Off-Campus Orientation & Mobility: Tips for Administrators
Presented by the FAPE Committee
California Association of Orientation & Mobility Specialists
Rev 6/12/22
Purpose and Goals�
To support Special Education administrators to deliver Orientation & Mobility (O&M) services that:
Educational Access is Not Just At School!
Most Designated Instructional Services (DIS), educational access is limited to school.
For O&M, educational access is legally defined as in the “home, school, and community”. IDEA Section Sec. 300.34 (c) (7) (i), California Ed Code, Section 35635, 4 (a) (2)
Federal Law: IDEA
Individuals with Disabilities Education Act
Image: map of the United States
IDEA: Community-Based O&M
Sec. 300.34 (c) (7) (i)
Orientation & Mobility means “services provided to blind or visually impaired children by qualified personnel to enable those students to attain systematic orientation to and safe movement within their environments in school, home, and community;…”
Under IDEA, community-based instruction is part of the definition of O&M instruction for students with visual impairments.
IDEA : O&M Skills
Sec. 300.34 (c) (7) (ii)
“(ii) Includes teaching children the following, as appropriate:
(A) Spatial and environmental concepts and use of information received by the senses…
(B) To use the long cane or a service animal …
(C) To understand and use remaining vision and distance low vision aids; and
(D) Other concepts, techniques, and tools.”
The scope of O&M is broad and open-ended.
IDEA: Transportation for Education Access
Transportation for access to educational services is to be provided by the school district.
Sec. 300.34 (a)
“Related Services – are transportation and other developmental, corrective, and supportive services as may be required to assist the child in benefitting from special education. 20 U.S.C. § 1401(26); 34 C.F.R. § 300.34; Ed. Code, §56363(a).”
IDEA: Transportation for O&M
Sec. 300.34 (a)
“Related services means transportation and such developmental, corrective, and other supportive services as are required to assist a child with a disability to benefit from special education, and includes…orientation and mobility services…for diagnostic or evaluation purposes.”
Transportation covers related services, including O&M.
for policy guidance on the IDEA
“Providing these children with needed orientation and mobility services at the appropriate time increases the likelihood that they can participate meaningfully in a variety of aspects of their schooling, including academic, nonacademic, and extracurricular activities.”
“These skills also should enhance the ability of blind and visually impaired students to obtain employment, retain their jobs, and participate more fully in family and community life.”
“Therefore, acquisition of orientation and mobility skills, like the acquisition of other skills such as academic and social skills, is of great importance to the social and economic independence of blind and visually impaired persons.”
California Education
Code
Image: map of California
“Expanded core curriculum: visually impaired pupils”�
Effective January 1, 2020
Amendment to
California Education Code
TITLE 2, DIVISION 4, PART 30, CHAPTER 4, ARTICLE 3.5,
Section 56353 & Section 56354
https://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill_id=20192020:0AB947
Ed Code: Certification Requirement
“If an orientation and mobility evaluation is determined to be needed for a pupil who is blind, has low vision, or is visually impaired, it shall be conducted by a person who is appropriately certified as an orientation and mobility specialist.”
Cal. Ed. Code § 56354 (a) (1)
LEAs must verify that the O&M has the “Clinical or Rehabilitative Services Credential in Orientation and Mobility.
Ed Code: Off-Campus Services
“The orientation and mobility evaluations described in paragraph (1) shall occur…in the home, school, and community, as appropriate.”
Cal. Ed. Code § 56354 (a) (2)
LEAs must allow O&M evaluation at home and in the community.
Ed Code: Services Beyond School Hours
“When appropriate to ensure that a pupil will receive adequate services under this section, those services may be provided before or after school hours.” Cal. Ed. Code § 56353 (c)
LEAs are allowed to provide both O&M and TVI services outside of school hours.
Ed Code: Parental Permission
“A local educational agency may require annual written parental consent to provide the services described in subdivision (b) when those services are provided before or after regular school hours and when those services are provided away from the school site.” Cal. Ed. Code § 56354 (1)
The LEA may require permission forms for O&M services outside of school hours and off the school campus.
Ed Code: Familiar and Unfamiliar Environments
“The orientation and mobility evaluations described in paragraph (1) shall occur in familiar and unfamiliar environments, in varying lighting conditions, and in the home, school, and community, as appropriate.”
Cal. Ed. Code § 56354 (a) (2)
The LEA must allow O&M evaluations in both familiar and unfamiliar environments.
Ed Code: Night Sessions
“(b) (2) The orientation and mobility evaluations described in paragraph (1) shall occur in familiar and unfamiliar environments, in varying lighting conditions, and in the home, school, and community, as appropriate.”
Cal. Ed. Code § 56354
O&M evaluations must include consideration of different lighting conditions. Night travel screenings may be indicated for students suspected of having worse vision at night.
Ed Code: Full Environmental Access
“…a local educational agency shall not impose any limitations that result in the preclusion or the limitation of the ability of a pupil to receive instruction in orientation and mobility services in the home, school, or community setting and in varying lighting conditions, as designated in the pupil's individualized education program and provided for pursuant to the federal Individuals with Disabilities Education Act( 20 U.S.C. Sec. 1400 et seq.). Cal. Ed. Code § 56354 (b)
LEAs may not place limitations on community-based O&M instruction
Ed Code: Effective Transportation
“(c) (2) If a local educational agency prohibits an orientation and mobility specialist from using their vehicles for the transportation of pupils to and from orientation and mobility instruction, the local educational agency shall provide, without cost to the orientation and mobility specialist, an equally effective transportation alternative for that purpose.”
Cal. Ed. Code § 56354
LEAs must either allow the O&M specialist to use their vehicles for transport or provide free transportation that is comparable to the O&M specialist driving the student in their personal vehicle.
What is “Equally Effective” Transportation?
As effective as the O&M Specialist’s personal vehicle:
Relying solely on public transit may significantly increase transit time.
California Guidelines for O&M in Schools
“Guidelines for Programs
Serving Students With Visual Impairments”
Published by the California Department of Education
https://www.csb-cde.ca.gov/resources/standards/documents/viguidelines-2014edition.pdf
Liability
Student safety is paramount!
Your O&M Specialist has the skills, training, and environment needed to keep students at least as safe as students on a regular ed class field trip or on special ed community-based instruction.
O&M Safety Procedures
Environmental assessment
Monitoring distance
Scanning techniques
Off-Campus Safety Comparison
Regular Ed Field Trip
Special Ed Group CBI
O&M Instruction
O&M is a unique, highly individualized form of one-on-one instruction provided by a highly trained specialist.
O&M: not a just a “field trip”
Protect yourself and your LEA!
Create specialized policies, procedures and documentation
that are code-compliant and that address the unique characteristics of O&M.
Image: stick figure walking with long cane.
Parental Permission
Form:
Specific to O&M
Develop a form specific to O&M, because O&M lessons are different from generic school “field trips”:
LEA’s legal counsel should review the form
Team with your O&Ms to ensure that the procedures are reasonable.
Create Written Procedures
Forms:
Lessons:
Document Student Needs
What to document
Where to document
Summary: Minimizing Liability
Administrator’s role:
O&M Specialist’s role:
Fiscal Impact
Reimbursement�
In California, the state will reimburse the LEA for the costs of providing community-based O&M services
“If the Commission on State Mandates determines that this act contains costs mandated by the state, reimbursement to local agencies and school districts for those costs shall be made pursuant to Part 7 (commencing with Section 17500) of Division 4 of Title 2 of the Government Code.”
Costs
Costs associated with providing community-based O&M may include:
Cost: Transportation
Transportation Type | District Cost |
O&M Specialist drives student in personal vehicle | Reimbursement for mileage and for enhanced auto liability coverage |
* O&M Specialist drives student in district vehicle | Gas, vehicle maintenance, and auto insurance |
* Designated district driver drives student and Specialist in district vehicle | Gas, vehicle maintenance, auto insurance, and driver wages. |
* Ride-sharing service (e.g., taxi, Lyft) | Pre-pay plan or reimbursement to O&M Specialist |
Cost: Public Transit
We do not recommend relying on public transit to and from O&M lessons, because in most places:
When public transportation is the actual content of the evaluation and instruction, the district must cover the fares. For these students:
Cost: Liability Insurance
Liability insurance is a necessary and worthwhile investment
Cost: Potential Litigation
Litigation can be extremely expensive!
To maximize cost-effectiveness:
AND
Mobility: A Basic Freedom
Thank you!
The California Association of Orientation & Mobility Specialists appreciates your hard work to improve the daily lives and future prospects of our students.