BEFORE THE BOARD OF PUBLIC EDUCATION

OF THE STATE OF MONTANA

 

In the matter of the amendment of ARM 10.57.102, 10.57.114, 10.57.215, 10.57.410, 10.57.411, 10.57.412, 10.57.414, 10.57.415, 10.57.418, 10.57.419, 10.57.420, 10.57.421, 10.57.424, 10.57.425, 10.57.427, 10.57.428, 10.57.431, 10.57.432, 10.57.434, 10.57.435, and 10.57.437 pertaining to Educator Licensure Standards

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NOTICE OF AMENDMENT

 

TO: All Concerned Persons

 

1. On February 9, 2024, the Board of Public Education (board) published MAR Notice No. 10-57-289 pertaining to the public hearing on the proposed amendment of the above-stated rules at page 175 of the 2024 Montana Administrative Register, Issue Number 3.

 

2. The board has amended the following rules as proposed: ARM 10.57.102, 10.57.114, 10.57.215, 10.57.410, 10.57.411, 10.57.412, 10.57.414, 10.57.415, 10.57.418, 10.57.419, 10.57.420, 10.57.421, 10.57.424, 10.57.425, 10.57.427, 10.57.428, 10.57.431, 10.57.432, 10.57.434, 10.57.435, and 10.57.437.

 

3. The board has thoroughly considered the comments and testimony received. A summary of the comments received, and the board's responses are as follows:

 

COMMENT 1: One commenter opposed the revisions to ARM 10.57.102(2) and stated that the "a state board of public education or state agency" language is unclear on how this constitutes an accrediting body for higher education that is equivalent to CHEA or other similar institutions and has requested the board maintain licensing criteria that aligns to nationally recognized standards.

 

RESPONSE: The board disagreed with Comment 1 and stated that this language aligns with accredited specialist programs for school counselors ARM 10.57.102(2)(b)(ii) and approved preparation programs for educators ARM 10.57.102(5)(b).

 

COMMENT 2: Two commenters and MSCA opposed the removal of "school counseling K-12" in ARM 10.57.425(4) and stated that the Montana State University Counseling Department is currently working on a hybrid school counseling endorsement that would fulfill these licensure requirements and would allow vested and licensed educators to stay in their home communities, receive school counseling training, and increase the amount of prepared, professional school counselors in the field, and decrease the need for emergency authorizations. 

 

RESPONSE: The board disagreed with Comment 2 and stated the provisions for receiving a Class 5 Provisional License for school counselors are outlined in ARM 10.57.435.

 

COMMENT 3: Seven commenters, LDA, MASP, MPA, MSCA, NASP, and NCLD opposed the revisions to ARM 10.57.432 and stated it is unclear how OPI would determine whether people who have a degree in another field but taking courses concurrently would have sufficient course content and experience to be successful, and encourages the board to consider modifying or revising the proposal to ensure that school psychologists have affiliated school psychologist training, and has requested that the board maintain the requirement for verification from an accredited specialist-level program in school psychology and maintain the requirement to be within four course deficiencies of completion.

 

COMMENT 4: The MCASE Board and SAM Board supported the revisions in ARM 10.57.432 and stated that the revisions allow for more flexibility for recruitment into the field and that the proposal would not allow for individuals to become licensed who do not have the appropriate education or experience.

 

RESPONSE: The board disagreed with Comment 3 and agreed with Comment 4 and stated that the proposed revisions in ARM 10.57.432 allow for more flexibility by allowing more participation, rather than only those who are within four course deficiencies.

 

COMMENT 5: Seven commenters, LDA, MASP, MSCA, NASP, and NCLD opposed the revisions to ARM 10.57.434 and stated that due to the reduction in hours, Montana would no longer meet the standard requirements set forth by the National Association of School Psychologists.  This reduction could potentially harm the ability to negotiate the opportunity to participate in an interstate compact, which they are currently working on, receive federal funding and grants, and support recruitment in the profession.  The commenters have requested the board maintain the 1200-hour requirement.

 

COMMENT 6: The MCASE Board and SAM Board supported the revisions in ARM 10.57.434 and stated that the revisions allow for more flexibility for recruitment into the field and that the proposal would not allow for individuals to become licensed who do not have the appropriate education or experience.

 

RESPONSE: The board disagreed with Comment 5 and agreed with Comment 6 and stated that the reduction in hours in ARM 10.57.434 allows for a pathway for those seeking a Class 6 Specialist Licensure from out-of-state.

 

4. The rules amended in this notice are effective July 1, 2024.

 

/s/ McCall Flynn                                          /s/ Tim Tharp          

McCall Flynn                                               Tim Tharp

Executive Director                                       Chair

Board of Public Education                           Board of Public Education

 

 

Certified to the Secretary of State May 14, 2024.