Wisconsin Reading Coalition, via a kind email:

Thanks to everyone who contacted the legislature’s Joint Committee for Review of Administrative Rules (JCRAR) with concerns about the new teacher licensing rules drafted by DPI. As you know, PI-34 provides broad exemptions from the Wisconsin Foundations of Reading Test (FORT) that go way beyond providing flexibility for districts to deal with emergency teacher shortage situations.

As a result of written and oral testimony on PI-34, the JCRAR put a hold on PI-34 and will meet again on July 13th. We hope at that time they will seek modifications to the rule to more closely align with the statutory requirement that new elementary teachers, special education teachers, reading teachers, and reading specialists pass the FORT. This statute was passed for the protection of our beginning and struggling readers, and to encourage educator preparation programs to do a better job of covering this basic content information about reading acquisition. It is particularly critical in a state like Wisconsin where student reading scores are low for all sub-groups and have not improved for over two decades.

Of course, there is pushback from the people who recommended these licensing changes to DPI. Various associations of school administrators have urged their members to lobby the JCRAR members in favor of allowing individuals to become teachers of record without passing the FORT. The talking points they have provided to their members are enumerated below, along with our comments.

Please contact the JCRAR once more in advance of July 13th, asking them to maintain the integrity of the statutory FORT requirement. Following are the members of the committee:

Representative Ballweg (Co-Chair)

Senator Nass (Co-Chair)

Senator LeMahieu

Senator Stroebel

Senator Larson

Senator Wirch

Representative Neylon

Representative Ott

Representative Hebl

Representative Anderson

Talking Points for School District Administrators with WRC comments:

Wisconsin school districts are facing growing school staffing issues including high turnover, fewer applicants for positions, and candidate shortages in a variety of disciplines. With fewer new teachers entering the profession, new approaches to educator recruitment and retention are critical to ensure all children have access to high-quality educators. We are not opposed to an exemption from the FORT in true emergency cases where a district shows it is unable to hire a fully-licensed teacher, but we should not call these individuals high-qualified educators. We are opposed to allowing those licenses to be renewed year-after-year without the teacher passing the FORT. A one-year time limit for passing the FORT would be sufficient to help districts meet immediate candidate shortages while working toward having a highly-qualified educator in that classroom.

The licensure flexibility afforded under CR17-093 is universally supported by school leaders in their effort to address the growing workforce challenges faced by Wisconsin school districts. This is simply inaccurate. There are school leaders, both superintendents and school board members, who have spoken against exemptions from the FORT.

We must also point out that districts are currently operating under these proposed rule changes as part of the current Emergency Rule. These proposals are already making a positive difference in meeting these workforce challenges in districts throughout Wisconsin. This is also inaccurate. The current Emergency Rule is much narrower than the proposed PI-34. It allows 1-year, renewable licenses with a FORT exemption only if the district shows it cannot find a fully-licensed teacher. PI-34 allows any in-state or out-of-state college graduate to obtain a Tier I license and teach in districts that have not shown shortages.

School administrators support all aspects of the proposed rule but, of particular importance are the flexibilities and candidate expanding aspects in the Tier 1 license. This will allow for a much-needed district sponsored pathway to licensure, immediate licensure for out of state candidates, licensing for speech and language pathologists with a Department of Safety and Professional Services license and licensing for individuals coming into a district on an internship or residency status. These are effective, no-cost solutions to a significant workforce need in Wisconsin school districts. We are opposed to district-sponsored and out-of-state pathways to licensure where the candidates do not have to take and pass the same outcome exams required of other educators. There is no reason to hold these programs to a lower standard.

Educator licensure is simply a minimum requirement. District leadership is responsible for hiring and developing successful educators, and ultimately determining educator quality based on actual teacher performance and student outcomes. District administrators and families should be able to count on licensed applicants having the basic information about reading that they will need to successfully teach all students on day one. This is particularly important in districts that have fewer applicants from which to choose.

Reducing the Tier 1 license flexibility in the rule has the potential to impact as many as 2,400 teaching licenses, many of which are FORT-related stipulations. Any portion of these licensees that lose their ability to teach will exacerbate an already troubling workforce challenge and reduce educational opportunities for children. This concern can be met by maintaining an one-year emergency exception for districts that can show a fully-licensed candidate is not available. Eliminating the continuous renewal option for these licenses and requiring the FORT for district-sponsored and out-of-state pathway licenses will help ensure quality educational opportunities for children. The quality of the teachers is just as important as the quantity. Meanwhile, DPI should set appropriate standards in reading for educator preparation programs, and institute improvement plans for institutions that have low passing rates on the FORT. What does it say about Wisconsin that we have over 1400 teachers in the classroom under Emergency Rules specifically because they have not passed the FORT? At some point, we need to address the root of the problem if we are to have sufficient numbers of highly-qualified teachers for every beginning or struggling reader.