New America’s Comments on Proposed Teacher Preparation Regulations

Over the past few months, the education world has been abuzz about the U.S. Department of Education’s proposed regulations for Title II of the Higher Education Act (HEA) that monitor the quality and impact of teacher preparation programs. As with the last push for reform in this area, some groups have protested the proposed changes arguing that they rely too heavily on test scores and impose too much paperwork, among other reasons. But others—a coalition of alternative preparation programs, a new group of education school deans, and Teach Plus, to name a few—have championed reform. They see the need for stronger accountability and reporting requirements to ensure preparation programs graduate successful teachers.

New America joins these groups in support of the Department’s regulations. Earlier this month, we submitted public comments on the regulations, which we believe provide a much-needed update to state and institutional reporting and accountability requirements for teacher preparation programs. The proposed regulations rightfully move away from input toward output measures. For instance, they ask states to annually report on teacher preparation programs via common outputs such as employment outcomes, teacher and employer feedback, teacher performance, and assurance of specialized accreditation.

Still, there are specific areas in the regulatory text where modifications would provide more meaningful data and accountability. Below are just five of our recommendations for improving the proposed regulations to ensure that they help raise the bar for teacher preparation programs and lead to meaningful improvements in new teachers’ readiness for the job. For more details on our recommendations, including ways to improve the proposed timeline for reporting along with specific feedback on the state and institutional report cards, see our full comments.

Reporting and Accountability Requirements

  • The Department’s current definition of “new teacher” does not guarantee that states will report data on prekindergarten teachers—only K-12 teachers. Given the importance of teaching quality in the early grades, we propose revising the definition to ensure states with a post-secondary certification requirement for Pre-K teachers collect and report data on them, too.
  • Most states have invested in more rigorous teacher evaluation data based partly on student growth and partly on performance as measured by classroom observations. The proposed rules require states to report on graduates’ classroom effectiveness either using the student growth measure or the combined student growth and performance measure. While the latter offers a more comprehensive view of teacher performance, new teachers continue to be rated highly under state teacher evaluation systems. So, where available, states should be required to report both student outcomes and the combined measure.
  • In addition, states should not be permitted to identify a teacher preparation program in its highest rating category unless the state determines that the program had “above average student learning outcomes.” Language in the current proposed rules could provide a false sense that there is a high benchmark for which programs are rated effective or higher.
  • Beyond providing an “assurance” that a teacher preparation program is accredited by a specialized agency, states should be required to report on the level of program accreditation to give some sense of preparation program quality. The Council for the Accreditation of Educator Preparation (CAEP) intends to provide programs with different levels of accreditation based on assessment of quality. As long as CAEP continues with this plan, states should report this data.
  • For reporting on alternative and traditional certification programs, the proposed rules should not allow states to weight the employment outcome indicators differently based on type of program. The common starting point for alternative and traditional preparation programs should be the point at which a candidate has the opportunity to become a teacher of record.
New America will be watching closely as the Department moves forward to improve teacher preparation, including incorporating public comments on the proposed regulations and preparing for the reauthorization of HEA expected later this year. Check back at EdCentral for updates."


Kaylan Connally was a policy analyst with the Education Policy program at New America. She was a member of the PreK-12 team, where her work primarily addressed policies and practices that impact teaching quality and school leadership.