Administrative Rules of the State of Montana

BEFORE THE BOARD OF PUBLIC EDUCATION

OF THE STATE OF MONTANA

In the matter of the amendment of ARM 10.57.421 pertaining to teacher licensure

)

NOTICE OF AMENDMENT

TO: All Concerned Persons

1. On May 25, 2018, the Board of Public Education (board) published MAR Notice No. 10-57-283 pertaining to the public hearing on the proposed amendment of the above-stated rule at page 1004 of the 2018 Montana Administrative Register, Issue Number 10.

2. The board has amended the above-stated rule as proposed.

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: Dr. Rob Watson, Superintendent, Bozeman Public Schools and Administrative Representative on the Certification Standards and Practices Advisory Council, spoke in support of the proposed rule amendment. Dr. Watson discussed the state requirement for all students who graduate from accredited schools to have one credit of Career and Technical Education (CTE). Expanding CTE offerings in P-12 provides students with new opportunities for career readiness. The board added a BioMed CTE in 2008. The proposed computer coding and teacher education endorsements will add two new CTE options for students. Local industry and workforce employers are supportive of preparing students in skill sets listed in the proposed CTE offerings. The proposed CTE endorsements are consistent with the board's definition of Career and Vocational/Technical Education Program Standards as defined in ARM 10.55.1701.

RESPONSE #1: The board thanks the commenter for his comments and appreciates his support for expanding opportunities for students to explore new opportunities in CTE.

COMMENT #2: Dr. Kirk Miller, School Administrators of Montana, and Mr. Marco Ferro, MEA-MFT, spoke in support of the proposed rule amendments and believe the proposed rule supports the board's constitutional duty and mission to supervise and strengthen Montana's public schools. The proposed rule will ensure greater opportunities for students to engage in content that will prepare them for post-secondary success while considering current and projected workforce needs and job opportunities as described in 20-7-301(8), MCA.

RESPONSE #2: The board thanks the commenters for their comments and supports expanding opportunities for students in workforce and career development in fulfillment of the board's constitutional obligation to supervise and strengthen Montana's public-school system.

COMMENT #3: The Montana Public Education Center (MT PEC), SAM, MTSBA, MEA-MFT, MASBO, MREA, and MQEC submitted a letter of support for the proposed rule amendment, noting that by 2020 the U.S. Bureau of Labor Statistics predicts that there will be 1.4 million more software development jobs available than applicants. The proposed rule amendment will allow students the opportunity to "engage in content that will prepare them for post-secondary success while considering the current and projected workforce need and job opportunities."

RESPONSE #3: The board thanks the commenters for their comments and for expressing support for the proposed rule.

COMMENT #4: Mr. Dennis Parman, Executive Director, Montana Rural Education Association, spoke in support of the rule amendment noting that the rulemaking process has been slow and deliberate, allowing many opportunities for thorough debate and consideration of the proposal. MREA recognizes concerns regarding quality but supports the rule.

RESPONSE #4: The board thanks the commenter for his comments and appreciates the comments on the rulemaking process.

COMMENT #5: Mr. Cameron Wilson, Chief Operating Officer, Code.org, submitted a letter in support of the proposed rule amendment stating that Code.org has made "computer science more accessible for teachers through high-quality professional development pathways to certification" and urges the board's approval of the rule amendment.

RESPONSE #5: The board thanks the commenter for his comments regarding the availability of quality professional development opportunities for educators to learn computer coding.

COMMENT #6: Mr. Douglas Fischer, Trustee, Bozeman Public Schools, submitted comments in support of the computer coding proposal. Mr. Fischer stated that schools have an obligation to prepare today's students for tomorrow's careers. Mr. Fischer added that school districts must have maximum flexibility to bring qualified professionals to fill crucial positions to meet student demand for classes, without diminishing the quality of instruction.

RESPONSE #6: The board thanks the commenter for his comments and supports the concept of affording school districts flexibility to provide qualified professionals to teach students the necessary content and skills to enhance the potential for post-secondary and career success.

COMMENT #7: Dr. Carol Reifschneider, Interim Dean of the College of Education, Arts, and Sciences at MSU-Northern, and member of the Montana Council of Deans of Post-Secondary Education and representing the Council of Deans (MSU-Bozeman, MSU-Northern, MSU-Billings, UM-Missoula, UM-Western, University of Providence, Rocky Mountain College, Carroll College, Salish-Kootenai College, Stone Child College), spoke in opposition to the proposed rule amendment. The Council of Deans is concerned that the rules will negatively impact the quality of preparation for educators to teach computer science courses in K-12 schools. The Council of Deans believes 80 hours of preparation in computer coding is insufficient and does not provide the necessary pedagogy to effectively prepare teachers to teach computer science coursework in schools. The Council of Deans outlined several steps the educator preparation programs are taking to address school district challenges in Montana. The Council of Deans assert the proposed rule amendments are detrimental to the teaching profession, weaken the current Class 4 CTE endorsement 10,000-hour requirement, and that professional development courses will not replace what can be learned through a teaching endorsement in computer science.

RESPONSE #7: The board thanks the commenters for their comments. The board appreciates the concerns expressed by the Council of Deans of Post-Secondary Education regarding quality of teacher preparation. However, the computer coding and teacher education CTE endorsements will expand opportunities for P-12 students in schools of every size, across the state, to explore opportunities in computer coding and teacher education without compromising educator quality.

COMMENT #8: Dr. Tricia Siefert, Head of the Department of Education at MSU-Bozeman, submitted a letter that highlighted concerns that computer coding is a very narrow skill set within the much broader field of computer science and an educator needs to have the breadth of knowledge of a computer science degree to effectively teach the specific skill of computer coding.

RESPONSE #8: The board thanks the commenter for their comments and concurs that computer coding is a specific skill set within the broad field of computer science. However, exposing P-12 students to computer coding courses in P-12 will enhance opportunities for students to have an initial introduction to a CTE skill that may lead to further exploration of computer science in post-secondary education.

COMMENT #9: Dr. Nick Lux, MSU-Bozeman, Dr. John Paxton, MSU-Bozeman, and Dr. Yolanda Reimer, University of Montana, submitted a joint letter in opposition to the proposed rule amendment. The letter expressed four areas of concern: 1) the rule change is shortsighted with too much emphasis on computer coding and not enough emphasis in other areas of computer science, 2) coding is secondary in the process of learning computer science, 3) there are already teacher training mechanisms pertaining to computer science available within the Montana University System teacher training programs, and 4) that the proposed rule amendment is a misuse of the Class 4 endorsement as also stated by Dr. Siefert.

RESPONSE #9: The board thanks the group for their comments but believes that the proposed rule will expand opportunities for P-12 students to explore opportunities in computer coding and teacher preparation. The new computer coding and teacher education CTE courses may increase the number of students who consider post-secondary education opportunities and careers in the areas of computer science and teaching.

COMMENT #10: Devin Holmes, Founder: Teachers Teaching Tech, and Lander Bachert, K-12 Programs Director: Teachers Teaching Tech, wrote a letter in support of the proposed rule amendment. Teachers Teaching Tech provides rigorous, no-cost/low cost computer science curriculum and professional development opportunities to all Montana teachers, providing "a pathway for motivated teachers to fulfill the proposed 80-hour endorsement at no cost to them or their district." Teachers Teaching Tech 100% approves of the proposed rule amendment.

RESPONSE #10: The board thanks Teachers Teaching Tech for their comments and for the professional development opportunities they provide to Montana teachers seeking educational opportunities in computer science to meet the requirements of the proposed rule amendment.

/s/ Peter Donovan /s/ Sharon Carroll

Peter Donovan Sharon Carroll

Rule Reviewer Chair

Board of Public Education

Certified to the Secretary of State July 31, 2018.