Abstract
Every Student Succeeds Act (ESSA, 2015) eliminated the term highly qualified and reverted to each state's individual standards for the certification of teachers. Therefore, there is no longer a federally required minimum for content knowledge. A recent memo from the U.S. Department of Education Office of Special Education Programs (OSEP, 2022) provides additional guidance regarding special education certification and is meant to clarify state requirements. Neither ESSA nor the memorandum allows for emergency, temporary, or provisional waivers of certifications for personnel providing special education or related services. Since the memo is new, it requires discussion and interpretation to determine its full impact. Still, it may affect future teachers of students with visual impairments (TVI) and their state certification processes.
More than 20 years ago, the National Plan for Training Personnel to Serve Children with Blindness and Low Vision (NPTP) estimated a need for 5,000 new teachers of students with visual impairments (Mason et al., 2000). Since then, the shortage has continued, with Ferrell (2007) reporting approximately 250 teachers of students with visual impairments prepared annually across all personnel preparation programs in the country and Savaiano et al. (2022) reporting an overall decrease in the number of teachers of students with visual impairments from 20 years ago. Teacher shortages in visual impairment have also been documented more recently by the U.S. Department of Education, Office of Postsecondary Education (2021), and the American Association for Employment in Education (2020).
Numerous states have embraced a “grow your own” model in which scholars are recruited from the geographic region of need to address the shortage of TVIs. Many of these programs utilize grants and scholarships to attract applicants. In addition, states employing a grow your own model often form partnerships with colleges and universities to train applicants. However, according to the American Association for Employment in Education (2020) fewer than 10% of the surveyed universities had a training program leading to certification in teaching students with visual impairment. This model, coupled with ESSA's reforms, is causing certification standards to become increasingly varied across the nation.
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Certification Definitions
Because extensive variation in terminology across states is common, terms are used consistently to compare state requirements with clarity. We used the term certification as a global term to describe any route within a state that grants legal standing to perform the role of a TVI. Within the scope of certification, we use two additional terms: license and endorsement. We use the term license to refer to a standalone certification option; sometimes, this is referred to as initial licensure. The term endorsement is used to describe a certification option that is added to an existing teaching license.
Need for Current Review
This review of state policies was conducted as a part of a larger project to update the NPTP data from 20 years ago. The larger project includes an evaluation of eligibility criteria for visual impairment and deafblindness across states and an evaluation of state requirements for certification as a teacher of students with visual impairments or an orientation and mobility specialist. The entire dataset for the project is freely available on the research data—sharing service openICSPR (Schles et al., 2022).
This article addresses the review of state certification requirements for teachers of students with visual impairments. The research questions guiding this portion of the study were:
What are the requirements for certification for teachers of students with visual impairments as documented in official state regulations? To what extent are these requirements the same or different across states and territories?
Method
The qualitative document analysis research covered the United States and its territories (American Samoa, Guam, Northern Mariana Islands, and the US Virgin Islands excluding Puerto Rico because all documents were in Spanish). The states, territories, and Washington DC (N = 55) will be referred to as states here forward. The research team gathered digital policy and guidance documents containing information about the certification process for teachers within each state, created a codebook, and coded all documentation. The results were assessed through descriptive analysis.
Document Collection
The researchers conducted desk research to collect publicly available digital documents between January and February 2021. Further documents were gathered to provide the missing information in August and September 2021. The research team determined that all policy documents would take coding precedence over guidance documents provided by states. The documents gathered were administrative codes or rules, statutes, regulations, and other official state documents, such as procedural manuals. Often five or more documents were collected for each state to gather all necessary information. Documents were gathered from official state websites (e.g., state department of education website, state legislature website).
Visual Impairment Certification Codebook Components
The team developed 15 variables to capture a broad overview of each state's certification requirements for TVIs. Twelve codes were quantitative (eight binary, two continuous, and one categorical) and four were nominal data in the form of qualitative text responses about the terminology used within the documents.
License and Endorsement Data
The team collected information on seven variables to describe the license or endorsement (see definitions above). The first text variable gathered information on each state's license or endorsement title. The next four variables included binary data (0 = no, 1 = yes) for (a) whether the state has an initial license option for TVI, (b) coursework required, (c) standards listed, and (d) testing required. To receive credit for listed standards, the state's documents had to explicitly include standards specific to TVIs from the state or from a professional organization (e.g., Council for Exceptional Children). The sixth variable captured the type of test that was required as text data. Lastly, a categorical variable was used to collect data on the grade levels covered by the license or endorsement. The coding options were 0 = contingent on other or previous certificates; 1 = 3–21 only; 2 = birth–3 only; 3 = birth–21 combined; and 4 = both birth–3 and 3–21 separately (not combined). When coding standards and testing requirements, only requirements specific to obtaining certification in the field of visual impairments were considered.
Provisional and Emergency Certification Data
Four variables captured the data for both provisional and emergency certification. The research team defined provisional as a temporary certification in which enrollment in a program or alternate route, some coursework, and progress toward completion must be documented. The emergency certification was defined as a temporary certification without requirements for any discipline-specific coursework completed or enrollment in a program or alternate route. The first variable collected binary data on whether provisional or emergency certification was available in the state (0 = no, 1 = yes). The second was a text variable on the name of the certification. The third variable was a continuous variable on time or how long the certification lasts. The last variable was binary data on if the certification was renewable (0 = no, 1 = yes).
Coding Procedures and Reliability
A codebook with the aforementioned variable codes was created jointly by the research team using a priori codes to establish intercoder reliability. The a priori codes were created through a review of a selection of the initial documentation. The codebook established the name of the code, a definition, code type, code, and notes. An initial reliability check was conducted using two coders to code 20% of the total states (n = 11). Then, the team refined the definition for four codes within the coding frame with lower intercoder reliability (ICR). The outcome of the intercoder reliability was 82.9% with a range of 60.0–96.4% for individual codes. The variables with weaker levels of agreement were: (a) initial license, (b) standards listed, (c) provisional renewable, and (d) emergency certification available. In general, the documentation required a high degree of interpretation due to the depth of the documents and the latent content. The initial license data was challenging to gather because it was often situated under a different umbrella of certification (e.g., general teacher or special education). Standards were often found in supplemental documentation. Dense or latent content prevented the coders from understanding if a certain certification was renewable. Emergency certifications had varied terminology and many stipulations depending on the certification making it difficult to find the correct information.
The researchers recognize that reliability may be lower than typically presented. However, “more conceptually sophisticated coding frames typically produce lower ICR calculations” (O’Connor & Joffe, 2020, p. 8). Due to the complexity of the documents reviewed, it was determined that 100% of the data would be double-coded to increase validity of the results and improve trustworthiness of the data. If agreement was still not reached on an individual code, all three coders reread the documents and came to a consensus. The variables for lower reliability (lower than 80%) were discussed with all researchers.
Results
Overall, there was variability across states for all coding groups. Table 1 shows the results of all coding variables across all states and territories.
Summary of Certification Criteria for Teachers of Students With Visual Impairments.
Note. Y = yes; N = no; — = no data or not applicable. For grades, which is the grade levels covered by the certification, 0 = contingent on other/previous certificates, 1 = Part B only, 2 = Part C only, 3 = Parts B and C combined, 4 = both Part B and Part C separately (not combined).
License and Endorsement Data
A limited number of states (n = 23) offered a TVI license that was not contingent on additional certification areas. Most states required a previously or concurrently earned teaching license, such as elementary or special education, to add TVI certification. All states had options for endorsement in TVI, so this was not included in Table 1.
Variation of Terms in License or Endorsement Titles
State regulations varied in the terms used for their certification titles. Some examples of the titles used for TVI certification included: Visual Impairment (Pre-K-12), Teacher of Students with Visual Impairments, and SPED Blind/Visually Impaired. IDEA (2004) uses the terms visual impairment, blindness, and partial sight within their definition of visual impairment. Eighty-five percent of the states (n = 47) included either the term “visual impairment” or “visually impaired” in the professional teaching title. Seventeen states included the term “blind” or “blindness,” and two included the term “partially sighted.” A total of 16 states (29%) included either specific ages or grades (n = 2; n = 14, respectively) within the professional title. The term “Special Education” was included in 31% (n = 17) of the license or endorsement titles, as collected in the first text variable for licensing and endorsement data.
Age and Grade Range
TVIs are licensed to work with students across many ages and grades (see Table 1). Sixty-five percent of the states (n = 36) specified that TVI certification covered only the Part B age range (3–21 years). There were no states that provided certification to Part C only, though some states either specified that certification covered birth–21 years (n = 8) or that there were birth–3 years and 3–21 years certification options within the state (n = 1). Six states were clear that TVI certification was contingent on the ages covered by a previously earned initial license and two states had no information regarding the age or grade range covered by the certification.
Coursework, Standards, and Testing Requirements
Coursework was coded as required if the state documents listed specific set and hours of university coursework directly related to earning TVI certification. Fifty-six percent of the states (n = 31) did not require specific coursework. For the states that did have a specific coursework requirement, they either provided a required number of semester hours (e.g., 36 credit hours), specific coursework (e.g., eye anatomy), or both. Some states included semester hours for a specific topic (e.g., three credits of braille). Other states had a general requirement to take coursework within the visual impairment field, which could include other related fields such as orientation and mobility.
Standards were coded as yes (1) if the state documents included specific state or professional organization standards to be met to earn TVI certification. Testing requirements were coded as yes (1) if any content tests were required to earn TVI certification. Sixty-two percent of states (n = 34) did not list standards directly related to visual impairments. For states that did list standards, they were sometimes from a professional organization (e.g., Council for Exceptional Children) and sometimes they were state-specific standards. Sixty-four percent of the states (n = 35) required specific tests for TVI certification. Based on the initial coding of test types, the majority of the states required Praxis tests, though some had state-specific testing requirements. For the above codes, requirements for earning an initial teaching license in general or special education were not considered; only requirements specific to obtaining certification in the field of visual impairments were included.
Thirty-six percent of states (n = 20) did not require specific coursework but did require passing a test as a requirement for certification. Forty-two percent of states (n = 23) did not list specific standards but did require passing a test for certification. Six states (n = 6) did not have any requirements listed for coursework, standards, or testing requirements. See Figure 1 for a heat map of states that had courses or standards required. See Figure 2 for a heat map of states that had testing required.

States With Required Courses or Professional Standards.

States With Required Testing.
Provisional and Emergency Certification
There were many variations in terminology used to describe what we defined as provisional certification: Provisional, Conditional, Limited, and Out of Field Authorization. Forty-two states (n = 42) offered some provisional certification. Provisional certification was valid for 1–5 years depending on the state, and 19 states (n = 19) permitted renewal (see Table 1).
Emergency certification was also called by different names across states: Temporary, Limited, and Emergency. Thirty-six percent (n = 20) had some emergency certification, valid for 1–3 years depending on the state, and 20% (n = 11) of states allowed emergency certification to be renewed. See Figure 3 for a heat map of states that offered emergency certification.

States With Emergency Certification.
Discussion
This study was part of a larger investigation into eligibility criteria for visual impairment and deafblindness and TVI and orientation and mobility teacher certification across states. The purpose of this study was to document the requirements for certification in the United States and note any state differences. The variation in requirements for teachers to become certified to teach students with visual impairment can be seen through our results. Anecdotally, the level of complexity of this process is entirely dependent on which state you find yourself trying to become certified. The variability in certification requirements in each state means that the quality of teachers who provide services to children with visual impairments is also likely to vary across states.
Additional complexity is added since there are not personnel preparation programs in every state. Many prospective TVIs enroll in programs outside their home state. Since only a few states certify TVIs, reciprocity is used so often in the field that it is an issue when one state bordering another state has vastly different requirements for certification. Our data show a multitude of differences across certification criteria. When the certification requirements vary so much across states it can affect the level of training necessary which leads to TVIs in different states being held accountable to different requirements in the demonstration of knowledge through coursework, professional standards, and testing. While those are three variables coded in this study, it is likely there are other differences across states that affect teacher quality to provide services to children with visual impairments.
Ages and Grades
The ages and grade ranges associated with the TVI certification vary widely. Depending on the state, teachers can either be certified to teach birth–21 years or 3–21 years. TVIs certified in one state might be granted reciprocity in another state, and thereby, be certified to provide services to students for which they have received no preparation. Meaning this teacher would be considered qualified but has never been trained or taken coursework to work with infants and young children. Since younger children require a different pedagogical approach, the inconsistency of age certification may impact services provided to during this critical time of development.
Another issue to highlight in the area of ages and grade ranges is the number of states that do not have TVI certification covering the birth–3 years population. Presumably, there are mechanisms within states for allowing TVIs to serve on IFSP teams and work with families of young children with visual impairments, but the official state policy documents are not clear on the matter of how teachers who are not licensed in this age range are able to serve this population of students.
Certification Testing, Coursework, and Standards Requirements
State requirements for coursework, standards, and testing varied. The majority of states did not have particular course or standard requirements, but they did have specified test requirements. The foundation of new TVIs differs based on the program they attended, and it may be more challenging in some states and less stringent in others to complete the standards. Some states offer certifications in which teachers may choose to simply take the exam. Assessment and course requirements can affect how teachers feel about preparedness when they enter the field.
There are national professional standards for teaching students with visual impairments set by agencies such as the Council for Exceptional Children (CEC) and the Association for Education and Rehabilitation of the Blind and Visually Impaired (AER). While many university programs require that students meet professional standards to become a TVI; state regulations do not align with university requirements. For example, in a Midwestern state, students in the university program must meet CEC standards to receive an endorsement license in TVI. However, the regulations do not state that CEC standards are required to obtain the endorsement.
It is unclear how states with TVI preparation programs relate to the requirements. There are approximately 36 TVI programs in 30 states. Due to the lack of an up-to-date public listing of professional preparation programs for TVIs, this figure may vary. The preliminary research did not reveal a direct correlation between states requiring courses, the requirements within the regulations, and states offering TVI programs. State A, for example, offers two personnel preparation programs, but neither coursework nor standard requirements are included in the state rules. On the other hand, State B has significant coursework requirements within the regulations but no TVI personnel preparation program, which demanded a minimum of thirty (30) semester credits in visual impairment, although they did not list any specific coursework.
Types of Certification
The terms emergency, temporary, and provisional were used in ESSA and the 2022 OSEP memorandum as types of certifications that cannot be granted. However, after a conference with OSEP representatives, the inability to offer waivers as they are labeled is more of an issue with semantics within state documentation. In some states, the definition of emergency, temporary, or provisional certification aligns with the federal guidelines of an alternative route to certification. Therefore, those alternative routes of certification are still allowable under ESSA, even if the state refers to it as an emergency, temporary, or provisional certification process. Ultimately the terminology that is used in state documentation is not as important as the description of the process. Future policies should be updated to be more in line with the terminology of ESSA to avoid confusion.
Limitations
This study has two main limitations. First, it represents conditions present during the period in which the research was conducted. Many states were in the process of updating the codes and regulations that guide teacher licensure, and these changes are not reflected in the data.
Second, the researchers only coded the information found directly in the publicly available state policy documents which sometimes included making inferences about which sections of the regulations were applicable to TVIs. In general, the number of documents the information was spread across and the ambiguous language used in many documents made it difficult to locate all the information. Since most states require a foundational teaching license on which to add TVI certification, there are state requirements embedded in the initial licensing requirements (e.g., requirements to become a special education teacher) that are not captured in this data set.
Implications for Practice
Although this research may not directly affect the day-to-day practice of TVIs, there are significant implications for the quality of services being provided to children in different states. The discrepancies within the certification process create variations across states that cause differences in levels of teacher preparation and teacher quality.
There are substantial variances across state certification standards. In State A, for instance, a prospective teacher may merely need to pass a test to become a certified TVI. In State B, the same individual would require a master's degree to get certified. Varying certification requirements directly impact students because some may be assigned a special educator who has passed a test but has little to no preparation on the unique needs of students with visual impairments, while others are assigned teachers with considerable understanding of these needs. Another significant concern may be that the content assessments are not an effective measurement of the knowledge required to be an effective teacher in our field. While knowledge is helpful in understanding how to provide services to a unique population, there is other relevant information to consider, such as the application of skills and experience. Consequently, although reciprocity exists between most states, certification criteria across states remain inequitable which likely means that services to students remain inequitable. To make certification more equitable, states should focus on their requirements for demonstrating knowledge and skills (e.g., course requirements, professional standards, or both) rather than direct testing of only knowledge.
When guidance materials and agreements between departments of education and universities exist outside of the regulations, it adds another layer of complication to the process. These documents are not readily available to the public and outline essential components of the requirement for certification. Further research that focuses on in-depth interviews with state representatives who know all the licensing details for their state may provide more transparent and accurate data.
Footnotes
Declaration of Conflicting Interests
The authors declared no potential conflicts of interest with respect to the research, authorship, and/or publication of this article.
Funding
The authors received no financial support for the research, authorship, and/or publication of this article.
