CERTIFICATION STANDARDS COMMITTEE REPORT
AER Division Nine -- Orientation and Mobility
Newsletter -- Spring 1995
Reasonable Accommodation in O&M: A Brief Conference Report
William R. Wiener, Elga Joffee, Steve Lagrow
The Functional Abilities Assessment (FAA), which Division 9 accepted last spring in keeping with the spirit of the Americans with Disabilities Act (ADA), requires the profession to consider alternative techniques, auxiliary aids, services, or reasonable accommodations to evaluate disabled candidates for certification as O&M specialists. Following the passage of the FAA standards, university programs expressed the need to explore the possible array of alternatives and accommodations that could be used by persons with disabilities to satisfy the safety criteria for monitoring visually impaired travelers.
The Certification Standards Committee of AER's Division 9 therefore sponsored a conference March 14-15, 1995 in Crystal City, Virginia entitled "Reasonable Accommodation in O&M." The purpose of the conference was to assist the universities in exploring alternative techniques and accommodations that would permit persons with disabilities to safely teach O&M. Those invited included representatives from all 17 university O&M training programs approved by AER, disabled individuals who have taught O&M, and representatives from organizations that have an interest in this topic (click here for list of organizations).
Historical perspective
The certification standards for O&M instructors set by Division 9 of AER have historically contained criteria for minimal visual, auditory and physical functions. These criteria were meant to assure that the instructor was capable of monitoring the student, environment and traffic to ensure the student's safety. The original criteria included 20/20 visual acuity and a full field of view, normal hearing and no physical limitations. The visual standard was soon changed to 20/40 acuity and 120 degree visual field, the same as was required in many states for drivers' licenses.
Acuity and field measures were eventually replaced with a Functional Abilities Checklist (FAC) in recognition of the limitations inherent in using clinical measures of visual function. Among other things, the FAC standards required the certification candidate to demonstrate the ability to distinguish detail in the student's posture, gait and technique from distances ranging from 6 to 375 feet; perceive objects within 300 degrees in 3 seconds; verbally interact with the student and the public; discriminate and localize certain sounds; and travel in various environmental settings under a variety of conditions (such as monitoring a student while walking backwards down stairs).
In 1988 the Division appointed a committee to again revise the standards to make them more functional. Over the past 7 years, Division committees worked to develop vignettes which were to have formed the basis for a new Functional Abilities Assessment (FAA) to be administered to university O&M students during their blindfold/simulation experience. However, during the universities' field test of the FAA, it was learned that the testing required in the vignettes was impractical and too time consuming. The Committee therefore abandoned the FAA vignettes but recommended adherence to the standards that were implicit in them. In the spring of 1994, the Division decided by mail ballot that the universities would use those FAA standards to evaluate their students as they performed their regularly scheduled teaching responsibilities during clinical experiences.
The development of the FAA standards was strongly influenced by the ADA, which requires employers to judge any candidate for a job on his or her ability to perform the essential functions of that job, and to provide reasonable accommodation, where required, to enable that person to do so. Since most employers of O&M instructors require applicants to be AER certified or eligible for AER certification, it is essential that this precondition not discriminate against those with a disability.
Certification ideally should guarantee that the applicant is capable of performing all of the essential functions of the job, but it should do so in such a way that it does not unfairly discriminate against those who may perform those functions in alternative ways. One may argue that various aspects of the FAC did indeed discriminate against persons with disabilities by requiring the candidate for certification to demonstrate abilities that, in fact, are not essential functions of the job (for example, to scan and perceive the environment configuration of at least 300 degrees within 3 seconds), or to demonstrate the ability to perform an essential job function (such as monitoring a student who is descending stairs) in a manner which is not essential to that function (that is, while the instructor is negotiating the stairs backwards). As a result, the FAC was removed from AER's
certification standards, and in its place the universities were asked to evaluate students during their clinical experiences using the FAA standards from the previous vignettes.
When those standards were passed by Division 9, they contained language that required the profession to consider alternative ways to evaluate persons with disabilities. The FAA explained that when an otherwise qualified person with a disability is unable to perform the monitoring tasks, the universities should explore the use of alternative techniques or accommodations when needed. Such determinations are to be made on a case by case basis, and to be developed and agreed upon by the student and the university. Accommodations may include (but are not limited to) alternative techniques for teaching and for monitoring safety and student progress, modification of currently used techniques, and the use of assistants and adaptive equipment. It was expected that individuals with a wide range of disabilities (for example, persons who have mobility or sensory
impairments, or who use wheelchairs) would have equal opportunities to achieve certification.
[Picture shows man wearing blindfold walking along a crosswalk using a white cane; a second man using a white cane is about 5 feet behind and to his right, looking to his right. Caption says, "Visually impaired O&M instructor Michael Patten watches for traffic
while 'student' Jim Keim approaches the second lane."]
CONFERENCE HIGHLIGHTS:
Essential Job Functions
The conference began with a discussion of the evolution of certification standards, and an examination of the new FAA "Certification Criteria" that replaced the FAC. The group next discussed the essential functions of the job of the O&M specialist. Using criteria provided by the Equal Employment Opportunity Commission (based on the provisions of ADA), a job function was considered to be an essential function of the job if one or more of the following were true:
1. the position exists for the purpose of performing the function;
2. removing the function from the job responsibilities results in a fundamentally altered position;
3. other qualified individuals are not available to perform the task;
4. the job function requires a high degree of expertise.
Before the conference, the Committee sent the participants a list of 68 job functions required of the O&M specialist, asking them to use the above criteria to determine if these functions were essential to the job of a professional O&M instructor. These 68 job functions were drawn from a clustering of 37 direct teaching competencies and 7 indirect teaching competencies identified by Uslan, Hill and Peck with a breakdown of some mobility techniques and low vision procedures into separate functions (Uslan, Hill, and Peck 1989)
[Picture shows people walking along a sidewalk in front of stores and restaurants. Woman in front wears a blindfold and uses a white cane, a man using a white cane walks about 4 feet behind and to her left. Behind them are two other people, one turning to talk to people behind them. Caption says, "O&M instructor Robert Newman, who is blind, monitors 'student' in business area, followed by conference participants."]
From the participants' responses and discussion, it was apparent that there was a good deal of agreement on which factors may be considered essential functions of the job, and that the new FAA Certification Criteria were not broad enough to address all of those functions. At the request of the conference participants, the Certification Standards Committee agreed to expand the Certification Criteria, based on the essential functions of the job of the professional O&M instructor. A further suggestion was to have the Committee refer to Section VI of the AER University Guidelines. This section, titled the Competency Based Instructor, articulates 67 competencies to be demonstrated by graduates of these programs.
Alternative Strategies and Reasonable Accommodations The remainder of the conference was spent exploring alternative techniques and accommodations which may be helpful. The activities began by showing a videotape, made by Bill Wiener and Elga Joffee, of mobility instruction provided to them by two visually impaired instructors from the State of Nebraska, Division of Rehabilitation Services for the Visually Impaired. The videotape illustrated alternative techniques that were effective and that could be used by O&M instructors who are totally blind.
[Picture shows a woman wearing a blindfold standing on a curb ramp, with her cane at the edge of the street, and a man reaches sideways to hold the shaft of the cane. Caption says, "O&M instructor Kent Jones, who is visually impaired, and 'student' Sharon Sacks explore a blended curb.]
Next, presentations were made from representatives of four universities. Two of these universities, San Francisco State University (SFSU) and Northern Colorado University (NCU), each have a student who is totally blind enrolled in their program. Wendy Scheffers and Sandra Rosen from SFSU, and Dave Kappan, Bill Muir, Michael Graham, and Kevin Stewart from NCU discussed the alternative techniques and the philosophy that have formed the basis for their instruction. Purvis Ponder of Florida State University reported on his experiences with the preparation of an instructor who is legally blind. Finally, Bill Wiener discussed research on the use of the Mowat Sensor and an infrared scanning device as accommodations for blind instructors.
Following these presentations, a dialogue was held with five O&M instructors who have disabilities. Robert Newman and Regina Chevez, who are blind, and Kent Jones and Michael Patten, who have low vision, shared their experiences and strategies for teaching O&M. Pam Matheson, an O&M specialist who is now a wheelchair user [see "Teaching O&M from a Wheelchair"], discussed her plans to teach O&M again using adaptive strategies.
The major activity of the afternoon was a field demonstration of procedures that had been suggested by conference presenters and by mobility instructors with disabilities. There were five groups, each with an instructor who had a disability, two volunteers who traveled with sleepshades and/or simulation goggles as "students," two data recorders, and a group of observers/consultants. Four of the groups had a person to videotape the activities. The groups were each established to explore and demonstrate techniques in different situations: a blind instructor monitoring indoor and stair travel (the instructor was Regina Chevez); a low vision instructor monitoring residential travel (the instructor was Kent Jones), a blind instructor monitoring business travel (instructor was Robert Newman); a low vision instructor monitoring business and bus travel (the instructor was
Michael Patten) and an instructor in a wheelchair monitoring travel in residential and business areas and on stairs (instructor was Pam Matheson). The instructors had familiarized themselves with the areas ahead of time.
The following day, a representative section from each video of the afternoon's experiences was shown to the conference participants, and short presentations were made by the instructors who had participated in the taping. Robert Newman then led a discussion to put together a list of possible alternative procedures that could be used by the universities when they prepare instructors with disabilities. The list of these alternatives will be included in the complete report of the conference.
Next Steps
The conference raised a number of important issues. The most obvious was the responsibility now placed on the profession in general and training programs and employers in particular to ensure that unnecessary barriers for entry to the profession are eliminated, while continuing to ensure the safety of the student in varying environments. Yet, the issue is much more complex than that. We are now faced with the task of clearly defining the requirements of the job and determining how we can assess each candidate to ensure that he or she has the skills and ability to perform the job. Furthermore employers, rather than professional committees or training programs, are ultimately required to define the essential functions of the job on a case-by-case basis and within the context of the actual work environment. Thus, the skills required may indeed vary greatly from
instructor to instructor.
It was suggested that universities share with each other ideas for strategies, techniques, and technology that can help enable instructors who have disabilities to teach O&M. Bill Jacobson of the University of Arkansas in Little Rock graciously offered to compile these ideas into a newsletter that will be circulated among university O&M programs twice a year. Information that is received by either December or May will be included in the following newsletter.
After the conference ended, the Certification Standards Committee, joined by the chair of the University Review Committee, agreed to jointly prepare an expanded set of criteria based upon the "Competency Based Instructor" guidelines, and within it to include a new section on monitoring competencies. The new criteria will place emphasis on the specific function of the job rather than on an overall global ability which is thought to be necessary to perform those functions (for example, visual, auditory, or physical ability).
The Certification Standards Committee also agreed to compile a complete report of the conference activities and to share it with the profession. Individual committee members will be available to discuss the conference at regional and state meetings, and a written report, complete with a listing of alternative procedures and possible accommodations, will be prepared.
It is intended that students within our university programs will eventually be evaluated using the expanded competencies during their academic and clinical courses. In the interim, until the expanded set of certification criteria can be submitted to Division 9 for a vote, the standards that were approved by the Division and which are based on the FAA will be used to evaluate students. Those standards can be obtained by contacting the central office of AER.
[Picture shows the back of a woman stepping off a curb, with street to her left; in the street about 4 feet away to her right, a woman in a wheelchair watches, with a walkie-talkie in her left hand. Across the street, a woman stands on the sidewalk, holding something in front of her chest. Caption says, "O&M instructor Pam Matheson monitors "student" Sandy Rosen from her wheelchair. The potential role of an assistant was explored, using Dawn Lowery (seen across the street) as an assistant taking directions from Pam via a walkie-talkie."]
Certification Standards Committee members:
Elga Joffee, Co-Chair
Dr. William Wiener, Co-Chair
Diane Fazzi
Dr. Nora Griffin-Shirley
Robert McCulley
Dona Sauerburger
Brenda Sheppard
Dr. Annette Skellinger
Uslan, M., Hill, E., and Peck, A. (1989). The Profession of O&M in the 1980s; the AFB Competency Study. New York, NY: The American Foundation for the Blind