Response to Proposed Federal Teacher Preparation Regulations

Response to proposed Federal Regulations for Teacher Preparation

Submitted to regulations.gov on 1/30/15 

I am writing to express my opposition to the Department of Education's proposed regulations for teacher preparation programs. While there are undoubtedly a number of people providing far more detail about each of the aspects I address below, these are some of the key elements of the bill that are particularly problematic from my perspective as a teacher educator and as an educational researcher.

1. The instruments and staffing necessary to adequately meet the mandates for reporting set forth in the proposed regulations will detract from our academic mission. Universities simply do not have the financial resources to hire personnel to support this kind of data collection, analysis and record keeping. This means that existing personnel will be tasked with the job of reporting. The time that takes will come directly out of their other responsibilities which are all to the programs and students that we serve.

2. Related to my point above, we already have high levels of reporting and accountability. Teacher preparation programs must show that they are in compliance with all licensure regulations laid out by the states they serve, teacher preparation programs must remain accredited through appropriate professional bodies, and teacher preparation programs must provide accountability data to the Department of Education as well as state entities because of the funding we receive. Teacher preparation is already held to levels of accountability that are high and ongoing. Additional oversight by the federal government seems both like overkill and unnecessary.

3. The proposed regulations do not account for the simple reality that teachers are part of a large, complex social system. As such, they are only one factor that shapes student learning. There are many factors at work in the students' lives that are both out of the control of the teacher and completely undermining of any efforts a teacher makes. Therefore, assuming that the only ways to demonstrate proficiency are though the test scores of students is an extremely limited viewpoint. I do not have space here to elaborate, but there are so many stories of success I've seen that don't show up in the test results.

4. The districts most likely to have low test scores are the same ones with the highest need for teachers - and the highest teacher turnover rates. The new regulations punish universities like mine that specifically try to serve that population. Many of our graduates are excellent teachers with low test scores - but they are bringing rigor, stability, and compassion to urban areas. Tying Teach grant availability to test scores will hurt our ability to continue developing strong teachers who come out of and go into high-needs areas - because we serve primarily high-needs areas, we may not be able to attain high ratings (because our graduates' students have low scores), which will lose our access to those grants, which will become a barrier to the people who can help being able to access the courses they need.

5. Value added modeling, such as that proposed in these regulations, is a deeply flawed statistical approach. The American Statistical Association has written a thoughtful and informed response to value-added modeling that clearly demonstrates that VAM is not an appropriate tool for measuring teacher (or teacher preparation program) effectiveness. If the experts who develop the models believe they are being used incorrectly, it is unconscionable that the DoE would propose to use VAM for measuring program effectiveness.

6. The very development of these regulations undermines the dramatic efforts of teacher education over the past decades to improve itself. The regulations do not take into consideration that most programs now are accredited through agencies that hold them to research-based standards for teacher preparation. The regulations do not acknowledge that teacher preparation programs are engaged in continuous improvement plans that require the collection and analysis of data about ourselves and our graduates every year and to make program revisions based on those data. The regulations do not offer any acknowledgement that teacher education has become increasingly more rigor through engagement of the professional engaged in it leading their own development. And, by all research measures, teacher quality is improving as a result of these efforts.

In short, the federal regulations are unfair, unwarranted, and unneeded. The field needs to be allowed to continue its research-based, continuous improvement plan that is already producing better teachers than ever. The field needs to remain self-regulating. And, the federal government needs to refrain from placing additional reporting requirements that detract attention from the main goal: preparing world-class teachers.