Advocacy - Part 80 Regulations

January 12, 2000

Hon. Richard Mills, Commissioner
New York State Education Department
State Education Building
Albany, New York 12234

Dear Commissioner Mills:

The New York State Reading Association would like to take this opportunity to offer comments on the draft revisions to the Part 80 regulations which were presented to the Board of Regents at its December 1999 meeting.

Overall, the New York State Reading Association is supportive of the Department's and the Regents' efforts to enhance the preparation and continuing professional development of teachers in New York State. Such efforts can only benefit the children for whom we are a bridge to educational attainment and success in life's pursuits.

We are cognizant of the significant changes that were made as a result of the amendments to Part 52.21 of the Commissioner's regulations relating to the certification of college and university teacher education programs. Those new
regulations effectively define in large part the requirements that will be placed on teachers in the future, while the changes to Part 80 are minimal by comparison.

Specifically, we would offer the following comments and observations regarding the draft changes to Part 80:

Certification Issues:

the dual purposes of defining requirements for new teachers and of defining interim requirements for teacher candidates already in the system leads to a lack of clarity in some areas. As the regulations are implemented, this lack of clarity could have an adverse effect on decisions and choices made by teacher candidates. It might be useful in this regard to consider referencing or cross-walking between these regulations and the provisions outlined in the Part 52.21 regulations recently adopted.
a title change is proposed in the Reading Teacher certification to that of Literacy Teacher, Birth-6 and 5-12. Is it intended that all holders of a Reading Teacher Certificate will be issued new certificates that qualify them for these new titles? Or will there be no effect on current certificate holders?
it appears that the transitional certificate will be given only to career changers who hold existing graduate degrees and then enroll in a teacher education program which would require its own separate masters degree. If the Department is interested in expanding the teacher pool by attracting individuals from other professions, requiring such a second masters degree in
education may prove a serious disincentive to career changes. Couldn't applicants with a masters degree in a content area simply be required to complete an undergraduate teacher education program or pursue a shorter path to certification?
the three-year time limit on obtaining the master's degree required for attaining a permanent professional certificate remains problematic. Such a time constraint places an inordinate amount of stress on a beginning teacher who needs to focus intensively on classroom instruction and adaptation to the classroom. The three-year requirement could have the effect of creating a conflict between academic scholarship and professional practice. We recognize that the Professional Standards and Practice Board for Teaching has recommended that the Regents extend the validity of the initial certificate to a five year period for these same reasons. The Reading Association recognizes that the five year period is the same as is current practice at a time when the Department is seeking overall and structural changes. We would be concerned, however, that this change would create more negative results than positive and agree in principle with the position of the Professional Standards and Practice Board in its comments to the Board of Regents.
we remain concerned that the grade level splits related to the certification of Literacy Teachers and Special Education teachers will cause difficulty in finding and placing qualified special education and literacy teachers at any level. It is difficult enough to recruit sufficient qualified teachers under current constraints; adding the additional layer of grade level specialties
will contribute to the lack of qualified teachers at all grade levels.
·we are pleased that the draft regulations are definitive regarding the appropriate role and qualifications for araprofessionals. The provisions as drafted will help to ensure that teacher aides and assistants are NOT providing classroom instruction without the supervision of a qualified teacher.
moreover, we support the requirement for six semester hours of education-related coursework for continuing certification as a teacher assistant. However, we continue to advocate that these paraprofessionals should not provide direct instruction to students without supervision and guidance from a qualified teacher.
· NYSRA strongly supports "mentoring" and "internship requirements" for new teachers. The efficacy of these models has been shown in other areas and has been successful in New York State under limited experiences of the Teacher/ Mentor/Intern program. We look forward to assisting in the mentoring and practical experiences of upcoming Literacy Teachers in this state.

Professional Development:

the quality of professional development activities available in districts will vary greatly among the school districts in the state. Even though districts are currently required to prepare Professional Development Plans, some districts' requirements may be much more stringent (e.g., requiring teachers to complete additional college courses vs. participation in internal conference days). This will be very difficult to monitor (especially for quality and consistency) and places cumbersome paperwork requirements and monitoring responsibilities on local school districts to ensure that the 175 hours/five year requirement is met by each teacher. This becomes particularly sensitive in light of the relationship between the professional development hours and continued certification to teach.
decisions as to what constitutes "appropriate professional development" could lead to subjective decisions within local districts and has the potential of leading to issues and potential grievances with local teacher unions and representatives. This would be unfortunate whenone considers that the professional development plans are intended as a constructive and beneficial activity. It would be useful to provide sufficient clarity in the definitions so as to avoid or ameliorate potential conflicts over this issue. Additionally, allowing professional development hours as voluntary unless negotiated in the contract has the potential of placing financial burdens on local districts. Should local districts be required to pay tuition for college coursework?
the N.Y.S. Reading Association strongly recommends that participation in professional conferences be considered as hours toward continued certification. While the details of calculating the number of hours attained while attending overnight and day-long conferences must be worked out, clearly many professional and trade conferences provide significant learning and development opportunities that should be exploited.
on a separate, but related note, is there any reason why the Education Department cannot include in its role of certifiying teachers the verification of compliance with the professional development requirements? Since these proposed regulations require teachers to maintain a record of their professional development hours and activities, why can't this continue to be submitted to SED for issuance of the continued certification. Why has this responsibility now been proposed to be placed with the local districts which are already overburdened?

Other:

on a presentation note, we were appreciative of the time the Department took in laying out the various new requirements in graphic form in the Attachment"B" to the draft regulations. While there remain several areas of concern and in need of clarification, the chart helped to clear up many questions we might otherwise have presented.

Thank you for your attention to and consideration of our comments and observations. We look forward to the opportunity to discuss these regulations further as they proceed through the Regents approval process.

If you have any questions or require additional information regarding these comments, please contact Maureen Goodwin at 607-898-3367, or contact our legislative representatives at Carr Public Affairs, Inc., in Albany at 518-434-8830.

Sincerely,

Ann Stampf, President

Maureen Goodwin, Government Affairs Chair

c.c.: NYS Board of Regents
Peter Mannella, Carr Public Affairs, Inc.

NYSRA Statement on Part 80 regulations Changes