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Yesterday, the U.S. Department of Education officially published its proposed regulations for parts of Title II of the Higher Education Act (HEA). The put forth requirements for how states and institutions of higher education (IHE) report on the quality of programs that prepare teachers, as well as what accountability measures are tied to that reporting. The goal of Title II of HEA and the associated regulations are to improve the quality of preparation aspiring teachers receive—an area that has recently received much attention from , , as well as . The public has 60 days to comment on the many pages of proposed rules—but we’ve read through them so you don’t have to. What are some of the big changes? And what are some outstanding questions and concerns?

First, the big changes:

Reporting Requirements

• Currently, IHE and state reporting requirements for HEA Title II primarily consist of “inputs” to preparation program quality, such as whether or not programs require a minimum GPA for entry (without even asking, though, what that GPA requirement is). The newly proposed rules would replace the vast majority of these inputs with measures focused on program graduates’ “outcomes,” such as:
  • Employment outcomes, including job placement and retention rates, both overall and specifically in high-need schools
  • Level of graduate preparedness, through surveys of program graduates and employers
  • Graduates’ performance as teachers of record in the classroom, including some measure that reflects their students’ learning growth
• One new input measure would also be required: an assurance that a program has either received specialized accreditation by a recognized accreditor, such as the Council for the Accreditation of Educator Preparation, or that a program “.”
• Under the proposed rules, states and IHEs will be required to report data for each individual program offered by an institution/organization, not just the larger institution as is currently required. For example, an education school must report on its elementary education program separately from its secondary math program. And states will now be required to report data measures for alternative certification programs not housed in institutions of higher education as well, such as Teach for America.

Program Accountability

• Currently, states must only identify “low-performing” or “at-risk” programs (although 34 states have never identified a single low-performing program). The proposed regulations would require states to assign a performance rating to all programs, with a minimum of four performance levels, based on the newly-required reporting measures above in addition to any other measure(s) a state selects.
• The performance rating categories—and how programs are placed in each category—would be determined by each individual state, with the only federal stipulation for performance classification being that a program cannot be rated “effective or higher” if student learning outcomes are not at least “satisfactory.”
• A new federally-mandated consequence for consistently low-performing programs is loss of eligibility for offering newly-admitted candidates TEACH grants, which provide additional federal financial assistance to aspiring teachers who plan to teach in high-need schools and fields for at least four years after graduation.

Despite opposition from some higher education lobbying groups, the Department’s regulations generally reflect the discussions that took place…in the negotiated rulemaking hearing on this topic in early 2012.

Despite from some higher education lobbying groups, the Department’s regulations generally reflect the discussions that took place among the various non-federal stakeholders involved in the negotiated rulemaking hearing on this topic in early 2012. In fact, many of the Department’s proposed rules also reflect recommendations that my colleague, Laura Bornfreund, and I made in our Time to Improve  released earlier this year. These include 1) the basic outcome measures required to be reported; 2) reporting data at the individual program level for both traditional and alternative preparation providers; 3) an implementation timeline that ensures states and program have sufficient time to develop new data collection and reporting tools and thoughtfully determine how to best identify overall program performance levels; and 4) revoking TEACH grant eligibility from less high-performing programs, as the HEA law indicates that TEACH grants are intended for students attending “high-quality” programs.

However, digging deeper into the proposed regulations, there are reasons to be concerned that, in their current form, they may not be strong enough to promote meaningful improvements in the quality of teacher preparation. The biggest reason for concern is that, in an attempt to allow for different state contexts and promote innovative approaches, the Department may have provided too much leeway to states, allowing them to determine—and potentially game—the new reporting and accountability systems.

In an attempt to allow for different state contexts and promote innovative approaches, the Department may have provided too much leeway to states, allowing them to determine—and potentially game—the new reporting and accountability systems.

For example, the Department is proposing multiple potential definitions that states may adopt for certain measures, such as employment retention rates. And in some cases the proposed rules would even allow states to apply different definitions for different types of programs within a state (such as alternative versus traditional providers).

Although Time to Improve recommends that states have latitude to determine which measures to include in their program performance rating systems and in what combination, it also recommends clear definitions for how to define the outcome measures, such as job placement and retention rates. This way, at a minimum, individual metrics could be compared across programs in different states, even if the overall performance levels could not.

While recognizing the difficulty in coming up with “one-size-fits-all” definitions, it’s important to remember that the value in having a federal preparation program quality reporting system is to provide comparable data so that:

• states know where to provide assistance, and potentially reward or penalize programs;
• institutions and programs know how they compare to others in the state, and nationwide, and can focus on areas for improvement; and
• local educational agencies and prospective teachers can make informed choices about which programs to recruit from and attend, respectively.

������Ƶ will be submitting public comments on the proposed regulations that delve more deeply into this and other questions and concerns…check back for more details on those over the coming month.