edTPA Implementation Run Amok

As the so-called “safety-net” deadline of June 30^th approaches, it seems the status of edTPA mayhem is quickly picking up speed. The Regents are now considering a proposed amendment to extend the deadline to June 30, 2016 for other certification requirements such as licensure exams other than edTPA, workshops required for certification, and even program requirements, for those candidates who fail the edTPA, use the “safety net” and take and pass the obsolete ATS-W, and file and pay for certification. This will likely be voted on in April. Meanwhile, let’s review the questions you likely have at this point:

How does the “safety-net” thing work again?

If you are confused, you’re not alone. A CUNY dean was until recently advising candidates to take the ATS-W if they hadn’t already, believing that it was good advice to pre-emptively be ready to use the safety net in case of edTPA failure. This made some sense because in the fine print the “safety-net” provision stated that candidates who had taken the ATS-W prior to April 30, 2014 did not need to retake the exam to qualify for the safety net provision. Therefore, the logic goes, a passing score on that test should be valid for any candidate who doesn’t pass the edTPA. But no! The passing ATS-W score only counts AFTER you have failed the edTPA. Unless of course you had previously (prior to April 2014) taken and passed the test in the good faith that it was a requirement for certification. There is still confusion out there. For example, a SUNY college in a FAQ says:

Q.    If I have already taken the ATS-W before failing the edTPA, can it be used in place of re-taking the edTPA?

A.    NO.  You must take the ATS-W after your edTPA failing grade is posted.

While another SUNY school has the correct information. 

 Meanwhile, if you do the math, those wanting to take the 4-hour ATS-W on paper rather than a computer have to be ready to submit their edTPA by the end of next month in order to have time to get a score and register and take the ATS-W in case they fail in time for the June 30^th deadline. Even if the Regents pass the amendment in April, candidates are still required to have failed the edTPA and taken and passed the ATS-W prior to June 30^th, 2015.

What do the websites say?

Apparently Pearson had no trouble taking money from candidates who believed they could take the ATS-W pre-emptively, and now that it’s become a problematic situation, they have added a note to the website explaining you should only take the test if you failed the edTPA. To get information about how to get a voucher to take the ATS-W for free, however, you have to dig through your college’s website and emails to know what to do. Here’s a handy PDF of the instructions in case you need it. 

Can you register pre-emptively?

That might not be a bad idea, if you are concerned as most candidates are about passing the edTPA, because computer-based test slots in the weeks leading up to the deadline are likely to fill up fast and you may have trouble getting a reservation. It’s going to cost you though, because without the free voucher you have to pay $119 and if you cancel (if you pass the edTPA after all) you’ll only get $84 back in the refund. Pearson, always earning.

Can’t I just submit a crappy edTPA and then take and pass the ATS-W and be done with this nonsense?

Not a good idea because that’s exactly the mentality of people in the state’s Department of Education, so they have put some vague language in the fine print about how an edTPA with an unscoreable code “may or may not” count as a failing grade. Plus that failing score does stay on the TEACH account, branding you forever as a dud. Not that your future employers may care as they can decide for themselves about your qualifications. I did hear a horror story though about a candidate who thought she was lined up for a job in the New York City Department of Education, who was then told she wouldn’t get hired without a passing edTPA score, even though she was certified with the safety net provision.

I’m not worried about the edTPA, it’s this stupid ALST that is killing me!

Your frustration is perfectly understandable. From all accounts, the testing conditions of the ALST are a nightmare and even reasonably smart people are not passing, even when they score a 3 out of 4 on the essay portion. That’s likely because when the cut score was determined, people who made that determination were aiming for a 50% - 60% passing rate. Because let’s face it, this is all about trying to certify fewer teachers and pretending that this will convince the public that these new tests mean we have better new teachers than we did before. Again, talk to people at your college because it is possible that if you failed the ALST you can get a voucher to try again, and know that you may have to try again after that. Don’t have a panic attack. You are not alone. Everyone hates this test.

I’m still waiting to get my other test scores! I thought they said “early 2015” and since my calendar is filling up with deadlines I’d like to know where I stand.

Yeah, the new multi-subject test scores are delayed until “early 2015” because those people who work on cut scores are still figuring out what the passing standards will be so that more people will fail than was previously the case, even though the tests themselves are also harder now than they used to be. My advice: be prepared for a retake. Unless the Regents pass the amendment in April and that will give you another year.

Letter to Duncan on Proposed Regulations

Docket ID ED-2014-OPE-0057

January 30, 2015

The Honorable Arne Duncan

Secretary, U.S. Department of Education

400 Maryland Ave, SW
Washington, DC 20202

Dear Secretary Duncan:

I am a professor of childhood education at Mercy College based in Dobbs Ferry, New York, where I work in New York City’s public schools with our teacher candidates. Mercy is a private, nonsectarian, minority- serving institution with an enrollment of over 11,000 undergraduate and graduate students.  We have a rich tradition of community service both locally and abroad. I am responding to the U.S. Department of Education’s proposed regulations for teacher preparation programs released in the Notice of Proposed Rule Making (NPRM) on December 3, 2014.

Like other teacher preparation programs in institutions of higher education throughout the nation, we have been actively engaged in improving our programs, getting national accreditation (and Mercy College was the first to gain dual initial accreditation from NCATE and CAEP), and working with our partnering districts to provide exceptional beginning teachers for our state’s schools.

In New York State, our teacher preparation programs have also undergone continual reform influenced by the latest policy changes regarding more difficult licensure exams, which felt to many of us like an intentional effort to certify fewer candidates who had already passed the previous exams and requirements. Professor Darling-Hammond even noted at the annual meeting of AERA in 2014, “New York is a prototype of how not to implement teacher performance assessment.”

The regulatory proposal put forward by the Department is flawed for many reasons, but I will focus on what I consider to be the four most important ones. It is an unfunded mandate that grossly underestimates the burden of the proposed regulations; it is a top-down mandate lacking requisite deliberation and input from stakeholders; it creates what are nothing short of perverse incentives for institutions of higher education that will ultimately harm rather than help educational goals; and finally, it uses inappropriate measures and proxies for those measures despite an abundance of evidence regarding the damage resulting from the irresponsible misuse of standardized tests to measure things they were never designed to measure.  

Overall, if these proposed regulations were adopted, they would create an overreach of federal authority into what is currently state-level and institution-level decision-making, and they would set a dangerous precedent to alter federal financial aid policy through regulation rather than through the legislative process. This simply cannot stand as it violates fundamental principles of our democratic processes.

The Department mandates the following indicators as the basis of the rating system to be used by each state (NPRM, pp. 71833-71836):

·       Student Learning Outcomes

·       Placement and Retention Data

·       Graduate and Employer Surveys

·       Accreditation or State Program Approval

The costs associated with gathering and analyzing all of this data are prohibitive, for states and for institutions. They also place a burden of time and effort on institutions and their faculty and staff that are already stretched beyond capacity by the burdens of accreditation. Ultimately such an unfunded mandate will mean harm to all stakeholders, from teacher educators, to teachers, to children, and to the educational institutions meant to help them.

As a top-down mandate, the regulations ignore extant research on a number of issues, and clearly lack the necessary deliberation and input from experts that is required when seeking such broad and far-reaching changes to teacher education. They continue an inappropriate reliance of standardized tests for accountability with no scientific validity, such as the use of value-added modeling (VAM) found in the determination of student growth and in teacher evaluations where student growth is among the measures used, as evidenced in p. 71837 of the NPRM.  The regulations seek to hold institutions accountable for things they have no direct control over, including working conditions of their graduates, employment trends, the ability to collect valid and complete data, and so on. Privacy concerns are not addressed, while we are witnessing a fast-growing national concern about the implications for the massive data tracking that is occurring in education.

These proposed regulations create perverse incentives that will harm rather than help the needed improvements in teacher education. Institutions will be rewarded for not partnering with the high-poverty schools that could benefit from having pre-service teachers and faculty working with them, for not accepting non-traditional candidates into their programs, and for not helping to place graduates in the schools where they are most needed. I wrote of these perverse incentives on my blog in 2013 when the CAEP standards were first released and expressed the concern that such a focus on teacher effectiveness as defined by increasing test scores would lead to a growing lack of attention to many other important factors in considering issues of quality that would have a detrimental effect on P-12 students. The “rigorous teacher candidate entry and exit qualifications” (NPRM, p. 71835) now in place in our state are already having a negative impact on our work, with little evidence to suggest that these licensure requirements will lead to better teaching. For example, the considerable work entailed in completing the edTPA during student teaching has meant a greatly diminished focus on many aspects of preparing pre-service teachers to be capable of having the confidence and skills to be successful first year teachers. I am not alone in believing that this type of performance assessment belongs in the induction years rather than at a time of intense learning as a guest in another’s classroom.

What concerns me the most is the continued irresponsible misuse of standardized test scores to measure things they were never designed to measure. Even as a measure of student learning, we know that standardized tests have considerable limitations. When high stakes are attached, we know that we can have unintended consequences including cheating and data manipulation. VAMs and SLOs were not designed to measure teacher quality. While it is true that for a student to learn in a meaningful way, good teaching is an important factor, effort and interest on the part of the learner is also required, as are opportunities to learn, and a social surround to support learning. That includes high quality curriculum, professional support and development for teachers, extra-curricular activities that enhance students’ educational experiences, access to technology, and more. We know that due to inequities in funding, segregated schools and communities, and the staggering growth of families living in poverty in our country, these elements are not in place in too many of our schools.

Similarly, placing such an overwhelming emphasis on outcome measures in teacher education, neglects other important factors in examining the quality of programs. While teachers’ knowledge and skills matter, so do other qualities such as their ability to communicate and partner with families, to contribute to the school community in meaningful ways, to connect with students and make a difference in their lives. Not everything that matters can be measured by a score or a number. To suggest otherwise is to perpetuate a false view of the purposes of education in a democratic society.

Institutions responsible for preparing teachers are driven by a mission to improve education. Other disciplines may seek knowledge simply for knowledge’s sake, to expand our understanding of the world, but in education we have always worked to make things better. In this era of high-stakes accountability however, we have seen that federal overreach can have disastrous consequences. Our national obsession with competition, rankings and ratings, and the misuse of data is demoralizing the ranks of educators who see in their work a deeper meaning than a better test score.

Thank you for your consideration. I urge you to listen to the voices of professionals who have grave concerns about the proposed regulations and the harm that would result from any implementations.

Sincerely,

Alexandra Miletta/s

Assistant Professor of Childhood Education, Mercy College