The American Association of Colleges for Teacher Education has submitted comments to the U.S. Department of Education on the proposed teacher education program regulations.

Sharon P. Robinson, president and chief executive officer of AACTE, released the following statement to Arne Duncan highlighted in a press release:

The members of AACTE embrace accountability for their work. They are eager to understand the effectiveness of their graduates and seek continual program improvement to ensure graduates’ profession-readiness on day one in the classroom.

The regulatory proposal put forward by the Department, however, is not the appropriate way to hold programs accountable. It would draw energy, funding and attention away from innovative reforms, proven accountability initiatives and overall program improvement currently under way in teacher preparation programs across the country.

Our specific concerns include:

The regulations manifest federal overreach, requiring states to use a federally dictated rating system and indicators of effectiveness.

The regulations would be an unfunded mandate. The Department estimates the cost of implementation to be $42.1 million over 10 years, a number that is far below what has been estimated by states and organizations.

There is no evidence of efficacy of the proposed ratings system. Measures of program effectiveness are still being tested for validity and reliability, and attaching high-stakes consequences at this point is ill-advised.

The regulations would extend the K-12 “test and punish” model into higher education. Research has demonstrated that using value-added methodology to measure teacher effectiveness is fragile at best. Extending these metrics to the evaluation of preparation programs only adds to concerns of validity.

Given the complexity of annually assessing 25,000 individual teacher preparation programs using four federally mandated indicators, these proposed regulations are unworkable. Most states do not have the capacity to enact these assessments, as the requisite data systems are not in place. In addition, privacy concerns would be raised, and new burdens on teachers and principals to fill out surveys annually would further pressure limited capacity. The proposal would work against equity in education. By incentivizing teacher preparation programs to place new teachers in high-need schools without providing needed supports, the regulations would counter current efforts to achieve a more equitable distribution of experienced teachers.

The regulations would have a disproportionate impact on minority-serving institutions due to their mission to serve students from underrepresented groups or whose prior education has provided limited preparation for college. This would result in a less diverse teacher workforce. In addition, these profession-ready graduates serve in high-need schools, which are at a disadvantage in the proposed rating system.

Because the regulations would limit access to federal financial assistance (TEACH grants) for teacher candidates, they would negatively affect affordability and access to college for many students.

Read AACTE’s full submission here.

Article by Kassondra Granata, Education World Contributor