1. The use of one measure in the biennium (80% pass rate) on a licensure test to determine program survival is exactly what we teach our educators in poor practice..never use one measure to determine proficiency. Accreditation is about program improvement. Allow programs to provide a corrective action plan to when test scores do not meet an 80% pass rate. This is particularly true when Praxis tests change.

2. The annual report card is duplicative of material provided in Title II, the Biennial data, NCATE/CAEP, and SACS. We should focus our time on developing teachers not reporting additional data.

3. Please clarify the comments in the summary regarding the 8VAC20-542-20. Professional studies coursework and methodology, including field experiences, required in these regulations shall be designed for completion within a baccalaureate degree program - Does this mean you are requiring all initial licensure programs to be at the baccalaureate level? What about higher education institutions that offer programs in a 4 + 1 BS/MSED format? Will they have to change? If so how long will they have?

4. The 8VAC20-542-20. (page 11) eliminates the professional studies coursework cap. And 8VAC20-542-90 and 8VAC20-540-140 (pages 28-33 and pages 58-62) states the the  Professional studies competencies must be completed in the following areas, and competencies for each are set forth in the regulations:human growth and learning; curriculum and instruction; classroom and behavior management; assessment of and for learning,  the Teaching Profession; Reading, and supervised classroom instruction

5. However.... in  8VAC20-542-80 (pages 27-28) it states that Candidates in early/primary education preK-3, elementary education preK-6, and special education must complete a minimum of six semester hours of reading coursework as outlined in the reading competencies.  WE ARE NOW MIXING CREDITS AND COMPETENCIES

FURTHER it states 

Candidates seeking an early/primary education preK-3, elementary education preK-6 endorsement shall complete 12-15 semester hours each in English, history and social sciences, mathematics, and science addressing competencies set forth in these regulations or complete the following:

This is a total of 48 semester hours in four major content areas. What happened to competencies? We added more professional education courses and more content courses but we haven't addressed that we still have 120 hour degree program.