The comments below were submitted to the Illinois State Board of Education on behalf of the members of the Illinois Alliance of Administrators of Special Education.
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To: rules@ISBE.net From: Illinois Alliance of Administrators of Special Education (IAASE)
Re: PROPOSED AMENDMENTS FOR PART 25 (EDUCATOR LICENSURE)
The Illinois Alliance of Administrators of Special Education (IAASE), a dynamic professional organization of Illinois leaders, is over 1200 members strong and dedicated to enhancing the field of special education for improved outcomes for students, families, and schools.
On behalf of IAASE, we submit these comments and recommendations regarding Section 25.43 Endorsements for Special Education Teachers for your consideration.
Thank you.
Respectfully submitted,
Dr. Kathlene Shank and Linda Lenoff,
Co-Chairs Personnel Certification and Licensure Committee
Illinois Alliance of Administrators of Special Education (IAASE)
cc: Dr. Kevin Rubenstein, President IAASE
Illinois Alliance of Administrators of Special Education (IAASE)
cc: Dr. Kevin Rubenstein, President IAASE
Jami Hodge, President-Elect IAASE
ILLINOIS ALLIANCE OF ADMINISTRATORS OF SPECIAL EDUCATION (IAASE) RESPONSE
RE: PROPOSED AMENDMENTS FOR PART 25 (EDUCATOR LICENSURE)
Section 25.43 Endorsements for Special Education Teachers
KEY POINTS:
-We strongly oppose obtaining a LBS-I, Deaf/Hard of Hearing, or Blind/Visually Impaired endorsement on any existing educator license, merely through passage of a content test. The content tests were not designed to be the sole determiner of an endorsement in the LBS-I, Deaf/Hard of Hearing, or Blind/Visually Impaired areas.
-From the field, professionals and families of students who are Deaf/Hard of Hearing are also strongly opposed to adding an endorsement through a mere 18 hours of coursework. 18 hours is just not sufficient to meet the unique needs of students with hearing loss. In addition to educational coursework in teaching reading and subject areas specifically for children and youth who are Deaf/Hard of Hearing, teachers licensed in Deaf/Hard of Hearing are currently also required to have coursework in the sciences of Audiology coursework, Speech Pathology coursework, Linguistic development, Aural (re)habilitation, Sign Language, oral language and communication modes, specialized technology of hearing aids, cochlear implants, FM, etc. but these areas would be detrimentally diluted or even eliminated through this proposed amendment’s quick “fix” to teacher shortages.
-There is a required intensity of coursework and field experience essential to the foundation of a teacher of students with sensory disabilities (Deaf/Hard of Hearing, Blind/Visually Impaired) that impacts the quality of the work and decision making that is demanded for each child’s school and life success. In addition to student teaching, teachers endorsed in Deaf/Hard of Hearing and Blind/Visually Impaired have both specialized coursework and specific field experiences. For example: Deaf/Hard of Hearing speech, Deaf/Hard of Hearing language, Deaf/Hard of Hearing reading and content instruction, as well as student teaching. It is vital that teachers endorsed in sensory areas (hearing, vision) have an opportunity for interaction and supervised experience with their special population of students.
-It is also essential that teachers endorsed in sensory areas be able to communicate with their students. Knowledge and skills in sign language and spoken language is essential coursework for communicating with learners with hearing loss. Knowledge and skills in Braille reading and writing is a foundational expertise that is not required of educators who obtain the Blind/Visually Impaired endorsement through this amendment.
-Research shows underprepared teachers are also more likely to be teaching in high-minority and high-poverty schools. (“Addressing California’s Growing Teacher Shortage: 2017 Update,” Carver-Thomas, Desiree and Darling-Hammond, Linda, Feb. 8, 2017.) This could be another unfortunate consequence to ISBE addressing shortages through the proposed shortening of knowledge requirements of special education teachers.
-Research also shows that an increase in attrition is related to a decrease in the teacher’s education and preparation ("What Are the Effects of Teacher Education and Preparation on Beginning Teacher Attrition?" Ingersoll, R., Merrill, L., & May, H. (2014) Philadelphia: Consortium for Policy Research in Education.) To be prepared or have taught in general education is not sufficient to be prepared to teach in special education, simply by passing a test. The long-term impact of underprepared teachers in special education because of no coursework or the inefficient coursework, will adversely impact students, their school, and will increase teacher shortages in special education.
-We are in a situation now where we are all at competition with each other for these candidates – it's the highest paying district that can employ these individuals, leaving some of the less economic areas bare. There are other solutions available to address teacher shortages that will not dilute or eliminate the knowledge and skills required to meet the needs of learners with special education needs, such as: removing barriers/obstacles to teacher entry into preparation programs, scholarships and loan forgiveness, and allowing re-entry of retired staff by continuing and increasing days allowed to work within shortage fields.
OVERVIEW OF CONCERNS: A quick fix to teacher shortages is a flawed fix, when the lives of learners with special education needs will be negatively impacted through these proposed amendments to special education licensure.
We do not want to return to a time where the lack of appropriate training of teachers led to 20 years of Corey H. litigation. (Corey H. v. Chicago Board of Education, No. 12-2834, 7th Cir. 2013.) Reductions in coursework or eliminating the need for any special education coursework, will leave educators unprepared for the job to serve our special education learners.
The “Message from State Superintendent Dr. Carmen I. Ayala, April 30, 2019” states “Ultimately, my long-term goal is to develop an education system in Illinois that guarantees every child receives services, supports, and opportunities to thrive in their chosen path after high school.” These proposed amendments allowing for untrained or ill-prepared special education teachers are barriers to this path.
The burdens to the child and their families will be educational and social emotional ones, with barriers for achieving school, college, career, and life success, as the needs of the learner with special education will not be effectively met by these proposed untrained (endorsement solely through test passage) or under-prepared LBS-I, Deaf/Hard of Hearing, and Blind/Visually impaired Illinois endorsed teachers.
The additional challenges of the legal and financial consequences to school districts from the results of this amendment are predictable and unfortunate, but preventable if these proposed amendments to special education licensure (LBS-I, Deaf/Hard of Hearing, and Blind/Visually impaired) are withdrawn.
Section 25.43 Endorsements for Special Education Teachers
f LBS I ENDORSEMENT
CONCERNS: Shortcuts in training and allowing endorsement based merely on passing the LBS-I content test (as this test was never designed to be sole determiner of special educator license endorsement) is unfair to students with disabilities and their families, as the research clearly shows that student progress is negatively affected when the teacher is underprepared.
Illinois does not allow shortcuts for School Psychologists, Speech and Language Pathologists, School Social Workers, nor Nurses; yet for the professional that is most instrumental in assuring the learner with disabilities across the LBS-I spectrum will be allowed to perform this role with significantly less preparation under these currently proposed amendments. Being prepared as an early childhood, elementary, middle grades, art, music, health, PE, transitional bilingual, or high school content teacher, does not prepare anyone to have the knowledge and skills essential to providing an appropriate, unique, specialized educational program for learners across the disability range encompassed by the LBS-I endorsement (Autism, Emotional Disability, Intellectual Disability, Other Health Impairment, Specific Learning Disabilities, and Traumatic Brain Injury.)
Illinois Universities have capacity to serve many more LBS-I candidates, but the candidates are not meeting the Illinois increasingly imposed state restrictions for entry into LBS-I training.
Currently the State requires an ACT of 22 (63rd percentile) or 1110 SAT (69th percentile) for which there is no research to equate passing this test, with an individual becoming an effective entry-level teacher. Testing requirements for entry into training is an obstacle that has restricted young people, especially those of color, and non-traditional candidates (para-professionals and substitutes) from pursuing a special education teaching career. Changing from arbitrary basic skill test score cut-offs, to allowing the use of grades in college level English and Math classes, is a recommended solution for ISBE consideration to address teacher shortages. LBS-I candidates with lower ACT and SAT scores can and would be provided intense training and exposure to purposeful experiences through their educational program. Higher education can ensure graduates have "basic skills” as evidenced through their coursework.
The Basic Skills assessment should be eliminated for all (Section 25.720 Applicability of Testing Requirement and Scores b)Basic Skills Test.) The Basic Skills Test scores and college entry scores have impacted teacher shortages. The Basic Skills test has never correlated to good teaching and no new test will do it either. The cut-off scores for the Basic Skills test, ACT (22), or SAT (1030) are contributing significantly to the shortages and decline of teacher education graduates across the State and across subject areas. Some related data: In 2010-11, for teacher education program completers who were under the original Basic Skills test, statewide 18,712 individuals took State Content Area Tests. However in 2015-16, with the revised cut-score in place for the Basic Skills test, there was a significant drop to 7609 in eligible candidates taking State Content tests. In 2010-11, 2586 candidates took the LBS-I Content Test, however in 2015-16, only 1891 candidates took the LBS-I Content Test, a significant decline.
RECOMMENDATIONS: The LBS-I endorsement should not be obtained simply by means of passing a test, as a way to address teacher shortages. A content test such as the LBS-I can only measure minimal aspects of knowledge. It was not designed to be a discrete determiner of an individual's knowledge and skills to teach the broad range of disabilities encompassed by the LBSI endorsement. The resulting long-term adverse impact to learners with special education needs would be too great a consequence. The proposed amendment to LBS-I endorsement through content test passage should be withdrawn.
A solution is found in "Section 25.48, Short -Term Emergency Approval in Special Education," for individuals with a PEL (Professional Educators License) to be hired to teach learners encompassed by the LBS-I endorsement, if they have been offered a LBS-I teaching position and the individual has a plan to complete the coursework for the LBS-I endorsement within a three year timeframe." Given that the subsequent endorsement requires 18 hours of coursework, this pathway to endorsement is very doable in 3 years. The result of using this vehicle is the district/cooperative has a teacher in place, and within 3 years, the individual has at least 18 semester hours of coursework that will result in a teacher with more knowledge and skills than can be measured by passing a single test.
It is strongly recommended that this “Short-Term Emergency Approval in Special Education” continue to be issued beyond July 1, 2020 (as it is set to expire then.)
There are other solutions to teacher shortages as well. There are candidates wanting to enter the special education teaching profession, but are not allowed access due to the ever-increasing entry ACT and SAT requirements and Basic Skills cut-off scores, which are not grounded in research for effective teaching. It is recommended that the ISBE focus not be on removing knowledge and skills (reduction of coursework or the removal of field experience for sensory endorsements) from licensure, but instead removing obstacles/barriers to becoming a teacher candidate.
Other solutions are scholarships and loan forgiveness to cover tuition and living expenses to teacher candidates who commit to teach in shortage areas. Also eliminate barriers to re-entry of retired teachers, by continuing and increasing days allowed to work within shortage fields.
Section 25.43 Endorsements for Special Education Teachers
g) 2 TEACHERS OF STUDENTS WHO ARE DEAF OR HARD OF HEARING
CONCERNS: There is great concern in the field of Deaf/Hard of Hearing that the State would entertain to immediately weaken the integrity of the Illinois Deaf/Hard of Hearing licensure in order to meet any DHH shortages. This is not the answer to teacher shortages. This is a path forward fraught with continuous struggles for the child with hearing loss.
The true impact of a sensory disability is pervasive and must never be undercut through imposed reductions in DHH teacher training/licensure requirements. The consequence of this amendment will have a profoundly negative impact on student well-being, school achievement, and life success for learners who are Deaf or Hard of Hearing.
The Illinois historical perspective has proven that reducing the coursework requirements for teachers of students who are Deaf/Hard of Hearing in a time of shortage, presented the field with staff that did not benefit from the intensity of training needed, and were not equipped to address the true diversity of children with hearing loss. After the rubella outbreak of the 60s, the State allowed teachers to have reduced coursework and training, so to acquire quicker certification to be teachers of “hard of hearing” students. It took years of attrition for those teachers (who did not have the benefit of intensive training) to exit the field.
We do not want to return to a time where there were teachers who did not have the required intensive, quality training for teaching learners with a range of hearing loss and needs. Consequently ISBE created rigorous requirements to be a teacher of students who are Deaf/Hard of Hearing and these current requirements must continue. Without experience and rigorous training, “… professionals may not understand that hearing loss of any degree or type affects the quantity and the quality of interactions with others, which in turn may adversely impact language and academic, social, emotional, and career development.” (Ferrell, K. A., Bruce, S., & Luckner, J. L. (2014). “Evidence-based Practices for Students with Sensory Impairments” (Document No. IC-4). University of Florida, Collaboration for Effective Educator, Development, Accountability, and Reform Center)
With this current proposed amendment, future Illinois licensed DHH teachers are not required to ever have seen or interacted with a learner who is Deaf or Hard of Hearing. In the proposed amendments, a currently licensed teacher with any educational endorsement (music, biology, etc.) can merely pass the DHH content test (a test which was never designed to be the sole tool of determining qualification to be endorsed in Deaf/Hard of Hearing) or take a mere 18 hours coursework. This is woefully inadequate. “We live in a sound-oriented society. Extensive amounts of information are deliberately and incidentally conveyed through verbal interactions with others.” Ferrell, K. A., Bruce, S., & Luckner, J. L. (2014). Evidence-based practices for students with sensory impairments (Document No. IC-4). University of Florida, Collaboration for Effective Educator, Development, Accountability, and Reform Center.) Also, with this proposed amendment, teachers of students with hearing loss, will not even be expected to be able to communicate with the students they serve.
The population of students, who are Hard of Hearing or Deaf, is a diverse one and requires a depth of quality training. Understanding of the impact of hearing loss requires strong foundations in the sciences of Linguistic development, Audiology coursework, Speech Pathology coursework, Aural (re)habilitation, Sign Language, specialized technology, communication modes, etc. –all which now are ISBE-required and fully integrated into the instructional perspective of every DHH teacher, but would be detrimentally diluted or even eliminated through this amendment’s quick “fix.” It is not only the coursework, it is the also the synergy of the knowledge and skills, the interaction of all the specific training and opportunity for supervised experience that is currently required to be a successful teacher of learners who are Deaf/Hard of Hearing. It is the integrated application of all this knowledge, all these skills, to truly understand the unique linguistic, social-emotional, and communication impact of hearing loss on each and every subject area and social relationships, plus how to effectively communicate with the learner with hearing loss. This strikes at the very heart of hearing loss.
The long-term adverse impact of licensed teachers of the deaf/hard of hearing children who are untrained or ill-prepared to effectively meet student needs, will be devastating to the future of these children in school and in the community. There is a required intensity of coursework, student teaching and field experiences (in Deaf/Hard of Hearing: for speech, in Deaf/Hard of Hearing: for language, in Deaf/Hard of Hearing: for reading and content instruction, as well as student teaching) that is essential to the foundation of a DHH teacher that impacts the quality of the work and decision making that is demanded for each child’s school and life success. No teacher who holds a valid license with an early childhood, elementary, middle grades, secondary or special teaching endorsement, or a valid educator license with stipulations endorsed for transitional bilingual educator, should be allowed to add a sensory (deaf or blind/visually impaired) disability endorsement to their license through a single test or a mere 18 hours of coursework.
RECOMMENDATIONS: Requirements of the Deaf/Hard of Hearing licensure should not be lessened through a reduction in coursework or simply by means of just passing a test, as a way to address teacher shortages. The resulting long-term adverse impact to learners with hearing loss would be too great a consequence. The proposed amendments to Deaf/Hearing of Hearing licensure should be withdrawn.
There are candidates wanting to enter the special education teaching profession, but are not allowed access due to the ever-increasing entry ACT/SAT requirements and Basic Skill cut-off scores, which are not grounded in research for effective teaching. It is recommended that the ISBE focus NOT be on removing knowledge and skills (reduction of coursework or the removal of field experience for sensory endorsements) from licensure, but instead on removing obstacles/barriers to becoming a teacher candidate.
Other solutions are scholarships and loan forgiveness to cover tuition and living expenses to teacher candidates who commit to teach in shortage areas. Another solution is to work with Universities (ISU/ MacMurray) to offer coursework through a cohort taught locally by currently employed or retired, IL licensed Supervisors/Coordinators endorsed in Deaf/Hard of Hearing. Various State incentives could support this idea. Also work to eliminate barriers to re-entry of retired teachers, continuing and increasing days allowed to work within shortage fields.
Section 25.43 Endorsements for Special Education Teachers
g) 1 TEACHERS OF STUDENTS WHO ARE BLIND OR VISUALLY IMPAIRED
There is also great concern in the field of Blind/Visually Impaired that Illinois would also immediately and severely weaken integrity the Blind/Visually Impaired licensure in order to address teacher shortages. Again, a reduction in quality to teacher preparation is not the answer to teacher shortages.
The proposed amendment to add quick fix for the Blind/Visually Impaired endorsement for teachers who already hold any teaching license (art, early childhood) by simply either passing a content test (which was not designed to be the sole determiner of endorsement) or a mere 18 hours of this coursework will have long reaching adverse consequences to learners with Vision loss and their families, in school and in employment, now and in the future.
Licensed, but untrained teachers will not be able to meet the current and future vision needs of these students. Effective immediately with this proposed amendment, Illinois teachers in endorsed in the sensory area of Blind/Visually impaired, are no longer required to be proficient in Braille reading and writing. This lack of required skill in Braille and knowledge of Braille instruction in the current proposed licensure fix is astounding to the field.
From United States Department of Education Office of Special Education and Rehabilitative Services, guidance letter, June 19, 2013: “For decades, Braille has been a key tool for literacy for many blind and visually impaired individuals.” “Research has shown that knowledge of Braille provides numerous tangible and intangible benefits, including increased likelihood of obtaining productive employment and heightened self-esteem.“ “The purpose of this letter is to provide guidance to States and public agencies to reaffirm the importance of Braille instruction as a literacy tool for blind and visually impaired students, to clarify the circumstances in which Braille instruction should be provided, and to reiterate the scope of an evaluation required to guide decisions of IEP Teams in this area.” Skill in reading and writing Braille is essential in preparation of teachers endorsed in Blind/Visually Impaired, but this can be sidestepped through these proposed amendments by just taking the content test or allowing a reduction in hours of training for the endorsement.
The population of students, who are Blind/Visually Impaired, is a diverse one and requires a depth of quality teacher training. The education of a student who is Blind/Visually impaired requires more than just knowledge of specially-designed instruction in curriculum areas, but also skill and knowledge of teaching and supporting the expanded core curriculum (Compensatory, Functional and Communication Skills; Sensory Efficiency; Orientation & Mobility; Social; Independent Living; Recreation & Leisure; Use of Technology; Career & vocational; and Self Determination.) Knowledge and skills with low vision and blindness-specific assistive technology is important as well. Education of students with visual impairments requires "access to print or finding an alternative modality that will provide an equivalent quality and quantity of information.” "The skills and knowledge that sighted students acquire by casually and incidentally observing and interacting with their environment are often difficult, if not impossible, for blind and visually impaired students to learn without direct, sequential instruction by knowledgeable persons.” (ABF The Expanded Core Curriculum for Blind and Visually Impaired Children and Youths.)
With this proposed amendment, future Illinois endorsed Blind/Visually Impaired teachers are not required to have ever observed, instructed, or interacted with a learner who has a vision loss, if the teacher is now currently licensed with any educational endorsement. No teacher who holds a valid license with an early childhood, elementary, middle grades, secondary or special teaching endorsement, or a valid educator license with stipulations endorsed for transitional bilingual educator, should be allowed to add a sensory (deaf or blind/visually impaired) disability endorsement to their license through a single test or a mere 18 hours of this stated coursework.
The long-term adverse impact of Blind/Visually Impaired endorsed teachers who are untrained or ill-prepared to effectively meet student needs, will be devastating to the life success of these children in school, in employment, and in the community, now and in the future.
RECOMMENDATIONS: Requirements of the Blind/Visually Impaired licensure should not be lessened through a reduction in disability specific coursework or simply by means of just passing a test, as a way to address shortages. The resulting long-term adverse impact to learners with vision loss would be too great a consequence. The proposed amendment to Blind/Visually Impaired licensure should be withdrawn.
There are other solutions to teacher shortages. There are candidates wanting to enter the special education teaching profession, but are not allowed access due to the ever-increasing entry ACT/SAT requirements and Basic Skill cut-off scores, which are not grounded in research for effective teaching. It is recommended that the ISBE focus NOT be on removing knowledge and skills (reduction of coursework or the removal of field experience for sensory endorsements) from licensure, but instead removing obstacles/barriers to becoming a teacher candidate.
Other solutions are scholarships and loan forgiveness to cover tuition and living expenses to teacher candidates who commit to teach in shortage areas. Another solution is to work with Universities (ISU/NIU) to offer coursework through a cohort taught locally by currently employed or retired, IL licensed Supervisors/Coordinators endorsed in Blind/Visually Impaired. Various State incentives could support this idea. Another solution is to eliminate barriers to re-entry of retired teachers, continuing and increasing days allowed to work within shortage fields.
Thank you for this opportunity to give public comment.
ILLINOIS ALLIANCE OF ADMINISTRATORS OF SPECIAL EDUCATION (IAASE) RESPONSE
RE: PROPOSED AMENDMENTS FOR PART 25 (EDUCATOR LICENSURE)
Section 25.43 Endorsements for Special Education Teachers
KEY POINTS:
-We strongly oppose obtaining a LBS-I, Deaf/Hard of Hearing, or Blind/Visually Impaired endorsement on any existing educator license, merely through passage of a content test. The content tests were not designed to be the sole determiner of an endorsement in the LBS-I, Deaf/Hard of Hearing, or Blind/Visually Impaired areas.
-From the field, professionals and families of students who are Deaf/Hard of Hearing are also strongly opposed to adding an endorsement through a mere 18 hours of coursework. 18 hours is just not sufficient to meet the unique needs of students with hearing loss. In addition to educational coursework in teaching reading and subject areas specifically for children and youth who are Deaf/Hard of Hearing, teachers licensed in Deaf/Hard of Hearing are currently also required to have coursework in the sciences of Audiology coursework, Speech Pathology coursework, Linguistic development, Aural (re)habilitation, Sign Language, oral language and communication modes, specialized technology of hearing aids, cochlear implants, FM, etc. but these areas would be detrimentally diluted or even eliminated through this proposed amendment’s quick “fix” to teacher shortages.
-There is a required intensity of coursework and field experience essential to the foundation of a teacher of students with sensory disabilities (Deaf/Hard of Hearing, Blind/Visually Impaired) that impacts the quality of the work and decision making that is demanded for each child’s school and life success. In addition to student teaching, teachers endorsed in Deaf/Hard of Hearing and Blind/Visually Impaired have both specialized coursework and specific field experiences. For example: Deaf/Hard of Hearing speech, Deaf/Hard of Hearing language, Deaf/Hard of Hearing reading and content instruction, as well as student teaching. It is vital that teachers endorsed in sensory areas (hearing, vision) have an opportunity for interaction and supervised experience with their special population of students.
-It is also essential that teachers endorsed in sensory areas be able to communicate with their students. Knowledge and skills in sign language and spoken language is essential coursework for communicating with learners with hearing loss. Knowledge and skills in Braille reading and writing is a foundational expertise that is not required of educators who obtain the Blind/Visually Impaired endorsement through this amendment.
-Research shows underprepared teachers are also more likely to be teaching in high-minority and high-poverty schools. (“Addressing California’s Growing Teacher Shortage: 2017 Update,” Carver-Thomas, Desiree and Darling-Hammond, Linda, Feb. 8, 2017.) This could be another unfortunate consequence to ISBE addressing shortages through the proposed shortening of knowledge requirements of special education teachers.
-Research also shows that an increase in attrition is related to a decrease in the teacher’s education and preparation ("What Are the Effects of Teacher Education and Preparation on Beginning Teacher Attrition?" Ingersoll, R., Merrill, L., & May, H. (2014) Philadelphia: Consortium for Policy Research in Education.) To be prepared or have taught in general education is not sufficient to be prepared to teach in special education, simply by passing a test. The long-term impact of underprepared teachers in special education because of no coursework or the inefficient coursework, will adversely impact students, their school, and will increase teacher shortages in special education.
-We are in a situation now where we are all at competition with each other for these candidates – it's the highest paying district that can employ these individuals, leaving some of the less economic areas bare. There are other solutions available to address teacher shortages that will not dilute or eliminate the knowledge and skills required to meet the needs of learners with special education needs, such as: removing barriers/obstacles to teacher entry into preparation programs, scholarships and loan forgiveness, and allowing re-entry of retired staff by continuing and increasing days allowed to work within shortage fields.
OVERVIEW OF CONCERNS: A quick fix to teacher shortages is a flawed fix, when the lives of learners with special education needs will be negatively impacted through these proposed amendments to special education licensure.
We do not want to return to a time where the lack of appropriate training of teachers led to 20 years of Corey H. litigation. (Corey H. v. Chicago Board of Education, No. 12-2834, 7th Cir. 2013.) Reductions in coursework or eliminating the need for any special education coursework, will leave educators unprepared for the job to serve our special education learners.
The “Message from State Superintendent Dr. Carmen I. Ayala, April 30, 2019” states “Ultimately, my long-term goal is to develop an education system in Illinois that guarantees every child receives services, supports, and opportunities to thrive in their chosen path after high school.” These proposed amendments allowing for untrained or ill-prepared special education teachers are barriers to this path.
The burdens to the child and their families will be educational and social emotional ones, with barriers for achieving school, college, career, and life success, as the needs of the learner with special education will not be effectively met by these proposed untrained (endorsement solely through test passage) or under-prepared LBS-I, Deaf/Hard of Hearing, and Blind/Visually impaired Illinois endorsed teachers.
The additional challenges of the legal and financial consequences to school districts from the results of this amendment are predictable and unfortunate, but preventable if these proposed amendments to special education licensure (LBS-I, Deaf/Hard of Hearing, and Blind/Visually impaired) are withdrawn.
Section 25.43 Endorsements for Special Education Teachers
f LBS I ENDORSEMENT
CONCERNS: Shortcuts in training and allowing endorsement based merely on passing the LBS-I content test (as this test was never designed to be sole determiner of special educator license endorsement) is unfair to students with disabilities and their families, as the research clearly shows that student progress is negatively affected when the teacher is underprepared.
Illinois does not allow shortcuts for School Psychologists, Speech and Language Pathologists, School Social Workers, nor Nurses; yet for the professional that is most instrumental in assuring the learner with disabilities across the LBS-I spectrum will be allowed to perform this role with significantly less preparation under these currently proposed amendments. Being prepared as an early childhood, elementary, middle grades, art, music, health, PE, transitional bilingual, or high school content teacher, does not prepare anyone to have the knowledge and skills essential to providing an appropriate, unique, specialized educational program for learners across the disability range encompassed by the LBS-I endorsement (Autism, Emotional Disability, Intellectual Disability, Other Health Impairment, Specific Learning Disabilities, and Traumatic Brain Injury.)
Illinois Universities have capacity to serve many more LBS-I candidates, but the candidates are not meeting the Illinois increasingly imposed state restrictions for entry into LBS-I training.
Currently the State requires an ACT of 22 (63rd percentile) or 1110 SAT (69th percentile) for which there is no research to equate passing this test, with an individual becoming an effective entry-level teacher. Testing requirements for entry into training is an obstacle that has restricted young people, especially those of color, and non-traditional candidates (para-professionals and substitutes) from pursuing a special education teaching career. Changing from arbitrary basic skill test score cut-offs, to allowing the use of grades in college level English and Math classes, is a recommended solution for ISBE consideration to address teacher shortages. LBS-I candidates with lower ACT and SAT scores can and would be provided intense training and exposure to purposeful experiences through their educational program. Higher education can ensure graduates have "basic skills” as evidenced through their coursework.
The Basic Skills assessment should be eliminated for all (Section 25.720 Applicability of Testing Requirement and Scores b)Basic Skills Test.) The Basic Skills Test scores and college entry scores have impacted teacher shortages. The Basic Skills test has never correlated to good teaching and no new test will do it either. The cut-off scores for the Basic Skills test, ACT (22), or SAT (1030) are contributing significantly to the shortages and decline of teacher education graduates across the State and across subject areas. Some related data: In 2010-11, for teacher education program completers who were under the original Basic Skills test, statewide 18,712 individuals took State Content Area Tests. However in 2015-16, with the revised cut-score in place for the Basic Skills test, there was a significant drop to 7609 in eligible candidates taking State Content tests. In 2010-11, 2586 candidates took the LBS-I Content Test, however in 2015-16, only 1891 candidates took the LBS-I Content Test, a significant decline.
RECOMMENDATIONS: The LBS-I endorsement should not be obtained simply by means of passing a test, as a way to address teacher shortages. A content test such as the LBS-I can only measure minimal aspects of knowledge. It was not designed to be a discrete determiner of an individual's knowledge and skills to teach the broad range of disabilities encompassed by the LBSI endorsement. The resulting long-term adverse impact to learners with special education needs would be too great a consequence. The proposed amendment to LBS-I endorsement through content test passage should be withdrawn.
A solution is found in "Section 25.48, Short -Term Emergency Approval in Special Education," for individuals with a PEL (Professional Educators License) to be hired to teach learners encompassed by the LBS-I endorsement, if they have been offered a LBS-I teaching position and the individual has a plan to complete the coursework for the LBS-I endorsement within a three year timeframe." Given that the subsequent endorsement requires 18 hours of coursework, this pathway to endorsement is very doable in 3 years. The result of using this vehicle is the district/cooperative has a teacher in place, and within 3 years, the individual has at least 18 semester hours of coursework that will result in a teacher with more knowledge and skills than can be measured by passing a single test.
It is strongly recommended that this “Short-Term Emergency Approval in Special Education” continue to be issued beyond July 1, 2020 (as it is set to expire then.)
There are other solutions to teacher shortages as well. There are candidates wanting to enter the special education teaching profession, but are not allowed access due to the ever-increasing entry ACT and SAT requirements and Basic Skills cut-off scores, which are not grounded in research for effective teaching. It is recommended that the ISBE focus not be on removing knowledge and skills (reduction of coursework or the removal of field experience for sensory endorsements) from licensure, but instead removing obstacles/barriers to becoming a teacher candidate.
Other solutions are scholarships and loan forgiveness to cover tuition and living expenses to teacher candidates who commit to teach in shortage areas. Also eliminate barriers to re-entry of retired teachers, by continuing and increasing days allowed to work within shortage fields.
Section 25.43 Endorsements for Special Education Teachers
g) 2 TEACHERS OF STUDENTS WHO ARE DEAF OR HARD OF HEARING
CONCERNS: There is great concern in the field of Deaf/Hard of Hearing that the State would entertain to immediately weaken the integrity of the Illinois Deaf/Hard of Hearing licensure in order to meet any DHH shortages. This is not the answer to teacher shortages. This is a path forward fraught with continuous struggles for the child with hearing loss.
The true impact of a sensory disability is pervasive and must never be undercut through imposed reductions in DHH teacher training/licensure requirements. The consequence of this amendment will have a profoundly negative impact on student well-being, school achievement, and life success for learners who are Deaf or Hard of Hearing.
The Illinois historical perspective has proven that reducing the coursework requirements for teachers of students who are Deaf/Hard of Hearing in a time of shortage, presented the field with staff that did not benefit from the intensity of training needed, and were not equipped to address the true diversity of children with hearing loss. After the rubella outbreak of the 60s, the State allowed teachers to have reduced coursework and training, so to acquire quicker certification to be teachers of “hard of hearing” students. It took years of attrition for those teachers (who did not have the benefit of intensive training) to exit the field.
We do not want to return to a time where there were teachers who did not have the required intensive, quality training for teaching learners with a range of hearing loss and needs. Consequently ISBE created rigorous requirements to be a teacher of students who are Deaf/Hard of Hearing and these current requirements must continue. Without experience and rigorous training, “… professionals may not understand that hearing loss of any degree or type affects the quantity and the quality of interactions with others, which in turn may adversely impact language and academic, social, emotional, and career development.” (Ferrell, K. A., Bruce, S., & Luckner, J. L. (2014). “Evidence-based Practices for Students with Sensory Impairments” (Document No. IC-4). University of Florida, Collaboration for Effective Educator, Development, Accountability, and Reform Center)
With this current proposed amendment, future Illinois licensed DHH teachers are not required to ever have seen or interacted with a learner who is Deaf or Hard of Hearing. In the proposed amendments, a currently licensed teacher with any educational endorsement (music, biology, etc.) can merely pass the DHH content test (a test which was never designed to be the sole tool of determining qualification to be endorsed in Deaf/Hard of Hearing) or take a mere 18 hours coursework. This is woefully inadequate. “We live in a sound-oriented society. Extensive amounts of information are deliberately and incidentally conveyed through verbal interactions with others.” Ferrell, K. A., Bruce, S., & Luckner, J. L. (2014). Evidence-based practices for students with sensory impairments (Document No. IC-4). University of Florida, Collaboration for Effective Educator, Development, Accountability, and Reform Center.) Also, with this proposed amendment, teachers of students with hearing loss, will not even be expected to be able to communicate with the students they serve.
The population of students, who are Hard of Hearing or Deaf, is a diverse one and requires a depth of quality training. Understanding of the impact of hearing loss requires strong foundations in the sciences of Linguistic development, Audiology coursework, Speech Pathology coursework, Aural (re)habilitation, Sign Language, specialized technology, communication modes, etc. –all which now are ISBE-required and fully integrated into the instructional perspective of every DHH teacher, but would be detrimentally diluted or even eliminated through this amendment’s quick “fix.” It is not only the coursework, it is the also the synergy of the knowledge and skills, the interaction of all the specific training and opportunity for supervised experience that is currently required to be a successful teacher of learners who are Deaf/Hard of Hearing. It is the integrated application of all this knowledge, all these skills, to truly understand the unique linguistic, social-emotional, and communication impact of hearing loss on each and every subject area and social relationships, plus how to effectively communicate with the learner with hearing loss. This strikes at the very heart of hearing loss.
The long-term adverse impact of licensed teachers of the deaf/hard of hearing children who are untrained or ill-prepared to effectively meet student needs, will be devastating to the future of these children in school and in the community. There is a required intensity of coursework, student teaching and field experiences (in Deaf/Hard of Hearing: for speech, in Deaf/Hard of Hearing: for language, in Deaf/Hard of Hearing: for reading and content instruction, as well as student teaching) that is essential to the foundation of a DHH teacher that impacts the quality of the work and decision making that is demanded for each child’s school and life success. No teacher who holds a valid license with an early childhood, elementary, middle grades, secondary or special teaching endorsement, or a valid educator license with stipulations endorsed for transitional bilingual educator, should be allowed to add a sensory (deaf or blind/visually impaired) disability endorsement to their license through a single test or a mere 18 hours of coursework.
RECOMMENDATIONS: Requirements of the Deaf/Hard of Hearing licensure should not be lessened through a reduction in coursework or simply by means of just passing a test, as a way to address teacher shortages. The resulting long-term adverse impact to learners with hearing loss would be too great a consequence. The proposed amendments to Deaf/Hearing of Hearing licensure should be withdrawn.
There are candidates wanting to enter the special education teaching profession, but are not allowed access due to the ever-increasing entry ACT/SAT requirements and Basic Skill cut-off scores, which are not grounded in research for effective teaching. It is recommended that the ISBE focus NOT be on removing knowledge and skills (reduction of coursework or the removal of field experience for sensory endorsements) from licensure, but instead on removing obstacles/barriers to becoming a teacher candidate.
Other solutions are scholarships and loan forgiveness to cover tuition and living expenses to teacher candidates who commit to teach in shortage areas. Another solution is to work with Universities (ISU/ MacMurray) to offer coursework through a cohort taught locally by currently employed or retired, IL licensed Supervisors/Coordinators endorsed in Deaf/Hard of Hearing. Various State incentives could support this idea. Also work to eliminate barriers to re-entry of retired teachers, continuing and increasing days allowed to work within shortage fields.
Section 25.43 Endorsements for Special Education Teachers
g) 1 TEACHERS OF STUDENTS WHO ARE BLIND OR VISUALLY IMPAIRED
There is also great concern in the field of Blind/Visually Impaired that Illinois would also immediately and severely weaken integrity the Blind/Visually Impaired licensure in order to address teacher shortages. Again, a reduction in quality to teacher preparation is not the answer to teacher shortages.
The proposed amendment to add quick fix for the Blind/Visually Impaired endorsement for teachers who already hold any teaching license (art, early childhood) by simply either passing a content test (which was not designed to be the sole determiner of endorsement) or a mere 18 hours of this coursework will have long reaching adverse consequences to learners with Vision loss and their families, in school and in employment, now and in the future.
Licensed, but untrained teachers will not be able to meet the current and future vision needs of these students. Effective immediately with this proposed amendment, Illinois teachers in endorsed in the sensory area of Blind/Visually impaired, are no longer required to be proficient in Braille reading and writing. This lack of required skill in Braille and knowledge of Braille instruction in the current proposed licensure fix is astounding to the field.
From United States Department of Education Office of Special Education and Rehabilitative Services, guidance letter, June 19, 2013: “For decades, Braille has been a key tool for literacy for many blind and visually impaired individuals.” “Research has shown that knowledge of Braille provides numerous tangible and intangible benefits, including increased likelihood of obtaining productive employment and heightened self-esteem.“ “The purpose of this letter is to provide guidance to States and public agencies to reaffirm the importance of Braille instruction as a literacy tool for blind and visually impaired students, to clarify the circumstances in which Braille instruction should be provided, and to reiterate the scope of an evaluation required to guide decisions of IEP Teams in this area.” Skill in reading and writing Braille is essential in preparation of teachers endorsed in Blind/Visually Impaired, but this can be sidestepped through these proposed amendments by just taking the content test or allowing a reduction in hours of training for the endorsement.
The population of students, who are Blind/Visually Impaired, is a diverse one and requires a depth of quality teacher training. The education of a student who is Blind/Visually impaired requires more than just knowledge of specially-designed instruction in curriculum areas, but also skill and knowledge of teaching and supporting the expanded core curriculum (Compensatory, Functional and Communication Skills; Sensory Efficiency; Orientation & Mobility; Social; Independent Living; Recreation & Leisure; Use of Technology; Career & vocational; and Self Determination.) Knowledge and skills with low vision and blindness-specific assistive technology is important as well. Education of students with visual impairments requires "access to print or finding an alternative modality that will provide an equivalent quality and quantity of information.” "The skills and knowledge that sighted students acquire by casually and incidentally observing and interacting with their environment are often difficult, if not impossible, for blind and visually impaired students to learn without direct, sequential instruction by knowledgeable persons.” (ABF The Expanded Core Curriculum for Blind and Visually Impaired Children and Youths.)
With this proposed amendment, future Illinois endorsed Blind/Visually Impaired teachers are not required to have ever observed, instructed, or interacted with a learner who has a vision loss, if the teacher is now currently licensed with any educational endorsement. No teacher who holds a valid license with an early childhood, elementary, middle grades, secondary or special teaching endorsement, or a valid educator license with stipulations endorsed for transitional bilingual educator, should be allowed to add a sensory (deaf or blind/visually impaired) disability endorsement to their license through a single test or a mere 18 hours of this stated coursework.
The long-term adverse impact of Blind/Visually Impaired endorsed teachers who are untrained or ill-prepared to effectively meet student needs, will be devastating to the life success of these children in school, in employment, and in the community, now and in the future.
RECOMMENDATIONS: Requirements of the Blind/Visually Impaired licensure should not be lessened through a reduction in disability specific coursework or simply by means of just passing a test, as a way to address shortages. The resulting long-term adverse impact to learners with vision loss would be too great a consequence. The proposed amendment to Blind/Visually Impaired licensure should be withdrawn.
There are other solutions to teacher shortages. There are candidates wanting to enter the special education teaching profession, but are not allowed access due to the ever-increasing entry ACT/SAT requirements and Basic Skill cut-off scores, which are not grounded in research for effective teaching. It is recommended that the ISBE focus NOT be on removing knowledge and skills (reduction of coursework or the removal of field experience for sensory endorsements) from licensure, but instead removing obstacles/barriers to becoming a teacher candidate.
Other solutions are scholarships and loan forgiveness to cover tuition and living expenses to teacher candidates who commit to teach in shortage areas. Another solution is to work with Universities (ISU/NIU) to offer coursework through a cohort taught locally by currently employed or retired, IL licensed Supervisors/Coordinators endorsed in Blind/Visually Impaired. Various State incentives could support this idea. Another solution is to eliminate barriers to re-entry of retired teachers, continuing and increasing days allowed to work within shortage fields.
Thank you for this opportunity to give public comment.
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