The Massachusetts Board of Elementary and Secondary Education
Proposed Amendments to Regulations on Educator Licensure and Preparation Program Approval (603 CMR 7) and Educator License Renewal (603 CMR 44): Requirements for Teachers of Deaf/Hard of Hearing Students
I am presenting to the Board this month proposed amendments to 603 CMR 7.00, the Regulations on Educator Licensure and Preparation Program Approval, and 603 CMR 44.00, the Regulations on Educator License Renewal, for initial discussion and a vote to solicit public comment. The proposed amendments address requirements for the Teacher of the Deaf and Hard of Hearing educator licenses.1 With the Board's approval, we will solicit public comment on the proposed revisions to the regulations and bring them to the Board for a final vote in May 2014. These proposed amendments are intended to do the following:
- Eliminate the requirement for candidates seeking a Teacher of the Deaf and Hard of Hearing license to pass the Foundations of Reading test.
- Eliminate a previous proposal to develop a test of the teaching of reading to deaf and hard of hearing students.
- Revise the subject matter requirements for the Teacher of the Deaf and Hard of Hearing licenses to include additional focus in approved educator preparation programs on teaching reading skills to students who are deaf and hard of hearing.
- Require currently licensed Teachers of the Deaf and Hard of Hearing who have or seek the ASL/Total Communication designation when they renew or advance their license to pass a Department-approved ASL proficiency test.
These issues fall into two categories: requirements relating to the teaching of reading, and requirements for American Sign Language proficiency.
Proposed changes relating to teaching of reading
When the Board of Elementary and Secondary Education adopted the current regulation, 603 CMR 7.06 (27)(c)1., the Department expected to be able to offer an alternative test to the Foundations of Reading test as an option for applicants for the Teacher of the Deaf and Hard of Hearing licenses. The Department has not been able to obtain a test developer who could create an appropriate alternative test of teaching of reading to deaf and hard of hearing students. Consequently, we believe the test requirement should be eliminated and the regulations should be revised to require the educator preparation programs for the Teacher of the Deaf and Hard of Hearing licenses to address the subject matter of the reading test.
In addition, applicants for these educator licenses who are themselves deaf or hard of hearing (in particular, prelingually deaf applicants) and their advocates have pointed out that these applicants cannot pass the Foundations of Reading test, and therefore cannot qualify for the license, because the test requires knowledge of phonemes and other sounds in the teaching of reading, which they state makes the test content inaccessible to applicants who cannot hear sounds, or distinguish among them. They add that the deaf students they teach do not learn how to read through sound. The recommended revision takes into consideration that deaf and hard of hearing students, depending on their hearing loss, benefit from different approaches to teaching reading.
For these reasons, the proposed amendments would create new subject matter requirements for educator preparation programs for the Teacher of the Deaf and Hard of Hearing licenses, relating to the teaching of reading skills, and would drop the Foundations of Reading test for both licenses.
Proposed changes relating to American Sign Language proficiency
Under the current Regulations on Educator Licensure, new applicants for the license of Teacher of the Deaf and Hard of Hearing: ASL/Total Communication are required to demonstrate their proficiency in American Sign Language (ASL) by passing a test of sign language proficiency approved by the Department. The Department has now approved the Sign Language Proficiency Interview (SLPI), which is administered by the Massachusetts Commission for the Deaf and Hard of Hearing (MCDHH).
The Department and the MCDHH have agreed that teachers who obtained the Teacher of the Deaf and Hard of Hearing license before the administration of the SLPI should also be assessed on their ASL proficiency if they seek the ASL/Total Communication designation on their license. Consequently, the proposed amendments to the Regulations on Educator License Renewal would require currently licensed Teachers of the Deaf and Hard of Hearing who have or seek the ASL/Total Communication designation to pass the SLPI when they renew or advance their license. This also means that all educators with the Teacher of the Deaf and Hard of Hearing license (with no designation) will be required to identify the designation of the Teacher of the Deaf and Hard of Hearing license they seek, i.e., either ASL/Total Communication or Oral/Aural. The ASL/Total Communication designation will require demonstration of ASL proficiency through the SLPI, and the Oral/Aural license will not. The undifferentiated license, the Teacher of the Deaf and Hard of Hearing, will no longer be granted or renewed.
The Department has worked on these issues with the MCDHH, the Disability Policy Consortium, the Disability Law Center, educator preparation programs for Teachers of the Deaf and Hard of Hearing, and approved private schools serving deaf and hard of hearing students. We have received generally positive responses to the approach we are taking. We will continue our outreach to interested parties during the public comment period.
Proposed amendments are indicated by underline (new language) or strikethrough (deleted language). Sections of the regulations that are not being changed are omitted. For the complete text of the current Regulations for Educator Licensure and Preparation Program Approval, 603 CMR 7.00 and 44.00.
Alan Ingram, Deputy Commissioner; Heather Peske, Associate Commissioner for Educator Quality; Brian Devine, Director, Office of Educator Licensure; Marcia Mittnacht, State Director of Special Education; and Attorney Dianne Curran of our legal staff will be present at the Board meeting to answer your questions.
Enclosures:
1 The educator licensure regulations currently provide for two different licenses of Teacher for the Deaf and Hard of Hearing: Teacher of the Deaf and Hard of Hearing: ASL/Total Communication and Teacher of the Deaf and Hard of Hearing: Oral/Aural. However, most educators hold a Teacher of the Deaf and Hard of Hearing license with neither designation.