Establishment of clinically rich graduate level teacher preparation program.
Purpose:
Establishes program registration standards for pilot program and authorizes certain non-collegiate institutions to participate.
Text or summary was published
in the May 5, 2010 issue of the Register, I.D. No. EDU-18-10-00016-P.
Final rule as compared with last published rule:
No changes.
Text of rule and any required statements and analyses may be obtained from:
Christine Moore, NYS Education Department, 89 Washington Avenue, Room 148, Albany, NY 12234, (518) 473-8296, email: cmoore@mail.nysed.gov
Assessment of Public Comment
Since publication of a Notice of Proposed Rule Making in the State Register on May 5, 2010, the State Education Department received comments about the proposed amendments relating to the establishment of clinically rich teacher preparation pilot programs. The following is a summary of the comments and the responses of the Education Department.
1. COMMENT: Many oppose the Model B pilot because it differs substantially from a traditional teacher residency program.
DEPARTMENT RESPONSE: The Department supports expanding the definition of teacher residencies to develop additional pathways to attract teachers for high need shortage areas. The Model B pilot is similar to the Transitional B program that has been in existence for 10 years.
2. COMMENT: A few expressed concern over the collection and use of student achievement data.
DEPARTMENT RESPONSE: The Department is currently developing the Request for Proposal (RFP) for pilot programs and will explain more fully how student data will be collected and used in these pilot programs.
3. COMMENT: A few opposed the 30 credit content requirement as an admission standard and suggested the use of competency examinations in lieu of this requirement.
DEPARTMENT RESPONSE: Colleges have historically used rigorous examinations to meet specific course requirements. An applicant for this pilot may identify whether such an exam approach will be taken, and to what extent. The Blue Ribbon Commission will determine the appropriateness of this approach.
4. COMMENT: A few were opposed to the doctoral and terminal degrees requirement of faculty.
DEPARTMENT RESPONSE: To ensure the high quality of instruction of candidates, the Department believes that the current rigorous faculty regulations ensure the highest caliber of program instructors.
5. COMMENT: Many were concerned that non collegiate institutions could not offer the depth and breadth of preparation taught at Institutions of Higher Education (IHE).
DEPARTMENT RESPONSE: In order to ensure that selected programs offer a clinically rich teacher preparation program of the high quality, the Board of Regents will establish a Blue Ribbon Commission, comprised of highly renowned teacher educators, to evaluate all applications. The Commission will recommend those applicants that should be authorized to establish clinically rich teacher preparation programs to the Board of Regents, from collegiate and non-collegiate providers or in combination. The goal is to ensure a rigorous programmatic review and to select only the highest quality providers to assist in the preparation of teachers for high need schools. Emphasis will be on educating teachers in a holistic educational approach for the teaching profession, not in training teachers. IHEs have historically prepared teachers with this emphasis in educating teachers and the Department will require all providers to meet the registration standards for these pilot programs. For non-collegiate providers, the Regents will only award the master's degree if the institution has demonstrated that candidates have successfully completed all elements of the program authorized by the Regents. The Department encourages partnerships and recognizes the value of such collaborations between potential providers. Partnerships between collegiate and non-collegiate providers will be encouraged in the RFP.
6. COMMENT: A few were concerned with the scope of the clinical experiences and the possibly creating a two tier system benefiting the staffing of wealthy districts.
DEPARTMENT RESPONSE: The regulations require collaboration with only high need schools for their clinical experiences. This pilot program will not be a factor in creating a two tier system.
7. COMMENT: Some expressed that the regulations were hastily written and not research based.
DEPARTMENT RESPONSE: Through research in current clinically based teacher residency programs was completed prior to the thoughtfully drafting regulations.
8. COMMENT: Concern was expressed about the negative impact the pilot programs would have on programs already in existence.
DEPARTMENT RESPONSE: The pilots are intended for a very specific, small cohort of candidates committed to teaching in high need schools upon graduation. There should be no significant impact.
9. COMMENT: A few expressed concerns over lack of experience of non-collegiate entities providing such programs and of the role and timeframe of the Blue Ribbon Commission.
DEPARTMENT RESPONSE: The Blue Ribbon Commission will be provided adequate time and resources to thoroughly evaluate all applications for the pilot programs.
10. COMMENT: Concern was expressed with the lack of definition for the terms used in the regulations specific to the pilots.
DEPARTMENT RESPONSE: All terms specific to the pilots are defined in the regulations and will be further developed in the RFP.
11. COMMENT: There is need for more specific data on regional supply and demand in New York State.
DEPARTMENT RESPONSE: The Department is progressing with the State's initiative for developing a data collection system that will incorporate regional data on teacher supply and demand across the State.
12. COMMENT: There is a preference for Middle States accreditation over NCATE, TEAC, and RATE because Middle States is the entity that accredits all master degree programs. Other commenters questioned the timeframe for accreditation in this pilot program.
DEPARTMENT RESPONSE: The proposed programs will be focused exclusively for preparing candidates to become effective teachers and the regulation specifies that teacher preparation programs must achieve accreditation through a nationally recognize program accreditor within seven years of program registration. Middle States, is an institutional accreditor.
13. COMMENT: A master's degree is an academic degree and should be granted solely by IHE.
DEPARTMENT RESPONSE: The Regents will assure the quality of the program through a rigorous selection process by the Blue Ribbon Commission. and the program will be held to rigorous program registration standards, including prescribed curriculum and faculty requirements and at least one year of mentored experience in the classroom. Only graduates of such programs may be awarded an M.A.T degree by the Regents. The provider's faculty must also ensure that the graduate level work required to award the degree is sufficiently rigorous.
14. COMMENT: Organizations should have an established record of improving student achievement.
DEPARTMENT RESPONSE: The establishment of the Blue Ribbon Commission ensures that all applications are held to the same standards as traditional teacher preparation programs and demonstrate a proven history of improving student achievement.
15. COMMENT: Concern was expressed that graduates of these pilots will have difficulty being admitted into doctoral programs because their master's degrees were awarded by the Board of Regents (BOR) and that there is a conflict of interest with the BOR awarding these degrees.
DEPARTMENT RESPONSE: Education Law § 208 authorizes the Board of Regents to award degrees and the Board currently uses this authority to award degrees for graduates of institutions operating under a provisional charter and institution that have closed. The Blue Ribbon Commission, has been charged with ensuring that those applying through the RFP process meet the established criteria, including extensive quality assurance processes.
16. COMMENT: Concern was expressed that there was no dialogue between New York State and stakeholders.
DEPARTMENT RESPONSE: For the purposes of these pilots, as required under the State Administrative Procedures Act, the Department has engaged the public through a 45-day public comment period. The Department has received and reviewed comments on the regulations from higher education institutions. The Commissioner has also reached out to, and met with Deans from CUNY, SUNY, and independent colleges, as well as P-12 Educators. The Department will continue to have ongoing discussions with stakeholders to explore ideas for improving education in high need schools and shortage areas throughout the State.
17. COMMENT: Concern was expressed that the four year commitment by graduates would have a negative impact on provider programs and this should include a financial incentive.
DEPARTMENT RESPONSE: We encourage providers to provide financial incentives. The commitment of graduates is based on research to ensure the retention of qualified teachers and will be contingent upon the demand for teachers in high need schools.
18. COMMENT: One commenter expressed concern that the research indicates the failure of alternately prepared teachers.
DEPARTMENT RESPONSE: The Department supports continuing research in this area.
19. COMMENT: There has been no systematic study of the impact of the existing accreditation system.
DEPARTMENT RESPONSE: The Department continues to assess teacher preparation outcomes data, such as performance on state certification examinations. The proposed clinically rich preparation programs represent a pilot, one purpose of which is to gather data on the effectiveness of this alternative model.
20. COMMENT: New York State Education Department should differentiate the major requirements for teacher candidates in the 5-9 and 7-12 teacher education programs.
DEPARTMENT RESPONSE: Section 52.21(b) of the Regulations of the Commissioner of Education specifies the program registration requirements for certification in these content areas.
21. COMMENT: It is not feasible for program faculty to be able to observe a teacher candidate twice a month.
DEPARTMENT RESPONSE: Many teacher preparation programs meet or exceed this level of supervision to ensure that candidates are supported and mentored throughout their program.
22. COMMENT: Concern was expressed that there will be massive teacher layoffs in Fall 2010.
DEPARTMENT RESPONSE: The focus of the pilot programs will be on high need schools and shortage areas. Historically these positions are hard to fill and, with current teachers looking for positions, a deeper pool of potential hires will be available for STEM and other high need subjects in our high need schools. The proposed amendment should not have any significant impact on teacher layoffs.
23. COMMENT: Concern was expressed that an IHE's ability to prepare teachers through an alternate pathway will be diluted thus creating additional competition.
DEPARTMENT RESPONSE: The Department appreciates that, when the State was in need of preparing teachers through an expedited pathway to address teacher shortages in high need areas, IHEs met this demand by successfully preparing teachers through an alternate certification pathway. The continuing demand for teachers specifically prepared to be effective in high need areas indicates the need for innovative programs to address this specific need. The Blue Ribbon Commission will choose those providers for the pilots that, according to the standards identified in the RFP and Regulation, provide evidence of their ability to successfully meet the identified need. IHEs and non-IHE providers are able to compete for the pilot. The nature of these intense and highly focused programs is not anticipated to impact any successful IHE programs already in place.
24. COMMENT: Concern was expressed that non-collegiate providers will not be able to meet the needs of all student populations.
DEPARTMENT RESPONSE: Providers will be expected to provide evidence that they will be able to meet the needs of all student populations, and this criterion will be addressed in the RFP and the Blue Ribbon Commission will be selecting only those providers that can meet the needs of such students. Only providers that can demonstrate a proven history of improving student achievement for all students including Students with Disabilities and English language learners will be considered for the pilots.
25. COMMENT: Concern was expressed that it would be more efficient to make changes in established programs rather than develop alternative programs.
DEPARTMENT RESPONSE: The Regents' number one concern is the education of the children in New York State. The Department believes that these clinically rich pilot programs will address the student population in the State most affected by poverty by preparing highly effective teachers for high need schools. The Blue Ribbon Commission will ensure that the highest caliber of providers will be chosen to prepare teachers in these schools. Research will be conducted on the pilots in order to replicate the best practices in preparing teachers for high need areas.
26. COMMENT: An assessment of the quality and effectiveness of the pilot programs need to be assessed.
DEPARTMENT RESPONSE: The Department anticipates developing a RFP for the purpose of analyzing the impact on student achievement and teacher preparation through these pilots. Results of this research will be made public.
27. COMMENT: One commenter expressed concern that the regulations were done as an emergency rulemaking, as opposed to the usual rulemaking procedures.
DEPARTMENT RESPONSE: Emergency action was needed in order to ensure the timely implementation of the provisions of the proposed amendment to provide stakeholders with timely notice of the eligibility requirements and the program registration requirements for the pilot program so that they might complete the competitive bidding process for available funding before the 2011-2012 school year.
