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Docket ID ED-2014-OPE-0057
Honorable Arne Duncan
Secretary of Education
U.S. Department of Education
400 Maryland Avenue SW
Washington, DC 20202
Dear Mr. Secretary,
We are responding to the U.S. Department of Education’s proposed regulations for teacher preparation programs on behalf of Kappa Delta Pi (KDP), an international honor society and professional organization founded in 1911. Established to foster excellence in education and promote fellowship among those dedicated to teaching, KDP is comprised of 632 collegiate chapters and more than 34,000 educators who are preservice teachers, inservice teachers, administrators, and professors. Individually and collectively, Society members recognize excellence in education and strive to a high degree of professional growth and leadership in the profession. KDP has a rich legacy of supporting preservice teachers and their successful transition into the classroom through the use of evidence-based strategies and resources.
No Evidence of Validity, Reliability, and Usefulness
While we embrace the use of data and multiple assessments to continually improve the effectiveness of those entering the teaching profession, it is critical that the mechanism used to measure teacher effectiveness be valid, reliable, and useful. The proposed regulations are not consistent with these criteria. The inclusion of a rating system, performance levels, and high-stakes consequences in the proposed regulations would extend the current K–12 education policy with its “test and punish” accountability model into higher education. While most states are actively working on evaluating their teacher preparation programs, there isn’t an example of a state fully using the proposed performance-rating system nor is there evidence that the proposed indicators actually represent program effectiveness. A more prudent approach would be to first develop an evaluation system using measures that have been tested for validity and reliability with a multiyear pilot program, especially before attaching high-stakes consequences. Additional areas of concern with the proposed measurements include:
- Teacher preparation programs have no control over home environment, school culture, or other noninstructional variables that impact student achievement. Schools impact only 20% of variation in student scores on standardized tests; teachers impact as little as 9% (see Haertel, 2013). Therefore, common standardized assessments as valid measurements of instructional outcomes should be reconsidered before regulations are determined.
- While teacher preparation programs routinely seek much of this information for feedback and program improvement, any algorithm based on these data elements would be unlikely to generate a rating number that would accurately or substantively reflect program effectiveness.
- The proposed regulations do not include a guarantee of data quality, which causes concern given the large amounts of data required from both K–12 and higher education. Ensuring the data are valid and reliable is of paramount importance and a laborious task that takes ongoing and substantial resources not readily available in institutions or states.
Negative Impact on Recruitment and Retention
of Diverse Teachers Who Work In Urban Schools
The proposed regulations would require states to collect data on teacher preparation programs, including rigorous entrance requirements based on multiple measures (Federal Register, p. 71835). Unequivocally, we support the need for rigorous standards for program completion, as demonstrated by KDP’s legacy of advocating for excellence in teaching. However, with mandated entry requirements that typically define high-achieving students as those with high GPA and SAT or ACT scores, institutions whose mission is to serve populations of students who historically do not have high GPAs or SAT or ACT scores would be negatively impacted. Below are additional concerns we have with the proposed regulations as they relate to diversity:
- Historically Black Colleges and Universities (HBCUs), along with institutions whose purpose is to serve underrepresented groups such as minorities and those who are the first in their family to go to college, often graduate students from K–12 public schools where Advanced Placement classes were not offered and achievement scores were low.
- HBCUs and other minority-serving institutions (MSIs) could be harmed by connecting the eligibility of programs for TEACH Grants to each program’s rating via the proposed performance assessment system. Often students attending MSIs require financial aid. This potential restriction would affect students’ access to higher education.
- The proposed regulations would lead to a decrease in students of color becoming teachers, because the schools that traditionally graduate the largest numbers of minority students would be less likely to accept students who jeopardize their rating with low test scores.
Working Against Equity in Education
The proposed regulations require teacher preparation programs to measure their graduates’ impact on student achievement using value-added measures. There are well-known challenges associated with value-added measurements—in particular, data gathering and statistical analysis. Teacher preparation programs also may be compelled to place teacher candidates in more affluent schools rather than in at-risk, high-needs schools because the former have consistently high test scores needed to achieve the “effective” or “exceptional” rating. As such, the regulations proposed would serve to increase school inequities by limiting teachers prepared in and for high-needs schools. Other areas of concern related to equity in education include:
- Student achievement is influenced by variables in school culture. Yet, teacher preparation programs have no control over school culture (e.g., quality of resources available to assist students/teachers, consistency in/quality of leadership, availability of supplemental programs for students).
- Richard Ingersoll’s extensive research (Ingersoll, 2012; Ingersoll & Perda, 2013) based on the U.S. Department of Education’s own Schools and Staffing Survey indicated teacher attrition rates as high as 75% in high-minority, urban settings. Given lack of retention, increased pressure to meet higher test scores, and financial costs to replace teachers, the proposed regulations would add to the problem of chronic turnover of the least experienced teachers in high-needs schools.
- Beginning teachers, especially those in high-needs schools, need strong, sustained induction to remain in the profession. The current regulations do not address the need for the infusion of high-quality induction programs, intensive mentoring, and bridging of these programs between higher education and K–12 schools. Without these programs, the revolving door of beginning teachers serving in schools where children most need experienced educators will continue, thereby working against equity in education.
While KDP has chosen to address aspects of the new regulations we deem most important, we want to emphasize that there are problems with virtually every section of the Notice of Proposed Rulemaking on Teacher Preparation Issues. We urge you, Mr. Secretary, to weigh heavily the lessons learned from relying on standardized K–12 student test results to serve purposes for which they were not designed. Those lessons need to inform a more efficacious approach to accountability for teacher preparation programs. Given the remarkable lack of capacity and resources across the nation to implement the varied aspects of these proposed regulations, substantial unintended consequences may result. Given the importance of ensuring highly effective teachers in every classroom, national assessment regulations also must address alternative preparation programs and other pathways into the profession. That is, both traditional and nontraditional pathways need to be included in any new regulations.
The proposed rules represent a major shift in higher education policy, affecting federal student financial aid, with consequences for our K–12 school systems. As such, a proposed shift of this importance deserves no less than the full and public deliberation of Congress. Both the Elementary and Secondary Education Act and the Higher Education Act will be considered by Congress this year for reauthorization. The important discussion of the continued reform of teacher preparation across this country also calls for engaging with Congress and the legislative process.
Given KDP’s legacy of advancing excellence and professionalism in teaching, we would be pleased to respond to any questions that you or your staff may have or to provide any additional information regarding this response to the proposed regulations on teacher preparation programs. We can be reached at 317-829-1554 or via e-mail at firstname.lastname@example.org.
Faye Snodgress, CAE
Executive Director, Kappa Delta Pi, International Honor Society in Education
Elizabeth A. Wilkins, PhD
Professor, Northern Illinois University
President, Kappa Delta Pi, International Honor Society in Education
Haertel, E. H. (2013). Reliability and validity of inferences about teachers based on student test scores. Princeton, NJ: Educational Testing Service.
Ingersoll, R. (2012). Beginning teacher induction: What the data tell us, Phi Delta Kappan, 93(8), 47–51.
Ingersoll, R., & Perda, D. (2013). How high is teacher turnover and is it a problem? Philadelphia, PA: University of Pennsylvania, Consortium for Policy Research in Education.