• 8VAC20-543-20. Accreditation and administering this chapter E. Professional studies coursework and methodology, including field experiences required in this chapter shall be designed for completion within a baccalaureate degree program.

The proposed language referenced above suggests that approved teacher preparation programs must be designed as 4-year programs, and that 5-year programs would not be approved.  We oppose this proposal if it means that EPPs will no longer be able to offer initial licensure programs utilizing a 5th-year model which results in candidates earning a Master’s degree.

• 8VAC20-543-40. Standards for biennial approval of education endorsement programs.

b. Evidence that supervised clinical experiences are continuous and systematic and comprised of early field experience with a minimum of 10 weeks of full-time student teaching…

It’s not clear from the regulation whether a student teaching internship has to be at least 10 weeks in length or whether (2) eight-week placements (for a total of 16 weeks) will satisfy the requirement.  Please Clarify.

• 8VAC20-543-50. Application of the Standards.

C.4. The professional education program shall provide evidence of contributions to PreK-12 student achievement by candidates completing the program.

The state has a role/responsibility to provide EPPs information about where graduates are employed within Virginia’s school divisions.  Additionally, it should provide to the EPPs performance/annual evaluation data (particularly for Standard 7 Student Academic Progress of the Uniform Performance Standards and Evaluation Criteria for Teachers) so that EPPs may report/provide evidence of graduates’ contributions to PreK-12 student achievement.  The state should also share the responsibility for encouraging P-12 division and school administrators to cooperate fully with data gathering, completion of employer surveys, etc.

• 8VAC20-543-70. Annual Report Card

4. Number of candidates admitted in education endorsement programs who are in the top quartile of the college of university population.

The proposed requirement will present a resource demand on the university data management system. This is not information that the university data management system is currently designed to collect, particularly given the large number of majors represented by all teacher education candidates in our approved programs.

• 8VAC20-543-510, 520, 530: Special Education Add On Endorsements.

For each of the Special Education add-on endorsements, a competency should be added for management of instruction and behavior that specifies competency in providing positive behavioral supports based on functional assessment of behavior.

• 8VAC20-543-580, 590.  Mathematics specialist for elementary education.  Mathematics specialist for middle education

We support maintaining the current K-8 mathematics specialist license for two reasons. First, elementary teachers should have a detailed understanding of middle school mathematics and vice versa, providing a perspective on the learning trajectories students across multiple grade bands. Second, we would struggle to recruit enough candidates for a cohort in either grade band if the licensure were to be differentiated.

8VAC20-543-70. Annual Report Card

Annual report cards should not be required.  Educator preparation programs are already among the most aggressively regulated of all professions.  The reports that institutions must already submit to the Council for Accreditation of Educator Preparation (CAEP), SPAs in many instances, Title II, and SACS should more than satisfy what the proposed annual report cards are designed to accomplish.

8VAC20-543-40 Biennial Approval of Education Endorsement Programs

We oppose including the scores of program non-completers in the calculation for determining the 80% passing rate.

8VAC20-543-280 Proposed Engineering Education Program

We support adoption of this proposal.  Engineering is a critical feature of progressive P-12 STEM programs, and this proposal will help increase the number of teachers who are highly qualified in the area of engineering education.   

8VAC20-542-4590 & 9100 Early Childhood Special Education

We support the proposal which would allow those with Early Childhood Special Education licensure to add-on endorsement for 3- and 4-year-olds,.  Regarding ECE more generally, we also support the proposal which would allow emphasis at the undergraduate level on early childhood development as well as on content specific to P-3 licensure.  For the past two generations, research on the critical importance of the positive benefits that young children receive through exposure to best instructional ECE practices from highly qualified early childhood teachers has been compelling and unequivocal.

8VAC20-23-130 and 190  Foundations of Education

We support including instruction related to personal character, professional integrity, ethical decision-making, and professionalism in Foundations of Education coursework.  We also support continuing to include the study of social foundations as a foundational aspect of this instruction.  Changing "Foundations of Education" to "The Teaching Profession" seems arbitrary, and although we do not oppose it out of hand, we would appreciate understanding the rationale for this proposed change.