Dear Members of the Blindness and Low Vision Community,

We are reaching out to urge you to take a closer, critical look at the proposed Certified Vision Rehabilitation Occupational Therapist (CVROT) certification, which has been introduced as a new credential in the field. This proposal raises significant concerns that could impact the independent living model for people with blindness and low vision and reshape the field of rehabilitation in ways that may not be in the best interest of our community.

What’s at Stake?

The CVROT proposal introduces a new certification that, at this time, lacks substantial data to justify its development. Key issues we must consider include:

Complete Shift from Independent Living to a Medical Model

This new certification promotes a medicalized approach to blindness rehabilitation, undermining decades of progress toward empowering individuals with blindness and low vision to lead independent lives. Moving away from the independent living model could limit the autonomy and self-determination of the very people this certification aims to serve.

Reduced Standards for Certification

The CVROT introduces six new pathways for certification, one allows prospective candidates to become certified solely through self-study, bypassing academic training requirements and four paths do not require any study at all (CVROT proposal, pp. 56-59). This is a significantly lower standard compared to existing requirements for practice, and could (1) impact the quality of services that people who are blind or have low vision rely on, and (2) create liability concerns: What impact could the reduction in training and qualifications have on the liability of organizations, practitioners, and the safety of clients? Who will be held accountable if new certification holders unknowingly place their patient at risk, not having gone through a preparation program at all?

Scope of Practice Overlap

The proposed CVROT certification assumes the scope of practice of several existing certified professions (CVROT proposal, pp. 12-18), which have been developed and refined over decades with higher rigor and certification standards. This causes role confusion, double standards for certification, promotes misinformation about the scope of existing specialized professions, and dilutes our current standards of service.

A Call for Action

We urge you to speak up against any further development of the CVROT proposal and instead engage in transparent, inclusive conversations that bring key stakeholders together to address the documented need for services. These could include advocating for high quality in-service training programs to build capacity in the existing rehabilitation provider network.  This initiative would bring in hundreds of thousands of front-line rehabilitation specialists with training in targeted skills to support their interventions, refer clients to specialized services, and promote interprofessional collaborative practice, all while working within their existing scopes of practice and ensuring continuity of service based on decades of best practices.

We have worked long and hard to build a system that empowers people with blindness and low vision. Let’s ensure that any new proposals maintain our focus on upholding the standards of service and professional training that our community deserves.

For materials to support your inquiry into this proposal, please click this link to a Dropbox folder where you will find the full text of the proposal and supporting materials including draft letter template.  

Be sure to submit your comments to ACVREP comments@acvrep.org

by January 30, 2025!

Thank you for your attention to this matter,

Jamie Maffit, COMS, CLVT; Kerry Lueders, COMS, TVI, CLVT; Fabiana Perla, COMS, CLVT, Lachelle Smith, CVRT, CLVT, Katherine Alstrin, COMS, TVI; Emily Vasile, TVI, CLVT, VRT.