The proposed changes to teacher preparation programs include:

• Strengthening the Department’s expectations for collaboration between teacher preparation programs and their partner schools and districts by requiring them to establish, maintain, and review Memoranda of Understanding or similar collaborative agreements to systematically improve teacher preparation and the teaching and learning for all involved in collaborative clinical experiences;

• Requiring the student teaching experience to be at least a full semester (at least 14 weeks), full time, and in alignment with the daily schedule and annual school calendar. Candidates pursuing more than one certificate title, may complete two placements each of at least 7 weeks. The student teaching experience must be designed to provide candidates with opportunities to hone their practices in alignment with the New York State Teaching Standards and shall carry the number of semester hours required to obtain full-time status at the institution to ensure qualification for financial aid.

• Exempting certain experienced teachers from the 100 clock hour field experience requirement and the full-semester student teaching experience, and requiring that they instead complete at least 50 clock hours of student teaching. This exemption would apply to candidates who have previously completed an approved New York State teacher preparation program, those who hold a National Board certificate, and those with at least one year of effective teaching experience under a valid New York State or out-of-state teaching certificate. This change streamlines the regulations for already-certified teachers, which currently require different amounts of hours for field experiences and student teaching, depending on the certificate title.

• Strengthening the Department’s expectations for both school-based educators (cooperating teachers) and university-based teacher educators (supervisors) who work with teacher candidates during clinical experiences.

Proposed Amendments to Section 80-3.7

Section 80-3.7 of the Commissioner’s Regulations outlines the requirements for certification through the individual evaluation pathway. Currently, the coursework requirements for the individual evaluation pathway for certification are based on the educational study requirements for New York State approved teacher preparation programs, including student teaching. As a result, the student teaching requirement for the individual evaluation pathway for certification in Section 80-3.7 needs to change to align with the student teaching experience requirement proposed in Section 52.21.

The proposed changes to Section 80-3.7 would require candidates who apply for a certificate through the individual evaluation pathway to satisfactorily complete a 14- week, full-time, college-supervised student teaching experience. They could satisfactorily complete 70 full-time school days or 140 half-time school days as an employed teacher, provided that the employment must include at least one continuous period of no fewer than 35 days.

1. STATUTORY AUTHORITY:

Education Law 207 (not subdivided) grants general rule-making authority to the Regents to carry into effect State educational laws and policies.

Education Law 305(1) and (3) authorizes the Commissioner to enforce the educational policies of this State and execute all educational policies determined by the Regents and shall prescribe the licensing of teachers employed in this State.

Education Law 3001 establishes the qualifications of teachers in the classroom.

Education Law 3004(1) authorizes the Commissioner to promulgate regulations governing the certification requirements for teachers employed in public schools.

2. LEGISLATIVE OBJECTIVES:

The purpose of the proposed amendments to Sections 52.21 and 80-3.7 of the Regulations of the Commissioner of Education relating to student teaching requirements for teacher certification and the registration of teacher preparation programs is to create greater coherence with other statutory and Department initiatives related to ensuring that all educators have the knowledge and skills necessary to meet the needs of all students. Specifically, the amendments further align the Commissioner’s Regulations with requirements related to the Department’s federally approved Every Student Succeeds Act (ESSA) plan.

3. NEEDS AND BENEFITS:

The quality of the preparatory experience of aspiring teachers in New York State can vary significantly. In developing our plan under the Every Student Succeeds Act (ESSA) to ensure that all students have equitable access to effective instruction, the Department relied on recent research which shows that the quality of the preparation that aspiring teachers receive is a key factor in determining whether those educators enter and remain in the profession¹. There is also an important relationship between educator preparation and positive effects on student outcomes².

New York’s current field experience and student teaching requirements have been in effect since January 2000. (Currently, each candidate must do, at a minimum, two 20-day placements or a single 40-day placement.) Since then, there has been a national trend to increase clinical practice in teacher preparation programs. In 2010, the National Council for Accreditation of Teacher Education Blue Ribbon Panel report placed clinical practice at the center of teacher preparation, providing teacher candidates with the opportunity to connect theory with practice³. The U.S. Department of Education, Council of Chief State School Officers, and American Federation of Teachers joined the call for high quality clinical practice in teacher preparation programs⁴. The American Association of Colleges for Teacher Education Clinical Practice Commission recently released a report to help the field develop a common understanding of clinical practice and stated that, “clinical practice serves as the central framework through which all teacher preparation programming is conceptualized and designed.⁵”

As a result, states are following the guiding principle that more clinical experiences—intentionally constructed in partnership between P-12 and higher education, and with a focus on quality in addition to quantity—are better in teacher preparation programs. For example, as of July 2018, Louisiana requires a one-year residency, with 180 hours of clinical experiences prior to it. Effective September 2018, New Jersey is requiring 50 hours of clinical experiences and 175 hours of clinical practice (225 hours total) prior to the full-time semester of student teaching. By 2015, 34 states had moved to require a clinical practice placement of 10 weeks or longer, including all of New York’s neighboring states⁶.

Accordingly, building on the recommendations of the TeachNY Advisory Council and the edTPA Task Force, the Department convened a Clinical Practice Work Group in June 2017 to explore current practice and make recommendations for changes if deemed appropriate. The Work Group was composed of members from the P-12 and higher education communities from across the state (Attachment A) and met eight times from June 2017 through March 2018 to develop recommendations for updating the regulations.

The Work Group developed recommendations, which were presented to the Higher Education Committee of the Board of Regents in May of 2018 (Attachment B). The proposed regulation amendments are based, in part, on those recommendations.

The proposed changes to teacher preparation programs include:

• Strengthening the Department’s expectations for collaboration between teacher preparation programs and their partner schools and districts by requiring them to establish, maintain, and review Memoranda of Understanding or similar collaborative agreements to systematically improve teacher preparation and the teaching and learning for all involved in collaborative clinical experiences;

• Requiring the student teaching experience to be at least a full semester (at least 14 weeks), full time, and in alignment with the daily schedule and annual school calendar. Candidates pursuing more than one certificate title, may complete two placements each of at least 7 weeks. The student teaching experience must be designed to provide candidates with opportunities to hone their practices in alignment with the New York State Teaching Standards and shall carry the number of semester hours required to obtain full-time status at the institution to ensure qualification for financial aid.

• Exempting certain experienced teachers from the 100 clock hour field experience requirement and the full-semester student teaching experience, and requiring that they instead complete at least 50 clock hours of student teaching. This exemption would apply to candidates who have previously completed an approved New York State teacher preparation program, those who hold a National Board certificate, and those with at least one year of effective teaching experience under a valid New York State or out-of-state teaching certificate. This change streamlines the regulations for already-certified teachers, which currently require different amounts of hours for field experiences and student teaching, depending on the certificate title.

• Strengthening the Department’s expectations for both school-based educators (cooperating teachers) and university-based teacher educators (supervisors) who work with teacher candidates during clinical experiences.

Section 80-3.7 of the Commissioner’s Regulations outlines the requirements for certification through the individual evaluation pathway. Currently, the coursework requirements for the individual evaluation pathway for certification are based on the educational study requirements for New York State approved teacher preparation programs, including student teaching. As a result, the student teaching requirement for the individual evaluation pathway for certification in Section 80-3.7 needs to change to align with the student teaching experience requirement proposed in Section 52.21.

The proposed changes to Section 80-3.7 would require candidates who apply for a certificate through the individual evaluation pathway to satisfactorily complete a 14- week, full-time, college-supervised student teaching experience. They could satisfactorily complete 70 full-time school days or 140 at least half-time school days as an employed teacher, provided that the employment must include at least one continuous period of no fewer than 35 days.

4. COSTS:

a. Costs to State government: The amendments impose minimal additional costs on State government, including the State Education Department.

b. Costs to local government: The amendments impose minimal additional costs on local government, including New York State school districts and BOCES. Participation by school districts and BOCES in the clinical preparation of teacher candidates is voluntary.

c. Costs to private regulated parties: The amendment impose minimal additional costs on private regulated parties. Since 2002, State University of New York teacher preparation programs have required the student teaching experience to be at least 75 days in length, which is equivalent to the full-semester student teaching experience in the proposed regulation. The Department expects the additional clinical experience days to be embedded within the EPP’s revised program, without necessarily increasing the number of course credits, which means that tuition would not increase as a result of the additional days. Increases to program administration costs for institutions that do not already require a full semester of student teaching may include, e.g., salary and travel costs for university supervisors to spend more days in the field and additional stipends/honoraria for cooperating teachers.

d. Costs to regulating agency for implementation and continued administration: See above.

5. LOCAL GOVERNMENT MANDATES:

The proposed amendment does not impose any additional program, service, duty or responsibility upon any local government.

6. PAPERWORK:

The proposed amendment does not impose any additional paperwork requirements.

7. DUPLICATION:

The proposed amendment does not duplicate existing State or Federal requirements.

8. ALTERNATIVES:

Because the State believes that uniform certification standards are required across the State, no alternatives were considered.

9. FEDERAL STANDARDS:

There are no applicable Federal standards.

10. COMPLIANCE SCHEDULE:

It is anticipated that the proposed amendment will be permanently adopted by the Board of Regents at its April 2019 meeting. If adopted at the April 2019 meeting, the proposed amendment will become effective on April 24, 2019.

___________

¹ See, e.g., Ingersoll, R., Merrill, L., and May, H., “What are the effects of teacher education and preparation on beginning teacher attrition?” Research Report (#RR-82) (Philadelphia: Consortium for Policy Research in Education, University of Pennsylvania, 2014) (teacher candidates who complete programs that emphasize clinical practice are less likely to leave the profession after their first year in the classroom) http://www.cpre.org/prep-effects; Guha, R., Hyler, M.E., and Darling-Hammond, L., “The Teacher Residency: An Innovative Model for Preparing Teachers” (Palo Alto, CA: Learning Policy Institute, 2016) https://learningpolicyinstitute.org/product/ teacher-residency; Carver-Thomas, D., Diversifying the teaching profession: How to recruit and retain teachers of color (Palo Alto, CA: Learning Policy Institute, 2018) (Increased access to high-quality preparation, including at least a semester of student teaching, can improve the chances of teachers of color feeling successful in the classroom and continuing to teach long term) https://learningpolicyinstitute.org/sites/default/files/product - files/ Diversifying_Teaching_Profession_REPORT_0.pdf.

² Boyd, D., Grossman, P.L., Lankford, H., Loeb, S., & Wyckoff, J., “Teacher Preparation and Student Achievement,” Educational Evaluation and Policy Analysis 31(4), 416-440 (2009) (teacher candidates who complete programs that emphasize clinical practice are more effective during their first year of teaching) http://journals.sagepub.com/doi/abs/ 10.3102/0162373709353129. See also Fraser, James W. and Audra M. Watson, “Why Clinical Experience and Mentoring are Replacing Student Teaching on the Best Campuses” (Princeton: Woodrow Wilson National Fellowship Foundation, 2014) (positing “short stays in classrooms intensify the unacknowledged stereotypes and biases that many student teachers bring to their work with students of color” and “provide superficial, rather than deep, understandings of students’ lives, communities, and cultures”), retrieved from https://eric.ed.gov/?id=ED562067.

³ National Council for Accreditation of Teacher Education, Transforming teacher education through clinical practice: A national strategy to prepare effective teachers (2010), retrieved from https://eric.ed.gov/?id=ED512807

⁴ United States Department of Education, Our future, our teachers (2011), retrieved from http://www.ed.gov/sites/default/files/ our-future-our-teachers.pdf; Council of Chief State School Officers, Our responsibility, our promise: Transforming educator preparation and entry into the profession (2012), retrieved from https://www.ccsso.org/sites/default/files/2017- 10/Our%20Responsibility% 20Our%20Promise_ 2012.pdf; American Federation of Teachers, “Raising the bar: Aligning and elevating teacher preparation and the teaching profession” (2013) (survey reveals top problem experienced by teachers in their own training program is a failure to prepare them for the challenges of teaching in the “real world”; quality, depth, and duration of clinical experience is key) http://www.highered.nysed.gov/pdf/ raisingthebar2012.pdf.

⁵ American Association of Colleges for Teacher Education, A pivot toward clinical practice, its lexicon, and the renewal of educator preparation (2018), p. 14. Retrieved from https://aacte.org/professional-development-and-events/clinical-practice-commission-press-conference

⁶ National Council for Teacher Quality, Student Teaching national results, State Teacher Policy Database. [Data set] (2015), retrieved from https://www.nctq.org/yearbook/national/Student-Teaching-69.

The purpose of the proposed amendments to Sections 52.21 and 80-3.7 of the Regulations of the Commissioner of Education relating to student teaching requirements for teacher certification and the registration of teacher preparation programs is to create greater coherence with other statutory and Department initiatives related to ensuring that all educators have the knowledge and skills necessary to meet the needs of all students. Specifically, the amendments further align the Commissioner’s Regulations with requirements related to the Department’s federally approved Every Student Succeeds Act (ESSA) plan.

The proposed changes to teacher preparation programs include:

• Strengthening the Department’s expectations for collaboration between teacher preparation programs and their partner schools and districts by requiring them to establish, maintain, and review Memoranda of Understanding or similar collaborative agreements to systematically improve teacher preparation and the teaching and learning for all involved in collaborative clinical experiences;

• Requiring the student teaching experience to be at least a full semester (at least 14 weeks), full time, and in alignment with the daily schedule and annual school calendar. Candidates pursuing more than one certificate title, may complete two placements each of at least 7 weeks. The student teaching experience must be designed to provide candidates with opportunities to hone their practices in alignment with the New York State Teaching Standards and shall carry the number of semester hours required to obtain full-time status at the institution to ensure qualification for financial aid.

• Exempting certain experienced teachers from the 100 clock hour field experience requirement and the full-semester student teaching experience, and requiring that they instead complete at least 50 clock hours of student teaching. This exemption would apply to candidates who have previously completed an approved New York State teacher preparation program, those who hold a National Board certificate, and those with at least one year of effective teaching experience under a valid New York State or out-of-state teaching certificate. This change streamlines the regulations for already-certified teachers, which currently require different amounts of hours for field experiences and student teaching, depending on the certificate title.

• Strengthening the Department’s expectations for both school-based educators (cooperating teachers) and university-based teacher educators (supervisors) who work with teacher candidates during clinical experiences.

Section 80-3.7 of the Commissioner’s Regulations outlines the requirements for certification through the individual evaluation pathway. Currently, the coursework requirements for the individual evaluation pathway for certification are based on the educational study requirements for New York State approved teacher preparation programs, including student teaching. As a result, the student teaching requirement for the individual evaluation pathway for certification in Section 80-3.7 needs to change to align with the student teaching experience requirement proposed in Section 52.21.

The proposed changes to Section 80-3.7 would require candidates who apply for a certificate through the individual evaluation pathway to satisfactorily complete a 14- week, full-time, college-supervised student teaching experience. They could satisfactorily complete 70 full-time school days or 140 half-time school days as an employed teacher, provided that the employment must include at least one continuous period of no fewer than 35 days.

The amendments do not impose any new recordkeeping or other compliance requirements, and will not have an adverse economic impact on small businesses or local governments. Participation by school districts and BOCES in the clinical preparation of teacher candidates is voluntary. Because it is evident from the nature of the proposed amendments that they do not affect small businesses or local governments, no further steps were needed to ascertain that fact and none were taken. Accordingly, a regulatory flexibility analysis for small businesses is not required and one has not been prepared.

1. TYPES AND ESTIMATED NUMBER OF RURAL AREAS:

This proposed amendment applies to educator preparation providers (EPPs) and certain candidates for teacher certification in New York State, including those located in the 44 rural counties with fewer than 200,000 inhabitants and the 71 towns and urban counties with a population density of 150 square miles or less.

2. REPORTING, RECORDKEEPING, AND OTHER COMPLIANCE REQUIREMENTS; AND PROFESSIONAL SERVICES:

The purpose of the proposed amendments to Sections 52.21 and 80-3.7 of the Regulations of the Commissioner of Education relating to student teaching requirements for teacher certification and the registration of teacher preparation programs is to create greater coherence with other statutory and Department initiatives related to ensuring that all educators have the knowledge and skills necessary to meet the needs of all students. Specifically, the amendments further align the Commissioner’s Regulations with requirements related to the Department’s federally approved Every Student Succeeds Act (ESSA) plan.

The proposed changes to teacher preparation programs include:

• Strengthening the Department’s expectations for collaboration between teacher preparation programs and their partner schools and districts by requiring them to establish, maintain, and review Memoranda of Understanding or similar collaborative agreements to systematically improve teacher preparation and the teaching and learning for all involved in collaborative clinical experiences;

• Requiring the student teaching experience to be at least a full semester (at least 14 weeks), full time, and in alignment with the daily schedule and annual school calendar. Candidates pursuing more than one certificate title, may complete two placements each of at least 7 weeks. The student teaching experience must be designed to provide candidates with opportunities to hone their practices in alignment with the New York State Teaching Standards and shall carry the number of semester hours required to obtain full-time status at the institution to ensure qualification for financial aid.

• Exempting certain experienced teachers from the 100 clock hour field experience requirement and the full-semester student teaching experience, and requiring that they instead complete at least 50 clock hours of student teaching. This exemption would apply to candidates who have previously completed an approved New York State teacher preparation program, those who hold a National Board certificate, and those with at least one year of effective teaching experience under a valid New York State or out-of-state teaching certificate. This change streamlines the regulations for already-certified teachers, which currently require different amounts of hours for field experiences and student teaching, depending on the certificate title.

• Strengthening the Department’s expectations for both school-based educators (cooperating teachers) and university-based teacher educators (supervisors) who work with teacher candidates during clinical experiences.

Section 80-3.7 of the Commissioner’s Regulations outlines the requirements for certification through the individual evaluation pathway. Currently, the coursework requirements for the individual evaluation pathway for certification are based on the educational study requirements for New York State approved teacher preparation programs, including student teaching. As a result, the student teaching requirement for the individual evaluation pathway for certification in Section 80-3.7 needs to change to align with the student teaching experience requirement proposed in Section 52.21.

The proposed changes to Section 80-3.7 would require candidates who apply for a certificate through the individual evaluation pathway to satisfactorily complete a 14- week, full-time, college-supervised student teaching experience. They could satisfactorily complete 70 full-time school days or 140 at least half-time school days as an employed teacher, provided that the employment must include at least one continuous period of no fewer than 35 days.

3. COSTS:

The proposed amendment imposes minimal additional costs on educator preparation providers, teacher certification candidates, and/or the New York State school districts/BOCES who wish to hire them. Since 2002, State University of New York teacher preparation programs have required the student teaching experience to be at least 75 days in length, which is equivalent to the full-semester student teaching experience in the proposed regulation. The Department expects the additional clinical experience days to be embedded within the EPP’s revised program, without necessarily increasing the number of course credits, which means that tuition would not increase as a result of the additional days. Increases to program administration costs for institutions that do not already require a full semester of student teaching may include, e.g., salary and travel costs for university supervisors to spend more days in the field and additional stipends/honoraria for cooperating teachers. Participation by school districts and BOCES in the clinical preparation of teacher candidates is voluntary.

4. MINIMIZING ADVERSE IMPACT:

The Department believes that uniform standards for certification must be established across the State. Therefore, no alternatives were considered for those located in rural areas of the State.

5. RURAL AREA PARTICIPATION:

Copies of the proposed amendments have been provided to Rural Advisory Committee for review and comment.

The purpose of the proposed amendments to Sections 52.21 and 80-3.7 of the Regulations of the Commissioner of Education relating to student teaching requirements for teacher certification and the registration of teacher preparation programs is to create greater coherence with other statutory and Department initiatives related to ensuring that all educators have the knowledge and skills necessary to meet the needs of all students. Specifically, the amendments further align the Commissioner’s Regulations with requirements related to the Department’s federally approved Every Student Succeeds Act (ESSA) plan.

The proposed changes to teacher preparation programs include:

• Strengthening the Department’s expectations for collaboration between teacher preparation programs and their partner schools and districts by requiring them to establish, maintain, and review Memoranda of Understanding or similar collaborative agreements to systematically improve teacher preparation and the teaching and learning for all involved in collaborative clinical experiences.

• Requiring the student teaching experience to be at least a full semester (at least 14 weeks), full time, and in alignment with the daily schedule and annual school calendar. Candidates pursuing more than one certificate title, may complete two placements each of at least 7 weeks. The student teaching experience must be designed to provide candidates with opportunities to hone their practices in alignment with the New York State Teaching Standards and shall carry the number of semester hours required to obtain full-time status at the institution to ensure qualification for financial aid.

• Exempting certain experienced teachers from the 100 clock hour field experience requirement and the full-semester student teaching experience, and requiring that they instead complete at least 50 clock hours of student teaching. This exemption would apply to candidates who have previously completed an approved New York State teacher preparation program, those who hold a National Board certificate, and those with at least one year of effective teaching experience under a valid New York State or out-of-state teaching certificate. This change streamlines the regulations for already-certified teachers, which currently require different amounts of hours for field experiences and student teaching, depending on the certificate title.

• Strengthening the Department’s expectations for both school-based educators (cooperating teachers) and university-based teacher educators (supervisors) who work with teacher candidates during clinical experiences.

Section 80-3.7 of the Commissioner’s Regulations outlines the requirements for certification through the individual evaluation pathway. Currently, the coursework requirements for the individual evaluation pathway for certification are based on the educational study requirements for New York State approved teacher preparation programs, including student teaching. As a result, the student teaching requirement for the individual evaluation pathway for certification in Section 80-3.7 needs to change to align with the student teaching experience requirement proposed in Section 52.21.

The proposed changes to Section 80-3.7 would require candidates who apply for a certificate through the individual evaluation pathway to satisfactorily complete a 14- week, full-time, college-supervised student teaching experience. They could satisfactorily complete 70 full-time school days or 140 half-time school days as an employed teacher, provided that the employment must include at least one continuous period of no fewer than 35 days.

Because it is evident from the nature of the proposed amendment that it will have no impact on the number of jobs or employment opportunities in New York State, no further steps were needed to ascertain that fact and none were taken.