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:
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:
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:
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.
Massachusetts Department of Elementary and Secondary Education 135 Santilli Highway, Everett, MA 02149
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