8VAC20-542-20 I support lifting of the professional studies coursework cap. This change will better allow schools of education to address the many needs of the profession.

8VAC20-542-40 biennial reporting. Reporting pass rates as specified for program non-completers presents some difficulties for small teacher education programs. If a candidate leaves our program, it can be for several reasons. 1.) Candidates—especially in high-need areas—are being recruited by school divisions before they complete our program. School divisions offer provisional licenses and the candidate is teaching but is still counted as a non-completer. This should, I believe, be seen as a tribute to our preparation, but is instead, a threat to our required 80% pass rate. 2.) After admission to the program, candidates may exhibit dispositions or traits which are not compatible with excellence in teaching. These candidates are counselled out of the program prior to student teaching. Again, this appears to be a responsible and prudent action by the program, but can put it in jeopardy of falling below 80%. A better definition of non-completers for purposes of accountability is needed. With these two accounted for, a program could still be fairly evaluated on pass rates.