As Associate Vice Provost for Graduate Programs, College of Graduate Programs, and Interim Dean for the College of Education at Virginia State University, I am pleased to submit comments regarding the proposed Licensure Regulations for School Personnel. The State Board of Education and personnel in the Virginia Department of Education are to be commended for their efforts to offer a set of regulations designed to help ensure the licensing of highly qualified educators in the Commonwealth.

Faculty and staff in the College of Education have expressed their overall support of the intent of these regulations and collectively cited their appreciation for the addition of add-on endorsements in special education and mathematics specialist endorsement delineations.

The following are comments and suggestions offered in response to the request for public comment.

8VAC20-23-10

Part I
Definitions

8VAC20-543-10. Definitions.

• Clearly define the following:

• Administration and Supervision preK-12;
• Support Personnel; and
• Pupil Personnel Services.

Rationale: There is inconsistency in the use of the title of this category between both sets of proposed regulations. For example, the category is referred to as “…Support Personnel” in Part VI and “Pupil Personnel Services…” in Part I of the proposed licensure regulations. The category used in Part VI of the approved program regulations is “Administration and Supervision and Support Personnel.”

• Add the following definitions:

• “Clinically based experiences “means experiences of sufficient depth, breadth, diversity, coherence, and duration to ensure that candidates demonstrate their developing effectiveness and positive impact on all students’ learning and development. Clinical experiences, including technology-enhanced learning opportunities, are structured to have multiple performance-based assessments at key points within the program to demonstrate candidates’ development of the knowledge, skills, and professional dispositions that are associated with a positive impact on the learning and development of all PreK-12 students. (CAEP, Standard 2.3)
• Use the definition listed in CAEP, Standard 2.3.

Rationale: This term is not clearly defined within both sets of proposed regulations. Consistency between regulations is needed.

• "Professional studies" means courses and other learning experiences designed to prepare candidates to demonstrate competence in the areas of human development and learning, curriculum and instruction, assessment of and for learning, classroom and behavior management, the teaching profession, reading, and supervised clinical experiences.(Institutions offering education endorsements under Administration and Supervision and Support Services do not need to include a professional studies component as part of their program competency offerings.)

Rationale: No definition for professional studies is included in this section.

8VAC20-23-130. Professional studies requirements.

Professional studies requirements for early/primary education, elementary education, and middle education: 21 semester hours. These requirements may be taught in integrated coursework or modules.

• Add the following:

• Professional studies coursework and methodology, including field experiences shall be designed for completion within a baccalaureate or graduate degree program.

Rationale: Programs may be offered at both undergraduate and graduate levels of study.

8VAC20-23-190. Professional studies requirements.

Professional studies requirements for adult education, preK-12 endorsements, and secondary grades 6-12 endorsements: 18 semester hours. Professional studies requirements for special education: 21 semester hours. These requirements may be taught in integrated coursework or modules.

• Add the following:

• Professional studies coursework and methodology, including field experiences shall be designed for completion within a baccalaureate or graduate degree program.

Rationale: Programs may be offered at both undergraduate and graduate levels of study.

Part VI
Licensure Regulations Governing Support Personnel

• Clearly define the following:

• Administration and Supervision preK-12;
• Support Personnel; and
• Pupil Personnel Services.

Rationale: There is inconsistency in the use of the title of this category between both sets of proposed regulations. For example, the category is referred to as “…Support Personnel” in Part VI and “Pupil Personnel Services…” in Part I of the proposed licensure regulations. The category used in Part VI of the approved program regulations is “Administration and Supervision and Support Personnel.”

8VAC20-23-670. School counselor preK-12.

Endorsement requirements.

1. Option I. The candidate must have:

a. Earned a master's degree from a regionally accredited college or university and completed an approved school counselor preparation program that shall include at least 100 clock hours of internship and practicum experiences in the preK-6 setting and 100 clock hours of internship and practicum experiences in the grades 7-12 setting; and

b. Two years of successful, full-time teaching experience or two years of successful, full-time experience in school counseling in a public or accredited nonpublic school. Two years of successful, full-time experience in school counseling in a public or accredited nonpublic school under a Provisional License may be accepted to meet this requirement.

2. Option II. The candidate must have:

a. Earned a master's degree from a regionally accredited college or university and completed an approved school counselor preparation program that shall include at least 100 clock hours of internship and practicum experiences in the preK-6 setting and 100 clock hours of internship and practicum experiences in the grades 7-12 setting;

b. Two years of successful, full-time teaching experience or two years of successful, full-time experience in school counseling in a public or accredited nonpublic school. Two years of successful, full-time experience in school counseling in a public or accredited nonpublic school under a nonrenewable Provisional License may be accepted to meet this requirement.

• Clarification is needed regarding the following:

• Option I. and Option II. School counselor preK-12 requirements in 8VAC20-23-670. School counselor preK-12 (Licensure Regulations for School Personnel) and 8VAC20-543-610. School counselor preK-12 requirements (Review and Approval of Education Programs in Virginia).

• There is a discrepancy between proposed licensure and approved program regulations regarding teaching experience, etc. requirements. Both Options of the proposed licensure regulations include requirements for completion of an earned master’s degree, completion of an approved school counselor preparation program, internship and practicum clock hours, and teaching experience, etc. However, the proposed approved program regulations cite only the internship and practicum clock hours needed with no mention of the teaching experience, etc. requirements. [Note: It is understood that an earned master’s degree from a State Board of Education approved School counselor preK-12 program is required.]

• Is the teaching experience, etc. (as cited in Option Ib. and Option IIb. Of 8VAC20-23-670 also required for 8VAC20-543-610, item #14?