As a rule that requires a RFA, RAFA or JIS, this rule will be initially reviewed in the calendar year 2021, which is no later than the 3rd year after the year in which this rule is being adopted.

Since publication of Emergency Adoption and Proposed Rule Making in the State Register on November 29, 2017, the State Education Department (SED) received several comments:

1. COMMENT:

Several commenters raised a concern about the proposed amendment to the Regulations related to the Transitional G teaching certificate and the proposed addition of the language requiring that the post-secondary teaching experience must have been completed within the 10 years immediately preceding the application for the certificate. The concern is that there was no rationale for the 10-year limit, and that this will eliminate qualified former professors from the certificate pool during a time of STEM teacher shortages in the State.

DEPARTMENT RESPONSE:

The rationale supporting the addition of the 10-year limit to the regulation is that the Department must still ensure that the individual applying for a Transitional G certificate has the teaching skills necessary to walk into a classroom without any additional pedagogical coursework that would normally be required by anyone else pursuing a teaching certificate.

2. COMMENT:

One commenter was in support of the regulation change. However, this commenter raised a concern that Teaching Assistants (TA’s) currently have to quit their full time jobs as TA’s because this time doesn’t count as “teaching hours” when looking to get an initial certificate. Rather, they must take per diem substitute jobs because those hours do count. The commenter asks that the Department address this situation.

DEPARTMENT RESPONSE:

No response is necessary to the extent that the comment is supportive. In response to the concern raised by the commenter that is unrelated to the proposed amendment, the Regulations clearly specify that the duties of a teaching assistant are not the same as a teacher. Further, when using the 40 days in lieu of a formal student teaching experience, an individual is expected to be performing the duties of a teacher for 40 consecutive days with the same group of students.

3. COMMENT:

One commenter raised a concern that the proposed amendment related to the pre-professional certificate “rushes” people through teacher training, does not help, and creates more damage.

DEPARTMENT RESPONSE:

In response to this concern, the proposed amendment to Section 52.21 enables those who hold a preprofessional teaching assistant certificate to complete the student teaching or practica experience required in Section 52.21 of the Commissioner’s Regulations while employed under the pre-professional teaching assistant certificate, provided that the institution ensures that the candidate receives the same and/or similar student teaching experience as prescribed in Section 52.21 of the Commissioner’s Regulations at the location of the candidate’s employment. This change is to accommodate candidates who are employed under a pre-professional teaching assistant certificate in a school district or BOCES while completing the student teaching component of their educator preparation program. The intent of the Department is not to rush experience, rather to provide more flexibility in the existing regulations to those who may need it.

4. COMMENT:

A couple of commenters raised several concerns about the amendments to the Transitional G certificate and ask for several revisions. First, the commenters ask that the Department count adjunct teaching experience and teaching during a Ph. D. or post-doctoral fellowship in situations where the individual is the lead or co-lead instructor and responsible for a class towards the two years of satisfactory postsecondary teaching experience. The commenters also ask that the Department accept a range of “common titles” including professor, instructor, lecturer, teaching fellow, and adjunct professor to count as well. Next, the commenters request that the Department count two or more college courses per semester as “full-time” teaching for purposes of qualifying for the Transitional G certificate. Lastly, the commenters ask that the Department allow candidates with a range of degree titles within a discipline to obtain a Transitional G certificate for the certificate area to be taught. For example, a candidate with a Ph.D. in neuroscience could be able to obtain a Transitional G certificate in biology.

DEPARTMENT RESPONSE:

Experience gained by an individual who is employed as a professor at a college/university is acceptable, which would include an adjunct professor. Experience obtained by individuals who are teaching during a Ph. D. or post-doctoral fellowship in situations where the individual is the lead or co-lead instructor and responsible for a class may be acceptable if the college/university provides sufficient evidence to the Department that the experience is the same as or similar to that of a professor at the college/university.

In response to the commenters’ request for the Department to accept a range of titles, it is not the title that the Department is reviewing, but rather the duties of the experience to ensure that the individual is recognized by the college/university as a professor or recognized faculty member employed to teach at the college/university. To meet the two years of satisfactory teaching experience under the proposed amendment, the experience must include at least one course for at least two semesters per year for two years (e.g., one course in the Fall semester and one in the Spring semester in the 2016-2017 academic year and one course in the Fall semester and one course in the Spring semester in the 2018-2019 academic year).

In response to the last comment, the proposed amendment requires that the degree be in the area or a closely related area as the certificate area sought, which allows for a range of degrees. The Department would need to review the coursework to determine if the degree is in a closely related area.