As a rule that requires a RFA, RAFA or JIS, this rule will be initially reviewed in the calendar year 2017, which is no later than the 3rd year after the year in which this rule is being adopted.

1. COMMENT: On behalf of Teach For America’s New York region, I write in full support of the proposed rulemaking referenced above and the policy improvement that it would represent.

Teach For America is the national corps of outstanding recent college graduates and professionals who commit to teach at least two years in urban and rural public schools and become lifelong leaders in expanding educational opportunity. Approximately two-thirds of our alumni remain involved in education after their corps commitment, including nearly 1,200 teachers in New York State and thousands more across the country.

We have found that the current requirements for interstate reciprocity deter our alumni teachers with less than five years of teaching experience who seek to move to New York from other states, even when they have attended traditional institutions of higher education, and their certification coursework has led to a master’s degree.

Because of their “alternative certification” status, Teach For America alumni cannot move to New York to continue teaching in schools and districts that want to hire them, unless they duplicate their graduate program coursework. Understandably, this is a significant deterrent to our alumni and they choose to teach elsewhere, or move to New York and work in another field.

The proposed rule changes will positively affect teachers coming from the roughly 60% of Teach For America regions that have partnerships with institutions of higher education (IHE). For the other 40%, those with at least two years of experience who did not obtain a master’s degree or complete previous IHE-based coursework in another state, we recommend that New York establish a unique alternate certification pathway that recognizes their initial experience and training. These teachers could be required to take coursework through an accredited, IHE-based program, but would not have to start over through existing alternative certification programs in New York alongside inexperienced, first-year teachers.

We appreciate the Board of Regents focus on ensuring all teachers in New York State are prepared and trained at a consistently high level. We look forward to working in partnership with the state to inspire our interested alumni with previous teaching experience to start a new chapter of their career.

RESPONSE: The State Education Department appreciates the positive comment. Therefore, no response is necessary.

2. COMMENT: On behalf of the New York City Charter School Center, I write in full support of the proposed rulemaking referenced above and the policy improvement that it would represent. The Board of Regents is right to be concerned about how to supply our state’s public schools with the trained and talented teachers they need. Unfortunately, the state’s rules for teacher certification have not been supportive of out-of-state teachers who have the experience and training necessary to succeed in the classroom, adding layers of complexity and uncertainty that are frustrating for new teachers and the schools who hope to hire them. This is especially true in the case of teachers who gain certification through alternative-preparation programs in other states, and then seek recognition of that certification through New York’s reciprocity policies. If such teachers have less than three years’ classroom experience, as is common for alumni of Teach For America (TFA) and similar programs, their certification may not be recognized in New York.

According to district and charter school leaders, the current policy deters many talented and qualified teachers from moving to New York. Those who choose to come to New York anyway frequently enroll in a redundant second alternative preparation program that is essentially identical to their first (including in its two-year length, which is acceptable for New York programs). The new policy would not open the floodgates to all graduates of out-of-state alternative preparation programs; such teachers would still need to complete a preparation program from an accredited institution of higher education, hold a valid certificate equivalent to what they would need to teach in New York State, and pass required tests. (For example, roughly 40% of Teacher For America teachers coming from other states would not qualify for reciprocity because the training they receive is not part of a degree program.)The proposed rulemaking is also advisable, and best evaluated, in tandem with the concurrent proposal to eliminate the Individual Review pathway, which charter schools utilize regularly, in certain certification areas. Approval of both proposals would represent a shift toward a more rational, coherent, and predictable system. Only reducing Individual Review, however, would represent a significant setback for charter schools by reducing their total pool of eligible teachers.

In summary, the proposed rulemaking would correct this costly misalignment in state regulations. The Charter Center urges action to make sure that accomplished, trained, experienced, and certified teachers from other states are not turned away from teaching in the New York communities that need them most.

RESPONSE: The State Education Department appreciates the positive comment. Therefore, no response is necessary.