Public Comments by Dr. Vic Smith to Indiana State Board of Education, Dec. 5, 2012
I urge you to table the REPA 2 rules on your agenda today until the major new changes revealed just last Friday can be reviewed in additional public hearings.
The changes revealed in the revised rule released last Friday are substantial.
1. The revised draft shifts the authority for approving teacher education programs at universities from the Indiana Department of Education, as is the current practice, to the State Board of Education.
2. The revised draft cuts the classroom experience required for an administrator license from five years down to two years and would count teaching experience in higher education as classroom experience to qualify for a K-12 administrative license, either as a building level administrator or as a superintendent. This is a highly controversial subject to current administrators. No definition of how much teaching in higher education constitutes a creditable year is included in the rule. Reducing the amount of teaching experience required and eliminating the need for experience in K-12 classrooms should be subjects of additional public hearings.
3. The revised draft changes the approval of the content area tests required for licensure and the setting of the cut scores from the Indiana Department of Education to the State Board of Education.
The legal question here is whether the rule can be revised in these major ways at the last minute without triggering the need for another round of public hearings. Past practice in my 15 years of watching State Board rules go through the promulgation process has been that if hearings resulted in minor changes, those minor changes were made and the rule was passed. If major changes were made, however, the rules were resubmitted for an additional round of hearings.
I oppose all three of these changes. These revisions are clearly major changes, and under past practice, a new public hearing on the revised language should be in order.
I urge you to bring these major changes revealed for the first time last Friday to the public for additional public hearings.