A controversial federal proposal to improve monitoring of teacher-preparation programs had drawn more than 2,300 public comments by the end of January, with the overwhelmingly critical feedback reflecting coordinated opposition from higher education officials and assorted policy groups.
“It’s not just teacher prep that’s concerned about this. It’s the teaching profession. And it’s higher education,” said Deborah Koolbeck, the director of government relations for the Washington-based American Association of Colleges for Teacher Education. “Is teacher prep the test run for the ratings of higher education overall?”
The proposed rules, issued under the Higher Education Act, were released by the U.S. Department of Education in November, some two years after negotiations with representatives from various types of colleges broke down over the regulations’ shape and scope. Among other provisions, the rules would require states to use measures such as surveys of school districts, teacher-employment data, and student-achievement results to classify each preparation program in one of four categories.
Strong Opposition
The lowest-rated would be barred from offering federal grants of up to $4,000 a year to help pay for teacher education under the teach program. The comment period on the proposal closed Feb. 2.
A review of the comments submitted through Jan. 29 showed several main themes among the complaints, including that the rules would:
• Prioritize student test scores, potentially leading to deleterious effects on teacher-preparation coursework;
• Apply punitive sanctions to programs rather than support them;
• Expand federal meddling in state affairs;
• Prescribe flawed measures that would yield biased results; and
• Cost far more to implement than the $42 million the Education Department estimated.
In polite prose, many called on the Education Department to spike the rules altogether.
“There are problems with virtually every section of the [rules]. Given the depth and complexity of the shortcomings of the proposal, I urge you to withdraw it,” wrote Leslie C. Soodak, a professor at Pace University in Pleasantville, N.Y. She was one of many institutional representatives who drew on a template letter developed by the AACTE, which hoped to have at least 500 of its 800 institutions submit comments.
And then there were the less-than-polite comments, some from frustrated teachers.
As of Jan. 30, some 2,300 public comments had been submitted in response to the U.S. Department of Education’s proposed rules to heighten tracking of teacher education programs. Selected excerpts from the comments, which were overwhelmingly critical, are provided here.
“This additional public ranking based on flawed metrics has the potential to encourage institutions of higher ed. to tailor curriculum toward current standardized-testing practice that, in its current form, is not solid educational practice.”
—Suzanne Ehst, Goshen College, Mich
“California’s costs to implement the proposed amendments ... are estimated at $232,939,000 in development costs, and $485,272,059 in annual ongoing implementation costs. ... The extremely high cost would not provide the stated benefits of either improved accountability or transparency.”
—California Education Department; California Commission on Teacher Credentialing; California State Board of Education
“Cutting back the number of TEACH grant-eligible institutions will only exacerbate the problem of teacher shortages in the most challenging schools.”
—James C. Carl, Sacred Heart University, Fairfield, Conn.
“The federal government would be better served working with already existing organizations like [the Council for Accreditation of Educator Preparation] ... to improve the quality of teacher preparation, instead of striking additional bureaucracy and trying to independently re-invent the wheel.”
—Brad Maguth, teacher, Seven Hills, Ohio
“Many Vermont colleges and universities, including our state system, are struggling to financially support their programs under current reporting mandates. While we see the value in ... learning more about the placement and success of graduates, the logistics of gathering this information without further funding does not provide increased value to the programs.”
—Vermont Standards Board for Professional Educators
“The notion of determining the effectiveness for teacher education programs based on the test scores of the children they serve has an obvious socioeconomic bias that is demonstrably unfair to all.”
—Joseph J. McGowan, Bellarmine University, Louisville, Ky.
Source: U.S. eRulemaking Program Management Office
“Of all the boneheaded ideas which the Obama/Duncan [administration] has come up with, this takes the cake,” commenter Lisa Haver, a teacher, wrote.
Teachers’ unions were also among the major critics of the proposal. The American Federation of Teachers, in early January, began using its “e-activist” blasts to encourage members to send comments in opposition to the proposed regulations. Last week, the AFT upped the ante, hosting an event in Washington in collaboration with the Howard University School of Education. The general thrust of the gathering was that the rules might disproportionately penalize education schools producing teachers of color, who are already in short supply.
Still other commenters drew on a brief prepared by the National Education Policy Center, a left-leaning think tank at the University of Colorado at Boulder that is partly funded by teachers’ unions and generally opposes market-based education policies.
More Flexibility?
Far fewer comments focused on specific logistical questions about implementation.
One otherwise neutral comment, from an administrator at the University of Bridgeport, in Connecticut, noted simply that the college had experienced difficulty getting district administrators to respond to surveys on the quality of their teacher hires.
A commenter from a small, private women’s institution in Los Angeles, Mount Saint Mary’s College, cautioned that its teacher-candidates, who largely go on to teach in Catholic schools, wouldn’t be able to be tracked or measured using student-achievement data since students in such schools don’t take state exams.
Only a handful of commenters were outright supportive of the rules. At press time, a coalition of groups were preparing to submit a comment backing the proposal. The coalition’s members included: Democrats for Education Reform, a political action committee; Teach Plus, a nonprofit organization that supports teacher-leadership efforts; the National Council on Teacher Quality, an advocacy group; and the alternative-certification programs Teach For America and TNTP, formerly known as The New Teacher Project.
According to a draft of the groups’ comment, they will endorse the overall notion of placing programs in four categories and attaching consequences to the determination. But they also planned to encourage the Education Department to offer more flexibility to states as to the indicators used to rate programs.
Such organizations have generally endorsed more accountability for teacher preparation. Some have also been funded by like-minded philanthropies, such as the Chicago-based Joyce Foundation and the Seattle-based Bill & Melinda Gates Foundation. (Education Week also receives support from the Joyce and Gates foundations, but maintains editorial control over its coverage.)
On the other hand, many Washington-based higher education associations and lobbying groups, such as the American Council on Education, an umbrella lobbying group for higher education, were also expected to submit critical comments right before the period closed Feb. 2.
Whether the Education Department will be swayed by the volume of negative comments to rewrite or withdraw the rules remains an open question.
Next Move
Last year, the agency did change directions on its so-called “gainful employment” rule, which aims to ensure that graduates of for-profit colleges have access to good-paying jobs. But that happened in part because its original version of the regulations was overturned in court in 2011.
There is nothing in federal law that requires the department to make alterations to its proposal.
“The agency must give the public a chance to provide input, and has to explain if it has changed its regulations as a result of the process. But it doesn’t have to change a word,” said Michael J. Petrilli, a former Education Department staffer who helped develop regulations during George W. Bush’s administration.
“In this case, I suspect the department will go ahead with its current plan,” said Mr. Petrilli, now the president of the Thomas B. Fordham Institute, which generally backs stronger accountability mechanisms in education.
Mr. Petrilli cautioned that critics’ attempts to undermine the rules could backfire. “If opponents want to be constructive, they need to suggest ways to improve the regulation, not just argue for its elimination,” he said.
However, Marshall S. Smith, a former education adviser for three separate administrations—including President Barack Obama’s—noted that the Education Department could also take a middle-of-the-road course. It could offer options to states—for example, to make their judgments only every two years—and seek feedback on those alternatives, rather than immediately issuing a final set of rules, which are currently expected by fall of this year.
Whatever the agency decides, it will also have to consider teaching trends, Mr. Smith noted.
“They have to be aware of the larger context when they do this, and that includes the teacher shortage,” he said, referring to a nationwide decline in the number of individuals entering preparation programs.
