Career/Vocational Technical Education
Expectations for Chapter 74 Exploratory and 900 minimum program hours
|To:||CVTE Administrators and Leaders at Comprehensive High Schools|
|From:||Cliff Chuang, Senior Associate Commissioner|
|Date:||November 13, 2019|
Thank you for the feedback that many of you have given us about the proposed Chapter 74 Vocational Technical Exploratory Framework and codification of the 900 program hour minimum requirement for approved Chapter 74 Vocational Technical Education (VTE) programs over the past year. In particular, we are grateful for the specific and relevant information many of you shared during the session hosted and organized by Kathleen Duff (MSAA president and Newton CTE Director) at MSAA offices on October 18. As the proposed changes to 603 CMR 4.00: Vocational Technical Education related to these topics are scheduled to go forward to the Board of Elementary and Secondary Education at their November 19 meeting, I wanted to circle back to let you know the Department's current thinking on these issues and proposed next steps. The conversation is not over, but since we are moving into a more formal phase of the process, I wanted to be transparent about where things stand at this point.
It was particularly helpful to hear about the specific examples of how Exploratory programs operate in comprehensive high school settings. We heard general agreement about three key elements of a high quality Exploratory program:
- Students must be able to substantively and equitably explore a variety of Chapter 74 programs, especially ones that a student may not have otherwise considered and nontraditional by gender. Note: we anticipate defining this in the Exploratory framework to mean a minimum of five or more programs in the Exploratory Framework, aligned with the current regulatory framework that requires an Exploratory program to be provided once a school district offers five or more approved programs: "School districts that offer five or more approved vocational technical education programs shall provide a minimum of a one half year exploratory program approved by the Department for all incoming ninth graders." 603 CMR 4.03(4)(e)
- Students are able to complete substantive hands-on projects and tasks in the shops with qualified instructors—not just observe or spend time learning about the programs through reading and online exploration.
- Students are provided with sufficient time in each program shop to receive a real sense of the particular technical program and to cover the competencies outlined in the (draft) Exploratory Framework.
The main point of discussion at the Oct. 18 meeting focused on a third issue: sufficient time. There clearly is not general agreement with the Department's current guidance regarding schedules (p. 9) and "one half year", where "one half year means one-half of the total time spent in shop in the ninth grade. For most schools that would mean in the range of 198 – 247.50 hours." (p. 16). Essentially, this boils down to whether or not a model based on 1 out 7 instructional blocks (or 1 out of 8 instructional blocks) across a full year would suffice. (This model, common in a comprehensive high school 9th grade schedule, is roughly 124 – 140 hours).
A secondary issue is whether a schedule must allow for at least some large blocks of time in shops so that students have a real opportunity to explore. For example, can an exploratory program that consists of only 42-minute periods sufficiently allow for element #2 above (e.g. in a program like culinary)?
Later this fall/winter, we will re-convene the Exploratory Framework committee that has met over the last few years to further discuss these issues and make a final determination about the sufficient time issue, to be codified in the Framework, with the goal of having a final Framework approved by April 2020, but no later than June 2020. We previously successfully navigated a different issue related to how students make program selections at the end of the Exploratory, and we are committed to doing so with this issue. Several of your districts already have representatives on this committee, and we are open to adding new members. In addition, we will be sure to keep everyone apprised of any changes to the draft and to invite further comment and feedback prior to finalizing this Framework.
We heard your feedback about and fully acknowledge the structural differences between comprehensive high schools and high schools that are 100% VTE (regional vocational high schools, agricultural high schools, and city technical high schools). What all districts have in common is a desire to provide high quality VTE programs for their students. The Department is committed to allowing Chapter 74 programs to operate in multiple settings and with different delivery models while ensuring that all state-approved programs are of high quality, and that programs offer students with comparable experiences, credentials, and opportunities after high school. We cannot ensure equitable access to VTE if programs are not comparable and of high quality.
However, at this point, we are not proposing any changes to the 900 hour requirement as proposed in the draft regulations, for several reasons:
- The 900 hour requirement is already operationalized in the Chapter 74 New Program Application Process. This was put in place several years ago after significant consultation with the field, based on the determination that 900 hours is the minimum needed to address the vocational technical education frameworks, including the earning of industry-recognized credentials, hours required for students to earn specific licenses, and hours counted toward registered apprenticeship programs. This ensures that all programs provide similar levels of training for students to ensure program comparability and quality.
- This is predicated on the longstanding expectation that a VTE program can be completed within two years at "half-time" (½ * 990 hours * 2 years = 990 hours) with a bit of a buffer: so 900 hours instead of 990 hours (as is the case with some of our new After Dark programs). We could consider a bigger buffer, e.g. 850 hours, but such a change would be largely symbolic and wouldn't substantively change the Department's larger concern with programs that offer 600 hours or fewer.
- Some programs require additional hours beyond the proposed 900 hour minimum for students to have meaningful access to employment opportunities upon graduation (e.g. 1000 hours necessary for students to sit for the state Cosmetology exam), and we want to ensure at least some level of comparability across programs given the similar level of state investment.
That said, we heard the concerns expressed by many regarding the constraints of the comprehensive high school schedule and are prepared to use the waiver process outlined in the regulations to consider alternate delivery models that still demonstrate that programs are of sufficient scope to address the applicable Vocational Technical Education Framework.
We will be developing guidance (with your input) related to a waiver process that can support comprehensive high schools in meeting the 900 hour requirement, with a goal of issuing this guidance by April 2020, but no later than June 2020. Guidance will likely include the consideration of the following ideas, some of which were touched upon during our Oct. 18 discussion:
- Paired related academic courses. This is not a new concept and is in keeping with the current regulations that state the program of study shall "include related instruction that shall be primarily taught by licensed vocational technical teachers in the specific program area. Academic teachers may assist in the delivery of related instruction components when their particular expertise will enhance the instruction." 603 CMR 4.03(4)(a).
- For example, there is precedent for Health Assisting program teachers working with Anatomy & Physiology Teachers to deliver related science content. In this example the two teachers would be cross walking the Anatomy and Physiology course with the VTE Health Assisting Frameworks. Another consideration is having an Anatomy & Physiology class that is dedicated to HA students or having one that HA students attend. In either case their VTE competency attainment from the Anatomy & Physiology Course would be tracked.
- For another example, it is conceivable that the teacher of a Chapter 74 program such as Culinary Arts could work with a Chemistry teacher to deliver related science content. Keep in mind, however, that not all of a Chemistry course is relevant to a Culinary Arts program, whereas all Anatomy and Physiology may be relevant to a Health Assisting program.
- A paired academic course would not be a standard but an exception. Therefore, allowing for paired academic courses would be on a case by case basis through a waiver process.
- Common VTE Strands. The VTE Frameworks include common strands, which also count toward the 900 hours. There is already flexibility in how the common strands are delivered. Common Strands, such as Strand 5: Management & Entrepreneurship are usually addressed in the VTE Program curriculum.
Strand 5: Management & Entrepreneurship is sometimes taught as a separate class via a teacher other than the VTE licensed teacher.
- Example 1: Culinary Arts curriculum unit in which students design their own business.
- Example 2: Health Assisting curriculum in which students submit a proposal to improve and/or expand a health care facility.
- Example 1: An Entrepreneurship course is used to cover Strand 5. The students attend the class by program (all carpentry students participate at the same time). The content is designed with input from both the academic teacher and the vocational teachers so that Strand 5 competencies are addressed, and the content is relevant to each program. The VTE competencies are tracked.
- Example 2: Some programs utilize an Entrepreneurship course (such as described above) while some VTE programs cover Strand 5 in the VTE program solely by the vocational teacher.
In both of these cases, wherever we ultimately end up, we will provide time for districts to adjust to any new expectations, with 2020-2021 treated as a transition year at a minimum. Please do not hesitate to reach out to me or members of the CCTE team with questions or concerns. Thank you.
Last Updated: November 13, 2019