Member Voices: Comments to OMB on Proposed Federal Regulations

Editor’s Note: The following text includes issue prompts provided by the National Association of Independent Colleges and Universities followed by responses submitted to the U.S. Office of Management and Budget by Dr. Hennessy on December 14. AACTE encourages others to file comments with OMB by the January 2 deadline.

Issue 1. Assurance of Accreditation: The Education Department estimates that for states with accredited programs, the cost of assurance is estimated at 2 hours per teacher preparation program. In making this estimate, the Department has not provided any estimate of the cost of pursuing specialized accreditation if the program or state has not previously participated in specialized accreditation. Based on your experience, would this estimate be realistic for your institution?

New York State requires that teacher education programs be accredited by the Council for the Accreditation of Educator Preparation (CAEP). The cost of maintaining that accreditation now exceeds $500,000 annually in direct expenses, such as database management, two full-time staff positions, accreditation fees and related expenses, and other faculty and staff time for my institution. The costs associated with accreditation and recognition by organizations (e.g., American Psychological Association, National Association of School Psychologists, etc.) brings the total costs to the institution to almost $1,000,000 annually. If the regulations require that all educator preparation programs become accredited by a recognized accrediting organization, or by a state-established system, the cost to each institution will likely be in the tens or hundreds of thousands of dollars annually, depending on the size and complexity of each institution.

Issue 2. 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?

In the opinion of the staff member responsible for collecting and verifying information report in the Title II IRC, the changes in reporting requirements will add a minimum of 20 hours to report preparation. The new requirement that each registered program be reported separately or aggregated by new and not particularly clear methods is a great burden to institutions such as Fordham that has more than 20 teacher preparation programs, each of which has a traditional and alternative (TFA) track and most of which are offered at two different locations. Designing new software routines to disaggregate student and completer data, and to aggregate low enrollment programs using the new methodologies, will require a one-time 20-30 hours of programming time. The time estimate made by the Department is a vast underestimation of the time needed to complete the IRC.

Issue 3. Stakeholders meetings: The Department estimates states would need at least 35 hours to discuss methods for ensuring meaningful differentiation of performance, and defining the method for their ratings of “significant” and “satisfactory,” as key indicators. However, the Department assumes some states may have already established committees to meet these requirements at no additional costs. 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 state plans for the state report cards?

New York State has not yet formed a committee to discuss these issues. If history is a guide, the expectation that consensus will be reached in only 35 hours is unrealistic. Establishing those criteria will necessitate a series of meetings of stakeholders from across the state. Given how important those ratings will be to each educator preparation institution in the state, the number of hours is likely ten-fold and will involve representatives from the 120-plus such institutions in the state. The cost of travel and staff time for each institution and for the state has to be factored in to the Department’s calculations.

Issue 4. Student Learning Outcomes: The Department assumes that because all states have provided the assurance that teachers are provided with student growth measures for reading and math through their applications for State Fiscal Stabilization Funds (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 non-tested grades and subjects. Based on your experience sharing student learning outcomes measures with your state, would this estimate make sense in your state?

Issue 5. Linking SLO 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 assumes that because 47 states, D.C., and Puerto Rico received $575 million in grants for SLDS, they should be able to link student achievement to 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?

The attempts to link Student Learning Outcomes (SLO) to teacher preparation programs remain hugely unsuccessful. At this point, New York State cannot accurately link all candidates taking the new certification exams to their preparation programs, nor can the state accurately link public school teachers to their initial preparation programs. The errors in state data that have to be corrected in the preparation of the current Title II reports will be magnified considerably with the new reporting requirements. The state databases are not reliable enough to be used for these kinds of analyses, and the state is years away from having a reliable system for these purposes. The recent cancellation by the State of the contract with inBloom set back the state’s efforts to have a comprehensive data system in place by 2017. The funds to find a replacement for inBloom have not been allocated. Perhaps as Pearson increases its influence in the State, it will fund database development efforts—a highly doubtful proposition. Even if a comprehensive database is developed statewide, the work of linking student learning outcomes to specific teachers, and then linking those teachers to their initial preparation programs, and then rating those programs is an enormously expensive operation that has not been adequately considered by the Department. It is beyond naïve and more than somewhat disingenuous to suggest that unknown some ones in the State are going to perform these tasks in 150 additional hours of work as suggested by the Department.


James J. Hennessy

Dean, Fordham University Graduate School of Education