Items of Concern:

RE:  Proposed regulation: The education endorsement program’s candidate passing rates, reported by percentages, shall not fall below 80 percent biennially for program completers and program non-completers.

1. If students do not pass licensure exams and self-select to change majors, drop out of the university, or transfer this should not be held against a licensure program.  Most of these decisions are not within the control of the teacher licensure program. 
2.  If the idea is that programs should provide support and remediation for those who are in the program but struggling to pass licensure exams and should not be dismissed from the program, then perhaps differing wording would be appropriate:
   1. Perhaps – something to the effect (Persons admitted to a teacher education program are considered non-completers if the education program officially releases them in writing based on failure to pass licensure exams)

RE:  Addition of Annual Report Card:

1.  With all the reporting that Teacher Education programs need to complete for their state, their university, accrediting agency, federal government, etc., why can’t these be combined in some way or have the data taken from other reports, i.e. Title II??

2.  Another reporting requirement takes away from universities focusing on curriculum and instruction for the benefit of our future teachers. 

3. The language of “and other data as requested” is misleading and too open-ended and should be deleted.

RE:  8VAC20-543-500. Special education general curriculum K-12.

… The candidate also shall complete the competencies in at least one of the endorsement areas of Special Education General Curriculum K-12, in addition to those required under professional studies in 8VAC40-543-140, including reading and languageacquisition. 

Clarify “endorsement area”.  Does this mean specialization area as earlier defined - 8VAC20-543-80. Competencies and requirements for endorsement areas. –  F.  Candidates seeking an endorsement in special education- general curriculum K-12 must have one area of specialization in English, history and social sciences, mathematics, or science with 12-15 semester hours in the specialization area.

RE:  8VAC20-543-70

#4.  What data is used to determine top quartile?  High school gpa, SAT – what about graduate students, career switchers, students coming from community college who do not take SAT?