Stakeholders Raise Concerns Over Proposed Teacher Prep Rules
By Krista Kaput
For over a year, the Professional Educator Licensing and Standards Board (PELSB)—the state agency that oversees teacher licensure and prep—has been working to overhaul their process for approving and regulating teacher preparation programs in Minnesota. On Tuesday, there was a formal hearing on their proposed rules—which cover topics like who can serve as a teacher prep instructor, how new teacher prep programs are evaluated and approved, and what student teaching should look like.
The rulemaking process has garnered a lot of attention because, for the first time, the rules need to establish a clear process for teacher prep programs operating outside of colleges and universities. Up until 2017, all programs—including nonconventional programs—still had to operate through an institution of higher education. Legislators removed this requirement, and PELSB has been grappling with how to evaluate true alternative teacher preparation programs—which must still teach the same Standards of Effective Practice as programs based in institutions of higher education.
After seven rule drafts, a formal comment period, and additional last-minute edits, this week’s hearing marked a major milestone and gave stakeholders the chance to share concerns with an Administrative Law Judge (ALJ) who will weigh in on whether the proposed rules are consistent with state law. Unfortunately, there are several areas of concern that could stand in the way of innovative, high-quality, and effective programs flourishing in Minnesota.
Conflicts of Interest in the Review Process
A crucial part of the teacher prep program approval process is a Program Review Pane (PRP): a group of reviewers who assess program criteria and quality and make recommendations about whether a program should be approved or denied. The panel is supposed to be made up of knowledgeable professionals who can apply their expertise to objectively assess whether an application meets specific criteria laid out in law and rule.
Most states establish qualifications for individual members, but Minnesota is taking a more concerning approach by designating seats to specific special interest groups—Education Minnesota and the Minnesota Association of Colleges for Teacher Education (MACTE). Several testifiers raised concerns about potential conflicts of interest and objectivity that this could create in the PRP process.
And it’s not just speculation: Alternative providers have already voiced experiences of bias and conflicting feedback that they have received from MACTE reviewers. To ensure programs are evaluated based on the merits (and that nontraditional approaches are seen through objective eyes), the panel should be composed of independent individuals based on their experience and expertise—teacher preparation providers, educators, administrators, policy experts, researchers—and not organizational affiliation.
Teacher Educator Requirements
One of the most debated issues during the rulemaking process addresses how PELSB should set the bar for who can serve as a teacher educator, training the next generation of classroom teachers.
Up until now, there have been external factors influencing teacher prep: Because institutions of higher education grant college and graduate credits, their teachers need to abide by regulations from the Higher Learning Commission. Alternative teacher preparation providers, on the other hand, do not grant credits and are not subject to the same requirements. In fact, the new alternative teacher preparation law specifies that these programs must be allowed to use “nontraditional criteria to determine qualifications of program instructors, including permitting instructors to hold a baccalaureate degree only.” Examples include previous work experience, teaching experience, educator evaluations, and industry-recognized certifications.
Just three days before the ALJ hearing, and without opportunity for public comment, PELSB made a major last-minute change to require that all teacher educators complete teacher preparation. This change would block many high-quality, experienced teachers from serving as an instructor in teacher prep.
The change would exclude the nearly 400 teachers, including several in licensure shortage areas, who obtained their license through the portfolio route and have demonstrated competence in all of Minnesota’s professional teaching standards. It would also exclude teachers working on Tier 1 and 2 licenses—even if they have years of experience, high evaluations, or other expertise in the field.
Troy Haugen, Director of Career and College Readiness at Lakes County Service Cooperative, noted that the changes would adversely impact career and technical education (CTE) programs—a field with ongoing teacher shortages and where some licensure areas have no preparation programs in Minnesota.
Meanwhile, PELSB received push-back against a more reasonable proposal to require three years of teaching experience before becoming a teacher educator instead of just one. While the research shows that teachers don’t peak until after 3-5 years of teaching, Dr. Rhonda Bonnstetter of MACTE testified that this change would impact 24% of current teacher preparation faculty members.
Clearly, teacher educator requirements is an area where PELSB must do further work to align the requirements to law and avoid creating hurdles, while also creating the opportunity for high-quality and effective classroom teachers to be able to teach candidates.
Redefining Licensure Tiers
In 2017, Minnesota created a new licensure system with four clear, numbered tiers, each with different application and renewal requirements. The goal was to allow professionals to come into teaching based on different backgrounds and experience and to meet local district needs. PELSB’s new rules propose assigning new value to Tier 3 and 4 licenses, calling them “professional” licenses.
This language undermines the high-quality and effective teachers who are working on Tier 1 and Tier 2 licenses. These are standard licenses in law, not “emergency licenses,” nor does the law claim that teachers with a Tier 1 or Tier 2 license do not demonstrate competence in a particular subject. Many Tier 1 and Tier 2 licensed teachers have advanced degrees and years of high-quality and effective teaching as full professionals.
Moreover, over 20% of Minnesota’s teachers of color and Indigenous teachers hold a Tier 1 or Tier 2 license. Classifying them as anything less than licensed classroom teachers would be disproportionately devaluing educators of colors and Indigenous educators.
Excessive Approval Timeline
In the proposed regulations, it would take a prospective teacher preparation program at least 15 months to receive initial approval. This excessive timeline could be a barrier to attracting high-quality alternative teacher preparation programs with the potential to move the needle on teacher diversity and specific shortage areas.
Moreover, it is unnecessary. Lakes Country Service Cooperative and TNTP—two of Minnesota’s first alternative teacher preparation providers that have gone through the process—have repeatedly advocated for cutting the timeline in half. A speedier review process would remove a barrier for high-quality programs without undermining the due diligence necessary to approve programs.
You Can Still Get Involved!
The rulemaking process is nearing the end—but there are a few critical steps and chances to weigh in. Stakeholders have until 4:30 PM on September 21 to submit comments on the proposed regulations.
Then, PELSB and the public are given an opportunity to submit responses to comments that others have submitted. This is known as the rebuttal period and will be open from September 22 to 4:30 PM on September 28.
After September 28, the ALJ will issue a report on whether the regulations need to be further amended or if they can be adopted as they are.
For more background, read the latest rule draft and last-minute changes. And feel free to reach out with questions.