Under the Education Department’s proposed regulations, the federal government would require states to issue report cards for teacher preparation programs. (Paige Trisko/AP)

The U.S. Education Department late last year released a draft set of regulations for colleges of education, saying that too many teachers are not prepared to do their jobs well. The draft regulations, which would include ratings of schools by department-set criteria, were immediately controversial with educators and researchers for several reasons, including a provision that would link some federal funding in part to how well the students of their graduates do on standardized test scores.  Interested parties have until Feb. 2 to submit comments on the proposal here.

The National Education Policy Center at the University of Colorado Boulder recently released a review of the proposed regulations. It was written by Kevin Kumashiro, dean of the University of San Francisco School of Education, and identifies a series of major concerns, including “an underestimation of what could be a quite high and unnecessary cost and burden,” “an unfounded attribution of educational inequities to individual teachers rather than to root systemic causes,”  and  “a reliance on scientifically discredited processes of test-based accountability and value-added measures for data analysis.”

The California Alliance of Researchers for Equity and Education, known as CARE-ED, has written an open letter to Education Secretary Arne Duncan urging him to withdraw the proposed regulations. Scores of university-based researchers throughout California (including faculty, researchers, and administrators) have already signed, others can still do so through Jan. 31.  The letter, which will be submitted to the department, can be found online here, and you can read it below.

Open Letter to the Department of Education in Response to the Proposed Teacher Preparation Regulations under Title II of the Higher Education Act

Dear Secretary of Education Duncan and Department of Education Colleagues:

As university teacher educators (including faculty, researchers, and administrators), we strongly urge you to withdraw the proposed 2015 teacher preparation regulations. The proposed regulations do not reflect current research or up-to-date knowledge of teacher preparation, teacher and student assessment, or the purposes of education.

As elaborated in a comprehensive review of the proposed regulations, published by the National Education Policy Center and authored by Kevin Kumashiro, Dean of the School of Education of the University of San Francisco, there are five central flaws in the proposed regulations that should be addressed before their implementation:

• The regulations erroneously place unfounded blame on individual teachers for the perceived failure of the educational system in the United States. This analysis ignores important and well-documented factors that influence student success, such as the impact of poverty, the levels of trauma experienced by youth in urban areas, and accessibility of social services such as health care.

• The regulations include an over-reliance on value-added measures (VAMs), which purportedly identify a causal relationship between student achievement, as measured by high-stakes test scores, and teacher competency. This is a highly controversial form of measurement that several leading research organizations have declared invalid and unreliable. The proposed regulations extend this relationship further to link teacher preparation programs to student achievement; because teacher education programs will be judged by the scores of the students in their graduate’s classrooms, programs may be reluctant to place their graduates in the most difficult and highest poverty classrooms where standardized test scores are more likely to be low.

• The proposed regulations are an unfunded mandate that places an unreasonable burden on educational institutions, especially public institutions that prepare the majority of the nation’s teachers who serve in high poverty districts. The cost of collecting data on the placement and retention of teachers is substantial, especially when the validity of these data are in question.

• This program threatens funding sources, such as TEACH grants, for prospective teachers. Rather than providing this federal source of funding for teachers with financial need who are committed to teaching in high poverty areas, the legislation will reduce the number of institutions who have access to this grant. A consequence of this policy is likely to be that there is less incentive for new teachers of color to enter the teaching force.

• The regulations further narrow the conceptions of teaching and learning, rewarding teaching that is geared toward preparation for tests rather than toward deep engaged learning and preparation for participation in a democratic society.

We recommend that you develop a process for revising these regulations that substantively includes the educational community in advancing your goal of making teacher preparation programs more accountable for successful preparation of teachers. We suggest you convene classroom teachers and school administrators; academics with expertise in teacher education, teaching, learning and student achievement and assessment; and policymakers to develop accountability measures that more accurately assess program quality and the successful preparation of teachers.

Our country is founded on democratic principles that undergird our educational system and the very innovation we are known for throughout the world. The implementation of these regulations could mean that excellent teacher preparation programs and access to becoming and remaining a P12 teacher, especially among communities of color, is in jeopardy. For these reasons and because of our commitment to the future of our profession and the education and success of all children, we urge you to reconsider and significantly revise this proposed regulation.

As of January 26, 2015, the following California Teacher Educators signed this letter:

Katherine Schultz
Dean, Mills College School of Education
kschultz@mills.edu

Alfred Richard Schademan, Jr., Associate Professor, California State University, Chico
Amy Millikan, Director of Clinical Education, San Francisco Teacher Residency
Angel Valencia, Lecturer/Supervisor, CSU, East Bay
Ann Berlak, Retired, SFSU
Ann Schulte, Professor, California State University, Chico
Anna Richert, Professor and Faculty Director, Mills Teacher Scholars, Mills College
Annamarie Francois, Executive Director, Center X, University of California, Los Angeles
Annie Adamian, Adjunct Professor, California State University, Chico
Annette M. Daoud, Professor, California State University San Marcos
Antonia Darder, Leavey Presidential Endowed Chair of Ethics & Moral Leadership, Loyola Marymount University
Brian Gibbs, Lecturer, Claremont Graduate University
Christian Faltis, Professor & Director of Teacher Education, University of California
Christine Sleeter, Professor Emerita, California State University Monterey Bay
Christine Yeh, Professor and Chair, University of San Francisco
Christopher Thomas, Associate Dean, University of San Francisco
Cindy Cruz, Assistant Professor, UC Santa Cruz
Cristian Aquino~Sterling, PhD, Assistant Professor, San Diego State University
Danny C. Martinez, Assistant Professor, University of California, Davis
David V. Madrigal, University Field Supervisor, California State University, East Bay
David A. Stevens, Professor and Director of Clinical Experience, Pepperdine University
David R. Stronck, Professor, California State University, East Bay
Denise M. Fleming, Professor, California State University, East Bay
Eduardo F. Lopez, Faculty Advisor, UCLA
Elena Flores, Associate Dean, University of San Francisco
Elizabeth Fsy, Faculty: Liberal Studies and Child Studies, Santa Clara University
Elizabeth K. Baker, Professor of Practice, Director Mathematics and Science, Mills College
Elizabeth C. Reilly, Professor, Loyola Marymount University
Emma Haydée Fuentes, Associate Professor, University of San Francisco
Erica Hodgin, Research Director, Mills College
Franklin C. Pérez, Adjunct Professor, California State University, Fullerton
Gary Orfield, Professor, UCLA
Genevieve Negrón-Gonzales, Assistant Professor, University of San Francisco
Gilda M. Bloom-Leiva, Professor, San Francisco State University
Helen Maniates, Assistant Professor, University of San Francisco
Imelda L. Nava, Education Faculty, UCLA
Ingrid Seyer-Ochi, Visiting Associate Professor, Mills College
Isabel Nunez, Associate Professor, University of San Francisco
Ivannia Soto-Hinman, Associate Professor, Whittier College
J. Cynthia McDermott, Department Chair, Antioch University
Jaime Park, Faculty Advisor, UCLA
Janelle Scott, Associate Professor, University of California, Berkeley
Janet Irene Hecsh, Administrator in Charge, University Library, California State University, Sacramento
Jennifer Lucko, Associate Professor, Dominican University of California
Jennifer L. Ruef, Doctoral Candidate and Teacher Educator, Stanford University
Jenny Rikkers, MS Placement Coordinator and PT Instructor, California State University, East Bay
Jolynn Asato, Professor, San Jose State University
Joseph Kahne, Professor, Mills College
Karen Cadiero-Kaplan, Professor, San Diego State University
Kathryn Epstein, Professor, Holy Names University
Kelly Caufield Mogilefsky, Lecturer, California State University, East Bay
Kevin Baaske, Professor, California State University Los Angeles
Kevin Kumashiro, Dean, University of San Francisco
Kevin Oh, Assistant Professor, University of San Francisco
Leyla Perez-Gualdron, Assistant Professor, University of San Francisco
Lisa Edsall Giglio University Field Supervisor, California State University East Bay
Magaly Lavadenz, Professor, Loyola Marymount University
Maria Sudduth, Professor Emerita, California State University, Chico
Maren Aukerman, Assistant Professor, Stanford University School of Education
Margarita Berta-Avila, Professor, California State University, Sacramento
Margo Okazawa-Rey, Professor Emertia, San Francisco State University
Mary Howland, Professor, University of San Francisco
Megan Franke, Professor, UCLA
Megan Luce, Researcher, Stanford University
Michael J. Dumas, Assistant Professor, University of California, Berkeley
Miguel G. López, Associate Professor, California State University, Monterey Bay
Miguel Zavala, Assistant Professor, California State University, Fullerton
Minerva S. Chavez, Assistant Professor, California State University, Fullerton
Mónica G García, Assistant Professor, California State University, Northridge
Monisha Bajaj, Associate Professor, University of San Francisco
Nancy Harding, Professor, Pepperdine University
Nick Henning, Assistant Professor, California State University, Fullerton
Nicholas Meier, Adjunct Professor, Brandman University
Nicola McClung, Assistant Professor, University of San Francisco
Pamela Hunt, Professor, San Francisco State University
Pat Stall, Professor, California State University, San Marcos
Patricia Baquedano-Lopez, Associate Professor, University of California, Berkeley
Patricia Mitchell, Associate Professor, University of San Francisco
Patricia D. Quijada, Associate Professor, University of California, Davis
Paula M. Selvester, Professor and Chair of Senate, California State University, Chico
Peter McLaren, Distinguished Professor in Critical Studies, Chapman University
Rande Webster, Dean, Dominican University of California
Rebecca Akin, Visiting Professor, Mills College
Rebeca Burciaga, Assistant Professor, San José State University
Rebecca Fawns-Justeson, Associate Professor, California State University, Chico
Rebecca L. Loboschefsky, University Supervisor, California State University East Bay
Reynaldo Baca, Professor of Clinical Education, University of Southern California
Richard Kahn, Core Faculty in Education, Antioch University Los Angeles
Richard Stout, Program Coordinator/Instructor, California State University, Chico
Rick Ayers, Asst Professor, Teacher Education, University of San Francisco
Rita Kohli, Assistant Professor, University of California, Riverside
Roberta Ahlquist, Professor, San Jose State University
Rosa M Jimenez, Assistant Professor, University of San Francisco School of Education
Rosemarie Michaels, Assistant Professor and Chair, Dominican University of California
Ruchi Agarwal-Rangnath, Adjunct Professor, San Francisco State University
Sarah Capitelli, Assistant Professor, University of San Francisco
Shabnam Koirala Azad, Associate Dean, University of San Francisco
Sumer Seiki, Visiting Assistant Professor, University of San Francisco
Suresh Appavoo, Associate Professor of Education, Dominican University of California
Susan Roberta Katz, Professor and Chair, University of San Francisco
Susan Sato-Tenorio, University Field Supervisor, UCLA
Suzanne SooHoo, Professor, Chapman University
Suzie Abajian, Assistant Adjunct Professor, Occidental College
Teresa L. McCarty, Professor and GF Kneller Chair, UCLA
Theresa Montano, Professor, CSUN
Thomas M. Philip, Assistant Professor, University of California Los Angeles
Tonikiaa Orange, Instructor, Center X, UCLA
Tracy Lachica Buenavista, Associate Professor, California State University, Northridge
Tricia Gallagher-Geurtsen, Instructor, University of San Diego
Tyrone Howard, Professor, UCLA
Uma Madhure Jayakumar, Assistant Professor, University of San Francisco
Ursula S. Aldana, Assistant Professor, University of San Francisco
Valerie Ooka Pang, Professor, San Diego State University
William A. Sandoval, Professor, University of California, Los Angeles