State Chapter Advocacy Wins Changes to Proposed Florida Rule
The state of Florida recently passed a new rule governing the implementation and evaluation of teacher preparation programs. The Florida Association of Colleges for Teacher Education (FACTE) was very active during the development and public comment periods for this new rule, and while we did not secure all the changes we’d hoped, we did make a difference in the process and in the outcomes.
FACTE implemented a detailed advocacy strategy during the public comment period. One of our greatest assets was our relationship with the Florida Department of Education (FDOE), which has always worked to be partners with our programs. I cannot speak enough of the importance of building relationships with those charged with program approval before you are in the process of rule development. We have focused our efforts on building on our shared vision of ensuring every child in the state is taught by a high-quality educator.
The first step in our advocacy process was to attend public workshops regarding the proposed rule, ensuring that the voice of the teacher preparation profession was voiced. After each workshop, our FACTE Policy Committee reviewed the information, making proposed changes to the rule based on the public comment received. This information was shared via e-mail with our members along with information on how to submit their own comments on the proposed rule.
The next step was to get feedback from our membership about the proposed rule. We dedicated a session at our fall conference to this discussion, starting with an update from the chair of our Policy Committee on the rule and on changes that had been made based on previous public comment. (In Florida, the rule revision and public comment are fluid components of rule development. Public comment begins the day the initial proposal is made public and remains open throughout the revision period, closing only once the State Board of Education votes to pass the proposed rule.) As president of FACTE, I led the discussion that followed on the major components of the rule. My goal was to reach consensus related to concerns and strengths. We had a member taking notes and projecting them for the audience to view and comment on, ensuring that the notes were an accurate reflection of the conversation.
Based on the feedback and comments from our fall conference, I drafted a letter template that articulated the rule’s strengths and concerns identified by members. This template was shared with AACTE for feedback and improvements. Aaron Goldstein and Deb Koolbeck reviewed the draft letter, and then we held a conference call to discuss comments and recommended edits.
The revised template became the formal FACTE letter of comment and was submitted to the FDOE as part of the public comment process. In addition, we shared this letter with all FACTE members and encouraged them to personalize it to their programs and to add any other concerns they had with the rule. This letter template was distributed several times along with information about the public comment process and the importance of having our voices heard. The template was very effective for us—it helped those unsure of how to make public comment become more comfortable, and it resulted in an increased number of public comments from FACTE member institutions.
I am pleased to share that our public comment and advocacy efforts did result in changes to how the metrics to be employed will be calculated and to several of the definitions included in the proposed rule. On January 14, the State Board of Education met to the vote on the rule. Even though some changes had been made based on our efforts, there were aspects about which our members still had concerns. Therefore, the FACTE president-elect, the Policy Committee chair, and one Policy Committee member attended the meeting to share our concerns with the board. While the rule was passed unanimously, the State Board did encourage the FDOE to continue to work with us to monitor the first year of implementation.
You’ve got to move quickly in the policy world once implementation is in motion. The day after the State Board vote, I was in touch with the deputy chancellor for educator quality to begin advocating for ongoing dialogue to be sure the rule meets the goal of ensuring quality educators for every classroom. Our hope is that this visit will set the stage for our annual “Day on the Hill” meeting in March.