|Action||Comprehensive Revision of the Regulations Governing the Review and Approval of Education Programs in|
|Comment Period||Ends 10/31/2015|
8VAC20-543-280: Competencies for an Engineering Teacher Preperation Program
My background relevant to commenting on 8VAC20-543-280, “competencies for an approved teacher preparation program in engineering”, include the following: I have taught high school mathematics (pre-algebra through AP Calculus and Linear Algebra), completed a thirty-year career as a NASA aerospace engineer, served as chairman of an urban school board and as chairman of a Virginia Governor’s science & technology school board, and served as Senior Advisor to the Commonwealth for STEM Initiatives. In addition to my own background, I have consulted on this matter with a team of subject matter experts made up of a retired technology education coordinator of a large urban school division, an applied science and engineering university professor who works regularly with K12 programs in the Commonwealth, and two senior engineers – one from industry and the other from a large government R&T lab.
While not feeling qualified to comment on the pedagogical content, we found the technical competencies in this regulation to be right on target for the preparation of high school engineering teachers in the 21st century. The proposed regulation provides for a comprehensive education in the STEM constituents and how they must play together to support successful engineering endeavors. Basic engineering coursework is combined with the key mathematical courses used by engineers along with a broad interdisciplinary knowledge of the basic science disciplines to yield a holistic set of knowledge and skills. There is one possible addition that is not explicitly mentioned: computer programming. While it is likely that any student who has completed the engineering coursework listed in paragraph 4 along with experience required in paragraph 2.b, will have developed an adequate competency in computer programming, it might be a good idea to explicitly add computer programming or coding to the course listing in paragraph 4.
Significant additional strengths include 2.c (the role of failure in the engineering design process), as well as 6.a and 6.c (the cultural and social significance of engineering contributions along with knowledge of the historical development of engineering concepts and reasoning).
In 2010 the Committee on Standards for K-12 Engineering, which was formed by the National Academy of Engineering, remarked that (nationally) “there is not at present a critical mass of teachers qualified to deliver engineering instruction”. The competencies presented here in 8VAC20-543-280 should produce a cadre of highly qualified high school engineering teachers that will eliminate that concern in Virginia.
Thank you for the opportunity to provide comment on this very important proposed new regulation.
Response to Proposed Regulations Governing the Review and Approval of Education Programs in VA
As the Director of Human Resources & Administration for Page County Public Schools (Region IV), the following response represents the views of the Administration of Page County Schools. Response to some of the proposed regulation changes to Teacher Licensure include:
8VAC20-22-50. A few concerns with this proposal. First, I worry that the VDOE Licensure specialists will not be able to keep pace with the increase in licensure requests. Currently, the turn-around time (with provisionals being renewed every 3 years) is challenging (sometimes several months). It stands to reason, that adjusting from a 3 year review, to a 2 year review will increase their workload and ability to be efficient (unless there are plans to add VDOE Licensure specialists). Secondly, our school division is a rural Division in the Shenandoah Valley. Typically, we rank low among Shenandoah Valley School Divisions in teacher salaries. This provides great challenges in hiring and retention. Often, we have to hire provisionally licensed teachers, as fully licensed teachers choose higher paying Divisions. The 3 year provisional process has been fair and effective for our Division to hire competent, qualified teachers who are willing to work towards a goal. In recent years, we have seen a shortage in fully credentialed teachers. I am fearful that an unintended consequence of tightening provisional requirements could actually contribute to a teacher shortage, by making the requirements and time frame more strict.
8VAC20-22-90. As mentioned in 8VAC20-22-50, it does not seem prudent to tighten requirements for teacher licenses, during a time when economical constraints and available qualified teachers are limited (particularly for the rural, less economically advantaged counties). Our school division has relied heavily on Individuals that possess a Bachelors degree and are willing to enroll in a SPED Masters Program (quite often, these are our experineced SPED Paraprofessionals). The option of needing 3 hours for a provisional license has enabled us to put experienced paraprofessionals (with a Bachelors degree) into a classroom. I believe that extending the requirement to 9 credit hours would limit our effectiveness of finding willing, capable employees on the front end of their masters program in SPED. The 9 credit hour rule may actually create gaps, in which our only option would then be unqualified substitutes.
8VAC20-22-130. As long as teacher prep programs aren't adding total number of courses/credit hours, this would be OK. We need to be careful that we are not making license requirements more difficult, during a time when available, licensed teachers may be declining.
8VAC20-22-140. I believe that these recommendations are positive. One particularly helpful area is offering positive opportunities to add General Curriculum SPED add-on endorsements by level.
The Commonwealth of Virginia Code currently covers engineering and does an excellent job of preparing students for both career and college opportunities. Competencies are delivered by trained educators who are also content knowledge professionals. Career and Technical Education instructors welcome the opportunity to speak with anyone who has a vested interest in education and discuss the options available to the students of Virginia.
Teacher Education Program Regulations 8VAC20-543-50
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.
The proposed repealing of the current 8VAC20-542 and replacement with 8VAC20-543
On behalf of the Virginia Technology and Engineering Education Association, I request that changes not be made to the Regulations Governing the Review and Approval of Education Programs in Virginia. Specifically, the proposed repealing of the current 8VAC20-542 (items 8VAC20-542-10 through 8VAC20-542-600) and replacement with 8VAC20-543, with the associated additions of items 8VAC20-543-10 through 8VAC20-543-640. I offer the following to support our request:
- In 1988, the Virginia was the first Commonwealth/State to add Engineering courses to the existing Technology Education Program.
- In 2011 the Senate Joint Resolution 308' Establishing Shared Goals for an Engineering Program of Study with Shared Responsibility Among the Science, Mathematics, and Technology Disciplines was passed which specifies a partnership between our existing science, technology, and mathematics subjects to teach Engineering.
- In 2011, the Virginia Technology Education Association changed it their name to Virginia Technology and Engineering Education Association to reflect the Engineering Education (VTEEA) taught within our Technology Education Programs. This also mirrors the addition of engineering in our parent organization the International Technology and Engineering Educators Association.
- Engineering Education is already included in our Science, Technology, and Math Programs. Our schools are already teaching STEM in our K-12 courses. It is unnecessary to make further provisions for Engineering Education or Engineering Education Licensure.
- The VTEEA includes staff development in Engineering Education in their Summer Staff Development to assist in preparing all Technology and Engineering Education programs. Our Project Lead the Way (PLTW) instructors all have had in-depth instruction on teaching engineering in the required PLTW courses.
- The Technology Education curriculum is nationally recognized by the National Science Foundation, NASA, National Academy of Engineering, and other credible organizations that address the K-12 technology and engineering content and practices.
- We already have a teacher shortage throughout education. Creating another endorsement requirement will only add to the number of teachers to be hired for these positions.
Please support the programs that are already offered and the licensure currently in place. Do not add to already strained budgets and shortages of teachers. Our current Technology Education program in Career and Technical Education does an excellent job of preparing students for both career and college opportunities.
Proposed Engineering Endorsement and Proposed Engineer Education Program
I am opposed to the Licensure Regulations for School Personnel [8 VAC 20 -22} proposed Engineering Endorsement and the Regulations Governing the Review and Approval of Education Program [8 VAC 20 -542] proposed Engineering program. The proposed engineering endorsement duplicates content that has long-been covered and continues to be a part of technology education. Virginia is a national leader in secondary engineering education since the Technology Education Service created the first high school engineering courses in 1988. If the goal of the proposed engineering endorsement is to get more students to enter engineering, then, by definition that is Career and Technical Education. Such a program already exist in technology education and duplication of endorsements are not needed. Engineers already have an avenue to Virginia licensure thorough technology education (reference 8VAC20-23-270 Career and Technical Education--technology education], as well as, through the Career Switcher program, or through a provisional licensure program. Engineering is an integral part of Virginia's technology education program. This statewide program is improved thorough existing channels such as the curriculum revision schedule and the DACUM panels used annually by the Department of Education's Office of Career and Technical Education. To have a separate engineering endorsement and an engineering program, are clearly a duplication of services. During a time of continued budget constraints at the local school division, funding a separate engineering program is a waste of valuable resources, when engineering concepts are already in place within the technology education curriculum. Senate Resolution 308 passed in 2011 specified engineering education within Virginia is the shared responsibilities of science, technology, and mathematics and not the silo approach to STEM as proposed by the separate engineering endorsement. An engineering endorsement is already in place through technology education and engineer programs and concepts are already in place through the technology education curriculum.
Proposed Engineering Endorsement and proposed Engineering Education Program
To Whom It May Concern,
I am the President of the Virginia Association of Career and Technical Education and I am writing in opposition to the proposed engineering endorsement and that it be struck from the Licensure Regulations for School Personnel [8 VAC 20 - 22] and recommend the proposed regulations for engineering programs be stricken from the Regulations Governing the Review and Approval of Education Programs in Virginia [8 VAC 20 - 542]:
The rationale behind this opposition is due to the following reasons:
- The engineering endorsement duplicates curriculum and content that is an essential part of technology education. The technology education program curriculum is revised annually by the Department of Education Office of Career and Technical Education which actively partners with industry and business to provide dynamic and high quality programs to meet current, emerging and projected labor market needs. The technology career cluster and pathways lead to credentials that qualify students for a range of career opportunities from entry to professional level. Furthermore, if Engineers wish to change, improve, modify or add competencies/curriculum and/or skills should collaborate with Department of Education Office of Career and Technical not duplicate a program that is very successful.
- The proposal will create an individualism approach to STEM education that clearly is against the Senate Joint Resolution 308 passed in 2011 which specified engineering education within Virginia is the shared responsibility of science, technology and mathematics.
Virginia is and will continue to be a national leader in engineering education. Our Virginia Technology and Engineering Association members have been involved in the development of Standards for Technology and The National Assessment of Educational Progress Technology and Engineering projects as well as various National Academy of Engineering projects. In addition, our Technology Educators has become and will continually be internationally known for the annual Engineering Conference it host for elementary educators.
Sincerely Yours, Teresa Lindberg
Proposed Engineering Education discipline 8 VAC 20-543
The current proposal (8 VAC 20-543), designed to create an engineering discipline is unnecessary and redundant. Current Virginia Code (8VAC 20-542) already incorporates the instruction of engineering coursework within the Career and Technical Education umbrella. There is no statistical evidence that Virginia public schools are not meeting the needs of colleges and universities with regard to students continuing post-secondary study in the field of engineering. In fact, there is ample evidence cited by numerous studies that there are actually too many engineers graduating from our nation’s colleges and universities each year. Furthermore, according to the United States Department of Labor’s Bureau of Labor Statistics, the employment prediction for 2012-2022 job growth in mechanical, aerospace, and industrial engineering fields is slower than average.
I also oppose the proposal (8 VAC 20-23) creating an additional path for engineers to gain teacher licensure. Virginia Code (8 VAC 20-22) currently offers options for certification that are based on sound reasoning. There is no need to reinvent the wheel for engineers who are simply seeking to escape the pedagogy requirement. Research shows that content knowledge is only 20 percent of what makes a good teacher. Engineers need to understand the ramifications of decisions they might make in a secondary classroom and be especially mindful of adolescent development. Simply knowing how mathematics and science are applied to the engineering process is not enough to warrant placing engineers into a classroom without formal training. I certainly do not oppose having engineers in the Career and Technical education field, nor do I oppose having engineers teaching mathematics or science if that is their desire. What I do oppose is having a separate discipline for engineers and different licensing procedures for engineers to teach, especially procedures based upon faulty reasoning which, if followed to a logical conclusion, would say that only lawyers could teach criminal justice. Additionally, research shows that the science and engineering courses at the nation’s colleges and universities lose students based not on student performance or secondary school preparation, but on the quality of college education, be it poor teaching resources or lack of pedagogy. Pedagogy training is absolutely necessary to develop effective educators.
In the majority of comments posted I see no actual statistics provided that support the need for a stand-alone engineering discipline. The following publications should be read and digested prior to making a determination to add engineering as a discipline or making any changes to the regulations for endorsement for Virginia. This effort to change the existing Virginia Code is unnecessary, arbitrary, and redundant. Such a change will weaken the standards already in place and by which Technology Education teachers demonstrate on a daily basis the application of mathematics and science (engineering) through the use of technology. Science, Technology, Engineering and Mathematics (STEM) education is alive and well in Virginia without the proposed changes.
Against Engineering Endorsement separate form CTE
The National Academy of Engineering publications have consistently recommended that efforts toward K-12 Engineering Education standards should be in collaboration with Science, Technology, and Mathematics. Virginia’s Technology Education teachers, leaders, and professors have worked, since the 1980’s, to create an Engineering curriculum that starts as early as Kindergarten, proceeds through middle school and high school in several forms, and has produced graduates who have gone through university to professional engineering careers.
Publications and others who have promoted stopping what we are currently doing and starting a K-12 engineering curriculum, have done so in context of common core standards and outdated federal policy. The Commonwealth of Virginia not only has a working solution, but many of those teachers have reached out to their science and mathematics colleagues in collaboration and interdisciplinary efforts curriculum teams.
However, in the oft cited 2010 publication, Standards for K-12 Engineering Education? (See: http://www.nap.edu/download.php?record_id=12990 National Academy of Engineering) and particularly in the section, “Overall Conclusion,” is:
“The committee concluded that, although it is theoretically possible to develop standards for K–12 engineering education, it would be extremely difficult to ensure their usefulness and effective implementation. This conclusion is supported by the following findings: (1) there is relatively limited experience with K–12 engineering education in U.S. elementary and secondary schools, (2) there is not at present a critical mass of teachers qualified to deliver engineering instruction, (3) evidence regarding the impact of standards-based educational reforms on student learning in other subjects, such as mathematics and science, is inconclusive, and (4) there are significant barriers to introducing stand-alone standards for an entirely new content area in a curriculum already burdened with learning goals in more established domains of study” (page 1 Executive Summary).
However, Virginia does have extensive experience with K-12 engineering with different approaches and since the 1980’s. It is in this that a lack of true collaboration has occurred as Mathematics and Science SOL’s have created a separation and Engineering has been adopted as a component of Technology Education. The Virginia Department of Education has not adopted the name of its Technology Education Services as has occurred in the Virginia Technology and Engineering Education or the International Technology and Engineering Educators Association department name. This should be corrected as the only research-based engineering education is found in Technology Education. The book does cite the ITEEA Standards of Technological Literacy when making its case for and Engineering curriculum. Further, in “RECOMMENDATION 1” of the publication, Standards for K-12 Engineering Education? , “Federal agencies, foundations, and professional engineering societies with an interest in improving precollege engineering education should fund a consensus process to develop a document describing the core ideas of engineering that are appropriate for K–12 students. The process should include the views of a wide range of stakeholders. Work should begin as soon as possible, and the findings should be shared with key audiences, including developers of new or revised standards in science, mathematics, engineering, and technology at the national and state levels."
In “Guidelines for the Development of Instructional Materials,” “One important benefit of core ideas would be to support the development of guidelines for K–12 engineering instructional materials. Guidelines would help curriculum developers focus these materials on the core ideas and ensure that students would be exposed to materials representative of the actual practice of engineering. Thus guidelines could have an immediate, positive effect on the development of K–12 engineering curricula” (page 2 Executive Summary).
The Virginia Board of Education should direct the Superintendent of Instruction to use available resources such as Technology Education Services and began work to account for the current K-12 Engineering programs, teacher ability, and available national standards of practice. Only then should a separation from current practice occur.
Further, in “Special Characteristics of K–12 Engineering Education,” “K–12 engineering education has three important characteristics that must inform standards development and implementation. First, as noted in Chapter 1, compared to other K–12 subjects, engineering has a very small footprint in schools; in addition, almost no undergraduate programs provide training for prospective teachers of engineering. To put it simply, K–12 engineering education is in its infancy, and this has implications for standards. Second, engineering has strong connections to mathematics, science, and technology, school subjects for which there already are K–12 content standards. In addition, existing standards, particularly for science and technology, exploit their natural connections to engineering. Thus it is reasonable to ask if new engineering standards must include explicit links to these and perhaps other content standards. Finally, because of the postsecondary, professional track in engineering, some K–12 engineering curricula focus on preparing students to enter engineering schools, sometimes called the “pipeline” approach (e.g., Project Lead the Way, www.pltw.org). However, content standards for K–12 school subjects are typically based on a “mainline” goal, that is, general literacy in that field of study. This raises the question of whether there should be two sets of standards for K–12 engineering and, if so, how they might differ” (page 17).
I propose that this board reflect on the historical basis that 1, Engineering is a career field and that the study of careers is in the domain of Career and Technical Education. In this is the question of which other K-12 curriculum areas outside of Career and Technical education have endorsements and separate curricula in their career fields? 2) That as Virginia improves its effort to provide a K-12 Engineering Curriculum, that it be a collaborative effort amongst the Science, Technology, and Mathematics disciplines, and 3) that until real research and practice emerges as something different than what Virginia provides at developmentally appropriate levels, the domain “engineering” whether with a lower case or capital E remain in Technology Education. This would allow a transition, should one be necessary, rather than to further spread the education funding, efforts, and clarity. While there may be a prima facie logic to creating a new endorsement, history proves that education reform without due process or research leads to faulty logic and less student ability. In addition, claims that engineering is not present in Virginia K-12 are missing current data about what does occur. In addition, while the need for engineers is evident at some companies, it is the post-secondary institutions who need the K-12 pipeline. Industry requires the 4-year graduate. Univerisities need the high school graduates. Please do not allow this endorsement to continue as it is currently written. Instead, follow through with recommendations to create a true collaborative as the Governor's STEM Academies suggest.
Jesse W. White
Experience in Foundations courses
I can't imagine where my development as an educator and a scholar would be without my foundations courses. They have been an integral element of my PhD training. Retaining the "foundations" designator helps establish the purpose of these courses: to understand the philosophical and foundational elements of educational practice and research. Becoming a thoughtful agent of change requires matriculation in these courses. They are integral to the training of critically thinking educational practitioners and researchers.
Foundations of Education Change
I would like to voice my support for keeping the term "Foundations of Education" in our VA teacher prep standards. I appreciate that the proposed change would still require that future teachers receive instruction in the sociology, philosophy, and history of education, but the current proposal alters the ethical and social justice element that has been so instrumental to future teachers' professional development. To lose that would be to further create economic, cultural, and social divides across our society, which is counter to our democracy and the purposes of our public education.
Foundations of Education: No change necessary
Our society's move away from teaching as a profession hasn't been good for anyone: kids, teachers, or society. If teachers are entrusted to educate our children (and I hope they are!), we should ensure that they have the background, knowledge, and context about education to do this well. Though a name change might seem like a minor thing, the message it sends--and the additional changes it might cause--are at best unnecessary and at worst damaging.
The foundations courses in the VCU program have helped me to develop my understanding of the broader social and cultural construct of education. To be transparent, foundations courses were not the first courses I took in my program. I took two electives prior to taking my foundations courses, and felt lost. It wasn't until my first foundations course that I felt I had been given the building blocks for my graduate education. As soon as a student starts in the program and is in an elective class of mine, I tell them not to worry because once they take foundations, it will all make sense. They sigh with relief every time. These courses should be required and the name should stay the same. These courses are my foundation.
Gifted Education Endorsement
There is a concern that #9 of the new regulations is worded to reflect a classroom of only gifted students. The words "heterogeneously grouped" have been removed. How will this affect teachers and students in the future? What was the purpose of this change?
Do not remove 'Foundations of Education' from teachers' professional requirements
The Virginia Department of Education has proposed to eliminate the title of Foundations of Education from one of the professional studies requirements in the teacher licensure regulations and rename the requirement “The Teaching Profession.” While this may seem like a trivial change, I believe that it is actually a very significant and detrimental change. Foundations of Education has been a requirement in Virginia for at least the last 30 years and the content of such courses is still called for, even in the proposed regulation change. In the proposed regulation change, the title of the course changes from Foundations of Education to The Teaching Profession, yet the content of the course remains essentially the same. The proposed regulation appears below:
- 5. The teaching profession. Skills in this area shall be designed to develop an understanding of the historical, philosophical, and sociological foundations underlying the role, development and organization of public education in the United States. Attention must be given to the legal status of teachers and students, including federal and state laws and regulations, school as an organization/culture, and contemporary issues and current trends in education, including the impact of technology on education. Local, state, and federal governance of schools, including the roles of teachers and schools in communities must be included. Professionalism and ethical standards, as well as personal integrity must be addressed. Knowledge and understanding of Virginia’s Guidelines for Uniform Performance Standards and Evaluation Criteria for Teachers must be included.
The Foundations of Education field deals directly with teaching students not only the historical, philosophical, and sociological Foundations of education, but also with what it means to be an ethical professionalof education who has examined issues of personal integrity, especially as related to how one successfully remains in the teaching field and how one equitably serves and understands our increasingly diverse student population (the field of multicultural education is a sub-field of the Foundations of Education). In essence, the Foundations of Education courses around the state are already doing what the new regulations seem to want, thus why change the name?
This proposed change from "Foundations of Education" to "The Teaching Profession" will needlessly cut the course off from the discipline/field of Social Foundations of Education – a distinct field of study with graduate programs across the nation (e.g. University of Virginia; Virginia Tech; University of North Carolina Greensboro;University of South Carolina;and the University of Michigan to name a few).
The faculty who teach these courses have had specific training in the Foundations fields, and if the name is changed in the new regulations, I worry that this particular professional studies requirement may not end up being taught by the faculty best prepared to do the course justice.
Foundations of Education coursework provides a unique and critically important component of teacher education, bringing perspective and meaning to the task of teaching and fostering consideration of the role of public schools in our democracy. Study in Foundations of Education plays a key role in the development of reflective, thoroughly professional, and ultimately effective teachers for the Commonwealth because it places day-to-day classroom practice within wider contexts, providing time and space for consideration of such activities in light of the overall aims of education; such as education's role in supporting freedom of thought, social fairness, care for others, democratic self-government; and the role of schooling in students’ and teachers’ assumptions, beliefs, and attitudes surrounding diverse communities. In other words, Foundations of Education’s focus on the “whys” of education—from societal goals to cultural and social trends affecting all aspects of education—are critical to effective implementation of the “hows” of classroom practice. Historically, Virginia has served as a point of origin for many of the realizations of the crucial role education plays in our democratic society and Foundations of Education study serves to help Virginia’s teachers continue to understand, appreciate, and maintain these connections.
Proposed Engineering Course 8 VAC-543/ Apposed to additional stand alone course
Proposed Engineering Course; 8 VAC-543
It is my belief and experience that this proposed course, seperate from the courses already being offered to students in the commonwealth would be a mistake. Current research dictates that integrated Science, Technology, Engineering & Mathamatics, STEM education, is the best approach to preparing students along career paths in the Engineering and Technical fields. A "Silo" approach would be a step backwards. Career & Technical Education classes (CTE), Technology and Engineering education courses included, under the direction of the Virginia Department of Education have and are preparing the commonwealth's students to be College and Career ready. Technology education classes in the commonwealth have been national leaders in incorporating engineering courses and content since 1988 and this was further solidified in 2011 with Senate resolution 308 directing the shared responsibility for engineering content across Science, Technology & Mathamatics classes. Integration of and among these content areas is essential to establishing a strong future workforce. Further, the Engineering Design Process has been and will continue to be a foundational skill taught and implemented in a "Hands On" learning environment within Technology and Engineering classrooms.
Again, I believe this added course is redundant and uneccessary. Creating a "Silo" course when research indicates "Best Practice" is an integrated approach, would be a huge step backwards for the commonwealth and the students it serves.
Past President, ITEEA
Proposed Engineering Endorsement 8 VAC 20-23
I concur with George Bishop: "I oppose the proposal (8 VAC 20-23) creating an additional path for engineers to gain teacher licensure. Virginia Code (8 VAC 20-22) currently offers options for certification that are based on sound reasoning. There is no need to reinvent the wheel for engineers who are simply seeking to escape the pedagogy requirement. Research shows that content knowledge is only 20 percent of what makes a good teacher. Engineers need to understand the ramifications of decisions they might make in a secondary classroom and be especially mindful of adolescent development. Simply knowing how mathematics and science are applied to the engineering process is not enough to warrant placing engineers into a classroom without formal training. I certainly do not oppose having engineers in the Career and Technical education field, nor do I oppose having engineers teaching mathematics or science if that is their desire. What I do oppose is having a separate discipline for engineers and different licensing procedures for engineers to teach, especially procedures based upon faulty reasoning which, if followed to a logical conclusion, would say that only lawyers could teach criminal justice. Additionally, research shows that the science and engineering courses at the nation’s colleges and universities lose students based not on student performance or secondary school preparation, but on the quality of college education, be it poor teaching resources or lack of pedagogy. Pedagogy training is absolutely necessary to develop effective educators.
Additionally, the current proposal (8 VAC 20-543), designed to create an engineering discipline is unnecessary and redundant. Current Virginia Code (8VAC 20-542) already incorporates the instruction of engineering coursework within the Career and Technical Education umbrella. There is no statistical evidence that Virginia public schools are not meeting the needs of colleges and universities with regard to students continuing post-secondary study in the field of engineering. In fact, there is ample evidence cited by numerous studies that there are actually too many engineers graduating from our nation’s colleges and universities each year. Furthermore, according to the United States Department of Labor’s Bureau of Labor Statistics, the employment prediction for 2012-2022 job growth in mechanical, aerospace, and industrial engineering fields is slower than average.
In the majority of comments posted I see no actual statistics provided that support the need for a stand-alone engineering discipline. The following publications should be read and digested prior to making a determination to add engineering as a discipline or making any changes to the regulations for endorsement for Virginia. This effort to change the existing Virginia Code is unnecessary, arbitrary, and redundant. Such a change will weaken the standards already in place and by which Technology Education teachers demonstrate on a daily basis the application of mathematics and science (engineering) through the use of technology. Science, Technology, Engineering and Mathematics (STEM) education is alive and well in Virginia without the proposed changes."
"Social Foundations" in the Virginia teacher licensure sequence
Ensuring that pre-service teachers come to the teaching profession with an understanding of the sociological forces at work in education is an essential part of their ability to positively impact students' lives in a range of settings. Changing the title of this course leaves this essential component as a possible implication, a footnote, rather than an integral part of teacher training. The course title "The Teaching Profession" reflects a belief that the educational system is a one-size-fits-all approach, when we know this is not the case. Consider the importance of the social and philosophical elements of education and retain the title "Foundations" so that professors who are experienced in this field can continue to teach these courses and impart a broader understanding of the nature of the field of education to new teachers.
Foundations of Education- This Title Matters!
I'm writing to stress the importance of maintaining the title "Foundations of Education" (proposed to be changed to "The Teaching Profession") in the professional studies requirements of Virginia's teacher licensure regulations. This word change is not trivial- the term Foundations signals a broader and more contextual understanding of the historical, philosophical, and sociological underpinnings of our education system in a way that the porposed title does not. Foundations, as a distinct discipline, is critical to helping new teachers contextualize their roles and responsibilities as educators- it is a must-have and a powerful body of knowledge to instill in our future educational leaders.
Proposed Engineering Course 8 VAC-543/ Opposed to additional stand alone course
Commenter: Sidney Arthur Rader, DTE Retired
Proposed Engineering Course; 8 VAC-543
I was completely taken aback when I received notification of the fact that a proposal has been made to offer a separate engineering course within the Virginia Public Schools. For the majority of my Technology Education teaching career, I was not only involved with the courses offered within my curriculum area, but also with the promotion and support of engineering education. I developed a close relationship with the JETS Organization at the National Level and was the advisor to several teams winning the Virginia State Competition of the National Engineering Design Challenge Competitions. I was able to broker relationships between the Technology Student Association and the JETS Organization where the National Engineering Design Challenge was concerned. When the JETS Organization made its decision to cease operation due to lack of support and participation, Dr. Rosanne White, executive director of the Technology Student Association, reached out to the JETS Board and was able to negotiate the transfer of many of the programs and activites of the JETS Organization to the Technology Student Association. The TEAMS Program is alive and well today because of Dr. White and her dedicated staff at the Technology Student Association. The UNITE Program as well as the Engineering Design Competition within TSA are also providing students with opportunites for exposure to STEM integration activities that prepare them for career paths in the Engineering and Technical Fields. I believe that this proposed course, seperate from the courses already being offered to students here in the Commonwealth, would prove to be a mistake of paramount proportions. There is no denying the fact that research dictates that integrated Science, Technology, Engineering & Mathamatics, STEM education, is the most logical and successful approach to preparing students for Engineering and Technical fields. A separate course is unnecessary and would prove to be a step in the wrong direction. Through the Virginia Department of Education, Career & Technical Education classes (CTE), Technology and Engineering education courses included, students in the commonwealth have and are being approprialtely prepared for College and Careers. Our technology education classes and programs here in the commonwealth have consistently been rcognized as national leaders in incorporating engineering courses and content since 1988, and in some cases as myself, before. In 2011, Senate resolution 308 directed the shared responsibility for engineering content across Science, Technology & Mathamatics classes and the successes of this directive are evident across the commonwealth. It is essential and should be considered mandatory that this shared responsibility be sustained as a avenue to establishing a strong future workforce. The Engineering Design Process and a "Hands On" learning environment within Technology and Engineering classrooms within the commonwealth and across the nation will continue to be the preferred and most successful approach, with the support of math and science programs. Engineering is STEM.
The proposed added course is redundant, uneccessary, and a misdirection and waste of resources. Working within the framework of success that already exists is the best way to promote engineering within the commonwealth and the nation.
The importance of social foundations.
To the VA Board of Education,
I would like to register my support for maintaining language in the regulations for VA schools of education that emphasizes the importance of stand-alone courses in the social foundations of education. It is in classes such as these that students learn to hone their judgment and ethical decision making skills by exploring professional dilemmas and making decisions informed by knowledge of the lives of their students both in and outside of schools, as well as the history of education in this country. To short this opportunity can cause major problems for pre-service teachers. I teach students history/social studies methods. While we may discuss issues that come up in social foundations classes, I would have to curtail their instruction in pedagogical methods if I had to include the teaching of foundations in my courses. The schools of education around this state take their cue from you. What you value ends up guiding decisions about programs, hiring, and budgets at our schools. Maintaining a strong support for the social foundations will directly support our ability to graduate teachers who are ready to be successful in Virginia schools.
Gabriel A. Reich, PhD
Department of Teaching and Learning
Keep Foundations of Education as it is
As a veteran teacher with over 20 years experience, I am concerned that Virginia is considering changing the "Foundations of Education" course title to "The Teaching Profession". We need to make sure that our teacher preparation programs continue to provide the historical, philosophical, and social context necessary for developing effective and innovative educational programs and decisions. Changing the name is unnecessary and gives the impression that a teacher's professionalism is more important than the education they plan to help provide to our children. Our state's children deserve teachers who seek to develop and and implement learning opportunities through thoughtful reflection and continuing analysis of their practice. Foundations in Education courses are a critical starting point for new teachers to begin this process.
Keep the Foundations Requirement in Initial Teacher Licensure
As a teacher educator, I believe the Foundations requirement is a valuable part of our pre-service teachers' preparation. Please do not change the requirement!
Social Foundations in Elementary Teacher Preparation and Social Studies Methods
I am writing in response to the proposed changes to the Initial Teacher Licensure Regulations for elementary educators. As program coordinator and an instructor for the current required course (Foundations of Education), I would like to encourage the board to consider keeping the focus on social/political/economic/cultural contexts of education as a requirement for preservice teachers. I teach this course fairly regularly at Mason in our introductory semester, and I find that exploring with these topics allows preservice teachers to unpack their preconceived notions of schooling and to grapple with the idea that not all students experience school in the same way that they did. Their learning curve in this course is tremendous, and their openness to understanding how diverse learners school experiences vary across contexts. This is particularly important as our population continues to become more diverse and as our students attain teaching positions in the vastly different areas of Virginia.
Similarly, I would also encourage the board to reconsider removing the Social Studies Methods course requirements from elementary teacher preparation. Social Studies is a critical content area that is often the center of opportunities for content integration--a key instructional approach in elementary schools and one that is supported by a wealth of research in elementary student learning.
Thank you for your time,
Proposed Engineering Program Regulations
I am the program coordinator for a Virginia approved, nationally accredited technology teacher preparation program at a STEM intensive research university. I initially spoke to the Board of Education (BOE) and the Advisory Board on Teacher Education and Licensure (ABTEL) in 2014 regarding key clarifications of K-12 technology and engineering education at the state and national levels. The documents I cited form the foundation for Virginia's technology education program and include:
Garmire, E. & Pearson, G. (Editors). (2006). Tech Tally: Approaches to Assessing Technological Literacy. Washington, D.C.: National Academies Press. http://www.nap.edu
International Technology & Engineering Educators Association (ITEEA). (2000,2002,2007). Standards for Technological Literacy: Content for the Study of Technology. Reston, VA: Author. http://www.iteea.org
Katehi, L., Pearson, G., & Feder, M. (Editors). (2009). Engineering in K-12 Education: Understanding the Status and Improving the Prospects. Washington, D.C.: National Academies Press. http://www.nap.edu
National Academy of Engineering. (2010). Standards for K-12 Engineering Education? Washington, DC: National Academies Press. http://www.nap.edu
Pearson, G. & Young, A. T. (Editors). (2002). Technically Speaking: Why all Americans Need to Know more about Technology. Washington, DC: National Academies Press. http://www.nap.edu
Technology education program information on the Virginia Department of Education’s website (http://www.doe.virginia.gov/instruction/career_technical/technology/index.shtml) as well as the Virginia CTE Resource Center website (http://cteresource.org/about/) demonstrate that the program is aligned to national trends in K-12 technology and engineering education. In fact, some states (e.g. Missouri) and professional organizations (e.g. ITEEA, CTETE, VTEEA) use the term technology and engineering education. A separate engineering education program in Virginia is not needed because the Virginia model covers technology and engineering education… but the name has not been changed to reflect this. There are additional issues and confounding questions with the proposed engineering program in the Regulations Governing the Review and Approval of Education Programs in Virginia [8 VAC 20 - 542].
If the goal of the proposed engineering program is to get more students to enter engineering then, by definition, that is career and technical education. Such a program already exists in technology education and engineers already have a pathway to Virginia licensure through technology education (see 8VAC20-23-270. Career and technical education - technology education). Engineering (especially engineering design as outlined in Standards for Technological Literacy and the Next Generation Science Standards) is an integral part of Virginia’s technology education program. The technology education program in Virginia is improved through existing channels such as the curriculum revision schedule and DACUM panels used annually by the Department of Education's Office of Career and Technical Education. These processes involve engineers and other professionals. Engineers wishing to improve the technology and engineering education program in Virginia should collaborate with the VTEEA and the Department of Education's Office of Career and Technical Education rather than propose a full program duplication through back doors. If the new engineering program regulations are approved, will the state start fracturing all programs by specific professions?
Approved program Regulations - Several Items
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.
Earth Science coursework list: Add Geomorphology, remove Structural Geology
I am a geology professor in the Department of Ocean, Earth and Atmospheric Sciences at Old Dominion University and the advisor for the Earth Science Education students in our Ocean and Earth Science B.S. program. A faculty member for the past 35 years, I now teach a variety of geology courses for our undergraduate program – geomorphology, structural geology, hydrogeology, Quaternary geology, and research methods. Also, as the CoDirector of the MonarchTeach program, I am the lead faculty member from the College of Sciences working with the College of Education to increase the number of STEM majors who are equipped to teach science or math in secondary schools. I write as a concerned individual, and do not presume to speak for the University.
I applaud the tone of the new regulations which stress the rigor of understanding that our students must have in their content area. In the Earth Science recommendations for secondary schools (8VAC20-542-4340. Science - Earth science) I support almost all of the changes proposed; these changes help future teachers have the background needed to address the Essential Understandings and Essential Skills presently listed on the Virginia Department of Education website. I am thus presuming that future lists of Essential Understandings and Essential Skills will be very similar.
However, the new regulations left a course off of the list of prescribed courses that is absolutely essential for teachers – geomorphology. The list also contains a course that is only marginally useful to teachers – structural geology. If we add a single course to the list, it should be geomorphology, NOT structural geology. Our students need specific background in order to teach the topics in the Standards of Learning ES 7. and ES.8. and they will only get a small part of that information in a structural geology course. Essential Understandings built upon ES.7 include information about folded and thrust-faulted mountains, subduction zone volcanoes and trenches, mid-ocean ridges, rift valleys, fissure volcanoes, flood lavas, strike-slip faults, earthquake activity, magma, hot spots, faults, and the rock cycle. A structural geology course would cover many of these topics, a few of them in great detail. However, the topics covered by SOLs in ES.8. are soil, weathering, karst topography, carbonate rocks, caves, sinkholes, limestone solution acidic groundwater, permeability, waste disposal, pollution, regional watershed systems in Virginia, and the state’s major physiographic features - Chesapeake Bay, Appalachian Plateau, Valley and Ridge, Blue Ridge, Piedmont, and Coastal Plain. These are not topics covered in structural geology. However, ALL of the SOLs listed in both ES.7. and ES.8. ARE covered routinely in geomorphology courses. In order to understand the processes that form landscapes, the rocks, sediments, water and soils that are present directly beneath our feet and surround us, and how they are components of the global systems that control them, teachers must understand geomorphic processes and systems. Geomorphology should be on the required coursework list as much or more than any other course.
An easy fix might be to include both geomorphology and structural geology to the prescribed coursework list, but this change would add an unnecessary burden to the Earth Science curriculum. The typical Earth Science program already is difficult to complete in four years. Multidisciplinary fields such as geology are built from an understanding of many related sciences (chemistry, biology, physics, calculus), and so Earth Science students must take two semesters of all of these courses, as well as statistics. They take more introductory science and math courses than students in other science fields. In addition, they must take courses in meteorology, astronomy, and oceanography. If we add more specific courses to the Earth Science curriculum, we should add only what is truly necessary, and structural geology is not necessary.
Keep the Foundations Requirement in Initial Teacher Licensure
This class shaped who I am as a teacher. Without this class I would not be able to make everyday informed educational decisions for my ecse classroom. If you let just anyone teach this class, you might as well let anyone teach. It takes a special professor, with the educational background to teach this class. Keep it the way it is.
Foundations - the name says it all
Hearing that foundations of education may no longer be a requirement for students going into education is very concerning to me. In this class I learned so much that helped shaped the teacher I am. I still use materials from this class in my classroom today. BThe name foundations says it all. It is the foundation that crates a well rounded and knowledgeable teacher! We would not stop teaching students the foundation of math like numbers and adding. So why would we send teachers out into the world with out giving them the foundation they need.
Foundations of Education title should remain the same
I am a teacher educator at Radford University, specializing in teaching the Foundations of Education. My PhD coursework is in this field and it disturbs me that the state of VA is looking to change the title of one of the professional studies courses from "foundations of education" to "the teaching profession". Doing so will separate the course from its disciplinary roots, and the courses thus might not be taught by those who specialized in the foundations of education in their graduate coursework.
Many people have commented at this site: https://www.townhall.virginia.gov/L/comments.cfm?stageid=6643 regarding this title change (regarding Licensure Regulations for School Personnel [8 VAC 20 - 22]) and those comments are relevant to this section of the town hall comments as well, so please do look there to see what was posted regarding the Foundations of Education (can easily be picked out by comment title).
Further, an online petition was created and can be found here: https://www.change.org/p/virginia-department-of-education-retain-the-foundations-of-education-title-in-virginia-teacher-preparation-regulations?recruiter=406290682&utm_source=share_petition&utm_medium=facebook&utm_campaign=share_facebook_responsive&utm_term=des-lg-share_for_starters-no_msg
As of this writing (Oct 27, 9 pm), 219 people have signed that petition. One of my colleagues who lives in Virginia will be delivering the signatures and comments generated by this petition to the VADOE office before the comments period closes.
Thank you for considering.
Social Foundations of Education
Re: the proposed course
name change from "social foundations" to " the teaching profession."
strongly opposed, failing sufficient explanation.
I understand the described
course content remains essentially the same but I must presume this is
temporary, else why change the name? What can be afoot?
I have no personal
investment in the matter: I have no professional connection to any school of
I am afraid what I suspect is a move away from the estimable
tradition of John Dewey and progressive educational philosophy. Dewey held
public education to be a prime engine of social responsibility, social progress,
and social justice. To leave that to one side in favor of an emphasis on
teaching as a semi-isolable function would be parallel to a seminary's ditching
courses in the social context of ministry in favor of a " just preach the
gospel; leave social concerns to others" approach. The classroom of course is not a place for preaching but teachers themselves need to be aware.
Keep Social Foundations!
Understanding social foundations is essential to developing teachers that will be effective is a variety of school settings. Teachers need to understand how social and cultural contexts and issues influence their daily work with the learners. The core tenants of social foundations encourage thoughtful, reflective practice and encourage flexibility in instructional planning and delivery in order to meet the growing diversity among VA's school-age population.
Expand opportunities for effective early childhood education teacher preparation
The proposed language for early education teacher preparation programs (e.g. covering preschool- grade 3 and for 3 and 4 year olds specifically) would greatly enhance the effectiveness and impact of this growing and important sector of the education workforce. The proposed language focuses programs on the knowledge, skills, and competencies identified by research to contribute to learning and development of young children. In contrast to the current language the proposed language is a major improvement and will strengthen Virginia's early education system. Moving toward a competency-based system positions Virginia as a a leader nationally. And there is considerable interest and promise in a 4-year degree focused on teaching in early educaiton programs that could lead to initial licensure.
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Professional Studies Coursework Cap/Biennial Reporting of Pass Rates
8VAC20-542-20 I support lifting of the professional studies coursework cap. This change will better allow schools of education to address the many needs of the profession.
8VAC20-542-40 biennial reporting. Reporting pass rates as specified for program non-completers presents some difficulties for small teacher education programs. If a candidate leaves our program, it can be for several reasons. 1.) Candidates—especially in high-need areas—are being recruited by school divisions before they complete our program. School divisions offer provisional licenses and the candidate is teaching but is still counted as a non-completer. This should, I believe, be seen as a tribute to our preparation, but is instead, a threat to our required 80% pass rate. 2.) After admission to the program, candidates may exhibit dispositions or traits which are not compatible with excellence in teaching. These candidates are counselled out of the program prior to student teaching. Again, this appears to be a responsible and prudent action by the program, but can put it in jeopardy of falling below 80%. A better definition of non-completers for purposes of accountability is needed. With these two accounted for, a program could still be fairly evaluated on pass rates.
Teacher Education Program Regulations 8VAC20-543-50:8VAC20-543-70. Annual report card.
Teacher Education Program Regulations 8VAC20-543-50
Proposed regulation: The education endorsement program’s candidate passing rates reported by percentages should not fall below 80% biennially for program completers and program non-completers…
COMMENT: Additional clarity is necessary regarding required licensure assessments. For example, students may drop their educational programs due to failure of licensure exams, this should be a caveat in the discussion. In addition, students who pass these exams but move (many of our VA higher education students may be military spouses etc.) these students who depart the program should not be counted against the University.
To receive a provisional special education license only one class is currently required by VDOE.
COMMENT: I personally support the proposed change for provisional licensure requiring 9 credit hours/3 courses to ensure stronger and more prepared educators in our most vulnerable and educationally diverse students.
3.8VAC20-543-70. Annual report card.
Addition of Annual Report card: Institutions of higher education…
COMMENT: Teacher education programs complete an inordinate number or varied reports for the state, university, federal government and accreditation. Is there a way to combine a universal type reporting system? And – other data as requested by the board is too nebulous and misleading.
OVERALL FINAL COMMENT: Recognizing the needed changes to the state regulations it should also be noted that changes please note that any Program revisions require a one year preparation period.
Deaf and Hard of Hearing
4680. Special education hearing impairments deaf and hard of hearing
We applaud the change in the term “Hearing Impaired” to the “Deaf and Hard of Hearing”.
Specifically related to language found on p. 138 we would like clarifying language added to “Demonstrate proficiency in expressive and receptive sign language to include American Sign Language and contact varieties.”
- How do students demonstrate proficiency in ASL? Does completion or a specific grade (C or better) in ASL level 1 to level 4 demonstrate proficiency? Or do the students need to pass a receptive and expressive language assessment to show their competencies? If the Sign Language Proficiency Interview (SLPI) is used to judge their proficiency what score is required (some universities use Intermediate level others use Intermediate Plus level).
- Do students need to show proficiency in Signed English or Total Communication?
- We need clarification of the wording ”contact varieties”. Does this term refer to sign variations (regional signs) or does it mean sign communication systems (ASL vs. Signed English)?
Special education: Early Childhood
9100. Early childhood for three- and four-year-olds (add-on endorsement). We give the VDOE kudos for adding the ECSE license to those that can add the 3-4 year old endorsement. This is especially important as many school systems are providing inclusive Virginia Preschool Initiative (VPI) classrooms, and having both endorsements available to candidates in ECSE programs will qualify them to teach in these classrooms. However, we do have a question/need for clarification about this add-on endorsement for ECSE initial licensure pre-service candidates. Will pre-service initial licensure candidates who take coursework for both ECSE and the 3-4 year old add-on endorsement simultaneously in their programs be able to apply for the add-on when they apply for initial licensure in ECSE, or is the requirement that they receive their ECSE license first, then apply for the add-on endorsement?
4590 Additionally we applaud the addition of details reflecting best practices to the ECSE endorsement competencies, including: (1) adding early intervention and issues of cultural and linguistic diversity to competency; (2) additional details for the assessment competency; (3) language implying inclusion in competency; (4) adding details to teaching social and emotional skills to assist with behavior management (5) understanding speech and language development: stages of acquisition, cultural and linguistic diversity, ELL and pragmatic use of language; (6) added language about emergency care and effects of medication; (7) language specific to early intervention (e.g. coaching); and (8) writing skills.
We appreciate the addition of early intervention to ECSE, specifically in competency 11. The competence reads, “Completion of supervised experiences at the
preschool early childhood level in a variety of settings, including but not limited to early intervention, home-based, school-based, and community-based settings” (p. 141). Please clarify if a teacher with a provisional license in ECSE be required to complete a field experience in early intervention in addition to the content competencies to complete the requirements for the endorsement in ECSE.
8VAC20-542-4760. Special education adapted curriculum K-12.
We appreciate the changes under
34 Collaboration (p. 125)
The opening paragraph states, “The candidate shall also shall complete the competencies in at least one of the endorsement areas of Special Education Adapted Curriculum K-12, in addition to those required under professional studies…” Please note, there is only one area of endorsement under Special Education Adapted Curriculum K-12 so this language is incorrect.
3. Management of instruction and behavior (p. 125) We suggest the wording for “3
2c. An understanding and application of classroom and behavior management techniques and individual interventions, including techniques that…” be changed to an understanding and application of the three tiers of behavioral interventions and support and management: School-wide, classroom and individual, including techniques that:…
3. Instructional methods and strategies for the adapted curriculum. (p. 128) We suggest the wording for, “(2) Foundational knowledge…Additional skills shall include proficiency in a wide variety of comprehension strategies and writing, as well as the ability to foster appreciation of a variety of literature and independent reading; and reading and writing across the content areas.” be changed to Foundational knowledge…Additional skills shall include evidence-based emergent and early literacy strategies for students with complex disabilities including students using gestural, alternative or augmentative communication.
Still on p. 128, “(4) Alternative ways to teach content material including curriculum adaptation and curriculum modifications,” we suggest the addition of universal design for learning and assistive technology after “modifications.”
Continuing on p. 128, “(6) Strategies to promote successful integration of students with disabilities with their nondisabled peers;” we suggest a change to Strategies to initiate and support successful inclusion of students with disabilities with their nondisabled peers in their schools and communities
p. 129, “(7) Use of technology to promote student learning” we suggest a change to Use of instructional and assistive technologies to promote student learning and independence
Regarding Special Education: General Curriculum Add-on Endorsements: 8VAC-20-542-510–8VAC20-542-530
We appreciate the option for licensed general education teachers to seek an additional endorsement in Special Education: General Curriculum K-6, 6-8, or 6-12 and applaud this possibility. However, we have concerns about the selection of coursework. The proposed regulations place an emphasis on the foundations of special education. Licensed general education teachers should already have an introduction to special education course completed (at least those who received initial licensure in Virginia). We feel other coursework would be more beneficial to the teachers and their K-12 students. Two options relate to:
- Classroom management and behavior support: A glaring omission is the lack of coursework related to behavior support and classroom management. In language related to the “typical” K-12 special education: general curriculum license, it appears there was emphasis added to classwork related to behavior support and classroom management, which is not present at all in the language related to the add-on endorsements.
- Collaboration: The add-on endorsements don’t address coursework in collaboration, which is required in the “typical” K-12 special education: general curriculum license.
We suggest removing the requirement for coursework in foundations of special education and adding a requirement addressing classroom management and positive behavior support. If two courses were added, we suggest coursework related to collaboration.
We have a question regarding how the add-on endorsements relate to provisional licensure in special education. To explain we provide the following scenario: a student completes a degree with licensure in either K-6, 6-8, 6-12 general education (not special education) and as part of the degree they complete a Special Education Foundations Course. A school division then hires this graduate provisionally as a special educator. Could this graduate take only 12 hours of coursework under the new regulations and receive the add-on endorsement or would they still have to meet the 27 hours currently required for provisional licensure? The regulation as written requires clarification.
8VAC20-542-40 and 8VAC20-542-1340 - 10 weeks of student teaching
We are writing in reference to language found under 8VAC20-542-40 (specific language found on p. 15), 8VAC20-542-
890 (specific language found on p. 32), and 8VAC20-542- 1340 (specific language found on p. 61) regarding stipulation of 10 weeks of a summative clinical student teaching experience under the supervision of a cooperating teacher with demonstrated effectiveness in the classroom.
Our concerns are twofold:
- We suggest that the language, “a minimum of 10 weeks of full-time student teaching” is unclear and potentially limiting to programs. Full-time implies eight hours per day in the school having taken over for a teacher for 10-weeks; however, the regulations stipulate “The supervised student teaching experience shall include
withat least 150 clock hours spent supervisedin direct teaching,” which does not equate to 8 hours per day of full time teaching.
- Furthermore, “10 weeks of full-time” suggests programs that currently provide 14 weeks of a part time (20-30 hours per week), or two seven week full time placements requiring a minimum of 150 clock hours spent in direct teaching would no longer suffice. Differences in placement structures allows for multiple field experiences in elementary and middle or secondary schools for preK-12 licensures.
We do not believe this was the intent of the authors, but confusion could be generated by this language. We believe the previous wording requiring “at least 300 hours…to include a minimum of 150 clock hours of…teaching…” provides a clearer understanding of the time desired for field experiences and allows for some flexibility in programs that would nonetheless be rigorous.
8VAC20-543-40 (repealed 542-40) - Diverse school settings
8VAC20-543-40 (repealed 542-40)
4. Evidence of opportunities for candidates to participate in diverse school settings that provide experiences with populations that include racial, economic, linguistic, and ethnic diversity throughout the program experiences. The indicator of the achievement of this standard shall include evidence that the professional education program provides opportunities for candidates to have program experiences in diverse school settings that provide experiences with populations that include racial, economic, linguistic, and ethnic diversity within each biennial period.
We applaud this attention to preparing candidates for diverse school settings, however we ask the Board to consider the following barriers to the effective implementation of this regulation:
- Geographic limitations – Teacher preparation programs in the western, southwestern, and rural regions of Virginia have limited access to diverse, urban settings. Distance, economic, and travel time considerations are all barriers to providing quality learning opportunities in diverse schools. The few diverse school settings within a reasonable drive of the home institution will likely be overwhelmed with requests for field placements. Will these schools be able to accommodate all the requests?
- Quality of placements – If the geographic limitations are overcome, will the Board require that diverse school placements occur in accredited schools with fully licensed, proficient, or exemplary teachers? Such a requirement may further limit allowable placements while underscoring the high needs of urban, diverse schools.
- Faculty leadership/supervision – Placing teacher candidates in a variety of schools across a wide geographic area presents significant challenges for existing faculty to direct and supervise field experiences, while maintaining teaching and scholarly work. Relegating field work to graduate students and adjunct faculty may limit the quality of field supervision.
- Rural schools – rural schools with limited racial and ethnic diversity present a different set of teaching challenges including high poverty, students at risk of school failure, and schools facing economic hardship. We assume the requirement for diverse school settings will be applied to this population.
We also ask for clarification concerning the expectations of diverse school setting placements:
- Recommendations for type and duration of placements in “diverse schools“ - What level of engagement will be required for the “diverse school setting” placement? Will observation or assisting hours meet the requirement or is full time teaching required in this setting?
- Alignment with the definition of “diversity” as listed in 8VAC20-543-10 (repealed 542-10)
These questions in no way diminish the value of experiences in a variety of school settings. We raise these concerns to highlight the challenges implicit in the new regulations and ask for the Board’s assistance in defining the terms and considering the mediating barriers to implementation.
8VAC20-23-130 and 8VAC20-23-190 - Foundations of Education
We are writing to express our concerns with some changes proposed in the Teacher Licensure Regulations for the commonwealth of VA. Specifically, our concerns are in these areas:
8VAC20-23-130. Professional studies requirements item 5
8VAC20-23-190. Professional studies requirements. Item 4
In essence, the changes proposed in these sections seem to be doing four things:
- Removing the title “Foundations of Education” and replacing it with “The Teaching Profession.”
- Moving the assessment content out of the foundations course into a separate course.
- Explicitly adding in content on professionalism, ethical standards, and personal integrity
- Adding in content on Virginia’s Guidelines for Uniform Performance Standards and Evaluation Criteria for Teachers
While we certainly agree with item number 2 above, that the assessment content is important enough to be moved out and made a professional studies requirement of its own, we do have some strong concerns about item 1.
Our primary concern rests with changing the title of the professional studies requirement of “Foundations of Education” to “The Teaching Profession.” While it might seem minor, such a title change represents something very significant to the field of educational foundations.
Perhaps the writers of the proposed regulations are unaware that there is a field called the Foundations of Education (also referred to as the Social Foundations of Education), which is served, among others, by a national organization called the Council for Social Foundations of Education (CFSE). The CFSE has developed a set of professional standards purposed with informing state regulatory agencies on initial teacher certification requirements in the field of the foundations of education (http://csfeonline.org/about/csfe-standards/). Removing the wording of “Foundations of Education” from the professional studies requirement in the licensure regulations would, in effect, divorce this professional studies area from its disciplinary mooring. All professional studies requirements for licensure should be linked to an academic field/area because there is a need for a united professional voice to help articulate what happens in this course (especially when it concerns such a broad statement as “the historical, philosophical, and sociological foundations of education”). How the Commonwealth of Virginia titles a professional studies requirement (regardless of how an IHE ultimately titles the course) is important. By using the title “Foundations of Education,” the commonwealth is affirming the value of a particular professional field as well as helping an IHE understand who has the expertise to teach such courses (e.g. people who have graduated from PhD programs specializing in the Foundations of Education). The state regulations regarding teaching licensure are legal documents, and thus semantics DO matter.
Additionally, as relates to items 3 and 4 in the listing above, the disconnection of “foundations of education” as a title seems inconsistent with the wording that follows the title change in the proposed regulations. The Foundations of Education field deals directly with teaching students not only the historical, philosophical, and sociological foundations of education, but also with what it means to be an ethical professional of education who has examined issues of personal integrity, especially as related to how one successfully remains in the teaching field and how one equitably serves and understands our increasingly diverse student population (the field of multicultural education is a sub-field of the foundations of education). In essence, the foundations of education courses around the state are already doing what the new regulations seem, on the surface, to want.
Based on the fact above that the Foundations of Education is already doing what the proposed regulations seek for “The Teaching Profession” course to do, and that foundations scholars are the best equipped to carry out this mission, we assume that the proposed change to the title is merely a case of the writers of the regulation changes not fully understanding that the the terminology “Foundations of Education” is referencing a particular academic field/focus. We hope that our explanations above have illustrated how the term “Foundations of Education” is important, that such referencing determines how a university teacher preparation program best plans this course and finds qualified individuals to teach it, and thus needs to remain in the regulations.
8VAC20-542-90 - Online Instruction
8VAC20-542-90. This section describes recommendations for early/primary education, elementary education, and middle education teacher preparation that include “Understanding of the principles of online learning and online instructional strategies and the application of skills to deliver online instruction…” As worded, these recommendations are far too vague and may not be applicable to most teachers at this level. More specifically, “principles of online learning” are essentially no different than “principles of book learning” (or any other mediated environment). Modality does not meaningfully affect learning principles. Similarly, effective “online instructional strategies” are no different from effective classroom instructional strategies in general. The only difference is that a teacher may need to learn how to manipulate an online system, such as a Learning Management System (LMS), to implement and deliver a discussion board or provide access to a video lecture. The principles of good discussions, or effective presentations are the same whether =such strategies take place in the classroom or online. But if the intention is to promote the “…application of skills to deliver online” then a certain degree of specificity seems in order. Does “online” refer to synchronous or asynchronous technology and delivery (or both)? Should all teachers learn how to set up a course in an LMS? If so, which system….any? And most importantly, how relevant are these skills for the target teachers (early/primary education, elementary education, and middle education)?
From an instructional design perspective, “online” is just another form of technology-supported instruction. It might be best to remove the references to “online” and just keep the revised portion of the existing wording earlier in the paragraph:
“…selection and use of materials, including media and contemporary technologies.”
8VAC20-542-70 Annual Report Card
8VAC20-542-70. Educator preparation programs are required to submit the following reports annually: Biennial, Title II, PEDS, and the Annual CAEP Report. EPPs must also work annually toward reports that will be submitted for the CAEP self-study each seven years as well as for program-specific Specialized Professional Associations (SPAs). Most programs also have additional reporting requirements from their institutions and from regional accreditors, such as SACS. At what point will the strain of reporting be acknowledged as burdensome to the point that time is detracted from fulfilling our main purpose of preparing quality educators? Overlap already exists across many reports, and furthermore, the information that will be required in the proposed Annual Report Card is already available in the aforementioned reports. Therefore, we see a viable solution to be a more streamlined reporting system in which EPPs can submit information to multiple requestors in the same form. We would also suggest that rather than the addition of the proposed Annual Report Card, this information be made available to the public via the VDOE website.
8VAC20-542-50 Application of the Standards
8VAC20-542-50. This part of the regulations discusses the requirements for approval of education endorsement programs. In the proposed regulations, education endorsement programs may receive one of the following three ratings: approved, approved with stipulations, and approval denied. We are particularly concerned with the approval denied rating. According to the proposed regulations, an endorsement program may be denied approval if it does not have national accreditation or if its candidates’ passing rates on Board required licensure assessments fall below 80% for two consecutive bienniums.
We are very concerned about the unintended consequences of denying approval to an education endorsement program. Programs that are denied approval are not permitted to admit students for two years. Measures that are punitive do not result in program improvement nor do they motivate programs to take proactive corrections. It is extremely difficult for programs to rebound and come back after being gone for two years.
It is a critical time in education. We are desperately trying to address the declining number of teacher education candidates and the national teacher shortage. It is not the time to close education preparation programs.
As an alternative solution to closing programs for two years, we suggest placing programs on corrective plans. Programs could continue to serve students and the school divisions in their region while addressing any concerns. In addition, programs could be required to submit annual reports to document improvement and that demonstrate the support of their college and university.
Why We Need to Keep "Foundations of Education" Instead of "The Teaching Profession"
As a former public middle school math teacher in Virginia and, as a current associate professor of education at VCU I urge the board to reconsider the change in language in the propsoed teacher liencensure regulations from “Foundations of Education” to “The Teaching Profession.”
Foundations of Education is a well-developed field of study. Its coursework provides a unique and critically important component of teacher education, bringing perspective and meaning to teaching and fostering consideration of the role of public schools in our democracy. Study in Foundations of Education plays a key role in the development of reflective, professional, wise, and ultimately effective teachers for the Commonwealth because it places day-to-day classroom practice within its wider contexts, providing time and space for consideration of such activities in light of the overall aims of education. In other words, Foundations of Education’s focus on the “whys” of education—from societal goals to cultural and social trends affecting all aspects of education—helps teachers to carry out the “hows” effectively.
Removing the wording “Foundations of Education” from the professional studies requirement in the regulations would have the effect of cutting off this professional studies area from its disciplinary mooring. Professional studies requirements for licensure need to be linked to an academic field/area so that the coursework in teacher preparation is informed by research and discussion that comes from disciplinary communities. For example, Ethics and integrity are two areas included in the propsed category of “The Teaching Profession.” Ethics and integrity devoid of the focus on values and context that comes with study in the Foundations will likely lead to classes that fous on narrow compliance and a vision of a good teacher as one who merely does what she is told. It might seem counterintuitive, but replacing “Social Foundations” with the “Teaching Profesion” is a blow to the idea of teacher as professioanl, at least in any robust sense of the term “professional.”
In addition to being an educational researcher and a former teacher, I am also a parent of elementary school-aged children. When I think of the kinds of teachers I want for my children, I am certain that in addition to teachers with knoweldge and skills, they need reflective, passionate teachers who have thought long and hard about why they teach and how the work they do matters beyond the walls of the classroom, both for the children they teach and for wider society. Foundations of Education is a key component of the prepartion of these sorts of teachers.
Teacher licensure regulations
“Foundations of education” denotes a specific field of study with its own knowledge base and graduate programs. Well prepared faculty teach foundations of education courses and enhance teacher preparation by providing in-depth information about professional ethics and the meaning of education in a democracy. They teach preparing teachers the rich history of public education in our country and how to learn from the past, shaping meaningful and rich educational systems now and for the future. Foundations of Education’s focus on the “whys” of education—from societal goals to cultural and social trends affecting all aspects of education—is critical to effective implementation of the “hows” of classroom practice. All of that gets lost if the name “Foundations of education” is dropped and replaced by a term without history or disciplinary tradition, such as “the teaching profession.” It is not a wise move.
8VAC20-543-30. Application for new education endorsement programs.
The Deans and Directors of Virginia’s Colleges of Teacher Education met on October 8th, 2015 at the VACTE Fall Conference at Roanoke College to discuss the new regulations for approved programs. The suggestions being posted by the President of this organization are a result of this meeting.
With the new regulations for education programs, the matrices and other items for new programs should not be required. Suggestions as an alternative from this group included combining the reporting of revisions to programs with the Biennial Report and in a simpler format.
8VAC20-543-40. Standards for biennial approval of education endorsement programs.
The required 80% passing rate should only include program completers, and not program noncompleters. Also, please consider alternatives when negative program approval decisions are based on fewer than 10 program completers, especially when small numbers are reported for critical shortage areas.