Fairfax County Public Schools (FCPS) appreciates the opportunity to provide you with comments on some of the proposed changes to the Licensure Regulations for School Personnel.  We would like to express support regarding the following:

• The extension of the International Educators license from three to five years (8VAC20-23-10)

• The additional flexibility in the Elementary Education endorsements allowing more of the requirements to be met by passing rigorous content tests (8VAC20-23-150 & 8VAC20-23-160)

• The removal of the Test of English as a Foreign Language (TOEFL) requirement in the area of the Foreign Language endorsement (8 VAC 23 360).

• The proposed change to allow individuals that hold the Special Education Early Childhood endorsement the option to add-on the ‘Early childhood for three-year-olds and four-year-olds’ endorsement to their existing license (8VAC20-23-140 1)

• The proposed new add-on Special Ed – General Curriculum endorsement areas; these new options will allow current license holders with the required general ed endorsement areas a more streamlined and defined route to adding-on the Special Ed – General Curriculum endorsement area that’s aligned to the grade levels that they are already licensed to teach. 8VAC20-23-560; 8VAC20-23-570; and 8VAC20-23-580

We ask that the Board consider additional flexibility, and perhaps a new endorsement area, to satisfy the need for highly qualified immersion teachers due to anticipated rapid growth of the popular Language Immersion Programs around the Commonwealth. In immersion programs, students spend part of the instructional day learning in a language other than English and thereby acquiring that language.  FCPS currently offers Immersion programs in a growing number of schools with plans to expand our Two-way and World Language Immersion offerings in order to better serve a changing student population and meet the interests and demands for world language education in our community expressed through the FCPS Portrait of the Graduate.

The rapid growth in immersion programs nationwide has caused teacher openings in FCPS that are extremely hard to fill, as the current single path to serve as an immersion educator via an Elementary Education endorsement is making it too steep in time and cost for our area to still be an attractive destination for Dual Language/Immersion teachers. We advocate for the addition of a new Immersion Education endorsement, with a requirement for advanced proficiency in a world language and targeted coursework (that can also be met through assessment) to ensure quality immersion education. An Immersion Education endorsement would give a teacher highly qualified status to serve as a classroom teacher and would enable us to provide a more direct path to teaching for more candidates, especially those who are career switchers, move from Puerto Rico and other states. Utah, Rhode Island, and Illinois are among the states that have created a specific endorsement for Dual Language/Immersion Education in the past few years in order to respond to the growing demand for these effective programs across their states.  As Immersion Programs are expanding to include more elementary schools and languages across the Commonwealth, a new licensure path has become critical to staffing and continued success of these popular and effective programs.

In addition, we have concerns to share in the following specific areas:

8VAC20-23-40 B Additional clarification would be helpful regarding what would suffice as “Documentation must be submitted to verify the school’s status as a public or an accredited nonpublic school” for individuals that are seeking the licensure assessment exemption via reciprocity. Would the current VDOE “Report on Experience Form” suffice?

8VAC20-23-50 A.1 and 8VAC20-23-90 C FCPS does not support the proposed change to a two year provisional license as it will create a significant burden on VDOE Licensure Specialists as well as increase the processing and response time from the VDOE for licensure actions/requests.    These changes would also force most school districts to change their current “Non-Renewal” procedures, which currently align with the 3-year validity period of the provisional license and the tenure/continuing contract schedule in Virginia.

8VAC-23-50 4 & 4.a  We oppose the proposals to place the burden on the employing Virginia educational agency to ensure that the credentials issues by the US Military are active during the period the individual is teaching.  The employing VA educational agency should ONLY be required to ensure that a teacher of record holds the appropriate VDOE-issued license and endorsement area. The credentials issued by the US Military, or the license (NON-VDOE related) issued by the appropriate board for the occupational program area are already requirements for obtaining a renewable Technical Professional License; therefore, employing VA educational agency should NOT be responsible for ensuring that such non-VDOE issued credentials or licenses be active during the period the individual is teaching. This would be very challenging for employing VA educational agencies to track especially since the expired non-VDOE issued credential or license would have no direct impact on the validity period of the Technical Professional License or the teacher’s “Highly Qualified” status.

One solution would be to issue the VDOE Technical Professional License based on, and in alignment with, the validity period of the credentials issued by the US Military, or the license issued by the appropriate board for the occupational program area.   Another solution would be to simply make one condition for renewing the Technical Professional License be that the license holder must present the required non-VDOE issued credentials or licenses in order to renew the Technical Professional License. While this may not be the most ideal option, it will ensure that the teacher will have an active and valid credential issued by the US Military, or license issued by the appropriate board for the occupational program area at least every 5 years.

8VAC20-23-90 B.1.c  Please consider changing “c” under this section to read ‘need to complete an allowable portion of the requirements for the endorsement area’ and if possible, offer clarification on what the VDOE would consider allowable. Such as ‘in general, the candidate must be within 6 credits of meeting the requirements for the endorsement.’

8VAC20-23-90 C.1  FCPS continues to support this route to the Provisional (Special Education) License and do not believe that this option should be limited only to individuals that already hold a valid Collegiate Professional or Postgraduate Professional License.

8VAC20-23-90 C.2  We are very concerned about the potential impact of the proposed change to require individuals who have never held a license to complete 9 semester hours of courses in order to qualify for a Provisional (Special Education) License.  Such an increase would create an extreme burden on many VA school divisions and limit their ability to hire contracted teachers into what is already a critical shortage area.  One related negative impact would be increased reliance on substitute teachers due to the dearth of candidates that would be eligible for obtaining a Provisional (Special Education) License with the increase to 9 semester hours.

Another concern is that the proposed revision no longer requires that the candidate complete a “Foundations” course as a prerequisite for the Provisional (Special Education) License. The Foundations course is typically an introductory course and addresses the historical, ethical, and legal aspects of working with Special Education populations.

8VAC20-23-130 and 8VAC20-23-190 FCPS is concerned that increasing the Professional Studies requirement from 18 semester hours to 21 semester hours for these specific endorsement areas would make it much more difficult for individuals to complete and meet all Provisional Licensure requirements within the 3 year validity period.

8VAC20-23-130 4  FCPS believes that current regulations are sufficient in requiring that assessment competencies be met via a “Curriculum and Instructional Procedures” course and do not support this added Professional Studies requirement.

8VAC20-23-130 5  FCPS is concerned that the proposed change of the “Foundations of Education” requirement to “The Teaching Profession” would only serve to create confusion and difficulty for candidates seeking courses to meet this proposed requirement. 

8 VAC-20-23-330 We currently have a critical need for technology and engineering education teachers.  However, we are very concerned that the approval of the stand-alone Engineering Endorsement would only serve to create a new critical need area, particularly if it precluded technology education teachers from teaching engineering at the secondary level.  The proposed engineering endorsement appears to duplicate content that has long been covered and continues to be a part of technology education.  It is our understanding that the proposed endorsement was developed without the inclusion of Virginia’s technology and engineering education professionals.  This only perpetuates a “silo” approach to STEM education and runs counter to the sentiments of SJR308 (2011) that specified engineering education within Virginia is the shared responsibility of science, technology, and mathematics.

Thank you for the opportunity to comment and for your consideration.