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caomsfape@gmail.com

Reference: https://journals.sagepub.com/eprint/GSJ9UJWTUECHKEIFBQPX/full

Out and About in California:

Legislative Advocacy for O&M and ECC Instruction in the School System

Presented by Dr. Nicholas Casias, Brenda Naimy & Jaye Shupin

to the Orientation & Mobility Specialist Association

December 5, 2022

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“Visually impaired pupils: expanded core curriculum”

Assembly Bill No. 947

By Assembly Member Sharon Quirk-Silva

CHAPTER 778

An act to add Sections 56353 and 56354 to the Education Code, relating to special education.

ANNOUNCED OCTOBER 15, 2019

HAPPY WHITE CANE DAY!

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Districts can “consider” (not require) ECC

56353 (a) : The Legislature finds and declares that the expanded core curriculum is a set of knowledge and skills in which instruction or services, or both, may be beneficial to a pupil who is blind, has low vision, or is visually impaired. Local educational agencies may consider the expanded core curriculum when developing individualized education programs for a pupil who is blind, has low vision, or is visually impaired.

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Services Outside of School Hours Are�Allowed

56353(c): “When appropriate to ensure that a pupil will receive adequate services under this section, those services may be provided before or after school hours.

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Evaluators Must Be�“Appropriately Certified

56354 (a) (1): 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.

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Travel Environments & Conditions Must Be�Expansive

56354 (2): The orientation and mobility evaluations described in paragraph (1) shall occur in

  • familiar and unfamiliar environments
  • varying lighting conditions, and
  • home, school, and community, as appropriate.

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Transportation Must Be�Provided by District

56354 (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.

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Limitations Are�Prohibited

56354 (b): Except as specified in subdivision (c), 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.).

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Reports of Statewide:

Students Denied Community-Based O&M

Northern California

Folsom-Cordova Unified School District (FCUSD):

  • Community-based O&M halted completely for 6 weeks
  • After district lawyers reviewed the IDEA, the district allowed O&M within 3 blocks of the school campus.
  • No home visits.
  • Lessons limited to school hours.

Southern California

Los Angeles County Office of Education (LACOE and other districts):

  • O&Ms not allowed to drive students.
  • No transportation for O&Ms or for students to community sites for O&M instruction.
  • Uniform complaint filed against LACOE

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Step 1:

Try an Educative Approach

Inform administration of:

  • Federal law, IDEA
  • Section 300.34 (c)(7): O&M in the “school, home, and community”.
  • Section 300.34: transportation is a “related service” provided as needed to access special education, including O&M.
  • Federal regulations
    • Federal Register
  • State regulations (California has detailed Program Guidelines)

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State Dept of Ed dispute resolution procedure

Brenda filed a “Uniform Complaint” to LACOE

  • Complaint was upheld
  • LACOE was ordered to transport students for O&M
  • LACOE did not comply
  • Order not enforced

For your state’s procedure: search the internet for “dispute resolution”, “department of education”, and the name of your state

Step 2:

Utilize Existing Complaint Procedures

Option 1: For anyone

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Parent uses the IEP process outlined in IDEA to

  • Request community-based O&M
  • Make a “Compliance Complaint” if it’s in the IEP but not being provided
  • File for “Due Process” if the district won’t put it in the IEP
  • Any settlement pertains only to the child in the complaint
    • The district might or might not change its policy as a result
  • A lawsuit decided at the state federal level could set a legal precedent

We reached out to parents.

No parents filed a complaint against their school district.

Recommended resource: “Special Education Rights and Responsibilities”

Existing Complaint Procedures

Option 2: for parents only

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IEP Process

  • Compliance” complaint
    • If community-based O&M is in the IEP but the district is not providing it
    • Each state has its own procedure
  • Due Process” complaint
    • If the district declines to put it in the IEP
    • Your state may have a form, but a letter compliant with the law is sufficient
  • Due process hearing

A lawsuit decided in the parent’s favor at the state federal level could set a legal precedent for other families.

Existing Complaint Procedures:

Option 2: for parents only

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Step 3:

Identify the nature and scope of the problem

Statewide Survey of O&Ms

March 2018

64 O&M Specialists responded

  • 53 different school districts are represented
  • 39% of respondents reported administrative policies that significantly limit transportation for community-based O&M

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Step 4:

Gather Resources

Personnel

Documentation

Organizations

Image: drawing of three people sitting on office chairs, one using a computer at a table

Image: drawing of three people in front of three buildings

Image: drawing of three pieces of paper with lines to represent writing.

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Our Personnel Resources

  • Individuals with time, energy, and passion
    • O&M Specialists
    • Staff of O&M teacher preparation programs
      • California State University/Los Angeles
      • San Francisco State University

  • Expert advisors
    • Legal: private disability rights attorney
    • Legislative:
      • experienced lobbyists
      • experts from the successful Texas movement

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Our Primary Organizational Resources

Founding organization

California Association of O&M Specialists (our regional professional organization)

Primary partner agency:

California Council of the Blind (CCB)

Image: logo shows stick figure with arm raised holding a long white cane

Image: logo shows the outline of california with lines radiation from the area of the captial

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Our Additional Organizational Resources

Professional organizations

  • ERBVI (Association for Education and Rehabilitation of the Blind and Visually Impaired)
  • CTEBVI (Califonria Transcribers and EducCators for the Blind & Visually Impaired)
  • CARS (California Association of Resource Specialists)
  • JAC (Joint Action Committee, state lobbying group, now defunct)

Parent organizations

  • CAPVI (California Association for Parents of Children with Visual Impairments)

Consumer organizations

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Service agencies

  • All non-profits serving people with visual impairment statewide

Generic disability agencies

  • Centers for Independent Living (CIL)
  • Disability Rights of California (DRC): state contractor for Protection & Advocacy services
  • Disability Rights Education & Defense Fund (DREDF)

State agencies

  • California School for the Blind (CSB)
  • California Department of Education (CDE)
  • California Department of Rehabilitation (DOR)
  • California Deaf-Blind Services (CDBS): contact your state deaf-blind services project
  • California Teachers Association
  • State Universities (O&M teacher prepreparation programs)

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Our Documentation Resources

Federal and State Laws and Regulations

  • Individuals with Disabilities Education Act (IDEA)
    • Federal Register
  • California Ed Code
  • Texas Education Code (section 30.002)

Professional literature

  • AER Position Paper: “O&M in Naturalistic Environments”
  • More professional literature (specify)

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Our Financial Resources

Image: clos-up of a man pulling his empty pockets inside out.

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Step 5:

Consider Possible Options

Procedural:

  • Request Dept of Ed to
    • enforce existing law
    • issue CA regulations for IDEA

Professional

  • New position papers (CCB)

Legal: single case or class action

  • Parents initiate through IEP process

Legislative:

  • Propose a law to legislators
  • Codify key elements of ECC and CA Program Guidelines
  • Amend IDEA

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Step 6:

Target a Solution

Hybrid Approach: we tried it all!

  • Professional
    • CCB issued an official “Resolution” (position paper)
    • Good PR but non-binding
  • Procedural
    • Meeting with Special Ed Consultant to Dept of Ed
    • Conference call with Chair of Statewide Advisory Commission on Special Education
    • Conference call with Director of Special Ed Division of Dept of Ed
    • Dead end!
  • Legal: we contacted and attempted to recruit parents
    • Very low turnout
    • Dead end!
  • Legislative: by process of elimination

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Our Targeted Solution:

Legislation

Benefits of a law

  • Enforceable
    • Creates a legal recourse for parents
  • Validates standard O&M practice to LEA administrators
    • Directs LEAs in how to proceed
  • Showcases the issues: the background (introduction) section
    • Specifies problematical LEA practices
    • Explains how these constituted barriers to student needs

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Step 7:

Develop an Action Plan

  1. Delineate purpose of committee
  2. Review work done to date on this issue
  3. Specify ultimate goals
  4. Identify stakeholders and create communication system
  5. Outline steps towards goal
  6. Implement action plan
  7. Evaluate results
  8. Publicize results

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Step 8:

Legislative Action

Draft the bill

Develop a communications network with stakeholders

Obtain community input

Find a legislator to “author” the bill

Follow the bill through the legislature

Alert stakeholders when supportive action is needed

  • Write to legislators
  • Come to hearings
  • Spread the word

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SCAOMS Delegation to the Office Of

Assembly Member Quirk-Silva

Louis Lemonnier (Principal of Hope School), Marion Dawirs (Braille Transcriber), Dr. Nicholas Casias, COMS (President of SCAOMS), Katelynn Guerrero (9th grade student at Anaheim High), Kelly Grove (TVI), Dr. Robyn Casillas, COMS, Organizer; Assembly Member Sharon Quirk-Silva (with CAOMS hat and swag), Cecelia Vera (9th grade student at Anaheim High), Evan Guerrero (10th grade student at Anaheim High), Evelyn Maldonado (10th grade student at Anaheim High), and Cynthia Lopez (TVI).

Image: photo of 4 women, 3 men, and 4 children in front of a building with a banner “Sharon Quirk-Silva”

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NCAOMS delegation to the Office of

Assembly Member Brian Dahle

(From left to right) Shalee McClendon-Stent, parent; Shianna McClendon, 10th grader at Nevada Union High School; Sarah Souza, parent; William Souza, 8th grader at Ready Springs Elementary School; Assembly Member Brian Dahle, District 1; Mason Haase, 7th grade at Grass Valley Charter School; Debra Morris, Principal of Nevada County Superintendent of Schools Special Education Services; & Debra Christenson, O&M/TVI, Organizer.

Image: photo of 4 women, 3 children and 1 man in front of a room in front of an abstract painting

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COMMITTEE VOTES

FOR

AGAINST

Assembly Education

6

0

Assembly Appropriations

17

0

Assembly Floor

76vot

0

Senate Education

7

0

Senate Appropriations

7

0

Senate Floor

40

0

Governor Newsome

1

0

TOTAL SCORE

154

0

Votes in the Legislature:

OUR SCORE CARD

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Step 9:

Informing Stakeholders

Communication is key throughout:

  • Email announcements
  • Social media
  • Newsletter articles
  • Webinars
  • Conference presentations

Communication to infinity and beyond!

  • Webinars
  • Conference presentations
  • Journal article (JVIB)

Image: outline drawing of two heads facing each other and overlapping with arrows circling between them

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Ongoing Support

CAOMS provides ongoing support to O&M Specialists:

  • List of references and resources
  • Presentation materials
  • Letter to the school district on CAOMS letterhead

CAOMS will post additional materials on its website: caoms.org

Image: hand reaching up to another hand reaching out to grasp it

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Follow Up: 2020

The FAPE Committee met with the Director of Special Ed of the Dept of Ed.

  • We offered to present to SELPAs
    • SELPA: Special Education Local Planning Area
    • Regional groups of LEAs
  • We offered to help develop educational materials.
  • We asked if the Dept of Ed would issue regulations

The Dept of Ed issued a brief notification to SELPAs of the new law.

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Follow Up: 2021

The FAPE Committee re-introduced the ECC mandate:

  • Evaluation in all 9 areas of the ECC of suspected need
  • Instruction in all areas of evaluated need

The Chair of the Assembly Education Commitee

killed the bill (no new mandates!)

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ECC mandate: according to individual need,

  • Evaluation in all 9 areas of the ECC of suspected need
  • Instruction in all areas of evaluated need

Workload analysis mandate:

  • TVIs and O&Ms to conduct an annual Workload Analysis
  • LEAs to consider results of Workload Analysis for caseload assignments and hiring decisions

Current status

Follow Up: 2022

In Process

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Planned Follow-Up:

2023

Revise to reflect current status

ECC mandate: according to individual need,

  • Evaluation in all 9 areas of the ECC of suspected need
  • Instruction in all areas of evaluated need

Workload analysis mandate:

  • TVIs and O&Ms to conduct an annual Workload Analysis
  • Districts to consider results of Workload Analysis for caseload assignments and hiring decisions

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Yes We Can!

And so can you.

Every LEA, every state, every child!

Image: Multipcoor map of the Unitied States.

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Reference

“Advocating for Off-Campus Orientation & Mobility Instruction in California: A Successful Grassroots Movement”, by C. Jaye Shupin, Brenda Naimy and Nicholas B. Casias. Journal of Visual Impairment & Blindness, Volume 116, Issue 4. (First published online August 23, 2022.)

https://journals.sagepub.com/eprint/GSJ9UJWTUECHKEIFBQPX/full