To whom it may concern: 

I am the CTE Supervisor for Page County Public Schools. Over the past few weeks, I have had the opportunity to review the "Career and Technical Education High-Quality Work-Based Learning Implementation Guide" that was distributed. After careful consideration, I would like to raise several concerns:

1. Limited completers available:  Rural communities do not have adequate funding for course completers in all areas that align with possible WBL experiences.  This requirement heavily discriminates against students in rural areas who already do not have access to the plethora of courses that students in urban centers have.  When rural schools do not have completers that align with a desired WBL experience, the closest complementing course should be selected.  In PCPS we use these WBL experiences to help students gain perspective on future industries that they do not have access to in our classrooms.  The new HQWBL policies will prevent rural students from gaining “real-world experience in their chosen field.”

2. Limited sequential courses available: Rural communities do not have adequate funding to offer a multitude of sequential courses for students that would align with possible WBL experiences.  Students entering 9th grade often enroll in a “foundational” course in a career cluster they have shown interest in and that aligns with their Academic and Career Plan.  In tenth grade students often take the completer course in the sequence they started in 9th grade.  However, rural communities often lack level three courses that continue to align with students' career interests for 11th or 12th grade, thereby eliminating the possibility of registering for a WBL experience since the experience needs to be taken in the same semester as the CTE course.    This requirement heavily discriminates against students in rural areas who already do not have access to sequential courses that students in urban centers have. This will prevent students from gaining “real-world experience in their chosen field.”

3. No high school credit:  In rural communities, student interest in WBL programs often relies on receiving a high school credit for their internship.  In urban areas, where WBL experiences are plentiful, and usually paid, students have a monetary incentive to take the course.  In contrast, most rural internships are unpaid.  With the new policy taking place, and without the incentive of a paid or credited internship, a student has little motivation to participate in a potentially impactful experience.  This limits student opportunities to gain “real-world experience in their chosen field.”

4. Courses to gain credit while working:     In poorer rural communities, many students work to help their families with rising living costs.  Previously, students could attend their WBL placement during school hours and still work after school.  Without the opportunity to earn a credit at an off-site WBL experience, students may be forced to take an on-site course to obtain the needed credit for graduation- which may be a course they may not even have an interest in.   For example, a  student that could have had a WBL placement in Optometry and would have received a WBL credit for the completion of the placement, will need to take a course they have no interest in, and will not benefit from in order to obtain the course credit they would have earned.  Students will not be able to gain invaluable experiences in their desired field.  Taking a high school credit away from this valuable learning experience is baffling.  Our state should be looking to incentivize students to get MORE training and hands on experiences in fields they are interested in.  This change hinders students from acquiring “real-world experience in their chosen field.”

5. Worksite Impact:  WBL coordinators in rural communities often have a small pool of businesses that are willing to partner with school systems.  Maintaining strong relationships with these businesses is crucial.  With the system of WBL experiences needing state approval that will likely take up a lengthy time, coordinators must plan placements early, risking changes that could negatively affect or cancel placements.  I also worry that if a WBL experience that is sought out by the school (which PCPS have always done), then rejected by the state will sour community businesses in regards to future placements (even if the future placement would fit the state mandates).  In rural areas, we may only have one or two businesses in an industry.  If those relationships are soured, then we are limiting the impact we can have on students and their career preparation.  This will prevent students from gaining “real-world experience in their chosen field.”

6. Participation in SBE can be built into the CTE course:  The state has set unrealistic and unachievable expectations in regards to School-Based Enterprises. Students trying to achieve this WBL experience would need to spend the entirety of the experience during afterschool hours.  A ninety hour requirement is unrealistic for students, as well as staff.  This practice is not practical and discriminates against several populations in the school system:

   1. Students who work after school to provide necessary income for their families are discriminated against.

   2. Students who participate in sports would be discriminated against for pursuing athletics.

   3. Students who participate in fine arts would be discriminated against for pursuing their passions.

   4. Students in remedial after-school programs would be discriminated against.  

           Some of the class time students spend working on their SBE projects should be allowed  

as their hours toward a SBE.  In strong quality CTE classes WBL experiences are meant

to compliment, not compete with each other.  If a student spends class time in culinary

class creating a menu, researching the ingredients and planning for a catering event,

why wouldn’t that time count as time in class (It obviously follows the curriculum) as well

as the WBL event- as it is a school based enterprise.  The state should not punish quality

programs for creating quality experiences in a “double dipping” manner.  Those quality

programs are fulfilling both requirements at the same time.

7. Licensed professionals:  Rural communities often have few businesses available to evaluate and guide SBE.  IF teachers are licensed professionals, they should qualify as the industry professional/postsecondary subject matter experts.  They have the same training as others considered an industry professional.  An outside perspective could be beneficial, but should not be required.  Constantly requesting industry professionals strains local businesses and the community- especialy rural communities that have a smaller pool to request from.  This will prevent students from gaining experience and gaining “real-world experience in their chosen field.”

8. Timing of approval:  The effect of the WBL implementation not being completed and approved prior to the school year is concerning.  I do not pretend to understand the politics behind the timing.  In general I believe the document went live to most CTE personnel in late July/early August (unless one was watching streaming of Dr. Williams presenting directly to the board).  This date is after internships for the 25-26 school year would have been set up by school districts.  I can find no documentation in the implementation guide OR any of the live streams that documented that WBL experiences (specifically Internships) would no longer carry a credit with them OR that the most current  (and still posted) HQWBL guide posted on the VDOE website would not be honored this school year.  The necessary documentation for this year’s WBL experiences still has not been released at the ¼ mark for the school year.  Potentially I may have a student that has completed ? of the school year, and around a hundred hours of WBL time have their experience rejected.  This is not acceptable.

Our school system has consistently and rigorously implemented our HQWBL programs. We conduct thorough evaluations of businesses, assessing their facilities and discussing potential work-based learning opportunities. We engage with students multiple times: initially to understand their placement preferences, and subsequently, alongside parents, to explain the program, discuss the placement, and review the training agreement and plan. We collaborate with school counselors to ensure students are enrolled in CTE courses that closely align with their placements. Quarterly, we observe the placements and engage with both employers and interns to discuss progress. We maintain bi-weekly records of student hours and conduct frequent check-ins with employers and interns to assess the placement's success. I am a strong advocate for our internship program, but the state of Virginia is handicapping this valuable opportunity from our students.

In conclusion, for the reasons listed above, I believe the new High-Quality Work-based Learning policies disadvantage rural students.  These policies will hinder the ability to achieve meaningful HQWBL experiences.  The state of Virginia has an obligation to provide a quality educational experience to all students.  While rural school systems may not have the ability to offer a full menu of CTE courses to their students, those same school systems have a resource that allows their students the opportunity to gain experience in a field they are interested in pursuing.  The challenge of offering rural students opportunities to gain impactful experience has been adversely affected by the Virginia Department of Education.

Sincerely,
Thomas Pitts

CTE Supervisor
Page County Public Schools

tpitts@pagecounty.k12.va.us

540-778-7282 Ext. 2609