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.
