Areas of Question/Concern/Support:

1. Does 8VAC20-542-20 allow for master's level programs as well, or is it limited to baccalaureate level only?

2. The descriptions of categories in 8VAC20-542-40-1 and 8VAC20-542-50-B are flawed (1) because they do not include program non-completers who have been counseled out of a program and program non-completers who have not taken the Praxis II test, and (2) because both completers and non-completers count in the 80%pass rate mandate for the program. We have to be given credit for both keeping good candidates in, and counseling out the non-successful ones before completion.

3. With 8VAC20-542-40-6, colleges will need state assistance to obtain student achievement data from the P-12s for our completers employed in their schools.

4. 8VAC20-542-70 - This mandate for an Annual Report for the state raises a workload issue. In order to be compliant with the regulation to have CAEP accreditation, we already have to compile an Annual Report. We already have to do a Title II report annually. We already have a VA Biennial Report. So much of the data we report for these 3 is redundant. To require a 4th report is overkill.

5. With small programs it can take several years to accumulate the 10 completers needed to "officially count" in the pass rate for the 80% requirement. Small numbers means that the effect of one or two students has an inordinately huge impact on small programs as compared to larger programs. Also, the "sudden death" clause does not allow for programs to fix the problem and revise their training processes, which seems out of line when failing P-12 schools are given time and remediative assistance to improve.

6. With CAEP accrediation, we need to keep SPAs as an optional step.

7. When we are in a time of teacher shortages, why are we raising so many requirements for candidates? Many of the new requirements (such as specific SAT/ACT/GRE scores) have not been well-researched to prove their efficacy as meaningful selection criteria for effective teachers.

8. Since SACS already accredits college programs in the content areas of English, mathematics, history, etc., why does the state need to follow behind and "re-accredit" or "re-approve" those same programs a second time? It costs taxpayers for each process and each report.

9. It is great to have the "cap" removed from the professional studies requirements.

10. "The Teaching Profession" is a fine name for the foundations course.

11. At the end of this process of Approved Program Regulations Revision, the revisions of the matrices, the back-and-forth 3rd party process of "approving" them, the separate university internal curricular change systems, and the time consumed by all of these processes equates to an overwhelming burden on faculty and staff, and often removes us from our primary duties as teacher educators. That is not a good side-effect.