All Region IV school divisions want to hire the most highly qualified special education teachers. However, Special Education is a critical shortage area and the reality is that we just don’t have the applicants to fill the number of special education vacancies. This change will only result in having more substitute teachers placed in special education classrooms throughout Virginia. Additionally, the 9 semester hours that would need to be completed in order to be issued a provisional license, are courses that have become blended into Approved Programs. It will be very difficult for licensure specialists to determine if course work meets the specific content requirements as set forth by the VDOE Licensure Regulations. As an alternative, we would like to recommend changing the regulation to show completion of the 3 semester hours currently required and providing verification of enrollment in an approved licensure program.