Title II, HEA, State and Institutional Reporting Guide
on Teacher Quality

Pass Rates | Verification of Data | Rankings | Waivers
Student/Faculty Ratio | Low-Performing Institutions
How the Reporting System Will Work
Institutional Reports

PASS RATES

Use of multiple pass rates

Question: The law requires IHEs to report pass rates of their teacher preparation program graduates (completers) on tests needed for licensure or certification. Why does the reporting guide have IHEs aggregate scores of graduates into a few main categories and a summary rate rather than report for all tests?

Answer: Sec. 207 requires the Department of Education to create a clear and comprehensible public reporting system on state licensure and the success of institutions in preparing teachers. Because states use scores from different licensure and certification exams, a reasonable and comprehensible reporting system has to rely on use of a few key pass rates.

States typically offer dozens of different licensure and certification tests, and individuals take different batteries of tests depending on the area in which they want to be licensed or certified to teach. Data comparing pass rates on dozens of tests for each IHE would provide only confusing information, with little indication of how well the IHE as a whole was doing in preparing completers to meet all of the state's standards for initial teacher certification.

Therefore, the reporting guide asks IHEs to report pass-rates in a very few main categories, across six categories of tests -

• Basic skills;
• Professional knowledge and pedagogy;
• Academic content areas (e.g., mathematics, social studies, science, the arts, etc.);
• Teaching special populations (e.g., special education, English as a Second Language, etc.);
• Other content areas (e.g., agriculture, marketing, computer science, etc.); and
• Performance assessments.

The guide also calls for a single "summary rate" that reflects the total of the graduates' testing experiences.

Summary pass rates

Question: How should program completers who are prepared in and take tests for more than one licensure area or endorsement be counted when calculating aggregate and summary pass rates?

Answer: The Title II reporting guide defines aggregate pass rates as the proportion of program completers who passed all the tests they took in each of the six designated areas (see page 12 of the Reference and Reporting Guide). Summary pass rates are defined as the proportion of program completers who passed all tests they took for their areas of specialization among those who took one or more tests in their specialization areas.

Unfortunately, the guide is somewhat unclear on the issue of how to include program completers who are prepared and take tests in more than one area in the calculation of aggregate and summary pass rates. More specifically, the question that arises is whether those seeking certification or licensure in more than one area should then be counted twice in the aggregate and summary pass rates.

As was agreed in the deliberations of the consultative committee established by the Department for implementing Title II, pass rates are to be based on individuals, not tests. The summary rate is intended to be an overall measure of the success of program completers in passing state-required certification tests. For those who seek certification or licensure in more than one area, the issue is not whether they passed all tests in all areas, but whether they passed all tests in at least one area. Thus an individual is counted as a pass in the summary rate if they pass all required tests for any area in which they were prepared.

In the case of the aggregate pass rates, it does make sense to double count individuals who are prepared and seek certification or licensure in more than one area. The aggregate pass rate reflects the success of candidates prepared by teacher preparation programs in the different reporting categories (basic skills, professional knowledge, academic content area, etc.). The aggregate rate will provide information on the proportion of program completers who passed all the tests taken in the skill or knowledge areas in which they were prepared, among all program completers who took one or more tests in each area.

(Posted October 31, 2000)

"Individual-based" system v. "test-based" system

Question: In aggregating IHE's scores, why does the reporting guide adopt an "individual-based" system rather than a "test-based" system?

Answer: The Department conceivably could have gone in either of two directions. It could have adopted a "test-based system under which IHEs would compute their pass rates on the basis of the total number of tests that all graduates (completers) passed as a percentage of the total numbers of tests all of them took. Under this kind of system, for example, for two individuals who each passed one of two tests in a battery, the guide would have directed IHEs to report an overall pass rate of 50 percent (two passes out of four exams).

Given the law's focus on institutional accountability for the preparation of teachers to meet the standards for licensure or certification, NCES concluded that pass rates generated by a test-based system-which reported pass-rates on each of several tests-would be less meaningful than those generated by a system based on the percentage of an IHE's program completers who have passed the state's licensure and certification exams, i.e., an "individual-based system." In the example above, under this system the pass rate for each test is still 50 percent, but the IHE would report an aggregated pass rate of zero percent since both of the graduates had failed one of the tests in the battery. (The guide actually requires reporting only when 10 or more individuals take the same test or aggregation of tests; thus, the IHE would not actually report a pass rate for this example under either scenario.)

Partial completers

Question: Why does the reporting guide require IHEs to include in their pass rates the scores of those who pass or fail a test in a battery, but who have not yet taken all tests in the battery?

Answer: The guide has IHEs report pass rates for those who complete their teacher preparation programs in the most recent academic year. Some of these completers may not have taken the full battery of tests for their chosen area of specialization as of the "test closure date"-the date the state selects beyond which scores must be included in a follow-up report on pass rates of that cohort of completers. These individuals, who have not completed the full battery of required tests (for licensure or certification in a given content area or grade level) by the "test closure date," are considered "partial completers," and need to be accounted for in any successful reporting system.

People may be partial test completers for a variety of reasons, e.g., they may (1) fail an exam, and then decide not to take others or to delay taking others until they are better prepared; (2) move after graduation to a state that uses some but not all of the tests used in the state where the IHE is located; or (3) take (and either pass or fail) exams while still enrolled in the program, but decide for personal reasons after graduating either not to become a teacher or to delay doing so. Regardless of the reasons, if scores of partial completers are dropped from an IHE's reported pass rates, those rates would be skewed by the exclusion of scores from those who have failed to pass one or more examination. Moreover, eliminating partial completers from IHE pass rates is inconsistent with the congressional intent in section 207 of the HEA that the pass rates IHEs report provide the public a reasonable measure of how well an entire cohort of program completers does on their examinations.

(We recognize that some IHEs may want (or deserve) credit for their follow-up work with test takers to help them pass examinations after the test closure date. The guide allows IHEs to submit, in the report 3 years later, final pass rates on the cohort of completers to accommodate individuals who later complete the battery or retake tests.

Also, to reduce cost and burden, the guide does not require IHEs to report pass rates disaggregated for full completers and partial completers. However, IHEs are free to do so as supplemental information if they so choose.)

Treatment of completers of alternative route programs in IHE pass rates

Question: IHEs operate both regular teacher preparation programs and programs that the state establishes as alternative routes to certification and licensure. Since IHEs prepare future teachers who are enrolled in both kinds of programs, why doesn't the reporting guide have IHEs include scores of both groups in their pass rates?

Answer: It is true that some IHEs provide instruction to students who pursue alternative routes to certification or licensure. However, alternative routes-and the admissions processes for them-are typically quite different from the course of instruction in the "regular" teacher preparation programs the IHE otherwise provides and, therefore, should be reported on separately than pass rates for regular program completers.

For example, some alternative route programs are specifically tailored to professionals who would enter teaching-as mid-career professionals - with the requisite content knowledge in the subjects in which they will teach. Having IHEs combine the test results of very different groups of completers into a single IHE pass rate would therefore yield pass rate statistics that will only misinform and confuse the public about the pass rates of those who enroll in the institution's "regular" teacher preparation programs.

Moreover, section 207(b)(7) specifically directs states to include data on pass rates of program completers of alternative routes in their state reports. We believe that this statement reflects a congressional intent that states - and not IHEs - be responsible for reporting the pass rates of these individuals.

Institutions may use "supplemental information" to report pass rates of alternative route completers through coursework at its institution. The guide also permits IHEs to provide, as supplemental data, pass rates that combine "regular" program and alternative route program completers in a single "blended" pass rate.

Treatment of "successful" program completers

Question: Why does the reporting guide insist that an IHE's pass rates reflect the scores of all of its program completers, and not just those it considers "successful" by virtue of its willingness to recommend them to the state for licensure or certification?

Answer: The Title II reporting system is designed to provide information to the public on the success of institutions in providing sufficient training to all of the teacher candidates prepared by an institution. The guide therefore defines program completers as those whom the IHE determines have completed all requirements of its teacher preparation program and prohibits an IHE from only reporting data for those it would recommend to the state licensing authorities (likely, only those who have passed all tests). Such definitions prevent the reporting of misleading data that exclude scores of those whom the IHEs acknowledges - through conferring a degree, certificate, or other credential - have met all requirements of the program, but who would be expected to decrease the IHEs' reported pass rates.

The omission of the scores of these individuals from IHE pass rates would mislead the public as to the true pass rates of those who graduate from, or otherwise complete, teacher preparation programs.

(This prohibition will not adversely affect any IHE that has established receipt of a recommendation to the state agency as a requirement for program completion, since the individual already would have completed all other requirements of the teacher preparation program.)

Program completers of initial license or certification program in additional teaching field

Question: Do institutions (and states) include in their list of program completers those who already have a certificate or license to teach, but who have just completed a regular (or alternate) teacher preparation program needed for an initial license or certificate in an additional teaching field?

Answer: No. The Title II reporting system and its requirement for reporting of pass rates focus on the extent to which those who newly complete a teacher preparation program are able to pass the licensing or certification examinations they need to become teachers. Required reporting of pass rates on state assessments does not extend to those who already are licensed or certified to teach in any state. Therefore, institutions should include in their lists of regular and alternative route program completers only those completers who are seeking their first initial certificate or license.

In some states this may result in no pass rates being reported for some subject areas. For example, in at least one state those seeking a teaching license or certificate in the area of ESL (English as a Second Language) must already be licensed or certified in elementary education. Institutions in this state would not be expected to report pass rates on ESL assessments since all program completers who take the ESL assessment will already have an initial teaching license or certificate. Institutions (or states) with situations such as this may want to explain in supplemental information why they have no pass rates to report in some areas. However, institutions (and states) may also want to report the pass rates in those areas as supplemental information in order to better inform the public about how well teacher preparation programs prepare individuals who are already licensed or certified to pass additional subject-matter exams (such as ESL in this example).

On the other hand, lists of program completers will include those completers who are seeking initial certificates or licenses in two (or possibly more) areas at the same time. For these individuals, pass rate calculations will reflect scores on all examinations they take for initial certification or licensure in those areas.

(Posted August 30, 2000)

Program completers who plan to take tests for and teach in other states

Question: The reporting guide has pass rates calculated only on the basis of scores on initial licensure or certification tests used by the state in which the IHE is located. Many IHEs experience their best students moving to other states after graduating. Why does the guide insist that the IHE pass rates exclude scores of these "exported program completers"?

Answer: Incorporating into the IHE pass rates the scores on tests used in states other than the one in which the IHE is located (1) presents enormous methodological problems, (2) would likely make the costs of the reporting system prohibitively high, and (3) holds institutions accountable for training teachers to be able to meet other states' standards.

Educational Testing Service (ETS) has advised us that it has no means of determining for what state or states an individual is taking a test when he or she sits for a given examination. At a cost, ETS could provide the scores of each program completer on all tests taken for states other than the one in which the IHE is located. However, each state uses a different battery of tests and "cut scores." Hence, we wouldn't know from the testing company what state cut scores and correct examinations to apply to this amalgam of tests. This information would need to come from the completers themselves, which would require a very intensive and expensive follow-up survey, something that ED cannot require ETS to conduct. (In principle, this information alternatively could come from the IHEs if they kept records on the states to which their students move after completing the program to seek teacher licensing or certification. But even if all IHEs have this information for all of their program completers, the process of getting all of this information to the testing companies and having the testing companies then compute out-of-state pass rates would likely generate enormous challenges and cost.)

Moreover, a number of the larger states (e.g., California and Texas) use the National Evaluation Service (NES), so including test scores regardless of the state for which the test is taken would require coordinating data between ETS and NES. Quite simply, the costs and burdens of including the scores on tests not used by the state in which the IHE is located likely would undermine the entire reporting system.

However, if states and IHEs want, and are able to develop, procedures for securing (and paying for) this out-of-state pass rate information, IHEs may report these data as supplemental information.

Question: When must pass rates of program completers taking licensing or certification examinations or assessments in other states be included in the calculation of an IHE's pass rates?

Answer: Regardless of where an IHE's program completer takes a test, if the test is used by the state in which the IHE is located to determine who may receive an initial teaching certification or license, the test score must be included in the IHE's pass rates. The passing score (cut score) used must be of the state in which the IHE is located. However, if the test taken is not used by the state in which the IHE is located, scores on it do not need to be included in calculations of the IHE's pass rates. However, pass rates on tests taken in other states, if available, may be used as supplemental information by IHEs.

(posted August 21, 2000)

State assessment requirements

Question: In some states, certain institutions may require their students to pass all the assessments that the state requires for initial teacher certification or licensure as a condition to completing their teacher preparation program, while other institutions do not. How can a state help the public properly interpret the rankings of institutions by pass rates when institutions have these different requirements?

Answer: For purposes of Title II reporting, a program completer is one who has met all the educational or training requirements in a state-approved course of study for initial teacher certification or licensure. This definition is silent with regard to the practice of some institutions that require their students to take and pass all state assessments before they can complete all of the program's educational or training requirements (including practice teaching), i.e., become a program completer. (However, where a student already has completed the teacher preparation program and received a degree, etc. that proves program completion, the definition prohibits an institution or state from classifying the individual as a program completer for purposes of Title II reporting only after he or she subsequently passes the assessments the state requires of candidates for initial licensure or certification.)

Institutions that require students to pass state assessments before they complete the required educational and/or training requirements will report 100 percent pas rates for their program completers on these assessments. These institutions, in effect, will have weeded out students who do not pass assessments before they complete the teacher preparation program; hence, their 100-percent pass rates do not reflect how well the institutions have prepared all the students enrolled in their programs to pass the state assessments. On the other hand, institutions that have chosen not to have this requirement before their students complete their programs may well report lower pass rates, and so be ranked in the state report below the other institutions. Since these differences in ranking may say little about the relative quality of the different teacher preparation programs, states may wish to use supplemental information both to help the public understand what these rankings mean--and do not mean--and to consider providing alternative measures of assessing the quality of the teacher preparation programs in the state.

(posted June 19, 2000)

Question: What can states do to address the concern of institutions of higher education (IHEs) that they will be unfairly compared on pass rates because the definition of program completer in the Department's guide to implementing Title II recognizes that some IHEs have had in place a requirement to pass state-required assessments before granting a degree or considering someone a program completer? Some institutions feel that the definition allows certain institutions in a state to report 100 percent pass rates if they had in place a policy requiring their program completers to pass state-required assessments for licensure or certification when the 1999-2000 cohort started their programs, while other institutions in the state without such a requirement in place at that time will likely report lower pass rates.

Answer: The definition of program completer in the guide recognizes that some institutions had in place when the 1999-2000 cohort of students started their programs a requirement for granting a degree or recognizing program completion that students pass state-required assessments for certification or licensure. Such institutions will report 100 percent pass rates in their institutional reports due by April 2001, while other institutions without such a requirement will not necessarily have pass rates that high.

States in collaboration with institutions of higher education could address this issue by providing supplemental information in the institutional and state reports. The guide encourages states and institutions to provide supplemental information to provide a better explanation of pass rates and other institutional or state characteristics that must be reported in institutional reports.

One possible strategy would be for states where some institutions require passing state-required assessments before granting a degree (or recognizing program completion) to have all institutions report test results for every person in the cohort taking state-required tests who completed all required courses. States could use these supplemental data to calculate similar pass rates for all their institutions and to rank them using those pass rates. States also may consider asking institutions requiring students to pass state assessments before conferring a degree to include in their institutional report when they adopted that requirement, their rationale for it, and an explanation of how they use test results to improve their teacher preparation program. States and IHEs may also want to consider other strategies for using supplemental information to compare IHEs.

(posted August 21, 2000)

Reporting state average pass rates

Question: If fewer than ten students completing a teacher preparation program at an institution have taken a given assessment, does the institution have to report either the pass rate on it or the scores of those who took it to the state?

Answer: Consistent with section 207(f) of the Higher Education Act, institutions of higher education do not include in their annual institutional report to the state a pass rate for any particular assessment if fewer than ten completers (of their regular, non-alternative teacher preparation program) took the test. (This same rule extends to reporting any of the institution's six aggregate and summary pass rates; each must have test scores from at least ten program completers.)

But the law also requires institutions to include the state average pass rate for each assessment they include in their report, and this state average must be gotten from the state. The only way the state can calculate that average, however, is to get all test scores of any program completer who has taken any assessment.

States are also required to include the state average pass rate for each individual assessment, the six aggregates, and the overall summary in their annual report to the U.S. Department of Education (if it has scores from at least 10 program completers for the relevant pass rate).

Regardless of the size of an institution's teacher preparation program, many institutions only have a few completers who take assessments in certain subject areas. The state as a whole, however, may have a total number of completers in these subject areas greater than ten. Without having the scores of all of the state's program completers on each examination, the state will not be able to provide the statewide pass rates that the law requires. Hence, each state needs to ensure that its Title II data reporting procedures enable it (or the testing agency) to calculate state average pass rates based on test results of all program completers, regardless of the size of the teacher preparation program.

(As the guide states, these statewide pass rates only include test scores of individuals who complete regular teacher preparation programs. However, the state also will need to report pass rates for completers of each of its alternative routes. Thus, the state similarly will need to ensure that pass rates for its alternative routes reflect all those who have completed alternative route programs, again regardless of the size of any particular program, as long as the state has scores from at least 10 completers.)

(posted June 19, 2000)

Question: What should states do to ensure that statewide average pass rates are based on all program completers in a state who take a state-required assessment for licensure or certification?

Answer: States need to inform all their institutions of higher education (IHEs) that the calculation of required statewide average pass rates requires that the test results of all program completers be used. Statewide averages are used in both institutional and state reports. Consequently, all IHEs must submit the names of all of their program completers to the state or testing agency to ensure that the test results of any of them appear in the statewide average pass rates.

IHEs do not necessarily have to rely on a state or testing agency to calculate their own pass rates, however, if one of the following is applicable:

1. An IHE has fewer than 10 completers in some or all areas of certification or licensure who have taken state-required tests. Such institutions do not need to report such pass rates in their institutional reports due April 2001.
2. An IHE has 100 percent pass rates in all areas because it requires all students to pass state-required assessments in order to complete their regular programs. These rates must be reported in institutional reports if more than 10 program completers take a state-required test.

Since such institutions do not necessarily have to rely on the state or testing agency to calculate their pass rates, states may want to give consideration to the costs these IHEs might incur for calculating statewide pass rates. States may wish to discuss this matter with institutions and the testing agency.

(Posted September 22, 2000)

Dispute resolution

Question: If an institution of higher education (IHE) with a teacher preparation program is in dispute resolution over its pass rates when its institutional report is due on April 7, what should it report?

Answer: If an IHE is in dispute resolution, it will not know its final institutional pass rates by April 7, and consequently the state will not be able to report final statewide pass rate averages to it and other IHEs prior to that date.

An IHE in this situation must report provisional pass rates that reflect the scores of all program completers that the IHE is not disputing. Similarly, the state will provide institutions with provisional statewide pass rates based on all scores that are not in dispute. The IHE and the state must clearly designate these rates as provisional (e.g., with an asterisk) so that this is clear to the public.

If the U.S. Department of Education has been asked to resolve a dispute on pass rates, it will provide its resolution to both the affected IHE and to the state. After the dispute resolution process concludes for all IHEs in a state, the state must promptly inform IHEs of the final statewide pass rates. Following receipt of this information, any IHE that has reported provisional pass rates must promptly submit its final report to the state. As with all implementing procedures, states should establish schedules for submission of these final statewide pass rates and final institutional reports in collaborative discussions with institutions in the state.

(posted August 21, 2000)

Question: What is the Department's pass rate dispute resolution process?

Answer: If any institution of higher education has not been able to reach agreement with its appropriate state agency (or testing company if the state is accepting calculations of the testing company) regarding the calculation of a pass rate of its teacher preparation program completers, as required by the U.S. Department of Education's Title II Reference and Reporting Guide, it may request the Department to resolve the dispute. To do so, the institution will need to send to the Department a written request for a change in the pass rate within ten days of receiving the state's (or testing company's) resolution of the matter.

This request should be accompanied by the following written information: (1) an identification of the particular pass rate(s) that it believes the state and/or testing company has miscalculated; (2) documentation of the grounds for requesting the change(s) and the pass rate(s) that the institution believes to be incorrect; (3) the response of the state agency (and, as appropriate, the testing agency) to the institution's request for this (these) change(s); and (4) the name, address, and phone number of the appropriate institutional and state (and, as appropriate, testing company) officials to contact.

The institution should send this information addressed to the following individual:

(Posted March 14, 2001)

VERIFICATION OF DATA

IHE's ability to verify pass rate calculations

Question: How does the reporting guide ensure an IHE's ability to verify the pass rates attributable to its program completers?

Answer: The Department lacks the legal authority to compel states or testing companies to provide IHEs with the scores of individual program completers, data that the IHEs could use to verify the accuracy of pass rate calculations performed by the testing company or state. However, the guide acknowledges that for many IHEs these linked data may be the best way to verify pass rate calculations and directs states to try to develop procedures that can accommodate IHEs' desire for these linked data, to the extent possible. Where state law or policy does not permit the state agency to develop these procedures, IHEs still will be able to receive from the testing company or state a list of all completers whose scores are included in the pass rate calculations. They also will be able to receive the scores of these completers, albeit scores not linked to a particular test taker.

The cost and burden an institution assumes in this verification process will depend, in part, on the number of program completers whose scores it chooses to verify as properly included in the pass rate calculations and on its willingness to use random sampling.

General quality control

Question : What kind of quality control will exist to ensure that this occurs?

Answer: The guide requires states' agencies, in collaboration with all IHEs in their states, to develop procedures to implement the reporting methods and key definitions that the guide includes. In the report on procedures which is due to the Department by October 7, 2000 (and which the Department will forward to the Congress and otherwise make public), the state agency will need to describe its procedures for ensuring this kind of basic quality control.

More specifically, states will have to develop and implement procedures to ensure that they and IHEs use the definitions of program completer, teacher preparation program, and other terms that the guide specifies, and that all data are complete and accurate.

RANKINGS

Quartile rankings

Question: How is the reporting guide's ranking system fair? High-performing IHEs could be ranked toward the bottom even though they are doing well, and IHEs that serve large numbers of disadvantaged students may rank toward the bottom even though their teacher preparation programs are effective.

Answer: While no single measure can fully describe the complexity and quality of a teacher preparation program, the law requires states to rank institutions based on pass-rate data. To ensure both fairness and clarity in ranking, the guide requires that all institutions be ranked by quartile, and each institution that is ranked in the same quartile has the same ranking. The mean of each quartile as well as the range also is provided. All IHEs in the state with the same pass rates are ranked in the same quartile even if this means that the number of IHEs in each quartile differs.

Beyond these reporting rules, the guide stresses that ranking by pass rates is an incomplete measure of the relative quality of a state's teacher preparation programs. For this reason, the guide emphasizes that IHEs and states may report supplemental information that they believe will help the public better understand the relative quality of each IHE's teacher preparation program.

WAIVERS

State collection of waiver data

Question: Why does the reporting guide ask states to collect new information and report the number of teachers with waivers based on new definitions and categories, rather than according to the state's own definition of waivers?

Answer: Each state uses its own terminology and procedures for allowing schools to hire teachers who lack certification or licensure to teach in K-12 classrooms. Likewise, though all states have procedures for granting waivers of one kind or another, not all use the term waiver. Indeed, the Initial report of the Secretary on the Quality of Teacher Preparation, which relied upon state self-reporting and which the Department issued to Congress in January 2000, identifies a number of states that claimed that they do not even grant waiver - something which is known not to be the case.

Congress charged ED (through NCES) with developing "key definitions for terms, and uniform reporting methods" for all states and institutions to use in preparing their reports. See section 207(a) of Title II. The guide therefore includes a clear, reasonable, universal definition of the term "waiver" that will (a) provide basic meaningful information to the public, and (b) be the basis for each state's data on the numbers of individuals teaching with waivers.

In examining why states grant waivers (whatever term states use) to permit unlicensed or uncertified individuals to teach, it is clear that some reasons were more important than others. For example, a teacher who is licensed in State A and who moves to State B typically will be able to immediately begin teaching only with a waiver until she or he has met the specific requirements of State B. However, there is no reason to believe that this teacher is not otherwise qualified, and hence no reason to believe that the public needs to have the reporting guide require states to report the number of individuals in this situation who are teaching with waivers. On the other hand, of great interest to the public is the number of teachers whom the state allows to teach who no state has ever determined meets its basic requirements for initial certification or licensure. These data are very meaningful, and they are what the reporting guide requires states to collect.

In addition, at higher grade levels, uncertified or unlicensed teachers who are known to have adequate content knowledge are better able to teach than those who do not have this content knowledge. For this reason, and to make the reported waiver data as meaningful as possible, the guide requires states to disaggregate from the total number of persons who meet the guide's definition of waiver, the number of individuals who are teaching certain subjects and in certain grades who either (1) have majored in college in the subject they are teaching, or (2) have passed the state's content examination for that subject.

Collecting and reporting these two categories of data should not be difficult or unreasonably burdensome. We understand that states already require school districts, which would employ an individual without a state teaching certificate or license to teach, to apply to the state for some kind of a waiver. Therefore, as the guide now provides, states would need only to ensure that these "waiver applications" include, if for some reason they do not already, a place for the applicant to indicate whether she or he is already certified or licensed in another state, and the identity of that state. A similar "check-off" form can be used to collect data on individuals with waivers who have adequate subject matter content. (Section 207 requires states to report the distribution of those teaching with waivers across high- and low-poverty areas and across subject areas. So the state also would need to collect, aggregate, and report these data in ways that allows for this self-reporting. Hence it likely would need to coordinate some with each LEA in the state.)

STUDENT/FACULTY RATIO

Supervised teaching information

Question: How should institutions of higher education (IHEs) provide information on the number of faculty and on the student-faculty ratio in supervised teaching in the institutional questionnaire? (See the item in the institutional questionnaire on page 46 of the guide.)

Answer:Section 207 requires that IHEs report information on the faculty-student ratio in supervised practice teaching. (The reporting guide converts this ratio to a student-faculty ratio for ease of interpretation.) This ratio is to be reported in "publications such as school catalogs and promotional materials sent to potential applicants, secondary school guidance counselors, and prospective employers of the institution's program graduates," as well as in the institutional questionnaire. This information will provide consumers with information to make better choices regarding enrollment in teacher preparation programs and hiring program completers. States are not required to include IHE student-faculty ratios, or the related information that institutions provide them on the number of faculty and students who participate in supervised teaching in the state reports they will submit to the U.S. Department of Education (ED).

In the institutional questionnaire, IHEs must separately report the numbers of supervising regular faculty who, at any time during the academic year, have full-time appointments, who have part-time appointments, and who are (in name or effect) clinical faculty with rights and responsibilities of regular faculty. The questionnaire also requires that IHEs report the total number of students (in regular and alternative teacher preparation programs) who were in programs of supervised student teaching during the academic year. The total of the three categories of faculty along with the number of students involved in practice teaching over the course of an academic year are the numbers to be used in calculating the student-faculty ratio.

If IHEs offer supervised student teaching in only one term (e.g., semester, quarter, or trimester) or for the entire academic year, the numbers reported in the institutional questionnaire should reflect the number of faculty who supervise student teachers for that time period. But for IHEs that, depending on the term of the academic year, offer supervised teaching to different students (and perhaps by different faculty) the student-faculty ratio calculated as provided in the institutional questionnaire may not be provide the public the information that truly reflects the supervised teaching that the IHEs offer.

The Department encourages IHEs that conduct supervised practice teaching to different groups of students throughout an academic year to respond to the institutional questionnaire with an average student-faculty ratio for all the terms in which practice teaching is offered during the entire academic year. Instead of reporting the cumulative number of faculty and students in supervised teaching for the entire academic year as described above, these IHEs are encouraged to report (1) the average number of faculty, (2) the average number of students, and (3) the average faculty-student ratio, over all terms of the academic year in which they offer supervised practice teaching.

In addition, because IHEs may use the three types of faculty in supervising practice teaching to varying degrees of intensity, the total number of supervising faculty may not accurately reflect the amount of faculty involvement in supervised student teaching. Thus, a simple count of faculty (or any student-faculty ratio using that number) cannot be used to accurately compare the level of faculty supervision across IHEs, and neither section 207 nor the reporting guide requires states to compile for the public IHE-by-IHE information that might be used to make these comparisons. Only consistent use of full-time equivalent (FTE) faculty numbers would make comparisons of this kind useful. The reporting guide does not require faculty FTE numbers to be reported because ED determined that the additional precision such numbers would offer would not offset the additional burden such calculations would place on IHEs.

As with other areas of the reporting guide, IHEs are free to report supplemental information in their institutional questionnaires and publications that can provide a more complete picture of faculty support for students during supervised teaching. For example, those IHEs having relatively few faculty intensively involved in supervising practice teaching will report a relatively high student-faculty ratio. Some of these IHEs, in fact, may have their faculty working very intensively with students during supervised teaching. In situations such as these, IHEs are encouraged to see whether inclusion of supplemental information can help to better describe their program of faculty-supervised instruction. In addition, states may wish to work with their IHEs to develop a format to collect supplemental information that will help to better explain the approaches to practice teaching taken by teacher preparation programs in their state.

LOW-PERFORMING INSTITUTIONS

Identifying low-performing institutions

Question: Some states are working on new ways of approving and evaluating teacher preparation programs that better reflect program performance. These states may need several years to implement these new approaches. Can they defer submitting the procedure they will use for identifying low-performing institutions required by section 208, and the names of affected institutions, until the new performance-based, program-approval system is in place?

Answer: No. States may not delay reporting of information on low-performing institutions. Moreover, the Department has no authority to waive this or any other requirement of the state or institutional reports.

Title II requires states, in order to receive funds under the Higher Education Act (HEA), to have a procedure to identify and assist low-performing programs of teacher preparation within institutions of higher education. States must also provide to the Department of Education a statement of this procedure along with annual lists of low-performing institutions and any institutions at risk of being considered low performing. While the law provides that states must report this information not later than two years after the date of enactment of the HEA, which was October 7, 1998, the Department has interpreted the law as authorizing a one-year extension of the reporting requirement because of the additional time needed to issue the definitions and procedures states and institutions must use for collecting the information required by section 207 of the HEA. States now have to begin reporting their procedure for identifying low-performing institutions, and any institutions so identified, as part of their first annual state report to the US Department of Education due by October 7, 2001.

Beyond this, section 208 of the HEA says that states are solely responsible for establishing the procedure they use to identify low-performing institutions. The law does not require states to use any of the information that section 207 and the Department's reporting guide require states to include in their annual report. Nor does Title II address the relationship between the procedure used for identifying low-performing institutions and the criteria a state uses to approve programs of teacher preparation.

In the long run, states may want to link new rules for performance-based program approval to the procedure that they use for identifying low-performing institutions and those at risk of being considered low performing. However, until these new rules are in place, states must have some procedure for identifying and assisting low-performing institutions, and report this procedure and any affected institutions to the Department annually, beginning October 7, 2001. The Department urges states to collaborate with all institutions of higher education in the state on what this procedure should be.

(posted June 27, 2000)

Question: What is the timeline for identifying low-performing institutions?

Answer: States must have in place criteria for identifying low-performing institutions and institutions at-risk of being identified as low performing by October 7, 2001. These criteria must be included in the state questionnaire due to the U.S. Department of Education by October 7, 2001. If states have not had an opportunity to apply the criteria by October 7, 2001, they must do so as soon as possible but no later than the due date for the next annual state questionnaire of October 7, 2002.

(Posted March 9, 2001)

HOW THE REPORTING SYSTEM WILL WORK

State relations with private IHEs

Question: States are responsible for developing data collection procedures that apply to both public and private IHEs. What is being done to ensure that state agencies do not use the reporting requirements to intrude upon private IHEs and affect their historic independence?

Answer: The guide is clear that the reporting system should not be used as a vehicle for activities that private IHEs may view as overreaching:

Ultimately, though, the issue of how states treat private IHEs in response to the reporting system is something that state agencies and the IHEs themselves will need to work out.

Electronic reporting

Question: Is the Department planning to provide any assistance to states and IHEs in developing a web-based data collection system they may use for preparing and submitting their Title II reports?

Answer:Yes. The Department already has identified several commercial-off-the-shelf (COTS) software systems that it believes could be adapted to meet the needs of many states and institutions for Title II reporting, and it will provide the names of those systems to those interested. It is also working with a software vendor to develop a prototype system that may be more easily adapted for use in some states. If ED believes the prototype is workable, it will share information about the system with those interested.

Release to the Public

Question: When do states and the Department need to release to the public the information that states submitted to the Department in early October to meet their state Title II reporting responsibilities?

Answer: States--As with state release of the Title II institutional reports that it receives each April, each state's "open records" laws - not federal law - determine whether and when the state must make public the information it submits to the Department to meet its reporting responsibilities under section 207(b) of Title II of the Higher Education Act. While section 207(b) requires states to submit this information to the Department in October of each year, neither Title II nor other federal laws speaks to what states must do, if anything, to release this information to the public.

Having said this, the overall scope of Title II plainly favors public disclosure. In establishing the Title II reporting system, Congress focused on the public's lack of basic information about whether those who complete teacher preparation programs are prepared to teach, and what state licensing and certification requirements affect who teaches in our Nation's classrooms. Congress insisted that institutions and states quickly become more accountable to the public in these areas. Hence, we believe Title II anticipates that once states (and the Department) have finished the process of compiling the reports (see below), policymakers and the public would have access to the information in them.

The Department--To ease the reporting burdens that states otherwise would have faced in preparing and submitting the data and other information required by Title II, the Department had all states submit their data and information in electronic format to its technical assistance contractor, which is currently Westat. (Again, each state's "open records" law-not federal law-determines whether, when, and in what formats states need to make their electronic submissions available to the public.) Westat then assumed responsibility for converting and compiling these data and information into consistently formatted reports.

The Department will make these state materials available to the public in the form of completed state reports once Westat and the Department have -

1. Completed the process of compiling and reconfiguring the data and information submitted into comprehensible state reports, and
2. Provided each state an opportunity both to examine the reconfigured submissions that contain the data and other information provided to Westat, and to correct any oversights or omissions.
   

The department expects this process to be completes by mid-November of this year.

(Posted October 25, 2001)

INSTITUTIONAL REPORTS

Publicizing information

Question: Must states make institutional reports public after receiving them next April?

Answer: Whether states must make the IHE reports they receive in April of each year public -- and the process and timelines they must follow when required to do so -- are matters governed by each state's "open records" laws, not federal law. While Title II requires IHEs to publicize in school catalogs or other promotional material the pass rates and other information they include in these institutional reports, neither Title II nor other federal law speaks to what states must do with the IHE reports they receive.

Having said this, the overall scope of Title II plainly favors public disclosure. In establishing the Title II reporting system, Congress focused on the public's lack of basic information on whether those who complete teacher preparation programs are prepared to teach, and how state licensing and certification requirements may affect who teaches in our Nation's classrooms. Congress insisted that institutions and states quickly become more accountable to the public in these areas. Hence, we believe Title II anticipates that once institutional, state or national reports are completed, policymakers and the public at large will be able to review these reports to help determine how well particular teacher preparation programs and state policies as a whole are working.

We understand that immediate release of individual IHE reports may convey an incomplete picture; some important contextual information for the state as a whole might not be available until as late as the following October when the state prepares its own report to the U.S. Secretary of Education. Still, we believe that members of the public will very much want to review IHE reports as soon as the state receives them. As states determine how state law requires them to proceed, we note only that under the Title II reporting system the data that IHEs must report are final when submitted to the state. In particular, the system requires any disputes regarding computing and reporting institutional pass rates to be resolved before, rather than after, IHEs submit their reports.

(Posted October 20, 2000)

Question: What are the requirements for public disclosure in Title II of the Higher Education Act (HEA) for institutions of higher education with regard to the information in their institutional reports?

Answer: Title II has public disclosure requirements for institutions of higher education in sections 207(f)(1) and 207(f)(2). Section 207(f)(1) provides that institutions subject to the new national reporting system, i.e., those with a teacher preparation program enrolling students receiving federal assistance under the HEA, must report annually "to the State and the general public" certain information. This information consists of the pass rate of their program completers on assessments required by the state for teacher licensure or certification, the statewide pass rate on those assessments, and other basic information on their teacher preparation program, all of which is explained in the Department's Reference and Reporting Guide (see especially pages 43-47). While section 207(f)(1) provides that this reporting is to begin no later than April 7, 2000, the Department concluded that the law permits the first reporting to be deferred one year until April 7, 2001.

Section 207(f)(2) further requires institutions to report this same information "through publications such as school catalogs and promotional materials sent to potential applicants, secondary school guidance counselors, and prospective employers of the institution's program graduates."

Together these provisions mean that each institution must do two things upon submitting its required report to the state by April 7 of each year:

1. The institution must make the information in the current report available to the public. Some examples of how to reach the public include: providing a copy upon request; preparing a press release with the report's content; and posting and directing people to the report on the institution's Internet web site.
   
   
2. The institution must also include the current report's information in or with publications that it sends to potential applicants, guidance counselors, or prospective employers of the institution's program completers. The law does not require institutions to make a special effort solely for the purpose of distributing the information in the Title II report. Rather the information should be included in any materials it routinely sends to potential applicants, guidance counselors, and prospective employers.

As the Department has previously indicated, this second requirement does not mean institutions must annually reprint publications such as course catalogs just to incorporate the latest Title II information. The Department does, however, expect that the most recent Title II information will be added to these publications as normal publication deadlines for them are reached.

The Department has also gotten questions asking if the Title II report could be disseminated like the mandated reports on campus security and athletic programs. These reports must be produced and made readily available upon request. Institutions must send a notice of the availability of these reports to enrolled and prospective students. The institutions can, however, disseminate the reports through a Web site (but must also provide a paper copy upon request). Institutions are allowed to simply include a Web address (URL) for accessing the reports in the notification they must send out, but not include the full reports. The HEA provision governing the reports on campus security and athletic programs, however, specifically mentions electronic disbursement of information; Title II law does not. Further, the disclosure requirements in Title II are distinct and explicit regarding the inclusion of required Title II information in publications sent out to potential applicants, guidance counselors, and prospective employers of graduates. Title II makes no allowance for the report to be made available solely on a Web site.

The Department also notes that the Title II guide encourages institutions to add supplemental data to their reports to give the public a better understanding of the performance of their teacher preparation program. Such information is also likely to be helpful if included in materials prepared for the general public, potential applicants, guidance counselors, prospective employers of their program's completers, and others.

(Posted February 1, 2001)

This page was last updated on 10/25/2001.

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