30 Day Comment Period on Proposed One-Time Alternative Pathway to Eligibility


Proposed Change to Eligibility Criteria: One-time Alternative Pathway to Eligibility

Background of the Proposed Change:

ACVREP, as an international certification organization, has been approached by Australia, New Zealand and Canada to be more inclusive of their professionals and to recognize that the practices, with respect to the education and training of vision impairment specialists in those countries may be or have been different those currently in the United States.

The professionals who have approached us are working very hard within their countries to ensure that those who are blind and visually impaired are served with the same high standard, as in the U.S.


Historically, in Australia the government provided funding to agencies serving the blind and visually impaired in order to provide professional training in the field of visual impairments. These individuals have a four year post-secondary degree or diploma and have been professionally trained by their agencies through government funded professional training programs. These professionals would not meet the current ACVREP eligibility requirements because their "internship" was included as part of their agency training and there were not ACVREP certified professionals to supervise them, though they were supervised by qualified and well respected professionals in their own country. Australia is moving toward university training, but there are existing professionals who wish to seek certification, and may be opposed to any certification in their country if it creates a circumstance where they may be discriminated against in their profession due to certification they won't have access to.

New Zealand

The only O&M university program in New Zealand closed. ACVREP has been supporting New Zealand in its work toward having vision impairment specialists become recognized professionally in New Zealand by their governmental body and they are carefully crafting their professional description to mirror the requirements for our current certification model. There are qualified professionals in New Zealand that have been professionally agency trained that would seek certification at this time under this proposed One-time Alternative Pathway to Eligibility.


Canada is also working on expanding the availability of formal university level programs for training professionals in the field of visual impairment, but currently there are also experienced well trained professionals who received their training and verification of their qualifications through their government or nonprofit agency work.

Justification of Policy Proposal

Recognizing this, and understanding our own history in the United States, when ACVREP was formed in 2000 all professionals who had acquired certification under AER were welcomed as Certified by ACVREP, and as long as they continued to recertify every five years are still certified and practicing today. Many of those professionals who are regarded as leaders in their respective fields did not have a formal supervised internship, nor did they take and pass an exam to be originally ACVREP certified. Having internships supervised by Certified professionals only became a requirement in 2003, once there was enough Certified professionals in the country to make this a realistic expectation.

Based on the background above, as part of the Board's strategic planning efforts at its March Board meeting, the Board agreed unanimously, after much thought and discussion to approve the proposed One-Time Alternative Pathway for Eligibility for Australia, New Zealand and Canada.

This proposed change was then informally reviewed with The National Commission for Certifying Agencies (NCCA), the main organization that accredits certifying organizations, to determine if this would be acceptable by their accreditation standards. Through informal feedback, NCCA responded that providing this time limited, One-Time Alternative Pathway to Eligibility, would be acceptable under their accreditation standards. We were advised that to meet accreditation standards, this Alternative Pathway would need to be made available to anyone meeting the criteria - which would include the U.S. Having United States impact was not the initial intent of the board, but ACVREP recognizes the importance of accreditation through NCCA, and to adhere to their standards for best practices.

With this information that the One-time Alternative Pathway would need to be available, not only internationally, but also to candidates in the United States, the Board again discussed the advisability and benefit of moving forward with this proposal, and once again, after thoughtful discussion, unanimously agreed to move forward with the One-time Alternative Pathway to Eligibility.

The board recognizes that in the development of the profession of working with people with visual impairments, a university experience that is now considered traditional in the United States, but was not always so, is still emerging in other parts of the world. ACVREP appreciates that these individuals, much like some of our certificate holders in the United States that began their careers before this was possible for them, are dedicated, passionate, and effective in their areas of work. ACVREP believes that a University training program is the most appropriate way to enter our profession, but also recognizes that as with the history in the United States mentioned earlier, it will be necessary to provide a path for individuals not trained through this model who may now be in positions of leadership in their country, and sometimes internationally.

University training is emerging globally, but is in no way the global standard for our profession yet. When beginning certification in new areas, it is important to provide certification to the "boots on the ground" as was done in the United States, and has proven to be effective in creating a body of high quality certificate holders. Without a body of certificate holders, the certificate is not recognized in the local area.

These existing professionals already practicing in our field, should they choose to study and pass the examination process, and provide documented evidence of serving in the field for approximately 5,000-6,500 hours since 2012, in this one year window of time, will then be responsible to our recognized Code of Ethics, Body of Knowledge, and Scope of Practice, as well as maintaining their professional knowledge through continuing education and recertification every 5 years.

Through the hours of service required in the field, this certification would be impossible to receive for someone just graduating from a university, or someone that is only attempting to serve in the field part time. If these professionals are not already serving in our field full time since 2012, this policy makes it impossible for them to attain certification through ACVREP. ACVREP sees only benefit to providing certification to these professionals for several reasons.

  1. It obligates individuals already in the field who choose to gain certification through this method that is time limited, to adhere to our recognized field standards.
  2. It serves to make our certification one that is nationally recognized in at least 4 different countries, countries that all have contributed and continue to contribute to our field in meaningful ways.
  3. It expands the numbers of individuals holding our certificates, which gives increased value and validity to the certificate in a truly international way.

The Proposal:

One-time Alternative Pathway to Eligibility for Certification

ACVREP is offering a one-time Alternative Pathway to Eligibility for COMS, CVRT and CLVT between October 1, 2015 and September 30, 2016 under the following terms:

  • All applications for Eligibility under this provision must be submitted online to ACVREP between October 1, 2015 and September 30, 2016 only
  • Applicant must have a [4 year] post-secondary degree or diploma in any field. An official transcript is required to confirm the degree or diploma
  • Applicant must have been providing direct service in the field of their certification application since January 1, 2012 to present [present is intended as the date of their application]. That service must be documented with a letter on employer(s) letterhead and signed by employer(s) confirming full time employment during that period at a minimum of 30 hours per week of direct service. [equates to between 5,000-6,500 hours of minimum direct service]

Applicants who meet the above criteria and apply online to ACVREP for Eligibility will be declared Eligible to register for and take the Exam. Once passing the Exam they may apply for Certification. All fees must be paid in US Dollars as posted by ACVREP at the time of applications.

Process of Providing Comments:

The Board after reviewing comments may elect at its September 2015 Board meeting to move forward with the proposal as stated, not move forward with the proposal, or move forward with the proposal with changes made reflecting the comments received in the 30 day comment window.

The Board requests that in your comments you consider the following questions. The answers to these questions would help the Board understand your point of view, though any and all comments are welcome.

  1. What is your certification
  2. Do you think recruiting international certificate holders is worth doing in an effort to raise the standard of care for persons with visual impairment globally?
  3. Should you not find the proposed policy appropriate, what policy would be acceptable to have in place to allow for people who may not be from an area where university training was possible, or that it wasn't possible historically? During your consideration of a different policy, please remember that there may be a significant number of professionals in these countries that may be excluded from a certification otherwise, and thus may not support certification in their country for fear of being discriminated against. This was the same valid concern held in the United States when ACVREP was originally founded.

ACVREP has established an email address comments@acvrep.org in order to receive your comments. All Board members will have direct access to all comments. We will not be directly answering your emails, but each Board member will read all emails. The comment period will remain open until August 30, 2015.