Meeting of the Board of Regents | January 2009
THE STATE EDUCATION DEPARTMENT / THE UNIVERSITY OF THE STATE OF NEW YORK / ALBANY, NY 12234
Higher Education Committee
Office of Teaching Initiatives: Proposals to Focus Resources on Core Mission
January 5, 2009
Issue for Discussion
Should the Regents endorse the proposed changes to teacher certification processes to better focus resources on core mission?
Reason(s) for Consideration
Review of Policy
This item will come before the Regents Higher Education Committee for discussion at the January 2009 meeting.
The Department’s Office of Teaching Initiatives’ (OTI) core mission is to certify teachers for employment in the State's public schools. (The term “teacher” includes classroom teachers, school leaders, and pupil personnel professionals.) Resources available to the Department have been significantly reduced in the last six months and it is expected that the reduction in available resources will continue in the next State Budget. The Department must continue to provide teacher certification services to school districts and teacher applicants.
The Department’s certification functions are financially supported only by the fees collected for teaching certificates. These fees were last adjusted 17 years ago, in 1992. Without raising the application fees, the Department must look at other options to preserve sufficient funding while continuing to improve the efficiency of the certification functions. The Department has worked to continually improve operations through efficiencies to minimize costs and improve services. As an example, qualified college program graduates may now have their Initial certificates issued within one day of filing a completed application and college recommendation. This item describes additional improvements for the Regents consideration that would enable the remaining Office of Teaching Initiatives staff to best deliver services that focus on an adequate supply of qualified teachers.
Annually, the Department issues approximately 100,000 certificates. This number includes new teachers applying for their first credential, applicants from other states interested in relocating to New York, and currently employed teachers qualifying for advanced-level or additional certificates, as well as applicants for a variety of other credentials required for public school service.
Major Process Improvements Currently In Operation
Over the past few years, the Department has been engaged in a continual process of improving its work processes and staffing patterns to provide the best customer service possible in as short a time as possible for certification evaluation and processing and fingerprint clearance for employment. With the implementation of the TEACH system, online applications now account for 96 percent of all applications. Payment by credit card, school district verification of certification, and one-day certificate issuance for college-recommended applications are among the features of the TEACH system that have enabled us to provide more efficient and faster service.
Certification and fingerprint clearance are cyclical activities, with yearly peaks in activity. Previously, we relied on overtime (equivalent of 3 clerical FTE’s and 2 evaluator FTE’s) and temporary staff (equivalent of 8 clerical FTE’s and 1.25 evaluator FTE) during peak times in an effort to keep cycle time as low as possible. However, because we are no longer able to hire temporary help or pay overtime to our staff, and because we have lost 20 percent of our application processing staff, we are looking at additional ways to realize efficiencies in staff use and also to save money to support services to existing teachers and qualified applicants. While the one day cycle time accomplished for college recommended applications has been maintained, previous gains made in cycle time for the labor intensive individualized transcript evaluation applications have eroded (because of the budget cuts and decreased staffing). Cycle times that were 8 weeks in the spring of 2008 have now grown to a 15 week cycle time for individual transcript evaluation and a 20 week cycle time for certificate progression – moving from Provisional to Permanent or Initial to Professional. On an exception basis, at the request of a school district, the Department does provide an expedited review for qualified applicants to whom a school district has offered employment. These expedited reviews are completed within one week.
The Department has converted to an online fingerprint application and clearance system through TEACH for both applicants for certificates and applicants for employment in public schools. The recent addition of digital fingerprinting technology (LIVESCAN) has resulted in improved processing times (24-48 hours) due to the electronic transfer of information for those districts with access to the LIVESCAN system. These enhancements have resulted in similar efficiencies and improvements in customer service. However, efficiencies have not been fully realized due to our inability to fill vacant positions, the lack of universal availability of LIVESCAN (school districts/BOCES must purchase the equipment) and the expansion of the fingerprinting system to non-public schools. As more customers migrate to a LIVESCAN system for the submission of digital fingerprints, it is anticipated that processing times on average will become closer to the 24-48 hour cycle time that is possible under LIVESCAN.
New Proposals for Additional Improvements
In order to stem the rising cycle times and expense for transcript evaluation applications and insure that school districts have an adequate pool of qualified and certified teachers to employ, the Department must focus on its core functions and reduce time and resources expended on non-core functions.
The following proposals are presented for the Regents consideration and endorsement:
1. Number of Transcript Evaluations per Application
Limit the evaluation services provided for applicants for certification via transcript evaluation to a reasonable amount of service for the fee submitted. Currently, applicants receive a first evaluation if they are not eligible for the certificate, which includes a list of requirements that are not met. Then, when they submit additional documentation, their application is individually re-evaluated. Sometimes, the remaining requirements have been met (by the time of the second review) and a certificate is then issued. However, in too many cases, applicants still have not met all the requirements at the time of the second evaluation. Their applications remain open-ended and they receive repeated evaluations until they meet all requirements. Based upon current application patterns, we estimate that over 4,000 individual evaluations are completed annually on applications requiring more than two successive evaluations. This consumes a great deal of staff time, takes time away from applicants who are ready for certification, and contributes to longer cycle times for applicants who have met all of the requirements. We propose to eliminate this open-ended process. If, upon the second evaluation all requirements are not met and the applicant still does not qualify for the certificate, we will return the application as incomplete. Individuals would be required to submit a new application and fee in order to have their credentials reviewed again.
Rather than facilitate repeated attempts, a change in the regulations to require a new application with the required fee after the first application has been returned would likely increase the number of applicants who wait until all requirements are completed before filing for the second evaluation. Accordingly, we have estimated only half of this 4,000 total would require an additional application and fee.
By limiting each application to two evaluations, we also estimate a savings of one full time evaluator’s time, which could be applied to reducing our cycle time for new applicants and those who meet the requirements to be issued a certificate. It also would result in approximately $200,000 in additional fees annually (based on an estimate that 50 percent of these applicants would complete the requirements and re-apply within a year). These fees could be used to better serve teachers and qualified applicants.
If the Regents endorse this direction, staff will begin drafting the necessary regulatory amendments for action by the Regents.
2. Internship Certificates
Amend regulation to permit the Department to charge the same $50 fee for issuance of an internship certificate that is charged for all other college-recommended certificates. Under current regulation, no fee is charged for these certificates.
Internship certificates may be issued upon the recommendation of the college/university to graduate students who have completed 50% of an approved teacher education program and are placed in a school district to complete their internship. Originally, the college/university applied for the internship certificates for their students and administratively it would have been difficult to collect a fee from the graduate students. Today, the graduate student files the application for the certificate and therefore the mechanism exists to collect the fee from the applicant. Over the past several years the numbers of internship certificates issued has increased. Ten years ago, the Office of Teaching Initiatives issued less than 500 internship certificates per year. In the 2007-08 school year, it issued more than 3,000. Collecting a $50 fee for each internship certificate issued would yield an additional $150,000 in revenues to be used for current operations without raising the existing application fees.
If the Regents endorse this change, staff will begin drafting the necessary regulatory amendment for action by the Regents.
3. Printing of Certificates
Consider options regarding the printing and mailing of certificates. We currently print and mail approximately 100,000 certificates annually. A number of these are returned as undeliverable, requiring changing the address on our records, readdressing new envelopes, and mailing them a second time. In place of issuing paper certificates, certificates could be issued electronically and be available on the Department’s Web site. This would have the added benefit of encouraging school districts to use our web-based information to confirm the certification of potential hires and employed teachers and encourage school districts to rely on the TEACH system to confirm a teacher's certification rather than a paper document that can be forged. The more extensive use of the Web site would also provide an opportunity to keep teachers’ addresses relatively current.
We recommend exploring the option of only printing Permanent or Professional certificates. This would meet the needs of teachers and school leaders for a document to acknowledge their achievement while allowing for savings by discontinuing the printing and mailing of time limited certificates (which represent the majority of certificates issued.) We would also like to explore a future enhancement to TEACH, to allow certificate holders to print a record of their certificates if they wish.
California, Utah, and Maryland have discontinued issuing paper certificates and Georgia is in process of doing so. In an informal survey of states, several others reported that they also are considering or beginning work toward eliminating certificate printing.
We estimate an annual cost savings of $30,000 in special paper, envelopes, and mailing costs if we were to eliminate the paper certificates with the exception of Permanent and Professional-level certificates. There would also be savings in staff time in the Office of Management Services if these mailings were eliminated.
With the Board’s endorsement, we will continue our research on other states’ experiences and evaluate any additional actions New York might need to take to implement such a change.
4. Time Extensions for Provisional, Initial and Transitional Certificates
As teachers with Provisional or Initial certificates progress toward the Permanent or Professional certificate, a certain percentage request and are granted a time extension of up to two years to complete all requirements for the higher level certificate. Criteria for the granting of such extensions include maternity leaves, inability to find a teaching position, personal hardship, and military leave. The Department receives approximately 8,000 such time extension requests each year. Currently, the process for such time extension applications includes submission of documentation of the circumstances by the teacher. All but a few of these applications are granted. Reviewing all the documentation submitted is a labor and paper intensive process causing backlogs in the entering of incoming mail into the TEACH computer system for all certification applications.
All teachers applying for a time extension have met the appropriate certification requirements for the Provisional or Initial certificate and are working on completing requirements for the Permanent or Professional-level certificate.
We intend to temporarily suspend the requirement that an applicant for a time extension of a teaching certificate submit documentation of how he/she met one of the six criteria for an extension established in regulation. Instead, one two-year time extension would be granted upon application and attestation by the teacher that he/she met the requirement specified on the application. Certificate holders applying for a time extension would also be required to have passed the appropriate Content Specialty Test(s) (CST) before the extension is granted. In addition, we propose to amend the existing regulation to include Initial certificate holders as eligible for a time extension due to an inability to find a position as a teacher as with Professional certificate holders.
The implementation of this change will allow for the redeployment of an estimated four full time staff members to work on higher priority areas, specifically, transcript evaluation and applications for certificate progression from Provisional to Permanent.
5. Reissuance of Initial Certificates
Reconsider the provision in regulation for reissuance of an expired Initial certificate. The original intent of certificate reissuance was to provide a mechanism for the holder of an expired Initial certificate who could not find a teaching position to regain certification, but with the added requirement that the applicant demonstrate currency in the field. The current regulation was adopted in 2000 but the first Initial certificates (issued in September 2004) do not expire until September 2009. Accordingly, we are just now reaching the point where this provision in the Teaching Regulations will become operational.
In order to qualify for a certificate reissuance, a teacher must:
- Provide evidence that he or she has been unable to secure employment as a classroom teacher, which has resulted in not meeting the experience requirements for the Professional certificate.
- Complete acceptable professional development, up to a maximum of 75 clock hours, prior to applying for the reissuance.
- Retake the NYSTCE liberal arts and sciences test (LAST), assessment of teaching skills – written (ATS-W) and appropriate content specialty test(s) (CST) within one year prior to application.
Because of the complexity of administering these requirements, it will be costly and labor intensive to implement and would require considerable programming additions (for which funding was eliminated) to TEACH. It would further delay processing of all applications, as we would take on another new work process with reduced staffing.
Similarly, the reissuance provision as written makes it time consuming and expensive for a teacher with an expiring Initial certificate to meet the criteria and we predict that this will result in a significant decrease in the supply of teachers.
We recommend exploring alternatives to the reissuance provision, resulting in amending or rescinding Section 80-1.8. The principle upon which we would redraft the regulation is that certificate holders who were unable to find a position as a teacher, should be allowed a renewed Initial certificate to obtain employment as a teacher. If their Initial certificate has been expired for more than two years, the applicant would need to again pass the CST in order to qualify for a renewed Initial certificate.
It is recommended that the Board of Regents endorse the proposed changes to Office of Teaching Initiatives work processes to maintain and improve the quality of core services provided to teachers and those qualified for certification.
Timetable for Implementation
With the Regents endorsement of these changes in concept, we will proceed to make the necessary changes in work processes and to draft amendments to Commissioner’s Regulations where required. The proposed amendments will be brought to the Committee for formal discussion as soon as possible.