January 2 Deadline to Comment on Regulations’ Cost, Burden

As you may know, embedded in the teacher preparation program regulations proposed by the U.S. Department of Education is a request for feedback from the Office of Management and Budget (OMB) concerning the cost estimates and burden estimates of the proposed information collection. AACTE encourages you to respond to this request.

The deadline for the OMB request is January 2, 2015. Please note this deadline is a month earlier than the deadline to comment on the overall regulations.

The cost and burden rationale and estimates can be found on pages 71858 to 71884 in the December 3 Notice of Proposed Rule Making.

Why Comment Separately on the Cost/Burden?

The Department of Education has estimated that the entire cost to implement the new regulations, including creating and troubleshooting the statewide data systems, is $42.1 million over a period of 10 years. However, because the proposed regulation is considered a significant regulatory action, OMB is also being asked to weigh in on the cost and burden during the comment period. In crafting its response, OMB is seeking feedback, guidance, comments, and data from any interested person. This is an ideal time to illuminate the true implications of these regulations for teacher preparation and the teaching profession.

In particular, your comments will help OMB with the following objectives:

  • Deciding whether the proposed collections are necessary for the proper performance of the Department’s functions, including whether the information will have practical use.
  • Evaluating the accuracy of the estimate of the burden of the proposed collections, including the validity of the methodology and assumptions.
  • Enhancing the quality, usefulness, and clarity of the information to be collected.
  • Minimizing the burden on those who must respond. This includes exploring the use of appropriate automated, electronic, mechanical, or other technological collection techniques.

In addition, you might want to review the Department’s supporting statement for OMB to justify its collection request. This document offers insights into the Department’s perspectives as well as what information OMB is interested in receiving.

What Feedback Is Useful?

You do not need to complete a full cost analysis, but there are places where your expertise and experience can guide OMB on where to best focus its time and energy in doing its analysis. In addition, we encourage you to share this opportunity with others in your department or at your institution who you have determined could contribute to this conversation – it need not be only teacher preparation.

Here are some key estimated areas for implementation costs you might discuss in your comments:

  • Assurance of Accreditation: The Department of Education estimates that it will take 2 hours per teacher preparation program for a state to determine whether the program either has specialized accreditation or provides teacher candidates with content and pedagogical knowledge and quality clinical preparation, and has rigorous entry and exit standards. This estimate does not include the cost of pursuing specialized accreditation if a program does not already have it, nor does it consider the time it would take for a state to determine if a program that does not have specialized accreditation is able to meet the alternative standard. Would this estimate be realistic for your institution?
  • Institutional Report Cards: The Department estimates the initial burden for each institution of higher education (IHE) to adjust its recordkeeping systems to report data for each program would be 4 hours. Based on your existing Title II Institutional Report Card recordkeeping, would 4 hours be enough time to update the data collected to meet the new requirements?
  • Stakeholder Meetings: The Department estimates states would need at least 35 hours to discuss methods for ensuring meaningful differentiation of performance, and to determine the method for their ratings of “significant” and “satisfactory” as key indicators. This estimate is based on the assumption that some states may have already established committees to meet these requirements at no additional cost. Based on your experience in working with a coordinated effort on teacher preparation in your state, does this estimate reflect a reasonable amount of time to agree on plans for state report cards?
  • Privacy: The Department estimates states would need up to 14 hours to review and analyze state and federal privacy laws on program size thresholds (Note: The regulation would require programs with 25 students or more to report to the state). Based on your experience with educational privacy issues at your institution and in your state, is this estimate reasonable?
  • Student Learning Outcomes: The Department assumes that because all states have given the assurance that teachers are provided with student growth measures for reading and math (through their applications for State Fiscal Stabilization Funds, or 2009 stimulus money), no additional costs will be incurred to measure student growth in “tested grades and subjects.” The Department also claims the 43 states and D.C. with NCLB waivers would not incur additional costs to measure student growth in nontested grades and subjects. Based on your experience sharing student learning outcomes measures with your state, would this estimate make sense in your state?
  • Linking Student Learning Outcomes to Teacher Preparation Programs: The Department estimates the cost of linking student learning outcomes to teacher preparation programs will depend on the data available in each state’s Statewide Longitudinal Data System (SLDS). The Department assumesthat because 47 states, D.C., and Puerto Rico received $575 million in grants for SLDS, they should be able to link student achievement to their teachers, and the teachers to institutions. Based on the status of your state’s data system and your institution’s participation in this system, does this estimate reflect the cost to your state or institution to make this link?
  • Employment Outcomes: The Department assumes that 41 states with SLDS can link data on teachers with their programs and current certification status and placement; are in the process of making these links; or plan to add this capacity. If the remaining states cannot make this link, they may need to obtain the information from the programs or teachers themselves, at an estimate of 150 hours for these states. Does this estimate seem reasonable for your institution and state?
  • Survey Outcomes: For states without teacher and employer surveys, the Department estimates it would cost the average state about $25,000 to develop the survey instruments. But the Department assumes that with the availability of online surveys, and the ability to fold teacher preparation questions into existing surveys, these costs could be overestimates. Based on your experience with teacher and employer surveys, does this estimate accurately reflect their cost?

We know your answers to these questions would require an enormous amount of information you may not have readily available, especially in the short holiday timeframe. Please know that you do not need to answer all questions fully to have an impact on the regulatory process! The total volume of overall responses matters greatly; even one example in response to one area would be extremely helpful. Together, our collective responses can have a real impact.

Where Should Comments Be Sent?

Comments should be addressed to the Office of Information and Regulatory Affairs, OMB, Attention: Desk Officer for U.S. Department of Education. Send these comments by e-mail to OIRA_DOCKET@omb.eop.gov.

In addition, AACTE would appreciate receiving a copy of your submission at regs@aacte.org.

Thank you for any assistance you can provide with this critical matter!

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Deborah Koolbeck

Senior Director of Government Relations, AACTE

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