1. 8VAC20-542-50. Application of the standards. The proposed change to “passing rates, reported by percentages, shall not fall below 80% percent biennially for program completers and program noncompleters” is likely to create outcomes inconsistent with its intended purpose. If the purpose of this regulation is accountability, then institutions cannot be penalized for the decisions of students who exit prior to program completion, sometimes to take a position in a critical shortage area, and then be counted in the institution’s “non-completers” data. In the event that an institution determines that a candidate should be counseled out of teacher education, for whatever reason discovered after s/he has been admitted, this reporting requirement will encourage institutions to play the numbers game to keep candidates enrolled in order to maintain accreditation against the intention of preparing high quality teachers. Accreditation/program approval should not be tied to candidates’ decisions to exit a program. Programs with small Ns are particularly vulnerable in losing accreditation status if this regulation is approved. These small Ns programs are often the same programs on the critical shortage lists. We cannot continue to set standards that then lead to teacher shortages.  

2. 8VAC20-542-70. Annual Report Card. The reporting requirements for teacher education programs is extensive and duplicates other reporting requirements (Biennial Accountability Measurement Report stated in 8VAC20-542-60, Title II, CAEP Annual Report, PEDS for AACTE institutions, etc.). Items #1-8 listed in this section duplicate many of the items also required in the regulatory item 8VAC20-542-60 Biennial Accountability Measurement Report, listed just prior to this item in the proposed regulations. Streamlining of reports seems plausible.

3. 8VAC20-542-890 and 8VAC20-542-1340. In the Professional Studies requirements, maintain the name “Foundations of Education” to emphasize the importance of philosophical and foundational underpinnings of a democratic education system, and the ethical framework that comprises teachers’ work.

4. I appreciate strengthening the competencies focused on Assessment in the Professional Studies requirements.