By Max Woolf, Senior Analyst and Catherine Birdwell, Client Research Analyst
Following months of anticipation and speculation, the U.S. Department of Education (DOE) recently published regulations for teacher preparation programs under Title II of the Higher Education Act. These proposed federal regulations would require states to rate teacher preparation at one of four levels—exceptional, effective, at-risk, or low-performing—based on certain indicators of quality, such as student learning, employment, and survey outcomes. Programs labeled as at-risk or low-performing would be barred from receiving TEACH grants, which are distributed to graduates who agree to serve in high-need fields or schools and represent an important source of federal funding for colleges and schools of education.
Meanwhile, the Council for the Accreditation of Educator Prep (CAEP), the leading accrediting body for schools of education, has been developing its own set of standards. Supposedly, the regulations that the DOE released were aligned with CAEP’s standards and developed in collaboration with higher education and P-12 leaders. In a 60-day period following the regulations’ December release, however, an astonishing 4,576 comments were submitted in response. Individuals from across education, including college leaders and stakeholders, national and regional accreditation agencies, and P-12 school districts, laid out a plethora of objections to and concerns with the DOE’s proposed approach to regulating teacher education.
As with any conversation involving higher education and government-led reform, this issue is far from straightforward. The Obama Administration’s intentions are well placed in that they focus on improving education for today and tomorrow’s learners. Like many who submitted comments, however, we believe that the regulations present expectations and requirements that will be difficult to execute and, more importantly, make the end result of improving teacher quality impossible to attain. CAEP, on the other hand, lays out a much more reasonable and better thought out approach that encourages collaboration and discussion among all relevant parties. By taking a softer line, however, CAEP’s approach may allow colleges to operate business as usual and stagnate true changes in P-12 education.
To help our readers further assess this issue and gauge the key differences between the DOE’s proposed regulations and CAEP standards, Eduventures analyzed the thousands of submitted comments. Five overarching themes emerged:
- Federal overreach. One of the top concerns stakeholders raised in their comments was whether these rules constituted an expansion of federal authority. Many comments noted this historical overreach of the federal government into what has traditionally fallen under the jurisdiction of states and institutions. Stakeholders expressed concern over the significant policy changes the regulations made without consulting Congress, specifically the decision to link TEACH grant access to ratings based on federally defined indicators. CAEP standards, on the other hand, place a heavy emphasis on working closely with states through partnership agreements on program review and by developing processes for gathering program impact data.
- Over-emphasis and reliance on student outcomes. Student learning outcomes are the central measure of progress in the proposed federal regulations and represent one of four indicators required to determine a program’s rating. While the regulations allow states to determine how each of the four indicators will be weighted, they place the highest emphasis on student outcomes by asserting that states may only identify a program as “effective” or “exceptional” if that program has satisfactory or higher student learning outcomes. CAEP has taken a more measured approach by including student learning outcomes as one of four components under Standard 4, which is only an element of the accreditation process. CAEP also explicitly acknowledges the flaws that can come from relying solely on student outcomes data and encourages the use of multiple measures to determine impact on P-12 learning.
- Burden on providers and states. Commenters also expressed concern over the burden the regulations place on providers and states in terms of time, capacity, and cost. By requiring providers to report to states by 2017, the regulations set forth an unrealistic timeline for both providers and states. This timeline assumes that it will take only two years for states and providers to adjust their data systems. Currently, however, many states do not actively or effectively collect student outcomes data, teacher effectiveness data, or employment satisfaction data. The regulations also do not mention the source of funding, leaving many to refer to them as another unfunded federal mandate. CAEP sets forth a longer and more reasonable timeline, with the 2013 standards going into effect no earlier than 2016. CAEP also presents providers with a variety of options for gathering data, offering to work with providers and outlining alternatives to consider when necessary, and requires the implementation of a quality assurance system to put measures in place to gather the data used to meet the standards.
- Impact on high-need schools and disciplines. The federal regulations seek to drive teacher candidates into high-need fields and high-need, low-income schools. The challenge, however, is that if student learning outcomes are the most heavily weighted indicator, then teacher preparation programs would be more motivated to place graduates in less challenging schools that can guarantee higher test scores. Programs would therefore move away from placing graduates in high-need fields, such as special education or English as a second language, and high-need, low-income schools, where research has shown that students do not test as well as their counterparts. CAEP similarly highlights this focus on high need schools and disciplines. It emphasizes the need for candidates to be prepared to teach in increasingly diverse classrooms and asks providers to actively recruit candidates to teach in hard-to-staff schools and high-need fields.
- Purpose of the proposed federal regulations. Many comments brought up the overall negative tone of the regulations, such as language that implies providers are not concerned with quality and assessing their programs, and the punitive nature of denying access to federal funding for programs that do not meet the criteria. There were also concerns about the lack of collaboration with and insight from colleges of education and other P-12 education leaders in the development of the regulations. The CAEP standards are generally more positive, with an emphasis on betterment, continuous improvement, and working extensively to develop standards with input from all relevant stakeholders.
Based on these five themes, the proposed federal regulations may be too stringent, while the CAEP standards may not be stringent enough. Ultimately, the most impactful approach to regulating teacher preparation likely lies somewhere in between.
Eduventures is seeking to convene roundtable conversations to discuss the similarities and differences between the proposed federal regulations and CAEP standards in order to develop actionable strategies for institutions to meet these challenges strategically and tactically. If you are interested about learning more, contact Catherine Birdwell, Client Research Analyst, at firstname.lastname@example.org.