The Education Department significantly underestimated how much time and money it would cost states and colleges to put in place new rating systems for teacher preparation, a variety of higher education groups contend in comments to the White House’s Office of Management and Budget. (Hat tip to Inside Higher Ed).
The department estimated that the proposed regulations, published in the Federal Register on Dec. 2, would cost some $42 million over 10 years. But that figure is “astoundingly low,” and “artifically low,” the higher ed. groups say in their letters.
The rules would require states to review programs and providers using data from surveys and student-achievement results, among other things. Poor-performing ones would eventually not be able to offer federal financial aid in the form of TEACH grants.
Comments about the the proposed rule’s cost and burden were due to the Office of Management and Budget on Dec. 2. (Comments on the actual policy proposals are due Feb 2; we’ll be covering those later this month.)
The American Council on Education, an umbrella group for many higher education associations, said that even though the feds have invested in data systems, only nine states can currently link K-12 student data to teacher-preparation programs. Inside Higher ED also posted a submission from the California Commission on Teacher Credentialing, which noted the costs associated with seeking legislative authority to link teachers, teacher education programs, and students.
The CCTC also said that it would have to develop some 57 new tests to generate student-achievement data that could be used for all of its licensing areas. It put the total cost of the regs in California at closer to $485 million for just one year.
“We urge you to reject these regulations as the extremely high cost would not provide the stated benefits of either improved accountability or transparency and would impose an undue burden on the State of California,” state officials said.
(It’s worth noting that the chairwoman of the CCTC, Linda Darling-Hammond, is among those who opposes using test scores as a measure of teacher effectiveness, as is state Superintendent Tom Torlakson, who also signed the letter.)
The American Association of Colleges for Teacher Education, the main membership group representing teacher colleges, meanwhile, has laid out an exhaustive list of all the areas in which it thinks the Ed. Department lowballed the burden. Its 38-paged, single-space document, for instance, says more than 11,000 programs don’t have the specialty accreditation (or its substitute) that the feds want to see and that most of the proposed measures would take far more staff and effort to put into place.
“The Department’s assessment that these regulations would actually reduce states’ burden in multiple areas is not at all credible, as they would add substantial data collection and assessment requirements. Numerous internal inconsistencies within the cost and burden estimates also are of concern,” AACTE President Sharon Robinson writes in the document.
Both ACE and AACTE said that the Office of Management and Budget should have a third party should audit the proposed rules to arrive at a better estimate of their cost.
In the meantime, if you’re wondering what exactly states and institutions would have to report, take a look at these report card templates the Education Department has posted. OMB is reviewing those, too.