To the Members of the Board of Elementary and Secondary Education and Mitchell Chester, Commissioner of Education

October 27, 2014

To:       Members of the Board of Elementary and Secondary Education

            Mitchell Chester, Commissioner of Education

           

From:   Barbara Madeloni, President, Massachusetts Teachers Association

            Janet Anderson, Vice President, Massachusetts Teachers Association

Re:       Changes Proposed by DESE to initial licensure and relicensure

On Monday, October 20, the Department of Elementary and Secondary Education released proposed changes to requirements for both initial licensure and relicensure. A day later, the DESE held its first “town hall” hearing about these proposals. These hearings were facilitated by the Keystone Center, but DESE staff were present.

While there are many questions to ask about these proposals that would allow us to gain some clarity of meaning (e.g., what does “grit” mean as a requirement for initial licensure?), the primary question is: How can anyone in good conscience connect an employment evaluation to licensure when these are entirely different areas of authority and oversight? We know of no other profession in which licensure is contingent on employment evaluation. More insidiously, the employment evaluations include student learning outcomes, thus connecting relicensure to student test scores.

We are asking the commissioner to rescind these recommendations in whole for the following reasons:

1.      The DESE is advancing policy options that almost exclusively base license advancement and license renewal on the summative performance ratings in the educator evaluation framework and the student impact rating derived from MCAS growth scores and District-Determined Measures. This is a misuse of measures of student learning and is counter to the DESE’s own assertions about how student learning measures would be used.

2.      As a professional organization representing approximately 80,000 licensed preK-12 practitioner-members, the MTA does not support either the design principles or the policy options outlined in this document. To connect licensure to evaluation is a serious breach of lines of authority and responsibility. The state’s determination of having met requirements to teach should not and cannot extend into performance on the job, which falls under the authority of school administrators. Further, linking performance evaluations to licensure puts all educators on notice: Be careful what you say and do or you risk not only your job, but also your ability to teach or administer in Massachusetts schools.

3.      The MTA does not support short-track preparation programs that allow unqualified and underqualified individuals to enter classrooms as teachers of record without the requisite knowledge and skills to be “classroom ready” on day one. Too often, these underqualified individuals enter high-poverty, low-performing schools, thus contributing to existing achievement gaps and the inequitable distribution of highly effective practitioners.

4.      The MTA decries the use of $550,000 in public funds to pay private vendors for this project. The process employed by these vendors shows little or no interest in engaging in meaningful dialogue about what is and is not effective in the current licensure and relicensure processes. Educators report that they have attended tightly controlled “town halls” in which the outcome seems predetermined and voices of dissent are not welcome. We need meaningful opportunities for input into the development of licensure regulations.

We urge the commissioner and the board in the strongest possible terms to heed the overwhelming opposition to these proposals from the people most directly affected and to act immediately to withdraw the policy options currently being considered.

Thank you.