdonald School that in recent years has offered this TVI AQ course (without a practicum) is not qualified to design, administer and oversee such a practicum requirement. As also noted earlier, according to information obtained from the W. Ross Macdonald School, those teaching this course do not have a masters degree in teaching students with vision loss, much less are they qualified to teach in a graduate university course in this field or to oversee the administration of a practicum.

The proposed revisions to the College’s guidelines for the second and third of the three existing TVI AQ courses suffer from the same problems that we have identified in this section of this brief regarding the first of the current TVI AQ courses. Moreover, because, as shown earlier, an Ontario teacher need in practice not complete the second or third of these courses to work in Ontario as a TVI, any proposed improvements to those courses is not assured to lead to any practical improvements for students with vision loss.

 

 c) Problems with The College’s Alternative Option of Offering AQ Courses and A Practicum Requirement Akin to Ontario’s Program for Teachers of the Deaf

The Ontario College of Teachers’ second survey presents three options, and requests a preference to be voted on, for offering TVI AQ courses, namely:

 

“Option 1    Five (5) new, individual 125-hour AQ courses.

 

Option 2     AQ Program

This will consist of:

• Schedule D: Teaching Students who are Blind/Low Vision (3-part specialist) AQ courses
• Five (5) individual 125-hour AQ courses
• 400 hour practicum

This new AQ Program would be similar to the current program for Teaching Students who are Deaf or Hard of Hearing. The current AQ Program for Teaching Students who are Deaf or Hard of Hearing is two academic semesters in duration and includes a 400-hour practicum

 

Option 3     Masters’ Level Program

Exploration of a masters’ level program”

We here address the second option, namely creating a program that includes combination of AQ courses and a practicum requirement. The College presents this as being akin to the Ontario training requirements to qualify to be a Teacher of the Deaf. As indicated earlier, we call for the third option, namely a masters TVI program.

The College’s second option is not spelled out in any detail. It assumes that the survey participant knows about the specific circumstances of training for Teachers of the Deaf in Ontario.

This second option may at first appear attractive. It appears to have the value of being raising TVI training to Ontario’s requirements for teachers that work with students with a comparable sensory disability, namely hearing loss. Before our most recent investigation of this issue, OPVIC had noted that training requirements for Teachers of the Deaf in Ontario are substantially higher than those for TVIs, and that there is no justification for the lower requirements to train as a TVI. We had earlier advocated for TVI training requirements to be raised to the level required for Teachers of the Deaf. At that time, we had thought in error that in Ontario Teachers of the Deaf must complete a masters degree in their field.

We have now further investigated the issue. We advocate for the College’s third option, a masters requirement, and not its second option, which the College’s second survey describes as AQ courses plus a practicum requirement. We here explain why.

When considering the College’s second option, it is essential to know about and take into account the peculiar and arbitrary historic reasons for the Ontario College of Teachers‘ requirements for Teachers of the Deaf. We don’t know how many, if any of the respondents to the College’s survey know this information. We only recently learned about it.

Ontario’s program for training to qualify as a Teacher of the Deaf in this province is delivered by York University’s Faculty of Education. Unlike UWO’s purely minor administrative role in the AQ blind/low vision courses, York University’s program is a graduate-level program. It is delivered by York’s Faculty of Education. It is directed by a York University professor with expertise in training Teachers of the Deaf.

As we understand it, York University’s program is substantively and functionally equivalent to a master’s program in the area of teaching students with hearing loss. It is functionally comparable to university programs offered outside Ontario that lead to a master’s degree. Its certificate or diploma is treated in other provinces as the same or equal to a masters. We understand that it is certified or accredited by a Canadian body that accredits such programs for training Teachers of the Deaf and or Teachers of the Deaf themselves.

As we understand it, for peculiar and seemingly arbitrary historical reasons, a student who completes the York program gets two things. First, they get a diploma or certificate from York. Second, they also get the AQ credit from the Ontario College of Teachers needed to qualify to work in Ontario as a Teacher of the Deaf. This is certainly not a validation in any way of the way TVI training has been or should be delivered in Ontario.

We understand that it is purely an arbitrary quirk of history that York’s graduate program for Teachers of the Deaf does not lead to a master’s degree. It is not because the York program itself is not comparable to a masters. York’s program considers itself to be equal to a masters program and that its students are deserving of a masters degree. Apparently, the reason that the Ontario College of Teachers has for decades treated this program as a series of AQ courses was as a way to validate York’s program within the framework of the College’s regulatory regime. A square peg was rammed as best it could be into the limited round hole that the College had available. That is a legacy of the history of how the program came to be decades ago, and of the quirks of how the Ontario College of Teachers opted years ago to fit this program into the College’s system for recognizing courses.

In other words, there is no compelling policy justification for that graduate program for Teachers of the Deaf to not lead to a masters, that should govern how reformed and strengthened TVI training in Ontario should be structured. There is no compelling reason to conclude that it is sufficient for a comparable graduate-level university program in Ontario for training TVIs not to be a master’s program, simply because that has been the historic, arbitrary approach to training of Teachers of the Deaf. Two wrongs don’t make a right. It is not good education policy to mimic, replicate or extend an irrational and justified quirk of history.

There are yet more compelling reasons for rejecting the College’s second option. As we have told the Ontario College of Teachers, UBC’s graduate TVI program is open to partnering with an Ontario university faculty of education, as a satellite campus. That would save the costs and time that would be needed to design a new Ontario university-based program from scratch. It would ensure that those studying in Ontario will have the benefits of the respected experience and expertise that UBC’s program has accumulated.

Were that avenue to be pursued, it would only make sense that the graduates of the Ontario-based program get a masters degree. Otherwise, the arbitrary quirk of history in the field of deafness education in Ontario would also lead to the irrational result that a student taking the TVI program in Ontario would not get a masters degree, while the same student completing the same program at the UBC campus in Vancouver would get a masters degree.

OPVIC hopes that Ontario could transform from being decades behind in the area of training TVIs to becoming a national leader in the area. We would like teachers from other provinces to want to train in Ontario to be a TVI. This is more likely to occur, or would only occur, if Ontario’s program results in a masters degree. For Ontario to become a centre of excellence, such a graduate program would have the added advantage of being a centre for research and innovation, with potential access to Canada’s largest concentration of students with vision loss. That would benefit students with vision loss, TVIs, and our society.

There is also a key difference between graduate level university training for Teachers of the Deaf on the one hand, and for such programs for TVIs. Canada does not have a national accrediting body for accrediting either TVIs or graduate university TVI training programs. In contrast, we understand that there is a national Canadian accrediting body either for Teachers of the Deaf or for programs for training Teachers of the Deaf, or for both, the Canadian Association of Educators of the Deaf and Hard of Hearing. We have not had an opportunity to investigate possible international regimes for accrediting TVI training programs.

We do not have specifics on those processes regarding students with hearing loss. Hence, if Ontario were to establish an AQ/practicum program that did not lead to a masters degree for TVIs, along the lines of the College’s second reform option being addressed here, we would begin at the starting point that its graduates would presumably not have their training recognized in other provinces. That means that Ontario would still not be a desirable destination for teachers in other provinces to come to train to be a TVI. As at present, Ontario TVI training could in future still not qualify for working as a TVI in Canadian provinces that require a masters degree.

Stepping back from those specifics, and looking at the big picture, once the Ontario Government and/or the College reaches the point of considering the College’s second option, they have by definition dispensed with the option of simply tinkering with the current TVI AQ regime (the College’s first option, shown earlier in this brief to be inadequate)Then the only remaining live choice is whether to structure the strengthened and upgraded training program as a masters program (as is the case for the UBC and Mount St. Vincent University programs), or something that delivers comparable content but which arbitrarily does not award a masters degree, like Ontario’s Teachers of the Deaf program. Once we are choosing between those two options, the choice becomes obvious. No interest would be served by opting for the second option that the Ontario College of Teachers’ second survey presents, as compared to adopting a masters requirement. It has no financial advantages. It has no academic or pedagogical advantages. It has several important disadvantages. The only interest it might serve, at best, would be to fulfil a bureaucrats hollow desire for some sort of superficial symmetry on paper between Ontario’s training requirements for TVIs and for Teachers of the Deaf. However, for the reasons set out in this section of this brief, any such superficial symmetry would not serve any academic, policy or practical needs or goals. It would not help students with vision loss, TVIs, or school boards. Such hollow bureaucratic niceties should not be allowed to trump the needs of students.

The best, simplest, neatest, cleanest least problematic and most effective solution is to require a graduate degree for Ontario TVIs. We next answer any concern that the Ontario College of Teachers has raised with us that this could create a barrier to entry to the field as a TVI, working to the detriment of students with vision loss.

d) Would a Requirement that a TVI Must Complete a Masters Degree Hurt Students with Vision Loss?

In earlier discussions with Ontario College of Teachers officials, we were presented with a possible concern that to require a teacher to complete a TVI masters degree to qualify to serve as a TVI in Ontario could hurt students with vision loss. The concern was expressed that this would make it harder or more burdensome to qualify as a TVI. This in turn might deter more teachers from seeking to qualify as a TVI.

We have offered the Ontario Government and the Ontario College of Teachers a comprehensive strategy to make reforms in this area work. Our reform proposals would help and not hurt students with vision loss. The status quo hurts students with vision loss. To date, neither the Ontario College of Teachers nor the Government have agreed to our proposals even though this has been placed before them, in this most recent round of advocacy, for over two years.

First the suggestion is purely speculative that teachers wanting to become a TVI would refuse to take a masters degree, but would take a 125 hour TVI AQ course, or three of those courses, or three of those courses plus three of the five proposed new TVI AQ courses. That speculation is belied by the experience of the many jurisdictions inside and outside Canada that require a masters degree to qualify as a TVI. For example, we understand that BC, Alberta, Nova Scotia, New Brunswick and PEI require a TVI masters degree. We have heard no suggestion that a masters requirement has precluded their recruitment of TVIs. We have heard of no Canadian jurisdiction eliminating its requirement of a TVI masters for that reason.

Second, Ontario recently doubled the length of study to qualify as a teacher, requiring two years of teacher’s college rather than one year. This reform was not jettisoned on the ground that it would similarly hurt students.

Third, underlying that line of speculation is the seriously flawed premise that Ontario should maintain indefensible, inadequate shorter training requirements for TVIs, in order to get more teachers to train to be inadequately-trained TVIs. When we face a shortage of doctors in an important area of medical practice, the solution is not to reduce the number of years of medical school and residency training, thereby creating inadequately-trained doctors. The same should go for TVIs, especially in light of their pivotal role for students with vision loss.

Fourth, there is no real assurance that a teacher would have a sufficient commitment and dedication to effectively serving students with vision loss if they are only required, in practice, to complete the bare minimum of a 125 hour AQ course to start working as a TVI, with no enforcement or tracking to ensure that a TVI ever takes other supposed-required TVI AQ courses. A person shows minimal commitment to serving students with vision loss if they merely take one 125 hour course. It can be undertaken in some cases on a lark, or to expand one’s CV, to try to jockey for a pay raise, or just to try out some new area of teaching. By so observing, we of course don’t mean to imply that Ontario’s current TVIs are not committed to their work and their students.

In sharp contrast, if a teacher commits to undertake a masters TVI degree, they show a far greater commitment to students with vision loss. We have received anecdotal feedback supporting this concern.

Fifth, this line of argument would seem to become irrelevant if the Ontario College of Teachers and the Ontario Government reject the College’s first option. As earlier explained, once the choice becomes one between the College’s second option (a program of AQ courses and practicum, akin to Ontario’s Teachers of the Deaf program) and requiring a masters degree, the time and effort commitment could be similar for a trainee. A key difference is whether they get a masters degree, and whether the program is assured to be delivered by a university’s faculty of education.

Finally, any concern in this context is effectively addressed if the Ontario Government were to implement our proposal that it fund the creation and operation of a masters-level TVI program at an Ontario faculty of education. For years, the Ontario Government has funded the Teachers of the Deaf program at York University’s Faculty of Education. Students in that program pay no tuition. As noted earlier, the cost of operating such a program could be substantially reduced if Ontario takes up the UBC TVI program’s commendable willingness to have an Ontario university be a satellite campus. Ontario’s program would still need to hire local faculty. That would substantially benefit Ontario. It would buttress Ontario’s TVI services with a local centre for research and excellence, properly independent of any service-provider or government bureaucracy.

Of course, such a new Ontario program might well charge tuition to out-of-province students who enroll in it. It would be desirable for Ontario to waive such a tuition for out-of-province candidates who enroll in the new Ontario program, if they commit to thereafter work in Ontario as a TVI. That would help incentivize more teachers to train in Ontario to be a TVI and to thereafter work here as a TVI. That could help address Ontario’s troubling TVI shortage.

 

 5. Other Important Issues

We here address other issues that further support the reform option that we urge the Ontario College of Teachers to adopt and to urge upon the Ontario Government.

a) The Ontario College of Teachers and Ontario TVIs in the Field Should Not Be Designing the Curriculum For Training TVIs

Underpinning this entire consultation and the earlier focus group that the Ontario College of Teachers convened is a fundamental flaw. Any design of the courses, course content and manner of instruction for TVIs should be designed by those professionals who have expertise and extensive experience in the proper training of TVIs, backed by research in the field of teaching students with vision loss. As noted earlier, that points to those faculties of education that now offer graduate programs for training TVIs. To that end, we set out in Appendix 1 the submission to this consultation by the Ontario College of Teachers that was submitted by key faculty members at the TVI graduate programs at UBC and Mount St. Vincent University. We endorse that submission.

Respectfully, the Ontario College of Teachers does not have expertise either in the specialty of teaching students with vision loss or in designing and operating a proper program for teaching TVIs. Similarly, as noted earlier, the W. Ross Macdonald School has experience with teaching students with vision loss in a residential school setting. However, its staff, none of whom have a graduate TVI degree, does not have the requisite expertise in designing and operating a proper program to train teachers to be a TVI. Their experience, at best, is in operating the current TVI AQ courses. Those courses are fraught with the deficiencies we have identified.

Similarly, we understand that the Ontario College of Teachers asked some Ontario TVIs about their views on what should be included in AQ courses for TVIs. Those TVIs have experience teaching students with vision loss. However, from information provided to us by the W. Ross Macdonald Schools, it appears that the vast majority of TVIs in Ontario do not have a graduate TVI degree. They would only have one, two or three of the Ontario College of Teachers current deficient TVI AQ courses. They too would not have experience and expertise in how to design a proper training program for TVIs, just because they have themselves worked as TVIs. Depending on their training and work activities, they may or may not be up-to-date in the latest research and development in the fields that relate to this area.

We commend CNIB/Vision Loss Ontario Canada’s national vision loss rehabilitation service provider, for responding to the Ontario College of Teachers survey as it did. CNIB has supported OPVIC’s call for a masters requirement for TVIs. CNIB did not purport to give advice on what to include in courses to train TVIs. This is appropriate since CNIB/Vision Loss Ontario does not train educators, and does not profess to have expertise in how to do so.

b) Serious Problems with the Ontario College of Teachers’ Current Approach to Investigating Solutions

We have concerns with the Ontario College of Teachers’ approach to solving this undisputed problem with TVI training requirements.

The Ontario College of Teachers appears to have first brought together a group to come up with the possible design of reformed TVI AQ courses before reaching a decision on whether reforming the AQ courses is an appropriate solution to this problem. As explained in our earlier briefs and further expanded upon above, the very system of AQ courses is inherently inappropriate and ill-suited for this training. The Ontario College of Teachers created the reasonable impression that it had pre-decided that this problem should be solved within the structure of AQ courses, the world with which the College may be the most familiar.

The Ontario College of Teachers went about designing new course requirements by forming a committee which appears to lack the key required expertise. We have seen no indication that that committee was staffed by or even included qualified university instructors with expertise in the design and delivery of proper training for TVIs. As well, the committee that the Ontario College of Teachers assembled has, among others, a significant contingent from the W. Ross Macdonald School. As noted earlier, none of that school’s staff has the requisite expertise in how to design and deliver a proper program for TVI training. This risks perpetuating deficiencies in the status quo.

The Ontario College of Teachers circulated a first survey which has serious design problems. The results of that survey, whatever they be, will in effect prove little if anything.

As noted earlier, the College’s first survey asks about a proposal to establish five new TVI AQ courses, listed above. The survey does not spell out any detail that would be included in any of these five AQ courses. There is no content to evaluate, beyond the course titles. That is a slim basis for gathering input.

Second, the College’s first survey does not offer respondents a range of choices for how to deliver TVI training. It only asks about a proposal of adding five new AQ courses for TVI training. It presumes that delivering TVI training via AQ courses is an appropriate solution. As detailed above, it is at the core of OPVIC’s position that AQ courses are not the appropriate way to deliver the required training. By this first survey, the College very substantially implies that it has rejected that position. We believe that the principled concerns of parents of students with vision loss deserve greater attention and respect.

Third, the College’s first survey and accompanying College email give what appears to be two contradictory statements about the proposal on which respondents are asked to respond. The College cannot know upon which of these two contradictory regimes any individual survey respondent is commenting.

At one point, the reader is left with the impression that these new AQ courses would be optional, and would not replace the existing three TVI AQ courses. The College of Teachers’ May 14, 2020 email, circulating this survey, stated the following:

“During its review of the three session Schedule D: Teaching Students who are Blind/ Low Vision AQ course guideline, the College received significant feedback regarding the need for further educational opportunities to advance professional practice in support of learners who are blind or have low vision.

You are invited to provide feedback regarding proposed new AQ courses. Regulatory Context: Teaching Qualifications

Please note that assignment or appointment to teach learners who are blind/low vision would still require additional teaching qualification in the Schedule D: Teaching Students who are Blind/Low Vision. These proposed new additional qualification courses would not satisfy this regulatory requirement. These new AQ courses would complement the existing Schedule D: Teaching Students who are Blind/Low Vision AQ Course.”

That statement clearly says that the five new courses that are being considered would not replace the three existing required TVI AQ courses. Contradicting this, at another point, the reader is left with a reasonable impression that these new courses would replace the existing three TVI AQ courses. The College’s survey form lists the five new TVI AQ courses that it proposes to establish, and then states in clear and categorical terms:

“The College is proposing that the successful completion of 3 of the AQ courses listed above would result in a Specialist additional qualification – Supporting Learners who are “

Fourth, the College’s first survey mainly asks the respondent if they “support the development” of a new AQ course in each of the five areas outlined. For example, the survey asks a respondent to indicate if they agree with:

“I support the development of a new AQ course to support teachers’ professional learning in Cortical Vision Impairment:”

That in substance merely asks if this is a good thing for someone to study to work as a TVI. Whatever percentage of respondents say yes or no to this is of little use to professionals who would design a proper university-based curriculum for TVIs. If it is a relevant topic for academic study, the fact that 10% or 90% of respondents said no should not make a difference on whether it should be included in the curriculum.

From our parents’ perspective, a proper graduate TVI program should include all of these five topics and more. We would defer to the academics who design and operate such university programs to determine, based on their research and expertise, what topics to cover, how to divide them up among different courses and how to allocate time among them.

Fifth, at least on one interpretation, the first survey contemplates that a trainee could undertake three of these five new courses. None is mandatory. A teacher who wants to train to be a TVI would not have the expertise to know in advance which of these five courses to take and which they could live without. Yet, the Ontario College of Teachers first survey is based on the fundamental erroneous notion that it would be the trainee who would make this decision.

Sixth, the College’s survey forms have accessibility problems. College surveys should be fully accessible, especially when doing a survey related to teaching students who have vision loss.

Seventh, as explained earlier, the College lacks the expertise to effectively evaluate whatever information it obtains from this survey and to properly incorporate it into curriculum design for TVIs. We do not believe that such curriculum should be designed or validated through such a survey process.

After this survey, the Ontario College of Teachers sent out a second supplemental survey on May 20, 2020. In that survey, the College appears to have already concluded in favour of the five AQ courses on which its first survey sought input. It states in material part:

“The College is now seeking feedback on the preferred structure of these courses, in relation to the existing Schedule D: Teaching Students who are Blind/Low Vision AQ course guidelines.

Part I: Course Structure

Please identify one of the below options as your preferred structure for these continuing education courses for educators:”

The three options offered in that second survey are quoted earlier in this brief. The College’s second survey does not explain that the training for Teachers of the Deaf to which its second option refers is offered at York University’s Faculty of Education, that it is in reality a masters program in all but name, and that its failure to lead to a masters degree is an arbitrary quirk of history, not one supported by a modern policy justification.

A respondent to this survey who does not have the detailed knowledge that a graduate TVI faculty would have, or that OPVIC has acquired through its own investigation, should not be assumed to be able to give a fully informed answer to this question. Here again, the survey results will be of little if any use for policy decision-making purposes.

 

 6. Conclusion

We therefore call upon the College to support the third option, the requirement for a masters degree, and to join with OPVIC and those united with us to support it. We ask the College to support our call for the Ontario Government to fund the establishment and operation of this needed program. If The Government can fund the program for Teachers of the Deaf, it should do so for Teachers of the Visually Impaired.

If instead the Ontario College of Teachers makes changes to the TVI AQ courses, this may create a superficial and inaccurate image of its having reformed and modernized the training of TVIs, but without delivering the true and much needed reform and modernization. Especially in the case of a vulnerable, low-incidence disability like vision loss among children, it is important to guard against such.

We learned earlier this spring that Ontario College of Teachers officials discussed the TVI training issue with Ministry of Education officials at an earlier meeting to which OPVIC was not invited. For over two years, OPVIC has been calling for a meeting to be convened of the key players in connection with this issue. This should include the Ontario Ministry of Education ((which oversees and funds Ontario’s education system),) Ontario’s Ministry of Colleges and universities (which funds and oversees Ontario’s university system, including university faculties of education), OPVIC on behalf of parents of students with vision loss, the CNIB, representation from Canada’s two university programs that offer graduate TVI degrees, and any university faculty of education in a major centre that could consider offering a TVI graduate program. We are delighted that Ontario’s Ministry of Education aims to convene such a meeting. We remain eager to work together with all involved to make real improvements of which Ontario can be proud and that students with vision need and deserve.

 

 Appendix 1 June 5, 2020 Submission to the Ontario College of Teachers from Certain Faculty Members at UBC’s and Mount St. Vincent University’s Graduate TVI Programs

June 5, 2020

To: The Ontario College of Teachers

We are submitting this initial response to the Ontario College of Teachers with regard to the proposed revisions to Additional Qualifications courses for Ontario teachers to be qualified to provide educational services (direct and indirect) to students who are blind or visually impaired. We are faculty members in Special Education-Visual Impairment at The University of British Columbia (UBC). UBC is the only university in Canada with dedicated full-time, tenure-track faculty overseeing the quality and content of graduate courses in this area.

Our most pressing concern with the Ontario College of Teachers is the reluctance to grant certification to professionals who choose to complete their Masters degree at UBC in the area of blindness and visual impairment and return to Ontario only to be told that they must take additional courses to be fully qualified. We believe that the UBC courses meet all three core AQ course requirements for the specialist qualification. And, actually, graduates from UBC exceed qualifications beyond the AQ courses. We are preparing an outline that maps our courses and content to your AQ courses that we would like to have considered as validation that if a student applies for their specialist and demonstrates completion of our program, that they will be awarded their Specialist qualification.

As for the new AQ course structure, we agree with colleagues in Ontario that the quality of preparation through three AQ courses is not sufficient to prepare professionals to meet the diverse and complex needs of students who are blind or visually impaired, often with additional disabilities. They do not appear to provide enough depth of content for a teacher taking these courses to be competent to work successfully as a teacher of students with visual impairment (TSVI). We are concerned that this causes inequity in the quality of education of students with visual impairments in the province. The AQ courses are structured in a fragmented way in that someone may have some knowledge about blindness but not low vision, or vice versa. The addition of the other five topic area courses (of which people might pick three) also causes fragmented knowledge in the breadth of what a TSVI needs to know and be able to do. It is our understanding that none of these new 5 course options are required. Given they are not required to work as a TSVI, many TSVIs in the province will be without the skill set to address the needs of students who are blind or visually impaired.

Blindness and visual impairment is a low-incidence area requiring specialized knowledge, much like education of students who are D/deaf or hard of hearing. Teachers working with this population of students should at minimum have the same level of preparation as those entering the field of D/deaf or hard of hearing. It is our understanding that most teachers in Ontario go through York University for their qualifications. This program includes a 400 hour practicum experience which is critical for demonstration of competence. The D/deaf and Hard of Hearing program at York includes 10 required courses. Students who are blind or visually impaired have the right to similarly qualified teachers given the complexity of learning needs for this low-incidence population. Key to the success of a university program focusing on the needs of students with visual impairments is the commitment to employ and support a full-time, tenure-track faculty member whose primary purpose is to oversee the quality of the program content, update courses to reflect current research findings and be in alignment with standards in the field. This person should provide leadership and conduct research in Ontario, Canada and beyond.

We have been in conversation with staff at Mount St. Vincent University, which has a similar level of preparation as the UBC program. They have similar concerns as those outlined above, and conversations with Mt. Saint Vincent staff would provide additional information as the Ontario College of Teachers moves forward. We will continue to be in contact with our colleagues in Ontario to provide additional information as needed and will follow-up with you with regards to the equivalency of a degree from UBC to courses in the AQ structure.

Sincerely,

Cay Holbrook, PhD
Professor
University of British Columbia
Educational and Counselling Psychology, and Special Education
Blindness and Visual Impairment

Kim Zebehazy, PhD
Associate Professor
University of British Columbia
Educational and Counselling Psychology, and Special Education
Masters in Special Education, Blindness and Visual Impairment

Kevin Stewart, EdD
Part-time faculty
Mount St. Vincent University
Faculty of Education
Masters of Arts in Educational Psychology, Blind and Visually Impaired

 Appendix 2 Specific Content Regarding Vision Loss in the Ontario College of Teachers’ April 23, 2019 Document Entitled “Additional Qualification Course Guideline” Regarding Part 1 of TVI Training

The following excerpts provide some substantive reference to curriculum that relates to students with vision loss:

1. “• exploring the Expanded Core Curriculum/Essential Skills that serves as the framework for educational practice for students with visual impairments including blindness (i.e., communication modes and functional academics, orientation and mobility, social interaction, independent living, recreation and leisure, assistive technology, career education, sensory efficiency and self-determination)

• critically exploring educational standards and practices of various organizations that support students who have visual impairment(s) including blindness (for example, Canadian National Standards for the Education of Children and Youth who are Blind or Visually Impaired, Council for Exceptional Children and Canadian National Institute for the Blind [CNIB])”

2. “exploring Unified English Braille [UEB] – Literary and Technical and Music braille, as well as knowledge of the production of braille resources

• critically exploring literacy, numeracy and teaching strategies specific to learners who are blind or have low vision and/or have a condition of partial, or total impairment of sight or vision that even with correction affects educational performance adversely.”

3. “• critically exploring critical pedagogy that is committed to curriculum design using learners’ inquiry questions, passions, interests and unique needs of the Expanded Core Curriculum (E.C.C.)”
4. “• critically explore the implications that medical information related to students who are blind or have low vision might have on pedagogical practices and strategies

• critically exploring factors that influence how students who are blind or have low vision come to know (for example, lived experiences, unique ways of doing and thinking)
• critically exploring practices that support the multiple uses of braille that meet the needs of students who are blind or have low vision”
• critically exploring provincial legislation and policies that support human rights for all

5. “• critically exploring the Expanded Core Curriculum (E.C.C.) in program design and planning

• critically adopting classroom materials to meet the concept development of learners who are blind or have low vision, including those with additional exceptionalities
• critically exploring medical, genetic and eye conditions including Cortical Visual Impairment (C.V.I.) to inform program planning, development and implementation
• critically exploring the complexity and differences associated with learners’ vision in relation to planning, developing and implementing programs”

6. “• critically exploring a variety of assistive technologies to support learning and well-being”
7. “• critically exploring braille acquisition, braille literacy and broad literacy skills and how they inform program planning, development and implementation”
8. “• critically exploring and reflecting on past, current and evolving practices in Teaching Students who are Blind/Low Vision, Part I”