Action | Comprehensive Revision of the Regulations Governing the Review and Approval of Education Programs in |
Stage | Proposed |
Comment Period | Ended on 10/31/2015 |
Proposed Regulations Governing the Review and Approval of Education Programs in Virginia (8VAC20-543-10 et seq.)
Public Comments Submitted on behalf of the Faculty and Staff in the College of Education at Virginia State University
October 30, 2015
As Interim Dean for the College of Education and Associate Vice-Provost for Graduate Programs at Virginia State University, I am pleased to submit comments regarding the proposed Regulations Governing the Review and Approval of Education Programs in Virginia.
John Dewey once said that "Education is not preparation for life; education is life itself". Thus we understand that all things including regulations must evolve in order to reach perfection.
Over the past several months, faculty and staff in the College of Education have engaged in a thorough review of the proposed regulations and have expressed their overall support of the intent of these regulations. Faculty collectively cited their appreciation for the addition of add-on endorsements in special education, mathematics specialist endorsement delineations, and removal of the cap on professional studies requirements. However, during their review process several key proposed requirements were identified that may significantly impact our College of Education’s ability to offer high quality educator preparation endorsement programs leading to licensure at the level desired.
Our children and youth are our most precious resources and the State Board of Education along with 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 preparation of highly qualified educators in the Commonwealth. The Board also is to be commended for its efforts to strengthen the educator preparation program review and approval process by proposing increased measures of accountability for Virginia’s colleges and universities desiring to offer such programs. Moreover, we sincerely appreciate the Board’s transparency and support during this review process and look forward to continuing our efforts to prepare highly qualified, caring and committed educators in the Commonwealth. Our overall goal is to continue to develop and maintain innovative pockets of excellence to help ensure the future of our children and youth.
The following are comments and suggestions compiled by faculty and staff for addressing the issues that may significantly impact Virginia State University’s capacity to offer educator preparation programs leading to licensure in Virginia.
8VAC20-543-10
Part I
Definitions
8VAC20-543-10. Definitions.
Rationale: With the addition of the Annual Report, the biennial report is considered redundant; the majority of the information is reported in the proposed Annual Report.
Rationale: This language aligns with the notion of assessing program endorsement areas on a triennial basis (somewhat similar to that required by Virginia’s PreK-12 school accreditation standards).
Rationale: This definition appears in the proposed Licensure Regulations for School Personnel; it stands to reason that it also be included in the proposed approved program regulations.
Rationale: This term is not clearly defined within the proposed approved program regulations. Consistency between language used in CAEP and Board of Education approved regulations is needed.
Comment: Term needs to be clearly defined by Department of Education personnel since some teachers holding provisional licenses also may be enrolled in an approved initial licensure program. The question then becomes, “Which is the initial license?” This also needs to be clarified for accuracy in Title 2 HEA and other federal and/or state reporting.
Rationale: This category needs to be clearly defined in the approved program regulations, particularly as it relates to the School counselor preK-12 endorsement (i.e., the expectation is clear in the proposed licensure regulations, but not referenced in the approved program regulations).
Comment: 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.”
Rationale: The proposed definition broadens the scope of opportunities for institutions to explore should the opportunity arise. The Department of Education can participate in partnership agreements with accrediting agencies as appropriate.
Rationale: This requirement is not clearly articulated in the proposed approved program regulations.
Rationale: Align language with other definitions and proposed revisions to 8VAC20-543-40 to 60.
Rationale: With the addition of the Annual Report, the biennial report is redundant; the majority of the information is reported in the proposed Annual Report.
Part II
Accreditation and Administering this Chapter
8VAC20-543-20. Accreditation and administering this chapter.
Rationale: Language is revised to align with proposed definition for “Accredited program” in 8VAC20-543-10 and text in 8VAC20-543-40 through 60.
Question: When will this take effect based on relationship to CAEP requirements and standards, especially as pertaining to the current Department of Education/CAEP schedule for approved professional education seven year reviews?
Rationale: Programs may be offered at both graduate and undergraduate levels of study.
Comment: Consider increasing the opportunity to submit requests to offer new endorsement programs to twice a year (i.e., during all and spring semesters). (Currently requests may be made only once a year in the spring.) Institutions will then have an opportunity to make requests in the fall and make revisions, if needed, by the spring semester deadline.
“B. As provided in § 22.1-298.2, the Board of Education shall prescribe an assessment of basic skills for individuals seeking entry into an approved education program and shall establish a minimum passing score for such assessment. The Board also may prescribe other requirements for admission to Virginia's approved education programs in its regulations….”
Administration and supervision and Support Personnel” represent approved education programs. However, no entry level assessment of basic skills is required. Language in the Code is neither explicit nor implicit regarding whether or not these endorsement areas are exempt from this requirement.
“a. Results on Board of Education prescribed entry-level assessments;”
Rationale: Same as that provided for the previous item.
“b. Evidence that supervised clinical experiences are continuous and systematic and comprised of early field experiences with a minimum of 10 weeks of full-time student teaching under the supervision with demonstrated effectiveness in the classroom...”
Part V
Application of Standards for Biennial Approval of Education Endorsement Programs
8VAC20-543-50. Application of the standards.
Part VI
Professional Education Program Accountability
Rationale: Changes provide consistency of language used throughout the document.
Part VII
Competencies for Endorsement Areas
Article 1
General Competencies
Comment: This section is unclear and needs some revising. For example, the language implies that all education endorsement programs must complete professional studies requirements. This is not the case for some of the Administration and Supervision and selected Support Personnel endorsement programs.
14. The program shall include at least 100 clock hours of internship and practicum experience in the preK-6 setting and 100 clock hours of internship and practicum experience in the grades 7-12 setting.