Comment on Awful NPRM for Teacher Training

20 Jan

It is hard to express how profoundly inimical I find the set of proposed federal regulations for teacher education schools. These rules are not based on good science and are not motivated by experience or called for by leading professional educators. The costs are devastating for local school districts, state education budgets and universities. Students will be subjected to even more expensive testing that accelerates the well-known tendency for standardized testing to pervert curriculum. And the instruments being used for objectively evaluating teacher colleges are neither designed for that purpose nor capable of doing it. While these regulations will transfer policy control from states to the federal government, they will not only do little to improve teaching but to the contrary will harm schools, the teaching profession, and pedagogy.

Here in California, Linda Darling-Hammond, Chairman of the California Commission on Teacher Credentialing (CCTC) is among those who oppose using test scores as a measure of teacher training effectiveness, as is state Superintendent of public instruction, Tom Torlakson. Besides opposing using tests to evaluate education schools, the CCTC said that it would have to develop some 57 new tests to generate student-achievement data that could be used for all of its licensing areas. It put the total cost of the regulations in California at close to $485 million for just one year. [1]

Darling-Hammond was President Obama’s education spokesperson during his first presidential campaign and Tom Torlakson has been leading one of the world’s largest school systems for 15 years. These are dedicated talented and widely respected professional educators. The new rules would override their judgment and implement policies against the best thinking of California’s education leaders. That is beyond the scope of reasonable federal authority and in light of these facts; implementation of these rules would be crass authoritarianism.

The most alarming section of the regulations describes the indicators that states must gather and report:

Ҥ 612.5What indicators must a State use to report on teacher preparation program performance for purposes of the State report card?
While a State would be able to use additional indicators and establish its own “cut-scores,” it would be required to use the following indicators of teacher preparation program performance: (i) Student learning outcomes (ii) employment outcomes, (iii) survey outcome data, and (iv) an assurance that the program is accredited by a specialized accreditation entity recognized by the Secretary for accreditation of professional teacher education programs, or an assurance by the State that the teacher preparation program provides teacher candidates with content and pedagogical knowledge and quality clinical preparation who have met rigorous teacher candidate entry and exit qualifications.” [2]

Certainly, teacher education programs should be accredited by recognized regional accrediting organizations and this has been a long standing practice throughout our nation. A survey of employers that hire newly minted teachers seems reasonable and the reporting requirements not overly expensive or burdensome. Although mandates like this have been routinely implemented since the 1950’s causing a bloating of school administrative staffs nationwide. Efforts to reduce reporting requirements would be a more helpful focus for these new rules. It would allow schools to put more money in classrooms. Although I understand the need to insure that tax dollars are spent appropriately, I also know that bureaucratization is fraught with mission creep and expenses that often exceed the value of the benefit that was expected.

Employment outcomes’ reporting is a job creation clause for bureaucrats that does little to ensure teacher program quality. It is the job of highly trained school district leaders to ensure that they are hiring quality candidates for the classroom. It would be quite unusual to find a school system leader who was not diligent in this aspect of his job. Unprofessional teacher training schools that provide poorly qualified teachers will not be able to place their teachers. These local school leaders are more effective at policing quality teacher outcomes than a federal bureaucrat at the Department of Education could ever hope to be. This requirement will only further burden local school districts and teacher colleges with expensive reporting rules that will do little to improve teacher education.

Student learning outcomes is by far the most intolerable, debilitating, and wrongheaded requirement in these proposed rules. It is intolerable because student outcomes are to be based on a pseudo-science which is widely disputed by professional statisticians and educators. Wherever these value added models (VAM) have been implemented, the outcomes have been unstable. The preponderance of evidence is that VAM is not capable of accurately identifying the causes of educational outcomes. VAM assumes those outcomes can be measured by objective means; that is a highly dubious assumption.

Furthermore, the learning outcomes section is debilitating because it will force more testing and do even more damage to pedagogy and state budgets. It is wrongheaded because it will cause curriculums to narrow, undermine creativity and exacerbate the environment that creates cheating and fraud.

The required indicators and definitions of terms in section of 612.5 clearly state that VAM or some method that is even less developed be used to evaluate teacher education colleges:

“The first required indicator of academic content knowledge and teaching skills would be student learning outcomes (see proposed § 612.5(a)(1)). “Student learning outcomes” would be defined as data on the aggregate learning outcomes of students taught by new teachers (as that term would be defined in § 612.2(d)) trained by each teacher preparation program in the State. The State would choose to calculate the data on student learning outcomes using measures of student growth (as that term would be defined in § 612.2(d)), teacher evaluation measures (as that term would be defined in § 612.2(d)), or both.

“Definitions of “student growth” and “teacher evaluation measure” would also be added to proposed § 612.2. “Student growth” would be defined as the change in student achievement in tested grades and subjects and the change in student achievement in non-tested grades and subjects for an individual student between two or more points in time. This could be a simple comparison of achievement between two points in time or a more complex “value-added model” [3] that some States already use to assess teacher preparation program performance based on levels of student growth associated with new teachers from those programs.” [3]

It is a requirement that locks in the current debilitating testing environment and accelerates the control of schools away from parents and communities toward state and federal government agencies.

As Professor Yong Zhao has written, “Under the spell of authoritarianism, Americans have willingly surrendered their beloved local governments to state and federal control. Locally elected school boards have turned into bureaucratic branches of state and federal government, for in effect, they only collect local taxes. They then use that tax money to implement the wishes of state and federal governments in curriculum, pedagogy, and assessment.” [4] It is time to put the brakes of the federal hegemony over public schools and recognize the wisdom of allowing diverse approaches across this great country to manifest. Do not kill creativity like other countries that use high stakes testing and authoritarian rule have done.

Sharon Robinson, President of the American Association of Colleges for Teacher Education writes, “The price tag for states to implement these regulations would be steep —higher, we believe, than the fiscal estimates provided in the proposed rules. … Furthermore, the proposed regulations mirror misguided rating systems and incentives that have created the unproductive, test-driven accountability environment of today’s K-12 schools — even as the administration has sought to address that very issue with increased flexibility for states in recent months.” [5]

Molly Corbett Broad, President of American Council on Education states, “Considering the size and scope of the regulations proposed, the limited extent to which systems capable of meeting the new requirements currently exist, and the existing data on the substantial costs to develop these systems, the estimate provided in the NPRM {Notice of Proposed Rule Making} grossly underestimates the actual burden these regulations would impose. [6]

Keving K. Kumashiro of the University of San Francisco reviewed these proposed regulations for the National Education Policy Center. He concluded:

“Improving teacher quality and teacher preparation should be a process that engages key constituents and communities and draws on both scholarly and practical expertise. The proposed regulations have not emerged from an inclusive, democratic decision-making process, or from the substantive involvement of qualified experts, or from sound research…. Additionally, the regulations reflect an historic over reach of the federal government through regulation, in at least three ways: the proposed regulations extend the reach of the federal government into what is currently the domain of states (program approval) and institutions(academic affairs); the proposed regulations extend to all states what is currently required only of states who received Race to the Top funding or ESEA waivers; and the proposed regulations make significant policy changes without substantive and inclusive deliberation with either the profession or Congress.” [7]

Kelly Field the senior education writer for the Chronicle of Higher Education reported, ‘”There are no state tests that I’m aware of that have been shown to be valid and reliable as a measure of teacher performance,” said Donald E. Heller, dean of the College of Education at Michigan State University. “They’re all constructed to measure student performance.” Extrapolating those tests to measure the programs that educated the teachers is even more of a stretch, he added.”’ [8]

The American Association of Colleges for Teacher Education (AACTE) disputes the claim that the implementation of this rule would cost between $42 million and $47 million. “In general, we find the analysis to vastly underestimate the development and implementation costs that states and institutions of higher education would incur if the regulations were to be adopted. The Department repeatedly, but erroneously, assumes that many states have much of the capacity in place to implement the proposed regulations.” [9] As noted earlier, California leaders believe the first year would cost half a billion dollars.

This NPRM is bad for teaching, bad for education schools and especially bad for poor communities. The testing associated with this proposal will exacerbate the negative experience good teaching suffered under George Bush’s “no child left behind”, a misguided policy widely considered a destructive abomination. Education schools will be saddled with new burdens that do nothing to improve their school. Still, it is poor communities that will suffer most of all. Education schools, in their own self interest, will not want their graduates to work in poor and minority communities. Across the United States many great state institutions focus on developing teacher corps capable of addressing the problems associated with poverty. With these rules in place it would be against their survival to continue that mission.

1)Teacher-Prep Regs Too Costly, Higher Ed. Groups Say By Stephen Sawchuk January 5, 2015 6:43 for Education Week


3) Ibid.

4) Zhao, Yong Who’s Afraid of the Big Bad Dragon? Jossey-Bass, San Francisco, © John Wiley and Sons, Inc. 2014.



7) REVIEW OF PROPOSED2015 FEDERAL TEACHER PREPARATION REGULATIONS: by Kevin K. Kumashiro, University of San FranciscoforNational Education Policy Center

8) New Rules Would Judge Teacher-Prep Programs on Job Placements and Student Learning By Kelly Field

9) The American Association of Colleges for Teacher Education (AACTE)

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