Proposed Regulations Governing the Review and Approval of Education Programs in Virginia (8VAC20-543-10 et seq.)

Public Comments Submitted on behalf of the Faculty and Staff in the College of Education at Virginia State University

October 30, 2015

As Interim Dean for the College of Education and Associate Vice-Provost for Graduate Programs at Virginia State University, I am pleased to submit comments regarding the proposed Regulations Governing the Review and Approval of Education Programs in Virginia.

John Dewey once said that "Education is not preparation for life; education is life itself".  Thus we understand that all things including regulations must evolve in order to reach perfection.

Over the past several months, faculty and staff in the College of Education have engaged in a thorough review of the proposed regulations and have expressed their overall support of the intent of these regulations. Faculty collectively cited their appreciation for the addition of add-on endorsements in special education, mathematics specialist endorsement delineations, and removal of the cap on professional studies requirements. However, during their review process several key proposed requirements were identified that may significantly impact our College of Education’s ability to offer high quality educator preparation endorsement programs leading to licensure at the level desired.

Our children and youth are our most precious resources and the State Board of Education along with personnel in the Virginia Department of Education are to be commended for their efforts to offer a set of regulations designed to help ensure the preparation of highly qualified educators in the Commonwealth. The Board also is to be commended for its efforts to strengthen the educator preparation program review and approval process by proposing increased measures of accountability for Virginia’s colleges and universities desiring to offer such programs. Moreover, we sincerely appreciate the Board’s transparency and support during this review process and look forward to continuing our efforts to prepare highly qualified, caring and committed educators in the Commonwealth. Our overall goal is to continue to develop and maintain innovative pockets of excellence to help ensure the future of our children and youth.

The following are comments and suggestions compiled by faculty and staff for addressing the issues that may significantly impact Virginia State University’s capacity to offer educator preparation programs leading to licensure in Virginia.

8VAC20-543-10

Part I
Definitions

8VAC20-543-10. Definitions.

• Delete the following definitions:

• “Biennial accountability measures”
• “Biennial accountability measurement report"

Rationale: With the addition of the Annual Report, the biennial report is considered redundant; the majority of the information is reported in the proposed Annual Report.

• Add the following definitions:

• “Triennial accountability measures” means those specific benchmarks set forth in 8VAC20-543-40 to meet the standards required to obtain or maintain program approval status.

• “Triennial accountability measurement report" means the compliance report submitted to the Virginia Department of Education as needed by an accredited professional education program when annual assessment scores and other selected criteria (as determined by the Board of Education) fall below specified benchmarks.

Rationale: This language aligns with the notion of assessing program endorsement areas on a triennial basis (somewhat similar to that required by Virginia’s PreK-12 school accreditation standards).

•  “Approved program” means a professional education program recognized as meeting state standards for the content and operation of such programs so graduates of the program will be eligible for state licensure. The Virginia Board of Education has the authority to approve programs in Virginia.

Rationale: This definition appears in the proposed Licensure Regulations for School Personnel; it stands to reason that it also be included in the proposed approved program regulations.

• “Clinically based experiences “means experiences of sufficient depth, breadth, diversity, coherence, and duration to ensure that candidates demonstrate their developing effectiveness and positive impact on all students’ learning and development. Clinical experiences, including technology-enhanced learning opportunities, are structured to have multiple performance-based assessments at key points within the program to demonstrate candidates’ development of the knowledge, skills, and professional dispositions that are associated with a positive impact on the learning and development of all PreK-12 students. (CAEP, Standard 2.3)

• Use the definition listed in CAEP, Standard 2.3.

Rationale: This term is not clearly defined within the proposed approved program regulations. Consistency between language used in CAEP and Board of Education approved regulations is needed.

• “Initial Licensure”

Comment: Term needs to be clearly defined by Department of Education personnel since some teachers holding provisional licenses also may be enrolled in an approved initial licensure program. The question then becomes, “Which is the initial license?” This also needs to be clarified for accuracy in Title 2 HEA and other federal and/or state reporting.

• “Administration and Supervision and Support Personnel” means an individual who has earned an appropriate graduate degree from a regionally accredited college or university with an endorsement as a school administrator, school counselor, school psychologist, school social worker, or vocational evaluator. (Teaching experience is not required unless otherwise outlined under the specific endorsement requirements.)

Rationale: This category needs to be clearly defined in the approved program regulations, particularly as it relates to the School counselor preK-12 endorsement (i.e., the expectation is clear in the proposed licensure regulations, but not referenced in the approved program regulations).

Comment: There is inconsistency in the use of the title of this category between both sets of proposed regulations. For example, the category is referred to as “…Support Personnel” in Part VI and “Pupil Personnel Services…” in Part I of the proposed licensure regulations. The category used in Part VI of the approved program regulations is “Administration and Supervision and Support Personnel.”

• Revise definitions to read as follows:

• "Accredited program" means a Virginia professional education program accredited by a national accrediting body recognized by the U.S. Department of Education and/or the Council for Higher Education Accreditation (CHEA),

Rationale: The proposed definition broadens the scope of opportunities for institutions to explore should the opportunity arise. The Department of Education can participate in partnership agreements with accrediting agencies as appropriate.

• "Professional studies" means courses and other learning experiences designed to prepare candidates to demonstrate competence in the areas of human development and learning, curriculum and instruction, assessment of and for learning, classroom and behavior management, the teaching profession, reading, and supervised clinical experiences.(Institutions offering education endorsements under Administration and Supervision and Support Services do not need to include a professional studies component as part of their program competency offerings.)

Rationale: This requirement is not clearly articulated in the proposed approved program regulations.

• "Program noncompleters” means individuals who have been officially admitted into an education program and who have taken, regardless of whether the individuals passed or failed, required licensure assessments and who exit the program prior to completion. Program noncompleters shall have been officially released in writing from an education endorsement program by an authorized administrator of the program. Program noncompleters who did not take required assessments are not included in accountability measurement reporting pass rates.

Rationale: Align language with other definitions and proposed revisions to 8VAC20-543-40 to 60.

• Delete the following definitions:

• “Biennial accountability measures”
• “Biennial accountability measurement report"

Rationale: With the addition of the Annual Report, the biennial report is redundant; the majority of the information is reported in the proposed Annual Report.

Part II
Accreditation and Administering this Chapter

8VAC20-543-20. Accreditation and administering this chapter.

• Revise to read as follows:

• B. Professional education programs in Virginia shall obtain and maintain national accreditation from a national accrediting body recognized by the U.S. Department of Education or the Council for Higher Education Accreditation (CHEA), Professional education programs in Virginia seeking national accreditation through a recognized accrediting body shall adhere to procedures and timelines established by such body and the established Virginia Partnership Agreement. Professional education programs shall ensure and document that programs are aligned with standards set forth in 8VAC20-543-40 through 8VAC20-543-50 and meet competencies outlined in 8VAC20-543-60 through 8VAC20-543-640.

Rationale: Language is revised to align with proposed definition for “Accredited program” in 8VAC20-543-10 and text in 8VAC20-543-40 through 60.

 

Question: When will this take effect based on relationship to CAEP requirements and standards, especially as pertaining to the current Department of Education/CAEP schedule for approved professional  education seven year reviews?

• Consider including this information as part of the State/CAEP Partnership Agreement.

• D. What is an “earned major”; what does “equivalent in the area sought” actually mean?

• To ensure clarity of intent, please provide a couple of examples within the text of this section.

• These terms are not used consistently across universities (and even within some departments).

• Check with SCHEV for guidelines on how to define for Virginia programs.

• Revise to read as follows:

• E. Professional studies coursework and methodology, including field experiences, required in this chapter shall be designed for completion within a baccalaureate or graduate degree program.

Rationale: Programs may be offered at both graduate and undergraduate levels of study.

• Revise the last sentence to read as follows:

• G. “… These procedures shall result in recommendations to the Board of Education every three years (triennial basis) for one of the following three ratings: "approved," "approved with stipulations," or "approval denied.”
• Rationale: This language aligns with the notion of assessing program endorsement areas on a triennial basis (is similar to that required for accreditation designations for Virginia’s school divisions). Also, deletion of biennial approval of programs will reduce the amount of reporting, paperwork, etc. required by the state for review and approval of professional education programs.
• Revise to read as follows:

• H. Education endorsement programs shall be approved under this chapter based on compliance with the criteria described in 8VAC20-543-40, 8VAC20-543-50, and 8VAC20-543-60.

• Board of Education program endorsement area approval every two years is burdensome and redundant. A three year approval process is more reasonable. This language aligns with the notion of assessing program endorsement areas on a triennial basis (somewhat similar to that required by Virginia’s PreK-12 school accreditation standards).

• “I. The Department of Education will determine the timeline and procedures for applying for education endorsement program approval.”

Comment: Consider increasing the opportunity to submit requests to offer new endorsement programs to twice a year (i.e., during all and spring semesters). (Currently requests may be made only once a year in the spring.) Institutions will then have an opportunity to make requests in the fall and make revisions, if needed, by the spring semester deadline.

• Revise to read as follows:

• K. Professional education programs shall submit to the Department of Education on behalf of each education endorsement program under consideration an accountability measurement report as needed and an annual report card to include data prescribed by the Board of Education on education endorsement programs in accordance with department procedures and timelines.

• This language would be in alignment with other sections of the regulations as appropriate.

• 8VAC20-543-40. Standards for biennial approval of education endorsement programs.

• 1. Change to triennial reporting. Keep the other wording in the standard.

• This would allow application of a three year running tally procedure similar to Standard of Learning accreditation standards in Virginia’s PreK-12 schools.

• 2. Candidate progress and performance on an assessment of basic skills as prescribed by the Board of Education for individuals seeking entry into an approved education endorsement program.

• Written clarification is needed in the approved program regulations regarding how this requirement may be met for program endorsement areas such as Administration and supervision PreK-12 and School counselor preK-12 endorsement areas.

• The Code of Virginia states, in part, the following:

“B. As provided in § 22.1-298.2, the Board of Education shall prescribe an assessment of basic skills for individuals seeking entry into an approved education program and shall establish a minimum passing score for such assessment. The Board also may prescribe other requirements for admission to Virginia's approved education programs in its regulations….”

Administration and supervision and Support Personnel” represent approved education programs. However, no entry level assessment of basic skills is required. Language in the Code is neither explicit nor implicit regarding whether or not these endorsement areas are exempt from this requirement.

• Indicators of the achievement of this standard shall include the following:

“a. Results on Board of Education prescribed entry-level assessments;”

• Written clarification is needed in the approved program regulations regarding how this requirement is met for program endorsement areas such as Administration and supervision PreK-12 and School counselor PreK-12 endorsement areas.

Rationale: Same as that provided for the previous item.

“b. Evidence that supervised clinical experiences are continuous and systematic and comprised of early field experiences with a minimum of 10 weeks of full-time student teaching under the supervision with demonstrated effectiveness in the classroom...”

• Clarify how this language relates to program requirements of Administration and Supervision and Support Personnel requirements (e.g., for Virginia State University School counselor PreK-12 and School Administration and supervision PreK-12 program endorsements.)

• Regulations need to clearly define requirements for teachers and administrators, school counselors, etc. Consider the use of a designation such as “Advanced Programs” to align with language used by CAEP.

Part V
Application of Standards for Biennial Approval of Education Endorsement Programs

8VAC20-543-50. Application of the standards.

• Revise entire section to align with language suggested for 8VAC20-543 -10, 40, and 60.

• Consistency in language is needed throughout the document.

Part VI
Professional Education Program Accountability

• 8VAC20-543-60. Biennial accountability measurement report.

• Delete biennial requirement. Require triennial reporting. Align language in this section with language used in 8VAC20-543-40 and 50, as appropriate.

• 8VAC20-543-70. Annual report card.

• Clarify 1. Institution's accreditation status (i.e., is this asking for the university regional or the professional education program accreditation status?), If both are needed, add the appropriate category.

• Change 2. To 2. Education endorsement program approval status;

• Change 7. Biennial to 7. Triennial

• Change 13. “…within two years of employment…” to “within three years of employment…”

Rationale: Changes provide consistency of language used throughout the document.

Part VII
Competencies for Endorsement Areas
Article 1
General Competencies

• 8VAC20-543-80. Competencies and requirements for endorsement areas.

• Clarify the following language in “A. The professional education program develops, maintains, and continuously evaluates high quality education endorsement programs….Candidates in education endorsement programs shall demonstrate competence in the areas in which they plan to practice and complete professional studies requirements and applicable assessments, in addition to meeting requirements for specific licenses, pursuant to the Licensure Regulations for School Personnel (8VAC20-22)….”

Comment: This section is unclear and needs some revising. For example, the language implies that all education endorsement programs must complete professional studies requirements. This is not the case for some of the Administration and Supervision and selected Support Personnel endorsement programs.

• 8VAC20-543-610. School counselor preK-12.

14. The program shall include at least 100 clock hours of internship and practicum experience in the preK-6 setting and 100 clock hours of internship and practicum experience in the grades 7-12 setting.

• Clarification is needed regarding teaching experience, etc. requirements for this endorsement area.

• There is a discrepancy between proposed licensure and approved program regulations regarding teaching experience, etc. requirements. In both options, the proposed licensure regulations include requirements for clock hours and a teaching experience, etc. However, the proposed approved program regulations only require the clock hours.