To: AASCU Presidents, Chancellors and Government Relations staff
From: Ed Elmendorf, Senior Vice President of Government Relations and Policy Analysis
Makese Motley, Assistant Director of Federal Relations and Policy Analysis
Barmak Nassirian, Director of Federal Policy Analysis
Re: Proposed Teacher Prep Regulations/Campus Sexual Assault
Date: 5/2/2014
Teacher Preparation
Last
week U.S. Education Secretary Arne Duncan announced that the Department
of Education will move forward on issuing new proposed regulations for
teacher preparation programs sometime this summer. Indeed, we have
learned that the Department transmitted a draft Notice of Proposed
Rulemaking (NPRM) to the Office of Management and Budget (OMB) for
regulatory clearance on April 28th. This regulatory effort was the
subject of a negotiated rulemaking in early 2012, and is intended to
articulate eligibility
for the TEACH grant program and implement statutory requirements of the
Higher Education Opportunity Act of 2008 with regard to institutional
and programmatic “report cards” on the quality of teacher preparation
programs at institutions participating in federal student aid. While we
will withhold judgment on the proposed regulations until they are
published, we have been quite concerned about the direction in which the
Department appeared to be heading in the unsuccessful 2012 negotiated
rulemaking process. Specifically, we hope that the new NPRM will
reconsider the following problematic elements of the previous approach:
- Use
of the unproven "value-added method" to assess teacher preparation
programs based on student outcomes on standardized tests. The American
Statistical Association just recently issued a policy statement
on this topic that should serve as an analytical warning to the
Department that the path it was pursuing was scientifically and
methodologically flawed.
- Imposition of federally mandated state criteria for teacher program assessment.
- Rating of teacher preparation programs based on the federally mandated state criteria.
- The
precedent-setting linkage of student aid eligibility to program rating,
as the previous proposal to link Title II state program accountability
with TEACH Grants would do.
As
you are aware, AASCU has taken a neutral stance on the administration’s
broader proposal of a college rating system, and we remain committed to
help the Administration and other stakeholders in devising reasonable
accountability metrics to better assess institutional impact. We
certainly don’t believe that teacher preparation programs should be
immune to accountability, but believe any metrics to assess or impose
accountability should be evidence-based and scientific, not politicized
or based on anecdotes.
While it is too early to know what
approach the pending NPRM will adopt, our concern about this regulation
transcends the immediate topic of teacher preparation, and centers on
the imposition of political perspectives on issues that have
historically—and quite correctly—been the exclusive domain of the
faculty and subject solely to their academic judgments.
We strongly urge you to inform your provost and dean or director of
teacher preparation program of this development and suggest that they
familiarize themselves with the substance of the issues discussed during
the last round of negotiated rulemaking on these regulations, so that they can be prepared to submit comments on the NPRM when it becomes available.
To facilitate timely communication with stakeholders on AASCU campuses, we have set up a closed teacher prep discussion
list that you, your provost, your education dean, and other teacher
prep stakeholders can join to monitor and keep up with developments. We
will circulate our analysis of the NPRM when it becomes available to
assist your campus with submission of comments.
White House Task Force on Sexual Assault
This
week, the Whitehouse Task Force on Sexual Assault led by Vice President
Joe Biden released a series of recommendations aimed at reducing the
number of sexual assaults on college campuses. The report
is the conclusion of an initial 90 day period of study where the task
force met with stake holders from inside and outside higher education. A
group of AASCU presidents led by Dr. Muriel Howard attended the
unveiling ceremony and provided feedback to the task force. If you have
feedback on the task force’s recommendations please contact Makese
Motley, Assistant Director of Federal Relations at motleym@aascu.org or at 202-478-4652.
You are encouraged to showcase campus safety initiatives that have proven successful on the AASCU Innovations Exchange
website. The Innovations Exchange is an open access resource featuring
successful programs and practices at AASCU institutions, on a broad
range of topics, with case illustrations presented in concise and
uniform manner. The case illustrations featured on the website are
broadly promoted and used to respond to requests from the White House
and U.S. Department of Education Officials as examples of effective
institutional practices. A new category of Campus Safety is being added
to the list of topics
addressed on the website in light of the Administration’s urgency
involving campus sexual assault prevention. Simply have the appropriate
contact on your campus complete the attached Innovations Exchange
submission form.
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