Appendix G, Orientation and Mobility Services

Revision 23-1, Effective Nov. 13, 2023

Function of Orientation and Mobility Vendors

Orientation and Mobility (O&M) vendors offer complex, interrelated services designed to promote independent travel skills for people who are blind or visually impaired.

O&M training prepares people to travel independently with competence and confidence. Orientation is the process of using the available senses to establish one's position and relationship within the environment. Mobility is the ability to travel in the environment with the help of an established tool including white canes, dog guide, and electronic travel aids.

Qualifications and Requirements

The O&M service provider must ensure that each person approved to provide O&M services to independent living people meets one of the following requirements:

  • The vendor is certified by either the Academy for Certification of Vision Rehabilitation and Education Professionals (ACVREP) or the National Blindness Professional Certification Board (NBPCB).
  • The vendor is not certified at the start of the contract, but he or she:
    • has a degree in O&M from an accredited college or university with an established O&M training curriculum and will be certified by ACVREP or NBPCB within one year of the contract date; or
    • has at least two years of full-time work experience teaching O&M skills for an entity that the service provider recognizes, such as a rehabilitation center, Veterans Affairs (VA) hospital, or educational system; and 
    • has three professional references indicating the person's ability to teach O&M skills to blind or visually impaired people; and
    • will be certified by ACVREP or NBPCB within one year of the contract date.

To continue contracting for independent living services, all O&M vendors under the contract must maintain ACVREP or NBPCB certification.


In addition to meeting the education, training, and experience requirements described above, all prospective O&M vendors must participate in required training developed by HHSC. Each vendor is responsible for all costs related to attending the training.

Internship Requirements

O&M vendors who use interns to serve people receiving ILS services must:

  • observe a minimum of 12 lessons during the internship;
  • document the observations; and
  • make the observations available for monitoring review by the service provider who may request them in any format for HHSC monitoring.

O&M interns must:

  • attend confidence builders training or its equivalent (interns are responsible for all training-related expenses);
  • be supervised by a certified O&M vendor for the duration of the internship;
  • be observed by the certified O&M vendor for a minimum of 12 lessons during the internship;
  • follow all standards for O&M services in this document; and
  • sign and forward reports to the supervising O&M vendor for his or her approval.

Scope of Services

Orientation and Mobility (O&M) services include:

  • an initial assessment of any of the person’s O&M skills including strengths, challenges and existing competency levels;
  • a review of the assessment results and training recommendations with the person; and
  • O&M skills training as agreed upon by the person, the service provider and the O&M vendor.

Vendor Objectivity

The O&M vendor must remain impartial and objective.

Referral Information

Before contacting the person, the O&M vendor receives referral information from the service provider.

Initial Assessment

Assessments may be conducted using the person’s functional vision, which is an opportunity for them to recognize that their vision may not meet all their travel needs.

The initial assessment includes an evaluation of the person’s O&M skills in multiple situations, which may include:

  • the person’s home and immediate surrounding area;
  • public areas, such as a church, park or college campus;
  • commercial areas, such as a bank, store or mall;
  • transit systems, such as paratransit or taxis, if available;
  • local buses and similar public transportation, if available;
  • rural areas, if applicable;
  • residential areas are those with light vehicle and foot traffic and some stop signs;
  • small business areas are those with heavier traffic and simple traffic lights;
  • downtown areas are those with heavy vehicle and foot traffic and complex traffic lights;
  • commercial transportation systems, such as buses, trains, and airplanes, if applicable; and
  • travel using low-vision devices, if applicable.

Post-Assessment Discussion

Following the initial assessment, the O&M vendor reviews the results with the person and answers any questions that he or she may have about the recommended training. A meeting with the person, service provider, and O&M vendor is strongly recommended, so that all parties can agree on the overall O&M training plan.

Documenting the Initial Assessment

Initial assessment reports must be documented and submitted to the service provider per the service provider’s requirements.

The assessment report includes the:

  • O&M vendor's observations and comments;
  • The person’s current skill level and recommendations for O&M skills training in each of the areas included in the initial assessment;
  • number of recommended training hours for each area;
  • the person’s goals for O&M training;
  • total number of recommended training hours;
  • anticipated period listing beginning and ending dates for recommended training;
  • person’s signature on their acceptance or rejection of the training recommendations;
  • height of the rigid cane that is most appropriate for the person using the measurement between the person’s chin and nose when standing up; and
  • description of all the travel aids that the person uses or would benefit from using.

Training Authorization

After submitting an assessment report, the O&M vendor must contact the service provider to discuss the initial assessment and get authorization to provide training services.

The topics covered during the discussion include:

  • the vendor's recommendations for training (if any), including recommendations on the:
    • O&M skills needed;
    • proposed completion date of the training; and
    • number of training hours authorized by the person’s service provider;
  • anticipated delays in services, if any;
  • special considerations or extended dates for direct training, if any;
  • the person’s readiness to begin nonvisual O&M skills training; and
  • the person’s understanding of O&M skills training and its potential benefits.

Monthly Progress Reports

After receiving authorization to provide training services, the O&M vendor must document each person’s monthly training progress.

Monthly progress reports must be submitted within 30 days of the end of each calendar month until the person’s O&M services are completed or services are no longer recommended by the person’s service provider.

Each person’s monthly progress report must include:

  • the number of training hours provided in each training area; and
  • a detailed narrative of each skill area addressed during the reporting period and the training location for each lesson.

Training locations include:

  • home, both indoors and outdoors;
  • public areas including bank, church and doctor's office;
  • commercial areas such as grocery store and mall;
  • transit systems including public transportation, paratransit and taxi,
  • rural areas;
  • residential areas such as light traffic and stop signs;
  • small business areas are those with heavier traffic and simple traffic lights;
  • downtown areas are those with heavy traffic and complex lights;
  • commercial travel including trains and planes;
  • a detailed explanation of anticipated training for the upcoming month;
  • an explanation of deviations from assessment recommendations, if any; and
  • a detailed narrative of cumulative progress, if training is complete.

Expectations of Training

It is expected that O&M training services for independent living people be conducted using nonvisual (blindfold) techniques and a rigid (nonfolding) cane. All exceptions must be discussed with the service provider before training services begin and must be fully documented in the O&M vendor’s required reports.

O&M vendors will discuss the benefits of nonvisual training with each person. Role modeling and peer support for nonvisual training are encouraged.

Travel Aids

The service provider provides one rigid, long, white cane for each person for O&M assessment and training, to be distributed by the O&M vendor. The O&M vendor conveys to the service provider the appropriate length for the person using the person’s height and other information.

If a person has a dog guide, they are assessed by the O&M vendor to ensure that they have proficient cane skills. O&M training can occur with either a cane or a dog guide.

The O&M vendor must include observations and recommendations of cane skills in the initial assessment. Recommended hours for training must include the person’s travel needs, regardless of the mobility tool (dog or cane). Additional hours are not requested for training with a dog guide.

In addition, O&M vendors give information about cane purchasing to each person.  People are responsible for acquiring all replacement canes, cane tips and back-up canes.

O&M vendors may recommend other travel aids or other items to the person’s service provider. But, the decision to purchase more items rests solely with the service provider.

O&M vendors are not reimbursed for items provided to a person by the service provider.

Providing Services

The O&M training may not exceed the extent of services such as type of training and total number of hours authorized by the person’s service provider.

O&M vendors cannot provide more than six hours of training on any given day, even if multiple people are served in that day. Lessons are approximately two hours long. Without prior authorization from a service provider, a person must not receive more than four hours of O&M instruction on any given day.

Consistent and frequent scheduling is recommended to maximize learning.

For people receiving independent living services, the service provider authorizes two to three hours for the initial assessment. The vendor’s initial assessment report should determine if training is necessary, the total number of hours needed to complete the training, and a breakdown of how the hours will be completed including number, length and frequency of training sessions. 

The service provider will review the initial assessment report and determine if the vendor’s recommendations align with:

  • the person’s goals
  • the complexity of the environment the person will be navigating such as distance, number of obstacles, amount of traffic, if public transit is involved, and the person’s current familiarity with the area
  • the person’s stamina and ability to walk, focus, and learn for the recommended length of a session which is based on conversations with the person and understanding of their disabilities
  • prior O&M completed under similar circumstances

Transporting people does not count toward training time. O&M vendors are not reimbursed for time spent in the car, even when a person is present.

The O&M vendor must notify the service provider within 24 hours about all:

  • no-shows, cancellations, or rescheduled appointments;
  • issues, concerns, or circumstances that might impact or delay planned services; and
  • issues that might delay the completion of services.

O&M vendors must get written approval from the service provider before deviating from any of these standards during training, even when based on a person’s needs.

If Services Are Interrupted

If training cannot be completed as planned or if services are postponed indefinitely because of unexpected circumstances, the O&M vendor must notify the service provider within 24 hours. The service provider will then document the postponed services.