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| Montana Administrative Register Notice 10-57-288 | No. 10 05/27/2022 | |
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BEFORE THE BOARD OF PUBLIC EDUCATION OF THE STATE OF MONTANA
TO: All Concerned Persons
1. On January 28, 2022, the Board of Public Education (board) published MAR Notice No. 10-57-288 pertaining to the public hearing on the proposed adoption, amendment, and repeal of the above-stated rules at page 103 of the 2022 Montana Administrative Register, Issue Number 2.
2. The board has repealed the following rules as proposed: ARM 10.57.416, 10.57.417, 10.57.426, 10.57.429, and 10.57.430.
3. The board has adopted the following rule as proposed: NEW RULE II (ARM 10.57.222).
4. The board has amended the following rules as proposed: ARM 10.57.109, 10.57.112, 10.57.201A, 10.57.216, 10.57.217, 10.57.218, 10.57.411, 10.57.412, 10.57.413, 10.57.415, 10.57.421, 10.57.425, 10.57.428, 10.57.432, 10.57.433, 10.57.601A, 10.57.601B, and 10.57.607, to be effective upon adoption.
5. The board has adopted the following rule as proposed, but with the following changes from the original proposal, new matter underlined, deleted matter interlined:
NEW RULE I (10.57.221) RECIPROCITY FOR MILITARY SPOUSES/DEPENDENTS (1) and (2) remain as proposed. (3) The applicant must: (a) be the spouse and/or a dependent of an active-duty member of the United States armed forces who has been transferred to Montana, is scheduled to be transferred to Montana, is domiciled in Montana (b) remains as proposed. (c) An applicant for a Class 3 administrative license must submit verified completion of the requirements of ARM
AUTH: Mont. Const. Art. X, sec. 9, 20-4-102, MCA IMP: Mont. Const. Art. X, sec. 9, 20-4-103, 20-4-106, MCA
6. The board has amended the following rules as proposed, but with the following changes from the original proposal, new matter underlined, deleted matter interlined:
10.57.102 DEFINITIONS The following definitions apply to this chapter. (1) remains as proposed. (3) through (5) remain as proposed but are renumbered (2) through (4). (a) An educator preparation program accredited by the National Council for the Accreditation of Teacher Education (NCATE) or the Council for the Accreditation of Educator Preparation (CAEP) or the Montessori Accreditation Council for Teacher Education (MACTE). A MACTE educator preparation program is subject to the following restrictions: (i) Completion of a MACTE accredited program may only be used by an applicant for licensure who has also completed at least a bachelor's degree; and (ii) The resulting license granted to an applicant for licensure who has completed a MACTE accredited program shall be limited to early grades or middle grades licensure and only for the grade levels covered by the MACTE accredited program completed by the applicant; or (b) An educator preparation program at a regionally accredited college or university approved or accredited by a state board of education or state education agency; or (c) An educator preparation program approved by a state board of education or state education agency that leads to licensure in the state of preparation. (8) remains as proposed but is renumbered (7). (a) For each course required by the program, multiply the numeric grade value earned by the number of credits for the course; (b) Sum the products for all the courses included in (a); and (c) Divide the sum calculated in (b) by the total credits for all the required courses. (10) and (11) remain as proposed but are renumbered (9) and (10). (a) the licensee has not earned the required number of (b) the licensee has earned the required number of (13) remains as proposed but is renumbered (12). (13) "Military dependent" means an adult dependent of a member of the armed forces of the United States, or a reserve component of the armed forces of the United States, stationed in Montana in accordance with military orders or stationed in Montana before a temporary assignment to duties outside of the state. (14) remains as proposed. (15) "Student-teaching portfolio" (16) and (17) remain as proposed. (18) "Year of administrative experience" means employment as a licensed administrator at any level within a P-12 school system, or in an educational institution specified in 20-9-707, MCA, for a minimum of a 180-day school year or its equivalent in minimum aggregate hours as defined by 20-1-301, MCA, and during that year, must have been at least a 0.5 full time employee (FTE). Experience as a County Superintendent may be considered as "administrative" experience with evidence of the following: (a) and (b) remain as proposed. (19) "Year of teaching experience" means employment as a licensed teacher at any level within a P-12 school system, or in an educational institution specified in 20-9-707, MCA, for a minimum of a 180-day school year or its equivalent in minimum aggregate hours as defined by 20-1-301, MCA, and during that year, must have been at least a 0.5 full time employee (FTE). Experience gained prior to initial licensure is not considered.
AUTH: Mont. Const. Art. X, sec. 9, 20-4-102, MCA IMP: Mont. Const. Art. X, sec. 9, 20-4-106, MCA
10.57.107 EMERGENCY AUTHORIZATION OF EMPLOYMENT (1) In accordance with 20-4-111, MCA, district administrators who have exhausted all possibilities for hiring a licensed teacher may request that the Superintendent of Public Instruction issue an emergency authorization of employment to the district to employ a person to teach. The following requirements must be met to ensure (a) remains as proposed. (b) The position must have been advertised at least statewide far enough in advance to reasonably enable qualified applicants to submit applications and be interviewed. The obligation of a statewide advertisement may be satisfied through any reasonable means, including use of the Montana Jobs for Teachers Service of the Office of Public Instruction. (c) The individual for whom the emergency authorization is being sought (i) through (iv) remain as proposed. (2) An emergency authorization of employment is valid for one year and is eligible for continued authorization from year to year depending on satisfaction of conditions set forth in this rule. (3) and (4) remain as proposed.
AUTH: Mont. Const. Art. X, sec. 9, 20-4-102, MCA IMP: Mont. Const. Art. X, sec. 9, 20-4-111, MCA
10.57.215 PROFESSIONAL DEVELOPMENT AND RENEWAL REQUIREMENTS (1) remains as proposed. (a) Applicants for an initial Montana Class 1, 2, 3, and 6 license whose degree is more than five years old and who do not have a current out-of-state (2) through (5) remain as proposed.
AUTH: Mont. Const. Art. X, sec. 9, 20-2-121, 20-4-102, MCA IMP: Mont. Const. Art. X, sec. 9, 20-4-102, 20-4-108, MCA
10.57.301 ENDORSEMENT INFORMATION (1) through (3) remain as proposed. (a) (i) through (4) remain as proposed.
AUTH: Mont. Const. Art. X, sec. 9, 20-4-102, MCA IMP: Mont. Const. Art. X, sec. 9, 20-4-103, 20-4-106, MCA
10.57.410 CLASS 2 STANDARD TEACHER'S LICENSE (1) through (3)(e)(ii) remain as proposed. (iii) a 3.00 or higher course work grade point average (GPA) as defined in ARM 10.57.102 and verified by the appropriate official from the educator preparation program (iv) verified completion of an educator preparation program, a current standard, unrestricted out-of-state educator license, and two years of successful teaching experience as defined in ARM 10.57.102 as documented by a recommendation from the out-of-state P-12 school employer on a form prescribed by the superintendent of public instruction. (4) and (5) remain as proposed.
AUTH: Mont. Const. Art. X, sec. 9, 20-2-121, 20-4-102, MCA IMP: Mont. Const. Art. X, sec. 9, 20-4-102, 20-4-103, 20-4-106, 20-4-108, MCA
10.57.414 CLASS 3 ADMINISTRATIVE LICENSE - SUPERINTENDENT ENDORSEMENT (1) through (1)(b) remain as proposed. (c) completion of courses covering Montana (i) (ii) (d) through (g) remain as proposed.
AUTH: Mont. Const. Art. X, sec. 9, 20-4-102, MCA IMP: Mont. Const. Art. X, sec. 9, 20-4-106, 20-4-108, MCA
10.57.418 CLASS 3 ADMINISTRATIVE LICENSE - SUPERVISOR ENDORSEMENT (1) through (1)(b) remain as proposed. (c) eligibility (d) through (f) remain as proposed.
AUTH: Mont. Const. Art. X, sec. 9, 20-4-102, MCA IMP: Mont. Const. Art. X, sec. 9, 20-4-106, 20-4-108, MCA
10.57.419 CLASS 3 ADMINISTRATIVE LICENSE - SPECIAL EDUCATION SUPERVISOR ENDORSEMENT (1) through (1)(b) remain as proposed. (c) three years of teaching experience or three years of experience in a P-12 school setting with a standard, unrestricted license as a fully licensed and assigned related services provider; (d) through (g) remain as proposed.
AUTH: Mont. Const. Art. X, sec. 9, 20-4-102, MCA IMP: Mont. Const. Art. X, sec. 9, 20-4-106, 20-4-108, MCA
10.57.420 CLASS 4 CAREER AND TECHNICAL EDUCATION LICENSE (1) through (2)(a) remain as proposed. (b) A Class 4B license issued to individuals with a certificate of completion from an apprenticeship program or associate or bachelor's degree from a regionally accredited college or university, but who do not hold a valid Montana teaching license with the appropriate career and technical education endorsement; and (c) through (5) remain as proposed.
AUTH: Mont. Const. Art. X, sec. 9, 20-4-102, MCA IMP: Mont. Const. Art. X, sec. 9, 20-4-106, 20-4-108, MCA
10.57.424 CLASS 5 PROVISIONAL LICENSE (1) remains as proposed. (2) A Montana educator may be issued only one Class 5 provisional license per teaching license (Class 1 or 2), administrator license (Class 3), or specialist license (Class 6). A Class 5 provisional license is not available for an initial Class 4 license or a Class 7 or 8 license. (2) remains as proposed but is renumbered (3). (a) remains as proposed. (4) through (5)(a) remain as proposed but are renumbered (5) through (6)(a). (b) a current Montana address or job offer from a (c) remains as proposed. (6) remains as proposed but is renumbered (7).
AUTH: Mont. Const. Art. X, sec. 9, 20-4-102, MCA IMP: Mont. Const. Art. X, sec. 9, 20-4-106, 20-4-108, MCA
10.57.427 CLASS 5 PROVISIONAL LICENSE – SUPERINTENDENT ENDORSEMENT (1) through (1)(e) remain as proposed. (f) for those applicants who have not completed the courses covering Montana (i) (ii) (2) remains as proposed.
AUTH: Mont. Const. Art. X, sec. 9, 20-4-102, MCA IMP: Mont. Const. Art. X, sec. 9, 20-4-106, 20-4-108, MCA
10.57.431 CLASS 5 PROVISIONAL LICENSE - SUPERVISOR ENDORSEMENT (1) and (1)(a) remain as proposed. (b) three years of appropriately licensed experiences as a teacher or counselor in the area requested for supervisory endorsement or three years of experience in a P-12 school setting as a fully licensed and appropriately assigned related services provider; and (c) remains as proposed.
AUTH: Mont. Const. Art. X, sec. 9, 20-4-102, MCA IMP: Mont. Const. Art. X, sec. 9, 20-4-106, 20-4-108, MCA
10.57.434 CLASS 6 SPECIALIST LICENSE - SCHOOL PSYCHOLOGIST (1) and (1)(a) remain as proposed. (b) completion of a specialist level degree from a NASP accredited school psychologist program which included a 1200-hour internship, of which 600 hours were in a P-12 school setting; or (c) and (c)(i) remain as proposed. (ii) recommendation from a NASP accredited specialist program defined in ARM 10.57.102, attesting to the applicant's qualifications being equivalent to NASP training standards, which included a 1200-hour internship experience of which 600 hours were in a P-12 school setting.
AUTH: Mont. Const. Art. X, sec. 9, 20-4-102, MCA IMP: Mont. Const. Art. X, sec. 9, 20-4-106, 20-4-108, MCA
10.57.435 CLASS 6 SPECIALIST LICENSE - SCHOOL COUNSELOR (1) and (1)(a) remain as proposed. (b) completion of a CACREP accredited school counselor program which included an internship in a P-12 school setting of 600 hours; or (c) and (c)(i) remain as proposed. (ii) recommendation from an approved specialist program defined in ARM 10.57.102, which included an internship in a P-12 school setting of 600 hours.
AUTH: Mont. Const. Art. X, sec. 9, 20-4-102, MCA IMP: Mont. Const. Art. X, sec. 9, 20-4-106, 20-4-108, MCA
10.57.436 CLASS 7 AMERICAN INDIAN LANGUAGE AND CULTURE SPECIALIST (1) A Class 7 American Indian language and culture specialist license is valid for a period of five years (2) through (5) remain as proposed. (6) A Class 7 American Indian language and culture specialist license may be renewed upon meeting the terms of the renewal as provided in the memorandum of understanding in (2). (6) remains as proposed but is renumbered (7).
AUTH: Mont. Const. Art. X, sec. 9, 20-4-102, MCA IMP: Mont. Const. Art. X, sec. 9, 20-4-103, 20-4-106, MCA
10.57.437 CLASS 8 DUAL CREDIT POSTSECONDARY FACULTY LICENSE (1) through (3)(a) remain as proposed. (b) compliance with all other nonacademic requirements for licensure as required by 20-4-104, MCA, ARM 10.57.201, and 10.57.201A; (c) recommendation from the Chief Academic Officer from a regionally accredited college or university verifying (d) through (6) remain as proposed.
AUTH: Mont. Const. Art. X, sec. 9, 20-4-102, MCA IMP: Mont. Const. Art. X, sec. 9, 20-4-106, 20-4-108, MCA
7. 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: Sixteen commenters, including NWMASS and MTPEC, supported licensure reciprocity for military spouses in New Rule I.
COMMENT 2: The Board Licensure Committee commented that the term "military dependent" in New Rule I should be defined and worked with Malmstrom Air Force Base to suggest the following definition: "Military dependent" is an adult dependent of a member of the armed forces of the United States or a reserve component of the armed forces of the United States stationed in Montana in accordance with military orders or stationed in Montana before a temporary assignment to duties outside of the state.
COMMENT 3: CSPAC recommended the Board either define the use of "dependents" or remove the new rule entirely in New Rule I.
COMMENT 4: The Governor's Office and Republican legislators commented that they support automatic reciprocity for military spouses and dependents in New Rule I and would encourage the board and OPI to enter into multi-state reciprocity agreements with states who have similar licensing standards to Montana.
RESPONSE to COMMENTS 1-4: The Board of Public Education agreed with Comments 1-4 in regard to New Rule I, with the exception that the reference in New Rule I(3)(c) refers to ARM 10.57.413, not ARM 10.57.415.
COMMENT 5: Fourteen commenters, including NWMASS and MTPEC, oppose proposed New Rule II, as it is duplicative and allows the superintendent to change rules, which are covered under other proposed rules.
RESPONSE: The Board of Public Education disagreed with the commenters, as this information is already allowable in ARM 10.57.102(3)(b)(ii).
COMMENT 6: Fourteen commenters, including NWMASS and MTPEC, support the following proposed changes in ARM 10.57.102: (2)(b): Accredited educator preparation program–suggested the board remove the stricken language in the first sentence to read "an educator preparation program at a regionally accredited college or university approved or accredited by a state board of education or a state education agency" (3)(b)(ii): Accredited educator preparation program–suggested the board include education to read "state education agency" (4): Age 3-21–suggested the board add a new definition for "Age 3-21" which would be defined as, "denotes a scope of service to children by licensed educators beginning at age 3, including preschools, kindergartens, and other early childhood programs authorized by law and continuing through the age of 21 under circumstances authorized by law"
COMMENT 7: CSPAC recommended support of the changes from grade to age in ARM 10.57.102(4).
COMMENT 8: The Governor's Office disagreed with changes in ARM 10.57.102(4) and stated that licensure definitions are commonly described by grade levels. (6): Approved preparation program–suggested changing the definition to "means an accredited educator preparation program as defined in (2) of this rule. (10): Endorsement- (a) change to "Age 3-Grade 3 (early childhood programs, including preschool or other early childhood programs authorized under exceptional circumstances pursuant to 20-5-101)"; (f) change to "Age 3-21"
COMMENT 9: CSPAC recommended support of the changes from grade to age in ARM 10.57.102(10).
COMMENT 10: The Governor's Office disagreed with changes in ARM 10.57.102(10) and stated that licensure definitions are commonly described by grade levels.
(18): Year of administrative experience–suggested changing the definition to "Age 3-21" and "for the equivalent of at least .5 full time employee (FTE) for a school year comparable to a 180-day school year.
COMMENT 11: CSPAC recommended support of the changes from grade to age in ARM 10.57.102(18).
COMMENT 12: The Governor's Office disagreed with changes in ARM 10.57.102(18) and stated that licensure definitions are commonly described by grade levels.
(19): Year of teaching experience–suggested changing the definition to "Age 3-21" and "for the equivalent of at least .5 full time employee (FTE) for a school year comparable to a 180-day school year. Experience gained prior to initial licensure is not considered unless such experience is gained as a student teacher engaged in "supervised teaching experience" as defined in ARM 10.57.102(16)"
COMMENT 13: CSPAC recommended support of the changes from grade to age in ARM 10.57.102(19).
COMMENT 14: The Governor's Office disagreed with changes in ARM 10.57.102(19) and stated that licensure definitions are commonly described by grade levels.
RESPONSE to COMMENTS 6-14: The Board of Public Education recognized Comments 6-14 and disagreed with the proposed changes, with the exception that the board agreed with the Governor's Office's opposition to the MTPEC recommendation to move from grade to age.
COMMENT 15: Sixteen commenters, including the MCDE, are concerned by the replacement of "accredited professional educator preparation program" with "approved educator preparation program" in ARM 10.57.102.
COMMENT 16: The MCDE commented that by approving the superintendent's proposed revisions, Montana EPPs are being held to higher standards set forth in Chapter 58 and those from out-of-state who have not completed accredited programs. Additionally, they suggest trusting data that shows alternatively prepared teachers from approved programs are more likely to leave the profession.
RESPONSE to COMMENTS 15-16: The Board of Public Education appreciates Comments 15 and 16 and thanked MCDE for voicing concerns and believes that the proposed definition, as currently written in ARM 10.57.102(5), is a compromise between all parties.
COMMENT 17: CSPAC recommended the board consult with MCDE to define "approved program" and outline more clearly what that is and how it differs from "accredited program" under ARM 10.57.102.
COMMENT 18: One commenter and the Governor's Office supported adding the proposed definition for approved educator preparation programs and accredited programs in ARM 10.57.102 and recognizes the diverse ways in which educators gain experience and can be licensed.
COMMENT 19: The Board Licensure Committee commented that the definition of ARM 10.57.102(2) "Accredited preparation program" should be struck and instead included under the new definition for (6) "Approved educator preparation program," which is the umbrella term for traditional and alternate educator preparation programs. They proposed the following definition: "Approved educator preparation program" means: (a) an educator preparation program accredited by the National Council for the Accreditation of Teacher Education (NCATE) or the Council for the Accreditation of Educator Preparation (CAEP) or the Montessori Accreditation Council for Teacher Education (MACTE). A MACTE educator preparation program is subject to the following restrictions: (i) Completion of a MACTE accredited program may only be used by an applicant for licensure who has also completed at least a bachelor's degree; and (ii) The resulting license granted to an applicant for licensure who has completed a MACTE accredited program shall be limited to early grades or middle grades licensure and only for the grade levels covered by the MACTE accredited program completed by the applicant then a (accredited/traditional); or (b) an educator preparation program at a regionally accredited college or university approved or accredited by a state board of education or state education agency; or (c) an educator preparation program approved by a state board of education or state education agency that leads to licensure in the state of preparation.
RESPONSE to COMMENTS 17-19: The Board of Public Education agreed with Comments 17-19 and thanked the Board Licensure Committee for bringing forward a solution that encompasses all educator preparation program pathways. The board has incorporated the new definition under Comment 19 in ARM 10.57.102(5).
COMMENT 20: The Board Licensure Committee commented that the definition of ARM 10.57.102(7) "Certification" was not revised consistent with the proposed changes in the rest of ARM. They recommended the use of the term "approved" in place of "accredited." They've suggested the following definition: "Certification" means licensure of an educator/specialist, as issued by the state of Montana, based on completion of a teacher, administrator, or specialist program of an approved educator preparation program. Certification includes grade level(s), endorsement(s), and classification.
RESPONSE: The Board of Public Education agreed with the Board Licensure Committee and thanked them for bringing language consistent with other proposed changes. The board has incorporated this new definition in ARM 10.57.102(6).
COMMENT 21: The Board Licensure Committee commented that the definition of ARM 10.57.102(9) "Coursework GPA" is confusing. They suggested the following definition: "Coursework GPA" means the weighted average of teacher education program course grades, weighted by credit hours, and calculated over the defined period of study at a regionally accredited college or university. The weights reflect the relative contributions of teacher education program course requirements, including content area coursework, based on contact hours or credits earned. The weighted average is calculated as follows: (a) For each course required by the program, multiply the numeric grade value earned by the number of credits for the course; (b) Sum the products for all the courses included in (a); and (c) Divide the sum calculated in (b) by the total credits for all the required courses.
RESPONSE: The Board of Public Education agreed with the Board Licensure Committee and thanked them for bringing proposed language to define Coursework GPA. The board has incorporated this new definition in ARM 10.57.102(8).
COMMENT 22: The Board Licensure Committee commented that the definition of ARM 10.57.102(12) "Lapsed license" still refers to "renewal units" in (a) and (b). They suggested removing "renewal" and inserting "professional development" to be consistent with the other proposed changes.
RESPONSE: The Board of Public Education agreed with the Board Licensure Committee and thanked them for the proposed language. The board has made these corrections in ARM 10.57.102(11).
COMMENT 23: The Board Licensure Committee commented that in the proposed definition of ARM 10.57.102(15) "Student-teaching portfolio," it is unclear whether student learning outcomes refers to the learning outcomes for the teaching candidate or the students in the K-12 classroom. They suggested the following definition: "Student-teaching portfolio" is a type of performance assessment that asks students to demonstrate what they have learned, how they engage in the learning process, and how they apply their knowledge demonstrating their preparedness for the teaching profession.
COMMENT 24: CSPAC recommended the board work with the MCDE to define "student teaching portfolio" in ARM 10.57.102(15).
COMMENT 25: The Governor's Office commented that student-teaching portfolio as defined in ARM 10.57.102(15) recognizes the diverse ways educators can demonstrate their knowledge and skills.
RESPONSE to COMMENTS 23-25: The Board of Public Education agreed with Comments 23-25 and thanked the Board Licensure Committee for bringing a proposed definition. The board has incorporated these recommendations in the new definition for ARM 10.57.102(15).
COMMENT 26: The Board Licensure Committee commented that the definition of (17) "Unrestricted license" is confusing and leaves out lifetime licenses. They have suggested the following language: "Unrestricted license" means a current renewable or lifetime license.
RESPONSE: The Board of Public Education initially agreed with the changes from the Board Licensure Committee, as the proposed definition from the superintendent conflicted with her original recommendation for the Class 7 License to be a lifetime license. The board approved MACIE's recommendation to revert to the current rule that requires the renewal process for the Class 7 license; therefore, the definition of unrestricted license is no longer needed to include lifetime licenses. The board has reverted to the superintendent's original recommendation that reads, ARM 10.57.102(17) "Unrestricted License" means a current renewable license that is not an emergency or provisional license.
COMMENT 27: The Board Licensure Committee commented that the proposed definition for ARM 10.57.102(18) "Year of administrative experience" refers to a 180-day school year. Given that many schools operate on a 4-day school week, they recommended the following language: "Year of administrative experience" means employment as a licensed administrator at any level… for a minimum of a 180-day school year, or its equivalent in minimum aggregate hours as defined by 20-1-301, MCA, and during that year, must have been at least a 0.5 full-time employee (FTE).
COMMENT 28: The Board Licensure Committee commented that the proposed definition for ARM 10.57.102(19) "Year of teaching experience" refers to a 180-day school year. Given that many schools operate on a 4-day school week, they recommended the following language: "Year of administrative experience" means employment as a licensed teacher at any level… for a minimum of a 180-day school year, or its equivalent in minimum aggregate hours as defined by 20-1-301, MCA, and during that year, must have been at least a 0.5 full-time employee (FTE).
RESPONSE to COMMENTS 27-28: The Board of Public Education agreed with Comments 27 and 28 and thanked the Board Licensure Committee for providing a proposed definition that is inclusive to school districts with 4-day school weeks. The board has incorporated these changes in ARM 10.57.102(18) and (19)
COMMENT 29: Thirteen commenters, including NWMASS and MTPEC, support the following proposed changes in ARM 10.57.107: (1): suggested an edit to the last sentence to strike "consideration" and insert "approval" (1)(b): added a sentence that reads "The obligation of a statewide advertisement may be satisfied through any reasonable means, including use of the Montana jobs for teachers service of the Office of Public Instruction"
COMMENT 30: CSPAC agreed with MTPEC's recommendation in ARM 10.57.107(1)(b).
(1)(c): struck "shall not be currently endorsed in the area of a requested authorization" (2): added to the end of the sentence to read "…and is eligible for continued authorization from year to year depending on satisfaction of conditions set forth in this rule"
COMMENT 31: CSPAC agreed with MTPEC's recommendation in ARM 10.57.107(2).
COMMENT 32: CSPAC recommended the board accept the superintendent's recommendation in ARM 10.57.107(1)(c)(iv) and (4).
RESPONSE to COMMENTS 29-32: The Board of Public Education agreed with Comments 29-32 and thanked CSPAC for their support of the recommendations. The board has incorporated these changes in ARM 10.57.107.
COMMENT 33: Twelve commenters, including the Governor's Office, NWMASS, and MTPEC, agreed with the proposed changes in ARM 10.57.109.
RESPONSE: The Board of Public Education agreed with the commenters to ARM 10.57.109 and accepted the rule as proposed by the superintendent.
COMMENT 34: Two commenters concurred with the task force recommendation in ARM 10.57.109, rather than the superintendent's recommendation, and stated the board does not have the authority to abdicate its responsibility.
COMMENT 35: One commenter stated that the superintendent should not decide on certification for unusual cases in ARM 10.57.109, as it paves the way for partisan politics to enter the process.
RESPONSE to COMMENTS 34-35: The Board of Public Education disagreed with Comments 34 and 35 and noted that OPI convenes an Education Licensure Review Committee that reviews licensure applications and finds appropriate resolution to recommend to the superintendent. Though the board takes their responsibility very seriously, they believe this OPI Review Committee is sufficient to review and recommend unusual cases.
COMMENT 36: Thirteen commenters, including NWMASS and MTPEC, agreed with the changes as proposed in ARM 10.57.112.
RESPONSE: The Board of Public Education agreed with the commenters to ARM 10.57.112 and accepted the rule as proposed by the superintendent.
COMMENT 37: One commenter stated that the proposed language in ARM 10.57.112 does not specify which Class 5 license the exchange teacher is eligible for.
RESPONSE: The Board of Public Education thanked the commenter for their input in ARM 10.57.112 and explained that the appropriate Class 5 license would be issued based on the educators' qualifications.
COMMENT 38: Thirteen commenters, including NWMASS and MTPEC, agreed with the changes as proposed in ARM 10.57.201A.
RESPONSE: The Board of Public Education agreed with the commenters and accepted the rule as proposed by the superintendent in ARM 10.57.201A.
COMMENT 39: One commenter stated we need to focus on background checks and drug testing of educators and that substitute teachers should go through the same types of testing.
RESPONSE: The Board of Public Education thanked the commenter for their input and stated that school districts have discretion to adopt local policy requiring criminal background checks and drug testing staff and employees.
COMMENT 40: The Board Licensure Committee commented that the language in ARM 10.57.215(1)(a) is an incomplete sentence and recommended the following language: (a) Applicants for an initial Montana Class 1, 2, 3 and 6 license whose degree is more than five years old and who do not have a current out-of-state license may be issued a license with verification of 60 professional development units earned within the five-year period preceding the effective date of the license.
COMMENT 41: Sixteen commenters, including CSPAC, NWMASS, Lindsay School Board, and MTPEC, agreed with the changes as proposed in ARM 10.57.215.
RESPONSE to COMMENTS 40-41: The Board of Public Education agreed generally with the commenters in Comments 40 and 41 and thanked the Board Licensure Committee for proposing clean up language. The board has incorporated the changes in ARM 10.57.215.
COMMENT 42: Sixteen commenters, including CSPAC, NWMASS, Lindsay School Board, and MTPEC, agreed with the changes as proposed in ARM 10.57.216.
COMMENT 43: Sixteen commenters, including CSPAC, NWMASS, Lindsay School Board, and MTPEC, agreed with the changes as proposed in ARM 10.57.217.
COMMENT 44: Sixteen commenters, including CSPAC, NWMASS, Lindsay School Board, and MTPEC, agreed with the changes as proposed in ARM 10.57.218.
RESPONSE to COMMENTS 42-44: The Board of Public Education agreed with the commenters in Comments 42-44 and accepted the rules as proposed by the superintendent in ARM 10.57.216, 10.57.217, and 10.57.218.
COMMENT 45: Seventeen commenters, including the UM Professional Education Unit Faculty, are concerned with the proposed changes for adding an endorsement in ARM 10.57.301, stating that an educator cannot have the qualifications, experience, and background knowledge in specialized fields by completing two years of teaching and passing the Praxis.
RESPONSE: The Board of Public Education disagreed with the commenters and believes the addition of ARM 10.57.301(3)(c) allows for more flexibility for local school districts to find licensed educators to teach under multiple endorsement areas. The board has retained the superintendent's proposed recommendation.
COMMENT 46: Fourteen commenters, including CSPAC, NWMASS, and MTPEC, supported the changes from grade to age in ARM 10.57.301.
RESPONSE: The Board of Public Education disagreed with these comments in ARM 10.57.301, as this is inconsistent with language in other board rules.
COMMENT 47: The Governor's Office disagreed with the suggestion in ARM 10.57.301 and stated licensure definitions are commonly described by grade levels.
RESPONSE: The Board of Public Education agreed with the Governor's Office and has retained the superintendent's recommendation in ARM 10.57.301.
COMMENT 48: Six commenters, including the Governor's Office, Republican legislators, and Lindsay School Board, supported the current changes in ARM 10.57.301, making it easier to add an endorsement, based on the ability to take the Praxis exam, rather than attend an educator preparation program.
COMMENT 49: CSPAC recommended the board accept the superintendent's proposed changes to ARM 10.57.301(3)(a) and (b).
RESPONSE to COMMENTS 48-49: The Board of Public Education agreed with Comments 48 and 49 and believe that the additional flexibilities proposed in ARM 10.57.301 are good for public education in Montana. The board has retained the superintendent's recommendations in ARM 10.57.301.
COMMENT 50: The Board Licensure Committee commented that the language in ARM 10.57.301(3)(a) refers to "endorsement program" completion, a term that is not used elsewhere in ARM. They proposed the following language to reflect the same language used in (2): (3)(a) completion of a program of study as verified by the appropriate official, defined in ARM 10.57.102.
RESPONSE: The Board of Public Education agreed with the Board Licensure Committee and thanked them for proposing clean up language in ARM 10.57.301(3)(a). The board has incorporated these changes in rule.
COMMENT 51: One commenter stated they are unable to obtain a specific endorsement, as they have a different endorsement from another state. (Health and Physical Education vs. Health Enhancement)
COMMENT 52: One commenter supported the BPE Internship Program to assist teachers in adding endorsements.
RESPONSE to COMMENTS 51-52: The Board of Public Education acknowledged Comments 51 and 52 and believe that the approved changes will provide for more flexibility that could ultimately assist out-of-state educators in getting their license in Montana.
COMMENT 53: Fourteen commenters, including NWMASS and MTPEC, supported adding the following language in ARM 10.57.410(3)(e) "verified completion of an educator preparation program, a current standard, unrestricted out-of-state educator license, and two years of successful teaching experience as defined in ARM 10.57.102 as documented by a recommendation from the out-of-state accredited P-12 school employer on a form prescribed by the superintendent of public instruction."
COMMENT 54: Thirteen commenters, including NWMASS and MTPEC, commented that by requiring a Praxis score that meets Montana cut scores is duplicative and unnecessary, as any recent licensed education graduate from another state with a standard license and two or more years of experience already has a pre-licensure assessment score. MTPEC recommended the following language under ARM 10.57.410(3)(e)(iv) "verified completion of an educator preparation program, a current standard, unrestricted out-of-state educator license, and two years of successful teaching experience as defined in ARM 10.57.102 as documented by a recommendation from the out-of-state state accredited P-12 school employer on a form prescribed by the superintendent of public instruction."
COMMENT 55: Twelve commenters, including NEMASS, supported the recognition of teaching licenses from other states.
COMMENT 56: Nine commenters, including the Governor's Office, Republican legislators, NEMASS, and Lindsay School Board, supported the revisions in ARM 10.57.410 that allow for multiple pathways to licensure to show competency beyond the Praxis exam.
RESPONSE to COMMENTS 53-56: The Board of Public Education agreed with Comments 53-56 and have incorporated the recommendation to add an additional pathway to licensure for out-of-state educators in ARM 10.57.410(3)(e)(iv).
COMMENT 57: Seven commenters opposed the revisions in ARM 10.57.410 that allow for multiple pathways to licensure and stated the Praxis does not indicate one's teaching ability, rather one should have to demonstrate competency through teaching experience.
RESPONSE: The Board of Public Education disagreed with these commenters in ARM 10.57.410 and stated the additional flexibilities will support recruitment and retention of educators.
COMMENT 58: Three commenters supported lifetime licenses and stated it is difficult to work another job in the private sector and still be able to get enough renewal units for licensure. Additionally, they stated that lifetime licenses may keep them in the profession to assist in substitute teaching or emergency authorizations.
COMMENT 59: Two commenters are concerned about lifetime licenses and stated that educators should continue to receive professional development and renewal process, as it relates to checks and balances.
RESPONSE to COMMENTS 58-59: The Board of Public Education acknowledged Comments 58 and 59 and commented that lifetime licenses will be recognized, and licensees will receive the appropriate license in Montana, based on their experience and education that meets the provisions under ARM 10.57.410. Professional development is still required for all classes of licensure.
COMMENT 60: One commenter and the Board Licensure Committee supported retaining the requirement for successful teaching experience in ARM 10.57.410.
RESPONSE: The Board of Public Education determined that successful teaching experience is no longer required for licensure, except for the new section that requires proof of two years' successful teaching experience if out-of-state educators cannot meet the requirements in ARM 10.57.410(3)(e)(i), (ii), and (iii).
COMMENT 61: The Governor's Office supported removing the required years of experience in ARM 10.57.410 for out-of-state educators and adding professional development opportunities to university coursework for recency requirements.
RESPONSE: The Board of Public Education agreed with the Governor's Office and has retained the superintendent's recommendations in ARM 10.57.410.
COMMENT 62: One commenter opposed changing the required years of experience from five years to none in ARM 10.57.410. Additionally, they do not believe the TEACH program is an incentive for new teachers, as it does not address the problem of low pay, long hours, affordable housing, and local or community support.
RESPONSE: The Board of Public Education determined that successful teaching experience is no longer required for licensure, except for the new section that requires proof of two years' successful teaching experience if out-of-state educators cannot meet the requirements in ARM 10.57.410(3)(e)(i), (ii), and (iii). The TEACH Act is not under the supervision of the Board of Public Education; rather it is part of the Governor's budget and is intended to increase starting teacher pay.
COMMENT 63: Thirteen commenters, including NWMASS and MTPEC, agreed with the changes as proposed in ARM 10.57.411.
COMMENT 64: Three commenters supported license reciprocity for National Board Certified Teachers.
COMMENT 65: The Governor's Office supported removing the required years of experience for out-of-state educators in ARM 10.57.411 and adding professional development opportunities to university coursework for recency requirements.
RESPONSE to COMMENTS 63-65: The Board of Public Education agreed with Comments 63-65 and have retained the superintendent's recommendations in ARM 10.57.411.
COMMENT 66: Two commenters supported lifetime licenses for National Board Certified Teachers.
RESPONSE: The Board of Public Education commented that lifetime licenses will be recognized, and licensees will receive the appropriate license in Montana, based on their experience and education that meets the provisions under ARM 10.57.411.
COMMENT 67: Fourteen commenters, including CSPAC, NWMASS, and MTPEC, supported the changes from grade to age in ARM 10.57.412.
RESPONSE: The Board of Public Education disagreed with these commenters in ARM 10.57.412, as this is inconsistent with language in other board rules.
COMMENT 68: The Governor's Office disagreed with the suggestion in ARM 10.57.412, as licensure definitions are commonly described by grade levels.
RESPONSE: The Board of Public Education agreed with the Governor's Office and have retained the superintendent's recommendations in ARM 10.57.412.
COMMENT 69: Fourteen commenters, including NWMASS and MTPEC, supported adding the following language in ARM 10.57.412: "completion of an educator preparation program, a current standard, unrestricted out-of-state educator license, and two years of successful teaching experience as defined in ARM 10.57.102 documented by a recommendation from a state accredited P-12 school employer on a form prescribed by the superintendent of public instruction."
COMMENT 70: Thirteen commenters, including NWMASS and MTPEC, commented that requiring a Praxis score that meets Montana cut scores is duplicative and unnecessary, as any recent licensed education graduate from another state with a standard license and two or more years of experience already has a pre-licensure assessment score. MTPEC recommended the following language under ARM 10.57.412(6): "completion of an educator preparation program, a current standard, unrestricted out-of-state educator license, and two years of successful teaching experience as defined in ARM 10.57.102 documented by a recommendation from a state accredited P-12 school employer on a form prescribed by the superintendent of public instruction."
COMMENT 71: One commenter and the Board Licensure Committee supported retaining the requirement for successful teaching experience in ARM 10.57.412.
RESPONSE to COMMENTS 69-71: The Board of Public Education conceptually agreed with Comments 69-71 and does not plan to repeat the language in this section, as it is already included under ARM 10.57.410, which they believe is sufficient.
COMMENT 72: One commenter stated that years of experience should be required in ARM 10.57.412 for those coming from out-of-state alternative preparation programs.
RESPONSE: The Board of Public Education stated that required experience is already included in ARM 10.57.410 for out-of-state educators who cannot meet the requirements under ARM 10.57.410(3)(e)(i), (ii), and (iii).
COMMENT 73: Thirteen commenters, including NWMASS and MTPEC, supported additional language in ARM 10.57.413 that reads "an applicant for a Class 3 Administrative License who completed an educator preparation program, which does not meet the definition in ARM 10.57.102, who is currently licensed in another state at the same level of licensure, may be considered for licensure with verification of two years of successful administrative experience as defined in ARM 10.57.102 as documented by a recommendation from a state accredited P-12 school employer on a form prescribed by the superintendent of public instruction and approved by the Board of Public Education."
COMMENT 74: The Board Licensure Committee supported retaining the requirement for successful administrative experience in ARM 10.57.413.
RESPONSE to COMMENTS 73-74: The Board of Public Education conceptually agreed with Comments 73 and 74 and does not plan to repeat the language in ARM 10.57.413, as it is already included under specific endorsement areas, which they believe is sufficient.
COMMENT 75: Three commenters, including CSPAC and the Governor's Office, supported the counselor to administrator pathway throughout ARM.
RESPONSE: The Board of Public Education agreed with the commenters and recognized through their work with unusual cases that this is an area of need for increased flexibility. The board has retained the superintendent's recommendations in ARM 10.57.413.
COMMENT 76: The Governor's Office supported removing the required years of experience for out-of-state educators in ARM 10.57.413 and adding professional development opportunities to university coursework for recency requirements.
RESPONSE: The Board of Public Education agreed with the Governor's Office and have retained the superintendent's recommendations in ARM 10.57.413.
COMMENT 77: One commenter supported a pathway for school psychologists in ARM 10.57.413 to be licensed as principals, like the proposed revisions allow for school counselors.
RESPONSE: The Board of Public Education disagreed with the commenter and stated that this is not an issue that has been previously brought before the board and that they would like more information before moving forward. The topic of a pathway to administrative licensure for school counselors has been brought before the board on a number of occasions as unusual cases and discussions with education partners.
COMMENT 78: Fifteen commenters, including NWMASS and MTPEC, suggested changes to ARM 10.57.414(1)(c) that read "(c) completion of courses covering Montana School Finance, Montana School Law and Montana Collective Bargaining and Employment Law, in order to qualify, such courses must have been provided either by: (i) an approved professional development provider pursuant to ARM 10.57.216 that has provided approved courses for at least five consecutive years in the required areas for which a candidate submits evidence to qualify for licensure; or (ii) an approved school administrator preparation program."
COMMENT 79: The Governor's Office and Republican legislators supported adding the option in ARM 10.57.414 for professional development in addition to traditional university coursework in Montana school law, finance, and collective bargaining.
RESPONSE to COMMENTS 78-79: The Board of Public Education generally agreed with Comments 78 and 79, with the exception to Comment 78 that required the professional development provider to have provided approved courses for at least five consecutive years. The board has incorporated these changes in ARM 10.57.414.
COMMENT 80: Thirteen commenters, including NWMASS and MTPEC, agreed with the changes as proposed in ARM 10.57.415.
RESPONSE: The Board of Public Education agreed with the commenters and have retained the superintendent's recommendations in ARM 10.57.415.
COMMENT 81: One commenter opposed the proposed rules that remove Montana before school law in ARM 10.57.415.
RESPONSE: The Board of Public Education disagreed with this commenter and stated that Montana-specific school law, which is required under ARM 10.57.414, is more appropriate for school superintendents.
COMMENT 82: Thirteen commenters, including NWMASS and MTPEC, agreed with the changes as proposed in ARM 10.57.418.
COMMENT 83: The Board Licensure Committee suggested the deletion of the word "requirements" in ARM 10.57.418(1)(c). The concept is that the applicant must provide verification of eligibility for a Class 1 or Class 2 teaching license endorsed in the field of specialization or Class 6 school counseling license.
RESPONSE to COMMENTS 82-83: The Board of Public Education generally agreed with Comments 82 and 83 and thanked the Board Licensure Committee for providing clean up language. The board has incorporated the changes from Comment 83 into ARM 10.57.418.
COMMENT 84: Thirteen commenters, including NWMASS and MTPEC, agreed with the changes as proposed in ARM 10.57.419.
COMMENT 85: The Board Licensure Committee recommended retaining the words "school setting" in ARM 10.57.419(1)(c). According to OPI, the intent was to delete the word "accredited," not "school setting." They have suggested the following language: (1)(c) three years of teaching experience in a P-12 school setting.
RESPONSE to COMMENTS 84-85: The Board of Public Education generally agreed with Comments 84 and 85 and thanked the Board Licensure Committee for providing clean up language. The board has incorporated the changes from Comment 85 in ARM 10.57.419.
COMMENT 86: One commenter opposed removing state-accredited in ARM 10.57.419, as it opens the door to where one receives experience from.
RESPONSE: The Board of Public Education noted that by adding in "P-12 school-setting," as agreed upon in Comment 85, the required experience will be reinstated in ARM 10.57.419(1)(c).
COMMENT 87: Fifteen commenters, including the Governor's Office, NWMASS, and MTPEC, agreed with the changes as proposed in ARM 10.57.420.
COMMENT 88: CSPAC recommended support of the changes from 10,000 to 5,000 hours of experience in ARM 10.57.420, and the reduction of professional development hours from 80 to 60.
RESPONSE to COMMENTS 87-88: The Board of Public Education agreed with Comments 87 and 88 and thanked them for their support. The board has retained the recommendations from the superintendent in ARM 10.57.420.
COMMENT 89: The Board Licensure Committee commented that edits are needed in ARM 10.57.420(2)(b) acknowledge completion of education. They have suggested the following language: A Class 4B license issued to individuals with a certificate of completion from an apprenticeship program, or an associate or bachelor's degree from a regionally accredited college or university.
COMMENT 90: Thirteen commenters, including NWMASS and MTPEC, agreed with the changes as proposed in ARM 10.57.420.
RESPONSE to Comments 89-90: The Board of Public Education generally agreed with Comments 89 and 90 and thanked the Board Licensure Committee for including additional language. The board has incorporated the changes from Comment 89 in ARM 10.57.420.
COMMENT 91: One commenter supported creating a group of cybersecurity experts to address the omission of a cybersecurity endorsement in ARM 10.57.421.
RESPONSE: The Board of Public Education noted that this endorsement would likely be allowable under Class 4 licensure. The board stated that they need more information before including the specific endorsement under ARM 10.57.421.
COMMENT 92: The Board Licensure Committee and CSPAC commented that the last two sentences under ARM 10.57.424(3) should be moved to the beginning of the rule as new (2), as the sentences are relevant to all Class 5 licenses, not just Class 5B.
RESPONSE: The Board of Public Education agreed with the Board Licensure Committee and thanked them for providing clean up language. The board has incorporated these changes under ARM 10.57.424.
COMMENT 93: Five commenters, including the Governor's Office, Lindsay School Board, and NWMASS, agreed with the changes as proposed in ARM 10.57.424.
COMMENT 94: The Board Licensure Committee commented that the term "state-funded school" in ARM 10.57.424(5)(b) traditionally refers to MSDB, Pine Hills, and Riverside. They believe the current language is confusing and proposed the following language: ARM 10.57.424(5)(b) a current Montana address or job offer from an accredited P-12 school in Montana.
RESPONSE to COMMENTS 93-94: The Board of Public Education generally agreed with Comments 93 and 94 and thanked the Board Licensure Committee for bringing proposed language to clear up any confusion on state-funded schools. The board has incorporated the changes in ARM 10.57.424.
COMMENT 95: Fourteen commenters, including CSPAC, NWMASS, and MTPEC, supported the changes from grade to age in ARM 10.57.425.
RESPONSE: The Board of Public Education disagreed with the commenters in reference to ARM 10.57.425, as this is inconsistent with language in other board rules.
COMMENT 96: The Governor's Office disagreed with the suggestion in ARM 10.57.425 and stated that licensure definitions are commonly described by grade levels.
RESPONSE: The Board of Public Education agreed with the Governor's Office and retained the superintendent's recommendation in ARM 10.57.425.
COMMENT 97: Thirteen commenters, including NWMASS and MTPEC, suggested the inclusion of the following language to ARM 10.57.427(1)(b) "…and two years of successful supervisory experience as a licensed administrator as defined in ARM 10.57.102, documented by a recommendation from a state accredited P-12 school employer on a form prescribed by the superintendent of public instruction."
COMMENT 98: The Board Licensure Committee supported retaining the requirement for successful supervisory experience in ARM 10.57.427.
COMMENT 99: Thirteen commenters, including NWMASS and MTPEC, suggested the inclusion of the following language to ARM 10.57.428(1)(b) "…and two years of successful supervisory experience as a licensed administrator as defined in ARM 10.57.102 as documented by a recommendation from a state accredited P-12 school employer on a form prescribed by the superintendent of public instruction."
COMMENT 100: The Board Licensure Committee supported retaining the requirement for successful supervisory experience in ARM 10.57.428.
RESPONSE to COMMENTS 97-100: The Board of Public Education conceptually agreed with Comments 97-100 and does not plan to repeat the language in ARM 10.57.427 and 10.57.428, as it is already included under the specific endorsement areas.
COMMENT 101: Thirteen commenters, including NWMASS and MTPEC, agreed with the changes as proposed in ARM 10.57.431.
COMMENT 102: The Board Licensure Committee supported adding "P-12" to the "school setting" language in ARM 10.57.431(1)(b) to be consistent with the rest of rule.
RESPONSE to COMMENTS 101-102: The Board of Public Education agreed with Comments 101 and 102 and thanked the Board Licensure Committee for providing clean up language. The board has incorporated these changes in ARM 10.57.431.
COMMENT 103: Thirteen commenters, including NWMASS and MTPEC, agreed with the changes as proposed in ARM 10.57.432.
RESPONSE: The Board of Public Education agreed with this comment and retained the superintendent's recommendations in ARM 10.57.432.
COMMENT 104: Fourteen commenters, including NWMASS, Lindsay School Board, and MTPEC, agreed with the changes as proposed in ARM 10.57.433.
RESPONSE: The Board of Public Education agreed with this comment and retained the superintendent's recommendations in ARM 10.57.433.
COMMENT 105: Thirteen commenters, including NWMASS and MTPEC, agreed with the changes as proposed in ARM 10.57.434.
COMMENT 106: The Board Licensure Committee supported adding "P-12" to the "school setting" language in ARM 10.57.434(1)(b) and (c)(ii) to be consistent with the rest of the rule.
COMMENT 107: Thirteen commenters, including NWMASS and MTPEC, agreed with the changes as proposed in ARM 10.57.435.
COMMENT 108: The Board Licensure Committee supported adding "P-12" to the "school setting" language in ARM 10.57.435(1)(b) and (c)(ii) to be consistent with the rest of the rule.
RESPONSE to COMMENTS 105-108: The Board of Public Education agreed with Comments 105-108 and thanked the Board Licensure Committee for providing clean up language. The board has incorporated these changes in ARM 10.57.434 and 10.57.435.
COMMENT 109: Fourteen commenters, including CSPAC, NWMASS, and MTPEC, agreed with the changes as proposed in ARM 10.57.436.
RESPONSE: The Board of Public Education disagreed with the commenters and approved recommendations provided by MACIE in Comment 110.
COMMENT 110: MACIE recommended the Class 7 License to only require a tribal delegate signature on the initial application in ARM 10.57.436. They suggested the board retain the five-year renewal process and allow for all professional development opportunities, including those required by the tribe as described in the MOU, to be acceptable under the renewal process.
RESPONSE: The Board of Public Education agreed with MACIE and thanked them for their involvement in the process. The board has incorporated these changes in ARM 10.57.436
COMMENT 111: Fifteen commenters, including CSPAC, the Governor's Office, NWMASS, and MTPEC, agreed with the changes as proposed in ARM 10.57.437.
RESPONSE: The Board of Public Education agreed with the commenters and retained the superintendent's recommendations in ARM 10.57.437.
COMMENT 112: The Board Licensure Committee commented that revisions needed to be made in ARM 10.57.437(3)(c) include (i), given the deletion of language in (ii). They have suggested the following language: (3)(c) recommendation from the Chief Academic Officer from a regionally accredited college or university verifying the applicant plans to teach.
RESPONSE: The Board of Public Education agreed with the Board Licensure Committee and thanked them for providing clean up language. The board has incorporated these changes in ARM 10.57.437.
COMMENT 113: The Governor's Office encouraged the board to consider striking ARM 10.57.437(4), as they believe CSPAC should not be reviewing Class 8 applications.
RESPONSE: The Board of Public Education disagreed with the Governor's Office, as CSPAC is tasked in ARM10.57.437 with making recommendations on the issuance of Class 8 licenses.
COMMENT 114: Two commenters agreed with the task force recommendation in ARM 10.57.601 to strike "or from any other credible source" or if the board would like to keep the language, then a definition should be provided for "credible source."
RESPONSE: The Board of Public Education disagreed with this comment and stated that this language needs to remain in rule and that a definition could possibly harm the flexibility regarding who could be considered a credible source.
COMMENT 115: The Governor's Office agreed with the superintendent in ARM 10.57.601 to keep the current rule as written to ensure members of the public are able to file a complaint about official misconduct.
RESPONSE: The Board of Public Education agreed with the Governor's Office and the current language in ARM 10.57.601 remains in rule.
COMMENT 116: Thirteen commenters, including NWMASS and MTPEC, agreed with the changes as proposed in ARM 10.57.601A.
RESPONSE: The Board of Public Education agreed with the commenters and retained the superintendent's recommendations in ARM 10.57.601A.
COMMENT 117: Thirteen commenters, including NWMASS and MTPEC, agreed with the changes as proposed in ARM 10.57.601B.
RESPONSE: The Board of Public Education agreed with the commenters and retained the superintendent's recommendations in ARM 10.57.601B.
COMMENT 118: Thirteen commenters, including NWMASS and MTPEC, agreed with the changes as proposed in ARM 10.57.607.
RESPONSE: The Board of Public Education agreed with the commenters and retained the superintendent's recommendations in ARM 10.57.607.
COMMENT 119: Thirty commenters, including MCDE, stated that Montana could retain our educators by incentivizing better pay, affordable housing, and more affordable health insurance coverage. Additionally, they stated that educators need to feel supported, respected, and appreciated for the professionals they are.
RESPONSE: The Board of Public Education recognizes that there are many factors related to the recruitment and retention issues facing the state, and that educator licensure is one small piece. The board has long respected and appreciated the work of public educators in Montana.
COMMENT 120: Seventeen commenters stated if standards are lowered, our state is doing a disservice to our youth.
RESPONSE: The Board of Public Education acknowledged the concern and will continue to support high-quality education in Montana.
COMMENT 121: Thirteen commenters, including NWMASS and MTPEC, agreed with the repeal of the following rules: ARM 10.57.416, 10.57.417, 10.57.426, 10.57.429, and 10.57.430.
RESPONSE: The Board of Public Education agreed with the commenters.
COMMENT 122: Five commenters, including CSPAC and the Governor's Office, supported the Indian Education for All requirements throughout the proposed revisions.
RESPONSE: The Board of Public Education agreed with the commenters and retained the superintendent's proposed revisions to incorporate Indian Education for All requirements throughout rule.
COMMENT 123: Two commenters, including the Governor's Office, supported the changes to Chapter 57 to help school districts recruit and retain qualified educators.
RESPONSE: The Board of Public Education agreed with the commenters and will continue to support the recruitment and retention of qualified educators in Montana and believes the changes in rule will provide more flexibility.
COMMENT 124: Three commenters, including MCDE, stated there is no evidence that relaxing or streamlining certification standards will attract more teachers to fill open positions and fix the teacher shortage. They have asked the board to show the data that proves that teacher candidates are waiting to come to Montana to take advantage of the lowered standards. Additionally, they have suggested the board decrease class sizes, provide more preparatory time, and investigate how to make the career of teaching more attractive to our younger generation.
COMMENT 125: The MCDE asked the board to consider the following suggestions: address the number of seniors pursuing post-secondary education, invite students to see themselves as educators by creating pathways, work with the Board of Regents to allow EPPs to offer endorsements in any area in which their resources permit, support students with scholarships who agree to teach in rural areas for a certain period of time, scale "grow your own" models, and ensure housing exists.
RESPONSE to COMMENTS 124-125: The Board of Public Education acknowledged Comments 124 and 125 and agreed that these are very important topics in public education and stated they needed more information before making any changes in rule.
COMMENT 126: One commenter asked the board to consider how these policy adjustments will impact current teachers and argued that the current changes will not benefit those who are currently in our Montana classrooms. They are concerned about licensing being under the direction of the superintendent and the Office of Public Instruction.
RESPONSE: The Board of Public Education responded that there are many revisions that could positively impact current classroom teachers such as the opportunity to add endorsements without seeking a traditional educator preparation program, pathways for school counselors to become administrators, and automatic reciprocity for National Board Certified Teachers. The Educator Licensure Unit has always been at the Office of Public Instruction.
COMMENT 127: NEMASS commented that they support local control and returning the authority for classroom teachers to a simpler process.
RESPONSE: The Board of Public Education has always respected local control and will continue to support their work at the local school district level.
COMMENT 128: One commenter urged people to keep politics out of schools and stated that it is not always about the money—a few thousand dollars will not fix the lack of support from government for public education.
RESPONSE: The Board of Public Education recognizes that there are many factors related to the recruitment and retention issues facing the state, and that educator licensure is one small piece. The Board of Public Education does not determine, issue, or have authority over K-12 school funding.
COMMENT 129: One commenter asked the board why the Montana Lottery profits were changed in 1990 from going to the teacher's retirement system to the school equalization account at the Office of Public Instruction. Additionally, they are curious why school boards allow teachers to live outside the district they work in.
RESPONSE: The Board of Public Education responded that these questions are outside the purview of the board, and that the allocation of lottery revenues is the responsibility of the Legislature and residency requirements for teachers is the responsibility of local school boards of trustees.
COMMENT 130: One commenter stated that we should look at teacher training as an apprenticeship program, especially for elementary teachers, and we would be able to recruit more teacher's aids, support staff, and volunteers with on-the-job training.
COMMENT 131: One commenter stated we should focus more on training programs to support teacher education training, especially for para educators. Additionally, they would like the board to incentivize senior citizens to give back to their communities through property tax breaks.
RESPONSE to COMMENTS 130-131: The Board of Public Education acknowledges Comments 130 and 131 and thanks the commenters for their interest in workforce development as it relates to educator preparation. The board does not have authority over property tax incentives.
COMMENT 132: One commenter stated that the reforms that have been proposed, and those in the past, have the underlying goal of undermining public schools to promote future privatization.
RESPONSE: The Board of Public Education stated that they take their responsibility of general supervision over the K-12 public school system very seriously and are not advocates for privatization of public schools.
COMMENT 133: One commenter stated that the board needs to make it easier on teachers that have J1 Visas. They would also like to see people in the licensure department that can answer licensure questions.
RESPONSE: The Board of Public Education recognizes that there are many factors related to the recruitment and retention issues facing the state and thanked the commenter for their concerns. The board acknowledged the Educator Licensure Unit at the Office of Public Instruction is tasked with responding to licensure questions.
COMMENT 134: One commenter stated she has worked with good and bad teachers, and the teachers they perceived as bad were pertaining to their sexual identity.
RESPONSE: The Board of Public Education acknowledges the comment.
COMMENT 135: One commenter supported the recruitment of teachers from within communities by supporting dual-credit teacher education coursework, 2+2 programs, and online/distance coursework. Additionally, they recommended the facilitation of cohort or "cluster hire" partnerships to assist staffing and provide an expanded social and professional network for new teachers.
RESPONSE: The Board of Public Education agreed that these are very important topics in public education and determined they needed more information before making any changes in rule.
/s/ McCall Flynn /s/ Tammy Lacey McCall Flynn Tammy Lacey Rule Reviewer Chair Board of Public Education
Certified to the Secretary of State May 17, 2022.
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