October 17, 2016

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Final Teacher Prep Regs Place New Burden on Districts

Last week, the U.S. Department of Education issued Higher Education Act (HEA) regulations on teacher preparation programs that will place new, unexpected burdens on school administrators. After reviewing the regulations, AASA believes they will not improve a district’s ability to recruit and retain effective teachers and will add to the already sizeable paperwork burden of school administrators without providing any useful information to them about teacher preparation.  

The final HEA regulations place an unfunded mandate on district personnel to complete an employer survey that assesses the performance of teachers who have graduated within three years from a teacher prep programs, and to submit student achievement data related to the new teacher's performance to state entities. The survey and data will be for all “new” teachers in all subjects including those subjects that are currently considered non-tested by the State. Since districts do not receive any funding from the Higher Education Act and are not required to be in compliance with the Higher Education Act, AASA reads these regulations as an unprecedented mandate for school districts.  

As we stated in our comments to the proposed regulations, the employer survey would be redundant and burdensome given that school administrators already have locally designed processes for evaluating teachers that are far more sophisticated and appropriate than a 30-minute survey instrument. AASA supports locally designed and developed teacher evaluation systems, particularly for new teachers who may need considerably more support and professional development than other teachers. We believe school administrators should focus on providing these opportunities for improvement for new teachers rather than filling out ill-defined employer forms to purportedly improve and rank teacher preparation programs. Even if each survey takes less than 30 minutes, supervisors would have many surveys to complete every year, which would force them to take time from other, more critical, student-focused tasks. 

In addition to the survey, the district would be responsible for transmitting student learning outcomes for each new teacher to the State. In many states, districts are not equipped to handle the amount of data sharing required by these new proposed regulations, and the burden to create a district-to-state feedback loop would be expensive and time-consuming. While states would have three years to design, implement and refine their data systems to enable district-level data to be securely shared with the state, years of experience tell us this work is slow-going and complex. The Department began awarding grants to states to support data systems that would allow states to link K-12 student achievement data to teachers and postsecondary systems in 2005. While some states and territories are currently developing or planning these systems, 25 states and territories do not even have plans to build these systems. The reality that these data sharing systems do not exist in over half of the country does not mean that districts would not be responsible for reporting this data to the state if these proposed regulations go into effect. Unfortunately, districts would have to allocate dollars and personnel to ensure this data is reported and these expenditures would come at a direct expense of providing direct instruction to students and complying with other local, state and federal mandates. AASA is also concerned about the security of the data to be shared. Especially in small, rural districts, the privacy of student data is difficult to guarantee. Many districts in rural areas are too small for data to be disaggregated while maintaining student anonymity. The complex data systems that will have to be built quickly to implement these regulations may not support such rigorous privacy measures.

Unless overturned by Congress or the next President, every state will be required to fully implement these regulations by the 2018-2019 school year. AASA is engaging with other stakeholders, including the higher education community, to strategize about what can be done to stop this unfunded mandate. Stay tuned. 

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