The U.S. Department of Education is accepting comments on its proposed regulations about teacher education until January 2, 2015. These regulations would impose VAM on teacher education. These institutions would be judged by the test scores of the students taught by the graduates of these institutions. Graduates would be incentivized to avoid the neediest students.
Please write today and urge the DOE not to impose discredited junk science on teacher education programs.
This is from the Conference on English Education of the National Council of Teachers of Education.
This document provides an overview of the U.S. Department of Education’s proposed regulations for teacher education programs, a list of points concerned educators, scholars, students and parents might use when drafting a response to the proposed regulations, and information on how and when to deliver a response. The authors of this Call to Action urge the CEE membership, as well as all concerned parties, to submit a response to these regulations immediately.
How to Comment: 1. E-mail OIRA_DOCKET@omb.eop.gov by January 2, 2015. 2. Submit comments through the comment portal on the regulations website: https://www.federalregister.gov/articles/2014/12/03/2014-28218/teacher-preparation-issues
Summary of Proposed Regulations
On December 3, 2014, the U.S. Department of Education proposed a new federal rule to extend accountability measures to teacher education programs.
Under this rule, teacher education programs would be graded based on the employment, placement, and performance of its graduates. Included in the performance ranking is the use of VAM (value added measures), a statistical formula that uses children’s tests scores to demonstrate teacher effectiveness.
These rankings will be used to determine eligibility for federal TEACH grants. The Office of Management & Budget is required to make a decision about the collection of information between 30 and 60 days after the regulations’ publication. For your comments to be fully considered, (1) submit them by email (OIRA_DOCKET@omb.eop.gov) or (2) through the comment portal (https://www.federalregister.gov/articles/2014/12/03/2014-28218/teacher-preparation-issues) by Jan. 2, 2015.
Points to Reiterate in Your Own Words: Too Much Testing
The tests used to create the VAM hinder teaching, learning, and innovation. They diminish the experience of school for teachers and children. They discourage teaching that responds to the child and encourage teaching to the test. Children are defined as data and ranked by test scores.
Flawed Methods, Bad Measures
The methods suggested to rank teacher education programs rely on measures that do not serve children, teachers, or schools. The regulations extend the controversial VAM and standards-based models of K-12 education to higher education. The American Statistical Society discredited the VAM as a valid measure of teacher effectiveness.
Hampers Innovation
Innovation demands risk; regulations demand obedience. By tying university programs to a federal rule, the regulations stifle creative responses to local education needs. Instead of meeting the needs of school systems, teachers, children, and parents, universities will be tied to meeting the standards of regulation, regardless of how those regulations fit the local context. In addition, a federal rule leaves university programs unable to meet new challenges and to adapt to changing conditions. 2 Federal Overreach States already regulate their teacher education programs. The proposed regulations transfer that power to the federal government and use the TEACH grants to enforce that power. This is the definition of federal overreach.
The Hidden Costs
The federal regulations demand data and performance from teacher education programs, but they place the costs of gathering and disseminating that data on states. This is another unfunded mandate from the federal government.
Caricatures of Teacher Education Programs
The report portrays teacher education programs as unaccountable producers of poorly prepared teachers. This portrait understands accountability as a statistical formula. Teacher education programs understand assessment and accountability as an ongoing, varied and supportive effort that focuses on the child as an individual with individual needs and abilities, Teacher education programs prepare many, many excellent teachers every year in an inhospitable climate to public education.
How to Comment: 1. E-mail OIRA_DOCKET@omb.eop.gov by January 2, 2015.
2. Submit comments through the comment portal on the regulations website: https://www.federalregister.gov/articles/2014/12/03/2014-28218/teacher-preparation-issues
Respectfully submitted,
Rebecca Powell, University of Southern Mississippi
Anne Elrod Whitney, Pennsylvania State University
Don Zancanella, University of New Mexico
Melanie Shoffner, CEE Chair, Purdue University
Sources
American Statistical Society on VAM http://www.amstat.org/policy/pdfs/ASA_VAM_Statement.pdf
Sharon Robinson, AACTE President http://hechingerreport.org/content/burdensome-restrictive-flawed-why-proposed-federal-regulations-for-teacherpreparation- programs-are-a-cause-for-concern_18389/
Jane West’s webinar: http://ceedar.education.ufl.edu/wp-content/uploads/2014/12/Teacher- Preparation-Regulations-for-CEEDAR.pdf
Anne Elrod Whitney’s piece Proposed Regulations Bad for Kids, Teachers, and Schools: http://writerswhocare.wordpress.com/2014/12/08/proposed-regulations-bad-for-kids-teachers-and-schools/
Diane Ravitch's blog 
I will certainly write a letter and send it through the correct channels. I will send out a message through our union email chain.
But, I would like to know where these college level teachers were when this system of “accountability” was being rained down upon the heads of k-12 teachers.
Can only answer for myself, Betsy. I have been right here, and all over cyberspace and in the community for years, actively fighting in behalf of primary and secondary school teachers. I am in higher ed and teach public policy.
Diane, am about to write my letter. Thanks for this info.
A lot of them were still talking about how since kids don’t know stuff, we must be idiots who don’t teach stuff. A lot of college professors still do talk like this — the above regs will only apply to teacher ed programs, so most college professors will continue to blame us for the inadequacies of their students. They will not change their minds — see the light — until VAM is used directly to rank them, until their tenure is being taken away.
Not a good idea to paint all higher ed instructors with the same brush,
If your monolithic statement was true, Diane Ravitch probably would not have started this extraordinary venue where we share information and opinions. She teaches at NYU.
Same goes for my own colleagues, many of whom are adjunct professors who do not loll about with tenure. I have honed in on occasion about the inadequacy of some schools of Education, as have others here who teach college students.
Many in teacher education were shocked, shocked when the EdPTA test came down the pike. Many have not read the CCSS or the standards from the Council on Teacher Preparation Accreditation that were written to please Arne and had actually had to be approved by USDE for students to receive TEACH grants.
If you read the proposed federal regulations for teacher education, especially the definitions, you can see that all of these dumb accountability measures imposed on K-12 and the embedded “theory of action” is whole cloth. VAM and SLOs and the ethos of stack-ranking for k12 is carried forward in these regulations.
The footnotes tell the story as well. Not one critical reference to VAM or to USDE’s own studies that show there is no research, NONE, to support the validity of the SLO process which is the system for evaluation treated as comparable to VAM for about 70% of teachers. In this respect, the attention given to VAM has been understating the problem with USDE.
Also note that higher education has either been sleeping or it has been complicit in the design of the PARCC and SBAC tests that will be the basis for judging teacher education programs in ELA and math. Those tests may also be used for part of the evaluation of teachers placed in grades 6-12 because there is supposed to be “literacy” testing in all subjects.
The concept of academic freedom in higher education, including teacher education, is being thoroughly undermined. I have posted on this subject more than once, including some of the jargon on accountability from the teacher education accreditation standards written to pass muster Arne and, as usual, open the doors for teacher education by for-profit “providers.”
Students are not data points, and neither are teachers. Please stop preaching differentiation and then standardize everything. In a court of law, reasonable doubt changes everything. Should that not be the same in this case, where there is far more than just reasonable doubt?? VAM is a bad idea, and one that raises a lot of questions ethically and professionally. The only people who seem to 100% support it are the folks who know nothing about teaching, but have the $$. That’s a problem.
Sent them my feedback that they will almost certainly dislike and ignore.
Here are my “3 concerned cents” of public comments to the USDOE on their propoosed rules for teacher preparation programs. Mind you, I wrote this in 3 minutes.
To the USDOE:
To the United States Department of Education-
I am strongly opposed to the proposed rules for teacher preparation programs. The Department is putting the education-cart before the unequal-education horse. I believe in the concept of national standards for all children. I do not support Common Core because they were not designed by the best in educational academia and were driven by Pearson, corporate America and philanthropists working to privatize public education. All that said, it is wrong to promulgate rules for 50 states’ teacher preparation programs that will continue to allow them to offer traditional teaching endorsements and alternate pathways and then measure effectiveness of our teachers by students’ standardized test scores. Not one state in the U.S. has standardized testing for students with IEPs that allows Each and Every Student to demonstrate the knowledge we need to assess measurable progress, and for the majority, closing the achievement gap. Further, for EVERY child in America there are still too many loop-holes that allow gross inequity in the teacher instruction provided in classrooms, and not only classrooms in economically disadvantaged districts. States like MI that allow “permanent subs” for one-half of a school year with only two years of college. States like CA that allow “permanent subs” with only 4 years of college. The outrageous use of Teach for America teachers, and misguided belief that a student with four years of college can be trained to teach in six weeks. This is an outrageous assault on public education and the teaching profession.
Do not promulgate rules for teacher preparation programs that will create and perpetuate games and machinations by LEAs, PSAs and SEAs, along with creating greater inequity than we have now.
When the ESEA and the IDEA are reauthorized eliminate alternate pathways; create a battery of standardized assessments for every grade level that allow teachers and school districts to measure the academic achievement and measurable growth of EVERY child, and then create rules for America’s teacher preparation programs that is fair, unbiased, and restores respect and gratitude to every person who becomes and wants to become a teacher.
Marcie Lipsitt
Michigan
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COPAA SEAT Graduate, October 2013, Inaugural Class
Our lives begin to end the day we become silent about things that matter….
Dr. Martin Luther King
I am a lay advocate and do not give out legal advice.
how important is this…..compared to a demand to fire Arne Duncan?
greater than because the Obomber will find another lap dog to yip yap the edudeformers’ spew.
Gee, I wonder if TFA would be included in this legislation . . . hmmmmm . . .
How about reading through the regulations,if you really want to know. And this is not legislation, it is regulation within legislation that exists.
Laura,
Thank you for the clarification. My comment, though, was meant as satirical “tongue-in-cheek”.
Sent my comments.
EVERYONE PLEASE DO SO!!!
Especially considering the “rational” for the regulations (be prepared for the same old dog and pony show-actually a dog and pony show would be a lot better usage of our federal tax dollars than this shit):
“Recent international assessments of science, reading, and math knowledge have revealed that the United States is significantly behind other countries in preparing students to compete in the global economy. [27] Although many factors influence student achievement, a large body of research has used value-added analysis to demonstrate that teacher quality is the largest in-school factor affecting student achievement. [28] We use “value-added” analysis and related terms to refer to statistical methods that use changes in the academic achievement of students over time to isolate and estimate the effect of particular factors, such as family, school, or teachers, on changes in student achievement. [29] One study found that the difference between having a teacher who performed at a level one standard deviation below the mean and a teacher who performed at a level one standard deviation above the mean was equivalent to student learning gains of a full year’s worth of knowledge. [30]”
Blah, blah, blah. . . ad infinitum!!!
Please note that the comments due to the Office of Management and Budget by January 2 are to address concerns related to the time and cost of collection requirements. These regulations will require states and local schools to spend an inordinate amount of time collecting data on new teachers, including VAM data. Emails should go to OIRA_DOCKET@omb.eop.gov
Comments related to the regulations themselves are to be submitted by February 2 via the Federal Register: http://1.usa.gov/16okLNx
AACTE has prepared several helpful documents to guide you in writing comments.
http://aacte.org/resources/regulations
Also, please note that individual comments are needed, not one response signed by multiple people.
State legislators need to be aware of these regulations, since these unfunded regulations require extensive state-level activity.
There is already growing concern that even highly rated teacher education programs do not adequately prepare teachers to work in high-needs schools. The last thing we need is to provide MORE incentive for programs to push their graduates into schools that already highly successful, or out of the profession altogether.
–A tired special education teacher
There are no thoughtful educators in USDE. The regulations recycle tired arguments and ignore evidence.
Done and done! Despite what folks may think, register your objections early! We can not be passive in any sense. If you can’t even make a comment, you really can’t complain when the fight is harder.
Done!