The new CAEP standards will be required beginning in 2016. Other commenters recommended that States should not be required to adhere to one national system because absent a floor for compliance purposes, States may build better accreditation systems. 50. With respect to the comment that the Department did not propose a plan for creating or implementing a measure of student achievement in content areas for which States do not have valid statewide achievement data, the regulations give States substantial flexibility in how they measure student achievement. For the remaining States, the Department estimates that they will require 2,940 hours for each State, for a total burden of 58,800 hours nationwide (2,940 hours multiplied by 20 States). Several commenters stated that the Department's estimates were too low. We also disagree with the claim that program level reporting as required under these regulations is inappropriate due to the variation in program size and structure across and within States. The teacher of record for a class that includes students with disabilities who require accommodations is responsible for the learning of those students, which may include ensuring the proper accommodations are provided. We discuss authorities related to LEA compliance in the discussion under 612.1. The Gateway to the Profession: Assessing Teacher Preparation Programs Based on Student Achievement. By maintaining the current reporting cycle, States will have a year (2016-2017) to design and implement a system. Discussion: Having withdrawn our proposal to require that student growth and employment outcomes in high-need schools be considered in significant part, the final regulations provide States with broad flexibility in how they weight different indicators of academic content knowledge and teaching skills in evaluating teacher preparation programs. They stated that the proposed definition was not clear regarding how States would report on recent program completers who are entering the classroom. Some commenters stated that the proposed regulations violate the Tenth Amendment to the U.S. Constitution. The Department estimates that approximately 50 programs will lose their State approval or financial support. Alternate estimates from commenters ranged from 56 hours to 3,900 hours. Upon further review, the Department also recognized an error in the NPRM, in which we initially stated that this review would be a one-time cost. This initial estimate also included determining what it meant for particular indicators to be included in significant part and what constituted satisfactory student learning outcomes, which are not included in the final regulations. Comments: One commenter believed that the Department should require States to notify K-12 school officials in the instance where a teacher preparation program student is involved in clinical practice at the school, noting that the K-12 school would be impacted by the loss of State support for the teacher preparation program. Students who are aware that a teacher preparation program is not approved by the State may reasonably choose not to enter that program. There is no reason student data should ever be captured in any survey results, even if commercially available software is used or teachers are required to complete a survey before they can access and verify their class rosters. See, for example information on these indicators reported by Tennessee and North Carolina: Report Card on the Effectiveness of Teacher Training Programs, Tennessee 2014 Report Card. However, we also believe that States will make every effort to reduce the burdens associated with this provision. Discussion: The regulations require States to use the indicators of academic content knowledge and teaching skills identified in 612.5(a), which may include VAM if a State chooses, to determine the performance level of each teacher preparation program, to report the data generated for each program, and to provide a list of which programs the State considers to be low-performing or at-risk of being low-performing. On the other hand, some commenters suggested that teacher preparation programs report the demographics and outcomes of enrolled teacher candidates by race and ethnicity. Given that institutions will simply be posting on their Web site the final IRC that was submitted to the Department, we assume that the document has already been reviewed by all necessary parties and that all included data have been verified prior to being submitted to the Department. This is one example, but it suggests that States can use data on student learning outcomes for graduates of teacher preparation programs to help these programs identify weaknesses and implement needed reforms in a reasonable amount of time. Commenters further expressed concerns that for some States, where the number of teachers a program produces per year is less than 25, the manual calculation that States would need to perform to combine programs to aggregate the number of students up to 25 so that the States would then report the assessment of program performance and information on indicators would not only be excessive, but may lead to significant inconsistencies across entities and from one year to the next. This would be true regardless of the programs' start date or whether the students have previous education credentials. Open for Comment, Economic Sanctions & Foreign Assets Control, Public Land Order No. On the use of VAM specifically, we reiterate that the regulations permit multiple ways of measuring student learning outcomes without use of VAM; if they use student growth, States are not required to use VAM. Retrieved from University of Washington Center for the Study of Teaching and Policy Web site: http://depts.washington.edu/ctpmail/PDFs/Shortage-RI-09-2003.pdf. We have determined that this provision is unnecessary and have deleted it. Under 612.5(a)(1), States are required to transmit information related to student learning outcomes for each teacher preparation program in the State. Washington, DC: U.S. Department of Education. documents in the last year, 29 While we encourage States to find ways to make information on a program's costs available to the public, we do not believe the information is sufficiently related to a program's level of performance to warrant the additional costs of requiring States to report it. The State must do so in a uniform and comprehensible manner, conforming to definitions and methods established by the Secretary. Similarly, section 207(b) of the HEA and 612.7(a) do not concern a program's loss of eligibility to participate in the TEACH Grant program pursuant to part 686, but rather the statutory prohibition on the award of title IV student aid to students enrolled in such a teacher preparation program. Numerous commenters argued that this estimate was low. Commenters suggested a maximum of three months from the time that the program is identified as low-performing because, while waiting for the assistance, and in the early stages of its implementation, the program will continue to produce teacher candidates of lower quality. Commenters also contended that student outcomes have not been shown to be correlated with, much less predictive of, good teaching; VAM scores and rankings can change substantially when a different model or test is used, and variation among teachers accounts for a small part of the variation in student test scores. For example, while commenters raised the issue in other contexts, one commenter noted that entrance and exit qualifications of teacher candidates have traditionally been the right of the institution to determine when considering requirements of State approval of teacher preparation programs. Whether the program, (i) Is administered by an entity accredited by an agency recognized by the Secretary for accreditation of professional teacher education programs; or. In this Issue, Documents The Sindh Government has already taken the first step toward rolling out the new policy. (C) Recent graduates who have enrolled in graduate school or entered military service. The school multiplies 600 by 1.6, and that result is 960. 29. The required reporting elements of the IRC principally concern admissions criteria, student characteristics, clinical preparation, numbers of teachers prepared, accreditation of the program, and the pass rates and scaled scores of teacher candidates on State teacher certification and licensure examinations. The regulations do not require States to submit documentation with the SRCs that supports their data collections; they only must submit the ultimate calculation for each program's indicator (and its weighting). These assertions contradict the evidence cited above that VAM does measure the causal effects of teachers on student achievement, and that teachers with high VAM scores also improve long-term student outcomes. ; Goldhaber, D., & Hansen, M. (2010). (i) For each teacher preparation program, data for each of the indicators identified in 612.5 for the most recent title II reporting year; (ii) The State's weighting of the different indicators in 612.5 for purposes of describing the State's assessment of program performance; and. For example, Tennessee employs some of the outcome measures that the regulations require, and reports that some teacher preparation programs consistently produce teachers with statistically significant student learning outcomes over multiple years. Regarding the recommendation that institutions report whether their teacher preparation programs have partnership agreements with alternative route providers, we note that section 205(a) of the HEA neither provides for IHEs to include this type of information in their IRCs nor authorizes the Secretary to add reporting elements to them. A program that loses its eligibility would be required to provide transitional support, if necessary, to students enrolled at the institution at the time of termination of financial support or withdrawal of approval to assist students in finding another teacher preparation program that is eligible to enroll students receiving title IV, HEA funds. While we stress that the regulations do not require or anticipate the use of VAM to calculate student learning outcomes or teacher evaluation measures, we offer the following summary of VAM in view of the significant amount of comments the Department received on the subject. We note that, as of July 1, 2016, CAEP has not been recognized by the Secretary for accreditation of teacher preparation programs. Comments: Multiple commenters provided examples of other indicators that may be predictive of a teacher's effect on student performance and requested the Department to include them. While the new regulations will require financial aid offices to track and review additional information with respect to student eligibility for TEACH Grants, we do not agree that this would result in greater risk of incorrect packaging of financial aid. High Poverty Schools and the Distribution of Teachers and Principals. Other commenters recommended including geography as an indicator of a school's need, arguing that, in their experience, high schools' urbanicity plays a significant role in determining student success. First, it will decrease the chance that one aberrational year of performance or any given cohort of program graduates (or program participants in the case of alternative route teacher preparation programs) has a disproportionate effect on a program's performance. . Other commenters suggested requiring each State to demand from its accredited programs a 65 percent retention rate after five years. (3) In the case of a student who receives a new TEACH Grant within three years of the date that any previous TEACH Grant service obligation or title IV loan was discharged due to a total and permanent disability in accordance with 686.42(b), 34 CFR 685.213(b)(4)(iii), 34 CFR 674.61(b)(3)(v), or 34 CFR 682.402(c)(3)(iv), acknowledges that he or she is once again subject to the terms of the previously discharged TEACH Grant agreement to serve or resumes repayment on the previously discharged loan in accordance with 34 CFR 685.213(b)(7), 674.61(b)(6), or 682.402(c)(6) before receiving the new grant. A number of commenters also stated that the regulations would result in a process of determining eligibility for Federal student aid that will vary by State. For the purposes of this definition, a cohort of novice teachers is determined by the first year in which they were identified as a novice teacher by the State. The changes to part 686 in these regulations have no measurable effect on the burden currently identified in the OMB Control Numbers 1845-0083 and 1845-0084. Hence, we trust that what States report in the SRCs will complement their own systems of assessing program performance. In that year, the State will determine how many members of the 2017-2018 cohort of novice teachers have been continuously employed through the current year. Another commenter recommended that the proposed regulations include what the commenter characterized as the exemption in the Family Educational Rights and Privacy Act (FERPA) (34 CFR 99.31 or 99.35) that allows for the re-disclosure of student-level data for the purposes of teacher preparation program accountability. Discussion: Section 207(a) of the HEA requires that a State identify programs as low-performing or at-risk of being low-performing, and report those programs in its SRC. Retrieved from: http://gao.gov/products/GAO-15-598. This may depend on the distribution of novice teachers prepared by teacher preparation programs throughout the LEAs and schools within each State and also on whether or not some of this information is available from existing sources such as surveys of recent graduates conducted by teacher preparation programs as part of their accreditation process. Changes: We have removed the words as a significant factor from the second sentence of the definition. Another commenter suggested the inclusion of residency programs in the definition. The Department originally estimated that State higher education authorities responsible for making State-level classifications of teacher preparation programs would require at least 35 hours to discuss methods for ensuring that meaningful differentiations are made in their classifications. The GAO report noted that half the States said current title II reporting system data were slightly useful, neither useful nor not useful, or not useful; over half the teacher preparation programs surveyed said the data were not useful in assessing their programs; and none of the surveyed school district staff said they used the data. States must report this on the SRC during the first year of implementation, the SRC could provide States with a drop-down list representing common rewards or consequences in use by early adopter States, and States can briefly describe those rewards or consequences not represented in the drop-down options. In particular, these commenters argued that their States would include more than the minimum number of participants we used for these estimates. As such, we continue to believe those estimates were appropriate for the average teacher. These costs would vary depending on the extent to which a State determines that it can measure these outcomes based on a sample of novice teachers and their employers. (2009). Other commenters urged that aggregation of data to elementary and secondary data sets would be more appropriate in States with a primarily post-baccalaureate teacher preparation model. As noted in the NPRM, the Department assumes this will happen rarely and that the title IV, HEA funds involved would be shifted to other programs. (Working Paper 63). But we strongly believe that, except in rare circumstances, States will have enough data on employment outcomes for each program, based on the numbers of recent graduates who take teaching positions in the State, to use as an indicator of the program's performance. Finally, we agree that the regulation should clarify that the school board representatives whom a State must include in its consultative group of stakeholders are those of local school boards. We recognize that many factors influence student achievement. Table 208.20. Commenters expressed concern that the proposed regulations would shift this responsibility from the State to the Federal government, and stated that teacher preparation programs could be caught in limbo. We do not see how States can do this without somehow providing some form of weight to each of the indicators they use. Some commenters felt Start Printed Page 75571that the regulations should offer alternatives or otherwise address what happens if an institution is unable to secure sufficient survey responses. This may be because most licensure tests were designed to measure the knowledge and skills of prospective teachers but not necessarily to predict classroom effectiveness. (2018), Inequitable Opportunity to Learn: Student Access to Certified and Experienced Teachers. To the extent that they do not already do so, nothing in the regulations imposes additional accessibility requirements beyond those in the Rehabilitation Act of 1973, as amended, or the ADA. D. Boyd, P. Grossman, H. Lankford, S. Loeb, & J. Wyckoff. In fact, many States have worked or are working with CAEP on partnerships to align standards, data collection, and processes. (Working Paper No. Commenters noted that, in Texas, alternate route participants may be issued a probationary certificate that allows the participants to be employed as teachers of record for a period of up to three years while they are completing the requirements for a standard certificate. We believe that our cost estimates, as revised to respond to public comment, are accurate. , the American Educational Research Association, and the National Academy of Education. Discussion: We expect that States will ensure the validity and reliability of survey outcomes, including how to address responder bias and avoid political manipulation and like problems when they establish their procedures for assessing and reporting the performance of each teacher preparation program with a representative group of stakeholders, as is required under 612.4(c)(1)(i). Commenters also claimed that the HEA does not authorize the Department to require States, in identifying low-performing or at-risk teacher preparation programs, to use those indicators of academic content knowledge and teaching skills as would be required under 612.6. These activities included making changes in State laws where those laws prohibited the sharing of data between State entities responsible for teacher certification and the State educational agency. Note that additional requirements Other commenters argued that this provision inserts the Federal government into the State program approval process by mandating specific requirements that a State must consider when approving teacher preparation programs within its jurisdiction. [17] At the five percent low-performing or at-risk rate assumed in the TEACH Grants portion Start Printed Page 75605of the Cost, Benefits, and Transfers section of the Regulatory Impact Analysis, TEACH Grant revenues would be reduced by approximately $2.1 million at programs at private not-for-profit entities in the initial year the regulations are in effect and a lesser amount after that. The proposed regulations would not have required separate accreditation of each individual program offered by an entity, but we have revised 612.5(a)(4)(i) to better reflect this intent. 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