Call for Withdrawal of the Proposed 2015 Teacher Preparation Regulations under
Title II of the Higher Education Act
ATTACHMENT 1 TO AS-3201-15/APEP
ATTACHMENT 2 TO AS-3201-15/APEP
ATTACHMENT 3 TO AS-3201-15/APEP
RESOLVED: That the Academic Senate of the California State University (ASCSU) assert that the California State University (CSU), as the largest teacher preparation institution in the United States, already engages in robust evidence-based continuous improvement, including systematic and rigorous program review, accreditation by the California Commission on Teacher Credentialing (CTC), and has, for more than a decade, conducted annual surveys of teacher preparation graduates and their employers for the purpose of program improvement; and be it further
RESOLVED: That the ASCSU concur with the analysis submitted on behalf of the CSU by Dr. Beverly Young, Assistant Vice Chancellor for Academic Affairs, indicating that the proposed 2015 Federal Teacher Preparation Regulations under Title II of the Higher Education Act “represent an economic hardship due to their large cost burden” and that this cost burden would “adversely affect teacher preparation institutions nationally”; and be it further
RESOLVED: That the ASCSU recognize that many factors contribute to student success and failure, and that the proposed regulations pose an erroneous causal connection between students’ standardized test scores and the effectiveness of individual teachers and teacher preparation programs; and be it further
RESOLVED: That the ASCSU declare that the proposed regulations represent an unwarranted and detrimental intrusion in the states’ responsibility for teacher preparation and particularly jeopardize teacher candidates and programs serving high poverty and ethnically diverse communities; and be it further
RESOLVED: That the ASCSU acknowledge that the Commission on Teacher Credentialing, the California Department of Education, and the California State Board of Education have jointly signed a memorandum calling for the rejection of the proposed regulations; and be it further
RESOLVED: That the ASCSU call for the withdrawal of the proposed teacher preparation regulations; and be it further
RESOLVED: That the ASCSU distribute this resolution to the Secretary, United States Department of Education, CSU Chancellor, CSU Board of Trustees, CSU campus Provosts, CSU campus Presidents, CSU campus Senate Chairs, CSU Deans of Education, State Superintendent of Public Instruction, California Department of Education, Executive Director of the California State Board of Education, Student California Teachers Association, California State Student Association, California Teachers Association, Executive Director of the California Commission on Teacher Credentialing.
RATIONALE: The U.S. Department of Education, on December 3, 2014, proposed new regulations for teacher preparation programs under Title II of the Higher Education Act. Sixty days were provided for public comment. The proposed regulations require each state to assess and rate its teacher preparation programs every year. Teacher preparation programs would be given Performance Assessment Levels of Exceptional, Effective, At-Risk, and Low Performing. These ratings would be based upon student performance in K-12 schools. States would be required to provide low performing teacher preparation programs with technical assistance. If a teacher preparation program did not show improvement, it could lose state approval, state funding, and federal student financial aid.
According to a National Education Policy Center (NEPC) review,
“The rating is to be based on four indicators or performance outcomes, not all of which are weighted equally, and gives states some flexibility in determining the substance and the measurement of these outcomes. The four outcomes are:
1. Student learning outcomes (aggregate learning of the students in the classrooms of the graduates, consisting primarily of student growth or gains in test scores),
2. Employment outcomes (placement and retention rates of program graduates, in high-needs schools),
3. Survey outcomes (perceptions of the program by graduates and by employers), and
4. Accreditation (by the Council for the Accreditation of Educator Preparation [CAEP], or by the state with certain criteria as prescribed in the regulations, including curriculum content, clinical experiences, and entry/exit qualifications)” (Kumashiro, 2015).
In response to these proposed regulations, Dr. Beverly Young wrote two letters on behalf of the CSU. In the first letter, dated December 29, 2014, the CSU forcefully argued that the proposed regulations constitute significant time and cost burdens. Based on extensive and detailed cost estimates, the CSU calculated that the national costs would be at least eight times the U.S. Department estimated cost of $42 million over ten years. Such an unfunded mandate would jeopardize teacher preparation across the nation (see attached).
In the second letter, dated January 20, 2015, the CSU reiterated its cost objections and made substantive recommendations to the report card (ratings) component of the proposed regulations. There is particular concern for teacher candidates serving in low performing K-12 schools in low income and diverse communities. These candidates “will be adversely affected by the proposed regulations, [and] are likely to disproportionately be students in Historically Black Colleges and Universities and Hispanic Serving Institutions—the latter group including the majority of CSU Institutions.” These candidates and teachers will be in jeopardy of losing federal financial aid, such as Teacher Education Assistance for College and Higher Education (TEACH) grants.
On December 30, 2014, Tom Torlakson (State Superintendent of Public Instruction), Mary Vixie Sandy (Executive Director of the Commission on Teacher Credentialing), and Karen Stapf Walters (Executive Director of the California State Board of Education), jointly signed a memorandum rejecting the proposed regulations, “as the cost would not provide the stated benefits of either improved accountability or transparency and would impose an undue burden on the State of California” (see attached).
Finally, NEPC’s review reached five conclusions:
1. “The proposed regulations will likely burden institutions with cost and labor that is higher than estimated, which could constitute an expensive unfunded mandate.
2. The proposed regulations inaccurately conceptualize the impact and the preparedness of teachers as independent of larger systems. This happened in two ways:
(a) The proposed regulations inaccurately ascribe educational inequities and inadequacies to individual teachers, and in so doing, obscure paramount systemic flaws in education and society, and
(b) The proposed regulations define the goal of classroom readiness too narrowly.
3. The proposed regulations mandate the evaluation and weighting of outcomes that are narrow at best, and misleading at worst. [Because]
(a) The proposed regulations rely on a test-based accountability framework and on value-added measure for data analysis, which are scientifically inadequate and discredited processes for decision-making in education, and
(b) The proposed regulations rely on inaccurate causal explanations for placement and retention that may dissuade institutions from helping to place their graduates in high-needs schools, content areas, and communities.
4. The proposed regulations negatively affect federal funding for students in financial need, thereby restricting their access to the teaching profession, particularly for underrepresented groups.
5. Overall, the proposed regulations presume a narrow and diminished view of the purposes of public education.” (See attached)
California Department of Education, Commission on Teacher Credentialing, and State Board of Education Response to Title II Teacher Preparation Regulations
California State University Content Response to Proposed Title II Teacher Preparation Regulations
California State University Cost and Time Response to Proposed Title II Teacher Preparation Regulations
Proposed Title II Teacher Preparation Regulations:https://www.federalregister.gov/articles/2014/12/03/2014-28218/teacher-preparation-issues
NEPC’s Review of Proposed 2015 Federal Title II Teacher Preparation Regulations:http://nepc.colorado.edu/thinktank/review-proposed-teacher-preparation
Approved Unanimously – January 23, 2015