As the Director of Human Resources & Administration for Page County Public Schools (Region IV), the following response represents the views of the Administration of Page County Schools.  Response to some of the proposed regulation changes to Teacher Licensure include:

8VAC20-22-50.  A few concerns with this proposal.  First, I worry that the VDOE Licensure specialists will not be able to keep pace with the increase in licensure requests.  Currently, the turn-around time (with provisionals being renewed every 3 years) is challenging (sometimes several months).  It stands to reason, that adjusting from a 3 year review, to a 2 year review will increase their workload and ability to be efficient (unless there are plans to add VDOE Licensure specialists).  Secondly, our school division is a rural Division in the Shenandoah Valley.  Typically, we rank low among Shenandoah Valley School Divisions in teacher salaries.  This provides great challenges in hiring and retention.  Often, we have to hire provisionally licensed teachers, as fully licensed teachers choose higher paying Divisions.  The 3 year provisional process has been fair and effective for our Division to hire competent, qualified teachers who are willing to work towards a goal.  In recent years, we have seen a shortage in fully credentialed teachers.  I am fearful that an unintended consequence of tightening provisional requirements could actually contribute to a teacher shortage, by making the requirements and time frame more strict.

8VAC20-22-90.  As mentioned in 8VAC20-22-50, it does not seem prudent to tighten requirements for teacher licenses, during a time when economical constraints and available qualified teachers are limited (particularly for the rural, less economically advantaged counties).  Our school division has relied heavily on Individuals that possess a Bachelors degree and are willing to enroll in a SPED Masters Program (quite often, these are our experineced SPED Paraprofessionals).  The option of needing 3 hours for a provisional license has enabled us to put experienced paraprofessionals (with a Bachelors degree) into a classroom.  I believe that extending the requirement to 9 credit hours would limit our effectiveness of finding willing, capable employees on the front end of their masters program in SPED.  The 9 credit hour rule may actually create gaps, in which our only option would then be unqualified substitutes.

8VAC20-22-130.  As long as teacher prep programs aren't adding total number of courses/credit hours, this would be OK.  We need to be careful that we are not making license requirements more difficult, during a time when available, licensed teachers may be declining.

8VAC20-22-140.  I believe that these recommendations are positive.  One particularly helpful area is offering positive opportunities to add General Curriculum SPED add-on endorsements by level.