The Education Trust–New York issues public comment on proposal for teacher certification at SUNY-authorized charter schools

by | Aug 9, 2017 | Public Comment

The Education Trust–New York submitted the following letter in response to SUNY’s proposed teacher certification regulation for SUNY-authorized charter schools:

Ralph A. Rossi II
SUNY Charter Schools Institute
41 State Street, Suite 700
Albany, NY 12207

Dear Mr. Rossi:

We write to provide feedback on the “Governance, Structure and Operations of SUNY Authorized Charter Schools Pertaining to Teacher Compliance” proposed rulemaking (SUN-30-17-00024-P).

As you know, research reinforces the overwhelming importance of strong educators as the greatest in-school determinant of student success. As a result, the significance of the teaching profession cannot be overstated.

We share SUNY’s goal to recruit and retain excellent teachers, particularly for schools that disproportionately serve students of color and low-income students. From that perspective, the proposed regulation raises significant concerns about educator equity. While we certainly need innovation in teacher preparation, New York should not have to choose between innovation and rigor. All students deserve both.

Our concerns can be summarized in three categories: (1) the minimum certification requirements in the proposed regulation fall short of the research on the characteristics of effective teacher preparation; (2) the proposed regulation would create a second – i.e., lower – permanent tier of certification; and (3) there does not appear to be a plan to evaluate the effectiveness of this dramatic change on New York’s students to determine whether it should continue.

At the same time, we believe that a number of charter schools, school districts, non-profit organizations, and higher education institutions offer innovative approaches to teacher development and mentorship that the entire sector could learn from. Because of the importance of improving equity by ensuring that all students have access to strong educators, we support the idea of innovative, evidence-based, and highly accountable alternative pathways that encourage high-quality candidates to join the profession.

In that spirit, we offer the following recommended changes to address concerns with the proposed regulation:

(1) The minimum certification requirements in the proposed regulation fall short of the research on the characteristics of effective teacher preparation.

Based on findings from the National Council on Teacher Quality, best practices from teacher preparation programs, and other research, we recommend far stronger certification requirements – while enabling flexibility and innovation in how these requirements are fulfilled.

  • Teacher eligibility: The proposed regulations require candidates to have a Bachelor’s degree and a cumulative GPA of at least 3.0, and it allows exceptions for students with a lower GPA who have “demonstrated exceptional qualities or qualifications.” The rulemaking should better describe how it will (1) ensure the academic readiness of candidates (e.g., by drawing from among the top-half of all students and/or multiple measures that promote rigor); and (2) improve the diversity of the teacher workforce (e.g., by ensuring that the candidate pool be at least as diverse as the overall teacher workforce in the school district where the charter school is located).
  • Instructional program: The classroom instruction and field experience requirements are inadequate for permanent certification. At a minimum, the regulations should specify that:
    • Candidates receive instruction in (1) the content they are going to teach (or demonstrate mastery of the content through a subject-area degree or significant professional experience); (2) how to teach the specific content area they are preparing to teach (not simply “pedagogical core study”); (3) preparation to work effectively with English learners, students with disabilities, and diverse student populations; and (4) classroom management, including the use of praise and positive reinforcement. Although a broad range of instructional hours should be permitted in order to encourage innovative practices, we cannot envision this being accomplished in 30 instructional hours, as the proposed rulemaking suggests.
    • Candidates participate in student teaching or similar field experiences for a minimum of the equivalent of 10 weeks, rather than the 100 hours specified in the proposed regulation.
    • Field experience be supervised by an effective or highly effective teacher and include intensive mentoring, supervision, and feedback.
  • Pathway to certification: All participating charter schools should be required to use a high-quality, evidence-based structured observation protocol to help determine which candidates are prepared for temporary certification following their field experience. Long-term certification should require at least one to two years of supervised and supported teaching experience in the classroom. The regulation should require participating charter schools to provide evidence of how they will ensure that teachers who receive certification have demonstrated effectiveness.
  • Assessment: All participants should ultimately be required to successfully complete the certification exams required of New York State teachers, including the edTPA, in order to earn long-term certification. This provision would help ensure that teachers have the necessary knowledge and skills, and should be integral to resolving the issues raised below.

(2) The proposed regulation would create a second – i.e., lower – permanent tier of certification.

The proposed rulemaking specifies that teachers who receive this new certification may only use it at another SUNY-authorized charter school. In fact, the rulemaking would require applicants to sign an “affirmation” acknowledging that “the certification the candidate will receive… is not transferrable to any education corporation / charter school not authorized by [SUNY] or to any district school, and may not be recognized as a teacher certification under regulations of the state commissioner of education.”

This effectively creates two tiers of certification and two labor markets for teachers, and traps teachers in a subset of schools without adequate pathways to career advancement or even mobility. That is fundamentally unfair to educators.

One way to address this flaw could be to work with the Board of Regents and State Education Department to create a new “Transitional” alternative teacher preparation program, which would recognize (an improved) SUNY-authorized charter school teacher certification program and establish a pathway from its successful completion to state-sanctioned teacher certification, for a specific period of time and subject to review as described below. The Regents and SED would presumably seek to enact additional quality requirements beyond the proposed rulemaking, as well.

(3) There does not appear to be a plan to evaluate the effectiveness of this dramatic change on New York’s students to determine whether it should continue.

The regulation should include a specific time horizon, beyond which the pathway’s continued implementation would depend on the results of a publicly available evaluation.

The regulation should establish a clear protocol for studying the impact of this alternative teacher certification program based on factors including, but not limited to: student achievement (overall proficiency and growth), teacher recruitment (including the recruitment of teachers of color), and teacher retention (including the retention of teachers of color).

In addition, where the data exist, this evaluation should draw on the use of State-provided growth scores to compare the relative effectiveness (as one of multiple measures) of teachers who complete various certification pathways.

Thank you for your consideration on this important issue.

Ian Rosenblum
Executive Director