It was a quiet week in Lake Wobegone…
…and then new Teacher Prep regulations were released.
On December 3rd, the U.S. Department of Education released proposed new accountability regulations for teacher preparation programs. Public comment will be accepted until February 2, 2015. If implemented, these regulations will have a big impact on teacher education programs, especially those offered at a distance.
In this blog post, I review some of the highlights of what is proposed. I got a headache reading the fine print, so forgive me for getting anything that I report incorrectly.
We need to comment on this regulation and I’ll ask for your help in doing so. I’ll also contact our colleagues at other distance education organizations about joining together as a single voice in a commenting.
…And All the Children are Above Average
Given the funding that the Department of Education distributes in support of preparing new K-12 teachers, they are very interested in learning whether teachers are well-prepared. They also wish to provide consumer information to states and students, as well as prompting colleges to improve. In their own words (Note: unless stated otherwise, all quotes are from the proposed regulations released on December 3):
“Section 205 of the HEA requires States and institutions of higher education (IHEs) annually to report on various characteristics of their teacher preparation programs. These reporting requirements exist in part to ensure that members of the public, prospective teachers and employers (districts and schools), and the States, IHEs, and programs themselves have accurate information on the quality of these teacher preparation programs. These requirements also provide an impetus to States and IHEs to make improvements where they are needed and recognize excellence where it exists. Thousands of new teachers enter the profession every year, and their students depend on having well-prepared teachers.”
As part of this report, states were supposed to use their own criteria to identify “low-performing” or “at-risk” teacher preparation programs. The results resembled Garrison Keillor’s Lake Wobegone, that fictional town where “all the women are strong, all the men are good looking, and all the children are above average.” Just like those children, states identified almost all of their programs as above average:
“Notwithstanding the focus that Congress has placed on improving the quality of new teachers produced by teacher preparation programs and improving or closing programs that are low-performing, these State and IHE reporting requirements have not produced information that is sufficiently helpful to programs, the public, or the Secretary in improving low-performing teacher preparation…In 2011, the most recent year for which data are available, States identified only 38 teacher preparation programs as low-performing or at-risk…Over the last dozen years, 34 States have never identified a single low-performing or at-risk program at a single IHE.”
That means that of the 25,000 teacher preparation programs from 2,163 providers, only 38 (0.15%) were cited as needing improvement. You can see why the Department is concerned in the state-by-state reports for academic year 2011-12 at the Department’s website.
What Does the Department of Education Propose?
This is a rough summary, but I will cover the aspects that seem most interesting to our community.
Annual State Reports
Each state will be required to publish an annual State Report Card (SRC) of teacher preparation programs (underlining added):
“The Department proposes to add new § 612.4(a) to require that, beginning on April 1, 2018, and annually thereafter, each State that receives funds under the HEA report to the Secretary and the general public, using a SRC prescribed by the Secretary, (1) the quality of all approved teacher preparation programs in the State, including distance education programs, whether or not they enroll students receiving Federal assistance under the HEA…”
The State Report Card will have at least four possible grades for the programs:
“…beginning in April, 2019 and annually thereafter, each State would be required to report how it has made meaningful differentiations of teacher preparation program performance using at least four performance levels: ‘low-performing,’ ‘at-risk,’ ‘effective,’ and ‘exceptional’…”
While the state must follow a prescribed format and definitions developed by the Department, each state will have the ability to create a rating system unique to its own setting.
“To assist in the development of the State’s procedures for assessing and reporting teacher preparation program performance, each State would be required under § 612.4(c)(1) to consult with a representative group of stakeholders, including, at a minimum, representatives of leaders and faculty of traditional and alternative route teacher preparation programs; students of teacher preparation programs; superintendents; school board members; elementary and secondary school leaders and instructional staff; elementary and secondary school students and their parents; IHEs that serve high proportions of low-income or minority students, or English language learners; advocates for English language learners and students with disabilities; and officials of the State’s standards board or other appropriate standards body.”
Report at the “Program” Level
Rather than reporting at the college, university, or other entity level, the reporting will be for every teacher preparatory “program” that they offer, such as elementary, music, or special education:
“…we propose to require States to report on performance at the individual teacher preparation program level, rather than on the overall performance of all of an entity’s teacher preparation programs.”
Indicators that Must Be Reported
There are four main “indicators” that must be reported:
Student Learning Outcomes. The state would need to measure student growth for students in classes taught by “new teachers” in “tested grades and subjects” (scores in mandated state assessments) and in “non-tested grades and subjects” (measures that are “rigorous and comparable across schools and consistent with State requirements”). On the face of it, this sounds impossible. They built on previous work by following definitions from other Department initiatives, such as ESEA flexibility, the Teacher Incentive Fund, and the Race to the Top program.
Employment Outcomes. These include measures of teacher placement rate, teacher placement rate in high-need schools, the teacher retention rate, and teacher retention rate for high-need schools.
Survey Outcomes. The regulations will require reporting on surveys including: a) survey of new teachers to see if they felt their program prepared them to teach, b) an employer survey to capture perceptions of whether the new teachers that they have employed possess the skills needed to succeed in the classroom.
Accreditation or Alternative State Approval. The provider needs to determinate if: a) “the teacher preparation program is accredited by a specialized accrediting agency recognized by the Secretary for accreditation of professional teacher education programs” or b) meets other state criteria for alternative programs that are too long to list here.
This is simplified version of what is being proposed, as there are additional details for each of these indicators.
Distance Education Concerns and Questions
As a distance education community, we should provide comments to the Department about these regulations. We have until February 2 to submit those comments and my thinking is still in the early stages on what we might say. We will need your help.
First of all, the need to have programs offered via distance education was specifically included in these proposed regulations:
“In addition, during the negotiated rulemaking process, some non-Federal negotiators stated that it was not clear whether States had to report on the performance of distance education programs under this requirement. Non-Federal negotiators requested that we specify in the regulations that distance education programs must be included in a State’s reporting. We have therefore included language in § 612.4(a) to clarify that, for purposes of State reporting, States must report on distance learning programs that are being provided in the State.”
My initial thoughts and questions, from a distance learning point-of-view:
Distance programs not reporting now? When I look through 2011-12 state reports on teacher preparation, I see that there are 25,000 programs from 2,163 providers. In sampling the reports of a few larger states, very few out-of-state providers listed. Are most distance education programs not currently participating in these reports? Are those programs not seeking approval to offer their teacher preparatory courses in other states? I’d love to hear from you on this.
Differing measures by state. Did you notice that while the State Report Card format and definitions are set by the U.S. Department of Education, the measures used to judge whether a program is “low-performing,” “at-risk,” “effective,” or “exceptional” is up to each state? That’s fine as long as the program stays within its own state, but for distance education this raises a concern that we’ve seen before. Does this remind of anything? State authorization, maybe? The criteria and reporting requirements will differ for each state. In the age contentious debate over “Common Core” standards and the new AP American History test, it’s impossible to imagine standard measures being possible. Even so, we have consistently pushed for the Department to better engage the states in a conversation on state authorization issues. Engaging the states in group conversations on how to comply will be helpful to all as they can learn best practices from each other. If the State Report Card format is standardized and the definitions are standardized, but the measurements reported from the process differ greatly then we may be causing more confusion in the marketplace. And we must the remember that the 21st century marketplace is not confined to the boundaries of a single state.
What if a state does not treat all programs equally? It is conceivable that some states will devise measures that (intentionally or unintentionally) disadvantage a subset of programs. Some in education don’t like distance education. Others are protective of institutions within their own state. In another profession, I’ve been told of a bias against competency-based education. In state authorization, there are local requirements in a few states that are unpalatable or illegal for some institutions to meet. One can imagine scenarios in which a program might score highly in one state and poorly in another due to differences in measurements. What happens in these cases?
Difficulty of gathering data in other states. How hard will it be for colleges to track these measures in other states? For example, programs will have to know where each “new teacher” is employed and collect the student learning outcomes measures for those students. You will also need to track if that “new teacher” is still employed after a few years. You will also have to conduct surveys of the employers of “new teachers.” All of these will probably be easier to conduct in your own state than in other states. While that is more work in crossing state lines, isn’t that the burden that the college assumes by teaching students in other states?
What if a “new teacher” moves to another state? For employment measures, it is unclear what happens if a “new teacher” crosses state lines to become employed. Surveys are focused on students who remain in the state in which they were taught. The proposal also encourages the development of interstate sharing of information, but what is expected in the meanwhile for those students on the move?
Calculation of “burden” underestimated for distance programs. The Department calculated the extra burden that providers will assume in completing the new required documentation. Their logic estimates that there are an average of 14.65 programs per provider and that providers already collect and report this data. Therefore, they estimate the extra burden will total 13.65 hours (at one hour of per program). However, there is an unstated assumption that all the programs are in a single state. The burden grows when you multiply the number of programs for each provider times the number of states in which they serve students. If the measures are different from state-to-state, then this will add many hours of work for each state. Of course, they probably assume that the colleges are already reporting in those states, but there is still a multiplier effect and the extra need of understanding the differences and implementing solutions for each state.
We Need Your Help
Here’s where I need your help…
What am I missing?
What comments should we submit?
Is your college submitting comments and what are you saying?
Please send me your suggestions by January 20. Thank you!
There will be no more rating all our children (teacher preparation programs) above average. While there will be new reporting requirements, we will need to make sure that they fit with how distance education programs operate. Let’s give our opinions.
That is the news from Lake WCET, where all the women are strong, all the men are funny looking, and all the members are above average.