Docket ID ED-2014-OPE

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1 May 2, 2016 Docket ID ED-2014-OPE The Honorable John B. King, Jr. Secretary U.S. Department of Education 400 Maryland Ave, SW Washington, D.C Dear Secretary King: I write on behalf of the Council for Christian Colleges & Universities (CCCU), a Washington, D.C., based association of Christian institutions of higher education, with 153 located in North America and another 27 in 19 countries around the world. The CCCU s mission is to advance the cause of Christ-centered higher education and to help our institutions transform lives by faithfully relating scholarship and service to biblical truth. In , CCCU institutions enrolled 450,000 students and in total have produced over 1.8 million alumni. In April, the Department of Education published in the Federal Register a Supplemental Notice of Proposed Rulemaking (NPRM), in addition to the NPRM released in December 2014, for which we provided comments to the Department of Education on February 2, 2015 (attached following for your reference). The CCCU continues to affirm the Department s desire for discussion around improving teacher preparatory programs and appropriate measures for accountability, and we continue to share the Department s desire for the highest quality teacher preparation programs in our nation s colleges and universities. We are grateful for the opportunity to continue that discussion. However, the Supplemental NPRM, designed to increase accountability for teacher preparatory distance education programs, does little to assuage our concerns with the overall proposal. We are concerned by a lack of clarity within the language of the Supplemental NPRM, which leads to further questions about the effectiveness of the regulations. We are also concerned that the Supplemental NPRM continues to marginalize individuals committed to teaching in highneeds schools.

2 Lack of Clarity throughout the Supplemental NPRM: There are several elements of the NPRM that are ambiguous and need clarification. The first is the definition of a teacher preparatory distance education program, as updated in the Supplemental NPRM. It seems to apply to courses instead of an overall academic program. In addition, it is ambiguous as to how many courses in a program have to meet the definition before the entire program is considered to be offered through distance education. Many programs have hybrid or blended compositions; it would be helpful to know the exact circumstances under which programs would be held accountable in this new way as distance education programs. We are also concerned by the uncertainty in the process for assessing a program s rating. In this proposal, states would be required to report on the distance education program if at least 25 graduates of that program become certified in the state or aggregated according to the initial NPRM. The initial NPRM permits the states to use a lower threshold than 25, but it is unclear whether the same permission would be applied to distance education programs through the Supplemental NPRM. Finally, we are concerned about the consequences of tying TEACH grant eligibility to how a state classifies a teacher preparatory program. The Supplemental NPRM holds that if a state classifies a program offered by a distance education provider as low performing or at risk of low performing, students enrolled in that same program in other states lose their eligibility to receive TEACH grants. We are greatly concerned about the impact this could have on otherwise high-quality programs, not to mention the legal implications of one state exerting authority over another. Continued Marginalization of Individuals Committed to Serving High- Needs Schools Christian colleges and universities have a long history of preparing highly qualified teachers for America s classrooms. Students on our campuses are mission-focused and service-oriented; therefore, they are willing and able to teach in high-needs schools where students scores on their academic assessments are more likely to reflect poorly on the teacher preparation program. We urge the Department to look for ways to incentivize this willingness of students of programs at all colleges and universities, especially at programs that prepare teachers with the cultural competency to excel in their teaching environment. These programs

3 include distance education programs that prepare individuals not able to attend classes in person due to geography or familial obligations. Compliance challenges arising from the myriad of concerns we have highlighted in this letter, and in our previous letter, could result in these valuable programs shutting down. These challenges would continue to further marginalize not only the very people who want to serve in high-needs schools, but also the students at these schools. This would only increase our teacher shortage, decrease the diversity of teachers, and inhibit the recruitment of teacher candidates. All of these consequences are in direct contrast to the stated goal of this proposal: to increase the quality of teacher preparatory programs. The Council for Christian Colleges & Universities affirms discussions around improving teacher preparatory programs and believes there should be appropriate accountability. However, the Supplemental NPRM does not address our continued concerns regarding the proposal s overall effectiveness. Instead, we are even more concerned about the negative impact they could have on teacher preparatory programs in the years to come. Therefore, we ask the Department to withdraw these proposed regulations in light of the above concerns and instead engage the higher education community regarding how to best encourage and incentivize those institutions that are engaging in the most effective practices in teacher preparation. Sincerely, Shirley V. Hoogstra President

4 February 2, 2015 Ms. Sophia McArdle U. S. Department of Education 1990 K Street, NW, Room 8017 Washington, DC Re: Docket ID ED 2014 OPE 0057 Dear Ms. McArdle, I write on behalf of the Council for Christian Colleges & Universities, a Washington, DC, based association of Christian institutions of higher education, with 153 located in North America and another 24 in 17 other countries around the world. The CCCU's mission is to advance the cause of Christ-centered higher education and to help our institutions transform lives by faithfully relating scholarship and service to biblical truth. In , CCCU institutions enrolled 450,000 students and in total have produced almost 2 million graduates. This past November, the Department of Education proposed regulations that help ensure teacher training programs are preparing educators who are ready to succeed in the classroom. We at the Council for Christian Colleges and Universities (CCCU) share the desire for the highest quality teacher preparation programs in our nation s colleges and universities. Yet, we believe that the proposal has many deep flaws that will create a significant burden on all teacher preparation programs, will inaccurately reflect performance, and will not have the positive effect desired. Disproportionately Negative Effect on Institutions that Accept High-Numbers of High-Needs High School Students and Graduate High-Numbers of Teachers for High-Needs Schools Christian colleges and universities have a long history of preparing highly qualified teachers for America s classrooms. Students on our campuses are mission-focused and service-oriented, therefore, they are more likely to teach in the types of schools where student s scores on their academic assessments are far more likely to reflect poorly on the teacher preparation program. We believe these regulations would adversely affect our institutions, and could result in a less diverse and qualified workforce in these areas as well as aggravate shortages in high-need fields.

5 Methodological Problems Would Give Little Actual Value to the Results Much of our concern stems from the significant methodological problems present in the proposed regulations. These regulations shift the focus of state reporting from inputs to outcomes. In order to accurately track outcomes there must be effective assessments that consider the right variables. Here, neither is present. Student learning assessment tests were not intended to reflect the performance of a teachers preparation program. Because these tests were not designed with that purpose in mind, and to ascribe such significance to the test creates inherent methodological problems. In addition, a teacher preparation program itself cannot be held liable for the many other challenges students in a low-performing school may face. A teacher preparation program cannot be held liable for students whose performance may suffer from outdated textbooks or outmoded technology, an unsafe learning environment, or other such factors that have an adverse affect on their learning. Similar problems exist with the proposal to survey principals regarding a teacher s progress or tracking overall employment rates. The proposal does not address how to weigh a principals rating of a teacher against that principals effectiveness. Or whether the school district makes employment decisions for principals based on quality and effectiveness or based on seniority or other ineffective systems. Additionally, a teacher preparation program cannot be held liable for whether its graduates receive from their employer the kinds of professional development necessary for them to be highly effective in the context in which they teach. Additional methodological problems exist because not all program graduates will be able to be tracked. Those who teach internationally, out of state, or in private schools, will all be left out of the pool, leaving some institutions with only a very small sample of graduates on which its program will be evaluated. The Federal Government is neither Qualified nor Authorized to Review the Academic Quality of Higher Education Programs Title II, Section 207 of the Higher Education Act states that levels of performance shall be determined solely by the state. These regulations violate that provision. In addition, the required statistical collection of information would create a substantial burden and expense for states that could easily divert resources from educational improvement efforts that the states have embarked upon that they are both legislatively entitled to perform, and better able to tailor to their respective needs. 2

6 In addition to attempting to replace state evaluation of teacher performance, this proposal attempts to replace peer-reviewed accreditation of program quality, the long-standing system that has made the quality of higher education in the US the best in the world. This proposal would add to accreditation an additional requirement of federal approval in order for students in the program to be eligible to access Title IV federal funds. This would be a vast expanse of the federal government s role in the evaluation of the academic quality of programs, one it is neither qualified nor legally authorized to perform. Unlike peer-reviewed accreditation, which is a thoughtful process that looks closely at each individual program, this review would be take a cursory, assembly line approach to evaluation making possible the idea that an institution reviewed and accredited by respected fellow academics and administrators could lose funding based on a non-scientific, scattershot, one-size-fits-all survey money style review. This is clearly not the right approach to program evaluation which should be careful, methodical, particular, and individualized; nor is it legally permissible under the Higher Education Act. Finally, we believe that policy changes as significant as those proposed in these regulations should have the benefit of the legislative process. We would hope the Department would submit its proposal to the Congress for scrutiny and consideration during reauthorization instead of implementing federal policy change through regulation. The Council for Christian Colleges and Universities affirms discussions around improving teacher preparatory programs and believes there should be appropriate accountability. The system proposed by these regulations, however, is questionable under current law and has no, even purported, proof of effectiveness. Therefore, we ask the Department to withdraw these proposed regulations in light of the above concerns and to instead engage the higher education community regarding how to best encourage and incentivize those institutions that are engaging in the most effective practices in teacher preparation. Sincerely, Shirley V. Hoogstra President 3

February 2, 2015. Ms. Sophia McArdle U.S. Department of Education 1990 K Street NW Room 8017 Washington, DC 20006. Re: Docket ID ED-2014-OPE-0057

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