Considering that college and univesrity teacher education programs provide the majority of high quality teachers for the Commonwealth of Virginia and are the most heavily regulated and scrutinized entities who prepare teachers, any regulation that serves to deny approval on the basis of a single test score of it's teaching candidates should be re-considered.  The proposed regulations have added an additional category "Approved with stiuplations" which should help the teacher education programs maintain their endorsements and continue to provide high quality teachers for critical shortage areas. I affirm this addition:

• Approved with stipulations. The education endorsement program has met standards in subsections A and B of this section and is making documented progress toward meeting standards in subsection C of this section. Biennial passing rates that fall below the 80% requirement for program completers and noncompleters shall result in the education endorsement program receiving a rating of "approved with stipulations." The passing rate for program completers and noncompleters must meet the 80% passing rate requirement by the end of the next biennial period for the program to be approved; if the 80% pass rate is not achieved, the program will be denied.

In addition, the proposed regulations which remove the 18 hour and 24 hour cap on eduation courses that teacher education programs can require at the undergraduate level is helpful  in that the professional education competencies have increased, and we will need to develop additional courses to fulfill those requirements.

Another item in the proposed regulations, requiring all programs to be nationallly accredited could create additional demands in terms of data collection and reporting on colleges and universities with teacher education programs.  Requiring national accreditation must be tied to an agreement between the Commonwealth of Virgina and CAEP that seeks to minimize duplicate reporting of data and requiring data that teacher education programs have no authority or means to collect.