Braille Monitor                                     January 2018

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Accreditation: The Pros and Woes of Credentialing

by Edward Bell

Edward BellFrom the Editor: In 1995 Eddie Bell received a scholarship from the National Federation of the Blind. With his innate intelligence, persistence, and passion to help blind people, he has given back in ways that are exemplary. Dr. Bell is the director of the Professional Development and Research Institute on Blindness at Louisiana Tech University. He has extensive experience in rehabilitation for the blind and visually impaired and has presented widely throughout the United States and Europe. He has degrees in rehabilitation education and research, educational psychology, and human development. In addition, he possesses certification in educational statistics and research methods, rehabilitation counseling, and orientation and mobility. What distinguishes him, however, is the work he does to tie together teacher training, certification, and the evaluation of programs with the needs of consumers in search of quality programs leading to lives of success and independence. Here is what he has to say about training, certification, licensure, and accreditation and the way all of these should relate to services that lead to positive outcomes:

In the field of blindness education and rehabilitation, the terms accreditation, certification, licensure, competency, and evaluation are used both to describe good and bad practices. While most recognize the value of having an accredited college or university, a certified teacher, or a licensed physician, blind people have also found that these terms have brought with them negative consequences. So what are these concepts, and are they something to be embraced or fought? The answer is that it depends on what value these processes serve in helping people who are blind to live the lives they want, free from custodial practices and discriminatory policies.

At their core, all of these concepts have largely to do with ensuring that individuals receive quality training and education and are protected from negligence and incompetence. These are principles that I believe all members of the National Federation of the Blind would embrace and hold true. But where the departure begins is in how concepts like quality, training, competence, negligence, and incompetence are defined, which at a deeper level comes down to the values and expectations that one holds for the services provided.

Accreditation is the process of one agency or organization certifying that other organizations that are in the business of certifying professionals are doing that job in an ethical, systematic, and objective manner. Think of accreditation as the people who certify the certifiers. The certifiers, on the other hand, are the organizations that provide assurance that professionals are performing their duties in a competent, ethical, and professional manner. Many people need to be certified in order to do their jobs, including teachers, lawyers, doctors, special education personnel, and rehabilitation teachers—not to mention plumbers, electricians, contractors, and school bus drivers.

While we are on the subject, the terms "certification" and "licensure" are used interchangeably but often confuse the layperson in their meaning. For the purpose of this conversation there is little difference between these concepts, but for clarity’s sake here is the distinction. Licensure is handled state by state and contains legal ramifications for violations. Typical professions that are licensed by the state might include general contractors, licensed professional counselors, plumbers, electricians, physical therapists, real estate brokers, nutritionists, teachers, and medical practitioners. Certification, on the other hand, is governed by professional organizations that define the scope of practice for professionals, set the minimal criteria for demonstrating competence, and can revoke that certification if violations to the code of ethics or practice are violated. Certification does not have the same legal ramifications as licensure; however, it should be noted that many state licenses are based on professional certification and/or hold professional certification as a prerequisite to licensure. In both cases the purpose of certification or licensure is to set a minimal standard for acceptable practice, determine the appropriate fee structure, and bar entrance to the profession for those who do not meet the agreed-upon professional standard—in other words, to be the gatekeepers over that particular professional practice.

Certification, then, is the systematic process by which an organization establishes standards of practice, rigorous evaluation criteria, and methods of measuring performance in an objective manner. The certifying body will then set a minimum criterion for competence, and all applicants must meet at least this minimal standard in order to be deemed competent in that skill or profession. Today, most certifying organizations also establish some sort of ongoing professional development, continuing education, and/or a requirement to renew certification on a periodic basis. As a process then, certification seeks to establish reasonable standards, the means to measure whether individuals can live up to those standards, the roles and responsibilities for those who are deemed eligible under those criteria, and the mechanisms by which individuals who cannot meet the standards are barred from practicing in that profession.

As a principle, these certification practices have worked well across many professions. However, in the blindness field they have not always worked to serve consumers. Take, for example, the profession of orientation and mobility. The Association for Education and Rehabilitation of the Blind and Visually Impaired (AER) created the Certified Orientation and Mobility Specialist (COMS) credential back in the 1960s as a means of certifying that those interested in teaching cane travel were competent in teaching the skills to blind people. However, several of the organization's criteria for certification were based on visual acuity. Arguably, visual acuity is an objective measure and one that can be evaluated for each applicant. However, visual acuity is not a valid requirement for teaching mobility skills at all. One case in point: Dr. Fred Schroeder graduated from the O&M program at San Francisco State University with high marks but was subsequently denied certification as a COMS by AER based on his blindness. While the COMS certification has now been transferred to the ACVREP [Academy for Certification of Vision Rehabilitation and Education Professionals] organization, many of the certification principles continue to be based on visual efficiency and visual reference and are therefore not viewed by everyone as the most appropriate means of certifying competence in teaching orientation and mobility.

In 1999 the National Orientation and Mobility Certification (NOMC) was created specifically to (1) serve as a non-discriminatory certification avenue for blind and sighted people; and (2) to be based on the Structured Discovery method of cane travel, which is a nonvisual approach to teaching which capitalizes on the individual’s self-efficacy and self-awareness. The NOMC certification, being based on Structured Discovery, set as its criteria for competence the ability to teach individuals nonvisual mobility skills, increase their confidence, and promote the personal attitudes and public awareness of expectations surrounding blindness. Those who were not able to demonstrate these skills were not deemed competent using the NOMC certification framework.

In 2001 the National Blindness Professional Certification Board (NBPCB) was incorporated to govern the NOMC credential and its recipients. In its articles of incorporation the NBPCB purpose was established as: “To promote services of the highest quality for individuals who are blind or visually impaired through standards and certification to assure that professionals who serve such individuals are qualified; To establish, publish, and administer standards used to determine the qualifications of such professionals; To implement a process of certification and re-certification of professionals, based on the published standards; To continue, revoke, or suspend certification, based on findings relating to adherence to the standards; and To undertake other projects, programs, and activities.”

The first class of NOMC applicants was officially credentialed in July of 2001. Most of these have obtained and maintained employment for more than two decades, lending credibility to the methods and principles undergirding this certification practice. NOMC men and women maintain that certification for five years and then have to undergo recertification either through retesting or continuing education. Through continuing education, NOMC certificants are put in the position of continuing to work together, to learn together, to uphold a common standard of excellence, and to ensure that certificants remain true to their code of ethics.

In 2006, after more than twenty years of work by the National Federation of the Blind and the National Library Service and other constituents, a national standard for Braille competence was established, and a test of teacher proficiency was created. This exam was then pilot tested and validated by the National Federation of the Blind through rigorous field testing. However, other certifying organizations were not sufficiently interested in Braille proficiency to take on this responsibility. Consequently, in 2007 the NBPCB took on the literary Braille test and created the National Certification in Literary Braille (NCLB). As with other certification processes, those seeking NCLB credential had to apply to the NBPCB and complete a test of their ability to produce Braille using a Braillewriter and slate, proofread a passage, and know the rules of Braille. If minimal competence was demonstrated, those women and men were endorsed with the NCLB credential for a period of five years, after which time they would again need to retest in order to maintain their certification.

This practice was in keeping with mainstream certification principles and was the only means by which any organization could attest to the Braille proficiency of its certificants. The need for this test in the first place was due to the fact that no national standard ever existed for teachers to demonstrate that they in fact knew Braille. Having no national standard, the all-too-frequent result was that teachers would pass a Braille test at their university, with some tests being appropriately rigorous while others would be woefully inadequate. This single exit exam would then serve as the only assurance that the teacher knew Braille, with no need to again demonstrate this skill throughout their career. In fact there have been court cases and due process hearings because students were not being taught Braille even though they had a certified teacher of the visually impaired. In these cases, schools could state that their teacher of the visually impaired knew Braille because he or she passed a Braille test prior to starting their job, even if that was decades ago and the teacher did not remember any Braille. Today, as Braille competency tests are gaining steam, significant push-back has been observed in a number of states by TVIs who have held their jobs for many years and who know they do not have enough remaining Braille knowledge to be deemed proficient. Yet, these TVIs still work with children who are blind, many of whom should be taught Braille.

Certification, then, is the most promising protection against these types of injustices, so long as the certification practices are valid and consistent with the purpose for which they were created: (i.e., Braille proficiency) and that procedures ensure that professionals maintain some level of proficiency throughout their years of practice. How many of us would go to a surgeon who graduated medical school thirty years ago but who hasn't performed a single surgery in twenty-five years?

In 2012 the Braille Authority of North America (BANA) announced that Unified English Braille (UEB) would become the standard in the United States, which meant that every aspect of Braille would change. This change would involve everyone from the Braille reader to the publisher. While panic overtook many in the field, the NBPCB took on the task of writing professional competency standards, and by 2014 the National Certification in Unified English Braille (NCUEB) had been created. Between January and July of 2015, more than eighty-five people across eleven unique testing venues nationwide participated in a pilot test of the NCUEB. Individuals were eligible for the pilot test if they had participated in a UEB workshop and had made a commitment to learn the UEB code. Those data were analyzed, and strong evidence demonstrated that the NCUEB exam was equally as valid as its NCLB predecessor, that it appropriately identified those who were proficient in UEB versus those who were not, and thereby set the stage for the standard that should be followed for teachers and others who wish to demonstrate their proficiency in the UEB code. The full validation report was published in the Journal of Blindness Innovation and Research, and those wishing to obtain more information about the procedures that were followed should refer to that publication. The valid NCUEB exam, coupled with the five-year recertification period, made the NCUEB the first valid proficiency test of the new Braille code, and it was in place and ready for operation in advance of the January 2016 date set by BANA as the official UEB adoption date.

Meanwhile, other organizations have worked to catch up in testing competence in UEB. Instead of working with the organized blind, some professionals in the field of education of the blind sought out Educational Testing Services (ETS) in order to create a Braille proficiency test for teachers. Since ETS is a long-established testing company and since ETS provides the PRAXIS and GRE exams (which are required by most university programs), it was somewhat logical to seek them out for this task. However, by the admission of officials at ETS, they do not know much about Braille itself, have no vested interest in Braille, don't know the distinction between EBAE [English Braille American Edition] and UEB, and do not have qualified people on staff who are proficient in Braille.

As a consequence, the resulting Braille proficiency test that was created by outside consultants looks rigorous and comprehensive on the surface, but it is not all that it promises. Two fundamental problems exist with the ETS Braille test. First, while ETS maintains responsibility for the grading of the Braille exams, they leave it to each state to establish the minimal passing score for teachers. So, regardless of how rigorous the exam itself is, a state department of education can determine that getting 60 percent of the answers correct is sufficient to declare a teacher competent, while another state could set the standard higher or lower. Why would any state set such a low standard? They might because there is a significant teacher shortage in this country, the vast majority of personnel preparation programs are not holding students to high levels of Braille proficiency, and failing a high-stakes test would make the teacher ineligible for employment. And, to prevent lawsuits and unhappy parents, most state departments of education would rather dumb down the minimal competency standard for Braille proficiency than to tell parents they don't have a teacher to serve their children. So the vicious circle continues, with no single organization holding individuals accountable for being competent in the skill that they are hired to teach and no consistent metric for what constitutes reasonable competence. That is, except for the NCUEB, which to date is the only nationally representative measure of Braille proficiency that has been developed to serve this purpose.

Perhaps of greater concern is ETS's track record of providing accommodations to blind people. Any blind college student who has had to take the PRAXIS, GRE, or other ETS test and who has had to obtain accommodations can attest to the nightmare of qualifying for and obtaining reasonable accommodations through ETS. While it is true that most teachers of the blind are sighted, an increasing number of professionals entering the field are blind. Now, some of you may be thinking, "But why would a blind person who is a Braille reader need accommodations on a test of Braille proficiency?" And, this is perhaps the best question that you could ask and one that should be asked of the officials at ETS. Yes, it should sound ludicrous to you that a blind person would need to seek accommodations such as a sighted reader in order to take a test of his or her Braille proficiency. But that is exactly what you must do if you are a blind person and wish to take the ETS Braille proficiency test. If you are a blind person, you cannot take the ETS Braille competency test without a sighted reader as an accommodation. In keeping with ETS tradition, a sighted applicant can walk in off the street and take their Braille exam, receive a passing grade by some state department of education employee who likely doesn't know Braille, and maintain this endorsement for the rest of her/his career, even if he/she never touches Braille again. On the other hand, a blind person who may have been a proficient Braille reader from childhood must undergo rounds of red tape in order to get the accommodation of a sighted person in order to take a Braille test.

And this is the credentialing world in which we live. So, whose responsibility is it to ensure that testing companies and certification organizations are creating standards and tests that are valid and appropriate for the consumers it serves? This is where accreditation comes into play. Accreditation ensures that a certifying organization's practices are acceptable, meaning that they are competent to test and certify third parties, behave ethically, and employ suitable quality assurance. In practice, however, this all-too-frequently means that the organization in question is following the basic principles of establishing some standard, creating an evaluation around that standard, and ensuring that individuals can meet the standard. However, accreditation does not account for what is actually being certified or whether that certification has meaningful outcomes for the consumers who are affected. ETS, for example, could be said to be following all recommended standards for certification and would thereby be eligible for accreditation. But any third grader understands that a blind person should be able to take a Braille test without having a sighted person to serve as the reader.

When will those who wield authority in agencies and organizations that serve the blind finally determine that involving the consumer perspective is a key factor in any certification practice that will ultimately affect blind consumers? Not soon enough. Readers of the Braille Monitor know well the controversial history of the National Accreditation Council for Blind and Low Vision Services (NAC). Many pages of the Braille Monitor have been dedicated to protesting the reckless practices of NAC and the detrimental impact that NAC-accredited agencies have had on people who are blind, yet the input of the blind is still not a priority for these organizations. The proof is in the pudding. And, when consumers find that the pudding leaves a bad taste in their mouth, they will quickly discard that pudding in favor of something more satisfying.

The National Blindness Professional Certification Board (NBPCB) was incorporated in 2001 to govern the NOMC certification. In 2007 the NCLB Braille certification test was created and was successfully implemented until it was replaced by the NCUEB test of Unified English Braille in 2015. In 2015 the National Certification in Rehabilitation Teaching for the Blind (NCRTB) was created to certify rehabilitation teachers for the blind.

In 2009 the NBPCB created the agency certification process for training centers operating under the Structured Discovery approach. Using this process, a training center can be evaluated in six areas, and, if deemed competent, that center can be certified as a Structured Discovery center for immersion and training. While this process is not accreditation in the strictest sense of the word, it does operate under established criteria for demonstrating a minimal level of competence, using objective measures for evaluation, setting a criterion for acceptable practice, and providing strengths and weaknesses in a written report. Such agencies must undergo this evaluation every three years in order to maintain this designation and are provided reports of continuous improvement. Evaluations are conducted on-site by members of the NBPCB, who assess all areas of the curriculum, including the administration, instructional staff, student body, core curriculum, facilities, and involvement with consumer organizations. Currently, the centers who are recognized by NBPCB as meeting Structured Discovery standards include BLIND Inc, Colorado Center for the Blind, Louisiana Center for the Blind, Hawaii's Ho`opono New Visions Program, Nebraska Commission for the Blind and Visually Impaired, and the New Mexico Commission for the Blind.

The NBPCB has continued to work to meet the needs of the constituents who are the ultimate beneficiaries of its service—people who are blind. The NBPCB was recognized by the National Federation of the Blind in 2014 with a Dr. Jacob Bolotin award for excellence. This honor was bestowed on the NBPCB for its focus on high-quality training and certification—training and certification that is based on rigorous evaluation criteria and one which shares the values of its consumers.

How can an organization whose job it is to accredit the certification programs for professionals who serve the blind do this job effectively without consistent and comprehensive work with the organized consumer organizations? The answer is they cannot. For this reason, the NBPCB proudly has members of a consumer organization on its board of directors, NBPCB leadership attend the annual convention of the NFB, and its leadership has consistent and ongoing communication related to certification standards.

But there is also a cautionary tale here. As we know from history, members of the AER and AFB were also closely aligned with the members of NAC, served on each other's boards, and worked behind closed doors to agree on common practices—all of which had detrimental consequences for blind people. The NBPCB, however, guards against this threat by working not only with the consumers it serves, but also by conducting evaluations of its certificants and by obtaining professional feedback from the employers of those individuals. It is a fact that the current demand for NBPCB-certified professionals continues to outstrip the available supply. This does not happen unless an organization has rigorous standards, valid measures for assessing applicant competence, procedures for continuing to strengthen its training, consistent and productive communication with its consumers, and a world view that is based on a simple principle—to create highly qualified professionals whose mission is to help blind people live the lives they want.

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