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 December 27, 2017, the State Education Department (SED) received several comments:

1. COMMENT:

Several commenters wrote to support the proposed amendment to create a new certificate and tenure area in computer science. One commenter states that it is reasonable and should pass. Another commenter explained that there is a significant need for computer science literacy in not only NY, but the entire country. The commenter explained that the biggest hurdle is building the “pipeline” for computer science. The commenter explains that because salaries for IT professions are significantly higher than that of a teacher, it can be very difficult to find individuals trained in computer science may be difficult. To solve this, the commenter suggests working with private companies to partner with the state and send volunteers into schools to teach in exchange for a promotion of their company—but also warns of the risk of partnering too closely.

DEPARTMENT RESPONSE:

No response is needed to the extent that the commenters were supportive of the creation of a computer science certificate and tenure area. In response to the concern that there will be difficulty finding properly certified candidates for teaching computer science when a salary in an IT profession is significantly higher, the Department recognizes this, however, the Statement of Continued Eligibility (SOCE) provided for in the regulation will help with this transition by allowing those who already teach computer science to continue doing so for ten years.

2. COMMENT:

Multiple commenters wrote to the Department raising concern with the proposed new certificate and tenure area in computer science. The commenters explained that creating a tenure area in computer science would end up decreasing the number of students exposed to computer science courses in high school rather than increase it because it would limit the number of educators allowed to teach computer science. In addition, the commenters are concerned with the resulting pool of candidates for these positions because many students look to major in computer science and are not also “oriented toward teaching.”

DEPARTMENT RESPONSE:

The proposed amendments are designed to provide as much flexibility as possible to teacher candidates, while still ensuring that they possess the minimum knowledge, skills and abilities to teach computer science The proposed amendment also provides a statement of continued eligibility to allow those individuals who are already teaching computer science the choice between continuing the accrual of time under their current tenure area or switching to a new tenure area (computer science). In addition, please note that incidental teaching under section 80-5.3 for computer science will continue to be allowed under these proposed amendment.

3. COMMENT:

Several comments raised concerns related to the proposed new certificate and tenure area in computer science. These concerns include:

(a) That about 20% of technology education and business teachers are already competent in computer science instruction (including programming, coding, and automation content). Related to this, there are shortages and resource issues affecting these subjects and their teachers.

(b) Publications indicate that the desire right now for coding and programmers is only a short-term situation and will inevitably be replaced by the “next generation of A.I.” soon. Related, due to the lag time with increasing certified teachers in a new certificate area, by the time goals are achieved, the need for these teachers will be gone.

(c) Given lag time for ramping up certification numbers for a new subject area toward any critical mass, by the time we achieve supply goals, the need will quite possibly be dissolved.

(d) The proposed amendment was drafted without proper public vetting of all issues and could result in more wrong-headed political and excessively quick decisions.

(c) There is skepticism by many and suggests that the department look at how resources can be used to provide support for current teacher education programs for technology education, business, science and CTE with accompanying professional development opportunities for current teachers so that school districts can effectively utilize the professionals already employed in their schools to address the goals of computer science instruction.

DEPARTMENT RESPONSE:

In response to the concerns raised, the Department agrees that there are currently educational technology, business, mathematics, and science teachers who are competent to teach computer science and have been doing so. It is for this reason that the department is recommending a Statement of Continued Eligibility (SOCE) for those teachers who have been teaching computer science. Further, the intent of the proposed certification is to address the growing need and desire to prepare students to succeed in a world with constantly evolving computer technologies. As the times change, the Department will be constantly reviewing the current certification titles and pathways.

While the Department recognizes that there may be skepticism in the field about the new computer science certification pathway and tenure area, there is strong support for the creation of a computer science certificate to address the needs of students so that such students can be adequately prepared and college and career ready in this new technological computer age. The Department also recognizes that there will be an initial period of time that the Department will need to monitor the supply and demand of certified computer science teachers to ensure that the needs of school districts and BOCES are met.

4. COMMENT:

One commenter wrote to the Department to raise concerns about the proposal to create a new computer science certificate. One concern is that the proposal will actually impede innovation by school districts in meeting the growing demand for computer science classes. The commenter recommends delaying the proposal until the existing certificate and tenure areas have been reconsidered. Another concern raised is the fact that school districts are already having a difficult time finding qualified teachers. The commenter questions what individuals will pursue computer science certification and how many solely computer science teaching positions actually exist in districts. The commenter raises the point that there are already qualified individuals capable of teaching computer science and they recommend that the statement of continued eligibility be extended indefinitely for those employed before September 1, 2022. The commenter recommends “micro-credentialing” to allow teachers certified in fields like math and science to gain an extension. Last, the commenter believes that computer science certification and instruction should “begin with standards.”

DEPARTMENT RESPONSE:

In response to the comment that the proposal will impede innovation by school districts in meeting the growing demand for computer science, the Department has provided for a transition with the statement of continued eligibility for those currently teaching computer science until September 1, 2022 in order to provide flexibility to school districts—during this time the Department will evaluate the transition and if changes are necessary to effectively implement the new certificate area then the Department will do so.

The Department agrees that there are currently individuals employed that are capable of teaching computer science, and again, that is the basis for the statement of continued eligibility. In addition, please note that incidental teaching for computer science will continued to be allowed under these regulations.

In response to the tenure area concern, the proposal provides flexibility by allowing those individuals already teaching computer science the choice between continuing accrual of time under their current tenure area or switching to a new tenure area.

Lastly, in response to the concern about the standards, part of the Department proposal is to establish minimum and consistent standards for teachers of computer science, and to base these on recommendations from the K-12 Computer Science Framework (referenced in the Regents item memo above).

5. COMMENT:

One commenter wrote in support of the proposal to create a new certificate and tenure area in computer science. The commenter believes it is critical that students receive exposure and instruction in computer science before college, and knowledgeable teachers are essential. The commenter believes that computer science content and pedagogy are both important to this. The commenter also supports the Hunter College computer science proposal model because it meets a balance of computer science pedagogy and content.

DEPARTMENT RESPONSE:

No response is necessary because the comment is supportive.