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August 8, 2022 

Position Statement – Recommendations for NC Licensure Proposal 

This document is to share recommendations from NCACTE regarding the licensure proposal  currently under consideration by the Professional Education Preparation and Standards  Commission (PEPSC). NCACTE membership institutions, both public and independent, will be  impacted by this proposal; representatives from these institutions have been deeply engaged in  this work since the launch of the PEPSC subcommittees.  

The proposal, which has generated a lot of attention, was originally conceived by the NC  Human Capital Roundtable (HCRT) which in turn, met under the guidance of the Southern  Regional Education Board (SREB). Neither of these groups have any legislative authority in  North Carolina. Nonetheless, the Roundtable group met for many months to develop this new  teacher licensure model, which combines licensure with a salary structure. Despite the high  impact of this work, no notes or minutes were officially kept of these meetings. The original  proposal was touted as a way to increase both teacher supply and teacher quality by removing  supposed barriers while simultaneously increasing “off ramps” for ineffective teachers – a tricky  feat at best given how quickly districts are hemorrhaging teachers. Notably absent in the  original proposal’s development were three groups most impacted by the proposal – teachers,  public school human resource directors, and university-based educator preparation programs  (EPPs). The process raised serious questions about collaboration and inclusivity of relevant  stakeholder groups. In response PEPSC formed four subcommittees to examine the proposal  and provide feedback. The subcommittees include a mix of public-school officials, government  officials, university EPP faculty, NCAE representatives, alternative teacher preparation  programs, and SBE/PEPSC board members.  

As members of the subcommittees, we were leery and optimistic at the same time: leery  because this proposal was seemingly developed out of nowhere (What IS the Human Capital  Roundtable? What is their purpose?) but optimistic that PEPSC was now seeking feedback from  stakeholder groups. This was an opportunity for real and meaningful discussions about how  teachers are licensed: what current barriers exist not related to teacher or student  performance that could be removed? How can these groups collaborate and provide authentic feedback? How could we use the proposal to advocate for increased teacher pay? Excited by  this prospect, and unaware of the machinations of various groups behind the scenes,  subcommittee members dug in.  

From the beginning, the proposal seemed to be driven by DPI personnel. Right or wrong, DPI  personnel became the “go to” people to interpret the proposal, answer questions, take  minutes, schedule meetings, and synthesize the feedback. It was clear that DPI personnel had  been involved in the Human Capital Roundtable meetings and had been tapped as the ones  now to push it through. At the first subcommittee meetings, members were told in explicit  terms that their role was not to change the proposal but only to figure out a way to implement  it. What was the point in even holding subcommittee meetings if no feedback for potentially  improving the model would be accepted? This rocky start set the tone for the overall process; in  May 2021, NCACTE officially raised questions about the process and the proposal by sending a  formal letter to PEPSC Chair Patrick Miller. Our questions primarily related to our perception of  the reduced role of high-quality teacher preparation in the model and the impact of proposed  “effectiveness” measures to assess teacher performance for salary increases. We were assured  that our feedback would be considered for future revisions of the model. For the last 15  months, the subcommittees met and discussed the proposal. We talked about key issues, made  suggestions, and considered differing points of view. In February 2022, NCACTE created a list of  recommendations from our Advocacy & Policy Committee and sent it to our stakeholders,  including PEPSC members. In March 2022, the strawman version of the Roundtable proposal was unveiled for the State Board of Education. It was like a gut check. Despite our feedback and  suggestions for improvement, fundamentally little had changed with the proposal since its  original inception by the Roundtable group. A few details were added but that was all. In May  2022, NCACTE sent a final communication to PEPSC, again specifically raising questions about  implementation and the overall viability of the proposal in the hopes that final subcommittee  meetings would address these concerns.  

As the model continues to gain scrutiny, additional details have emerged, thanks in large part to  public information requests and citizen-reporting by classroom teacher Justin Parmenter and  others. Emails from individuals working for the Southern Regional Education Board and the  Human Capital Roundtable, various documents and meeting notes indicate that the objective  was to push the proposal forward regardless of any feedback that might call for a change of course. “I thought that CT (NC Superintendent Catherine Truitt) wanted to squash outside focus  groups and surveys? Or has that tune changed?” wrote Megan Boren, Project Manager of the  Southern Regional Education Board, to PEPSC Chairman Patrick Miller, in an email dated as  recently as April 20. In an email dated March 9 to DPI personnel, Chair Miller, and the  Roundtable members, Heather White from the PR firm Eckel & Vaughan advised that when  discussing the plan, “try avoiding phrases that emphasize the plan’s complexity or the burden it  would put upon districts to manage” — advice that seems to discourage transparent dialogue  about the realities of implementation. This advice was definitely taken to heart by the DPI staff;  when subcommittee members asked questions about anticipated difficulties in implementing  this plan, we were told more than once that the purpose of the subcommittees was not to  discuss implementation of the proposal, only to provide feedback about the plan itself. That’s  like asking NASA to launch a man into space with no plan of how to return him to Earth safely.  What’s the point of developing a proposal that could potentially become an implementation  nightmare? It has been noted by many on the subcommittees that this current proposal  appears extremely burdensome and complex to track for both NCDPI licensure staff and public school units. Many of the implementation details for this licensure proposal remain  unanswered at this time, pending final presentation of the model to PEPSC in September 2022.  

From the beginning, NCACTE members have worked in good faith to review the Human Capital  Roundtable Proposal (now rebranded as the more positive-sounding “Pathways to Excellence”  proposal) and have been transparent about its strengths and our concerns with it. On the plus  

side, we support increasing compensation for all teachers, compensating student teachers,  funding clearly structured advanced teaching positions that allow teachers to stay and lead in  classrooms, and creating pathways for experienced teacher assistants to move into teaching  positions with support. However, as of August 1, there are still several areas of concern with  the model. These have been shared in previous communications and remain unaddressed to  date. As such, we outline our recommendations below. We observe that several of these  recommendations also appear in documents from the NC Public School Forum and NCAE.  


1. Elevate, Rather than Devalue EPP Preparation in North Carolina. 

Although the marketing materials tout the proposal as lifting up EPPs, in fact, we believe it does  the opposite. Students who complete the traditional teacher training path will receive higher compensation in this proposal, but that group is shrinking. Traditional undergraduate  enrollment in teacher education programs is decreasing in this state. Once our biggest source  of future educators, our best and brightest high school students are now flocking to other  professions. This has caused the state to double down on alternative entry programs (originally  known as “lateral entry” programs). According to the NC DPI EPP Enrollment dashboard,  alternative entry teacher enrollment in NC has increased 114% since 2015. Alternative entry  teachers hold a bachelor’s degree and can be hired directly as teachers into the classroom.  Current policies require these individuals to simultaneously enroll in an approved EPP and be  trained in pedagogy, student learning needs, and engaging teaching practices. This is not an  ideal situation; we all agree that in a perfect world, rigorous and supervised training would  occur BEFORE an individual is given a classroom of children to teach. None of us would go to a  doctor who had never been to medical school or a lawyer who had never taken a law class.  Alternative entry policies were intended to be a band-aid, not a long-term solution.  

Instead of incentivizing EPP completion prior to employment by offering stipends or free  tuition and fees to those who opt to fully train as teachers, the Roundtable proposal doubles  down on alternative entry as the future of teacher preparation. The Roundtable proposal  allows alternative entry individuals to bypass an EPP altogether by way of “microcredentials,”  online mini-lessons which are not yet developed (that we’ve seen) OR “another approved  process” that also may qualify OR by passing certain tests OR by enrolling in an EPP program.  This is like allowing a doctor to bypass medical school if they can pass the test at the end of the  program without any training. Are there those who can do it? Sure. Is there more to becoming  a doctor than being able to pass a test? Absolutely. We all rely on the rigorous standards of  medical schools to determine if our doctors are qualified – we can trust in the training process  to ensure our doctors have been observed and evaluated and are able to diagnose our ailments  and treat them effectively. Shouldn’t the same be true of our teachers?  

2. Ensure Quality Teacher Education through Rigorous Accreditation/Program Approval. NC’s Educator Preparation Programs have been responsive to the teacher vacancy crisis. Even  as policy disincentives (like stopping master’s pay and limited salary increases) have  contributed to the diminished teacher supply, EPPs have worked consistently to recruit and  train quality teachers for NC classrooms. We have streamlined our programs to allow for quick  completion with high quality, research-based preparation methods. We have designed affordable programs for second-career changers to pursue teaching as a profession. We  established 2+2 programs with community college partners to increase and diversify pipelines  to the profession. We have worked with our school partners to collaborate on tailored teacher recruitment programs and offered scholarships and funding for teacher training. We have been  supportive of efforts to create fair accountability models for EPPs. In good faith and with the  best of intentions, we have put our collective energies into putting qualified and trained  teachers in North Carolina classrooms, even as enacted policies make our jobs more and more  difficult. We have 50+ EPP programs in our state, many of them offering online options,  reduced costs, and maximum flexibility. Many university-based EPP programs are accredited by  either CAEP or AAQEP, thereby ensuring a high level of quality and rigor. EPP completers have  extensive clinical experiences, including a 600-hour student teaching internship and a licensure  recommendation process that involves observation and evaluation by the supervising teacher,  the principal, and the university supervisor in a collaborative partnership. In NC, EPP completers  stay longer in the profession than other pathways and are more successful.  

We truly believe that no longer requiring EPP completion in lieu of less rigorous options is not  “flexibility,” but rather a significant reduction in our standards for teacher preparation that  will result in greater numbers of underprepared teachers leading classrooms. In recent years,  the number of alternative licensing programs that function as businesses has increased (e.g.,  Teachers of Tomorrow, #TEACH, etc). These preparation providers tout themselves as high quality solutions to the teacher shortage, but evidence suggests this is not the case. A recent  report from AACTE shows that across the U.S. while many prospective teachers enroll in  alternative preparation programs not based in higher education institutions, they are not  producing the number of teachers needed to fill critical vacancies. In Texas, Teachers of  Tomorrow (which also operates in North Carolina) was recently put on probation for their poor  teaching practices. Are there some alternatively licensed teachers who are successful? Of  course. But as policy, alternative licensure programs undeniably resulted in less credentialed and qualified teachers overall. The model may also inadvertently exacerbate inequities in NC  classrooms. Research shows that children in less affluent communities are taught by teachers  with less experience and training, a problem exacerbated by the “churn” of teachers leaving  classrooms in NC. Under the auspices of increasing teacher recruitment, the proposal provides  multiple ways for individuals with no teaching qualifications to immediately enter the  classroom. 

3. Increase Compensation for Experience and Advanced Credentials. 

In addition to the disincentivizing of traditional teacher preparation in lieu of alternative entry,  we continue to also be concerned with the lack of stable, reliable salary increases for teachers  missing in this model. The new positions proposed with advanced teaching roles may represent  a leadership path for some individuals – a move which is welcomed as a possible path for  teacher advancement – but the advanced licensure levels do not mean everyone who achieves  those levels will qualify or be hired into one of those positions. Minutes from the most recent  Budget and Compensation subcommittee meeting suggest there is still much discussion on  salary recommendations for teachers in this proposal. And the ongoing “merit pay” debate on  which effectiveness measures will be used to determine if teachers receive additional pay has  garnered much pushback from the teaching community at large. As of August 1, the proposal  does not include any recommendations for regular, annual salary increases for all teachers. We  believe the failure to recognize and reward teachers for their experience as well as their  achievements is a mistake. In any other profession, longevity and experience are valued. We  should be considering salary structures that allow for robust teaching salaries as a starting  point, with any additional compensation structures to be supplemental incentives. Other states have recently made such changes in efforts to staunch the flow of teaching vacancies.  Furthermore, advanced credentials, such as North Carolina’s significant investment in National  Board Certification should be clearly included and incentivized in the model. As recently as July  2022, former Governor Hunt advised North Carolina to include teachers in these conversations  and to ensure National Board certification remains “an important component” of the model. As  the folks who most directly work with individuals seeking teaching licensure and working  toward advanced credentials, EPPs can assure policymakers that raising teacher salaries overall  for all experience levels will function as a powerful recruitment incentive.  

4. Attend to Implementation Now, Not Later. 

We feel compelled to point out that there seem to be underlying forces driving this work  forward in spite of the fact that this model still needs lots of refinement and work. This  summer’s revelations of various behind-the-scenes conversations to discourage input even as  the subcommittees continued to meet is highly troubling. As already noted, this proposal was  crafted by the Human Capital Roundtable with no input from the people who work most closely  with teacher licensure in our state, the people who can readily explain the problems and can articulate issues and solutions. Instead, a proposal has been pushed forward that we believe  will result in serious implementation problems and will move the responsibility of teacher  preparation away from the colleges and universities that are situated and qualified to handle it  and on to the school districts, who are already strained for resources.  

5. Engage Educational Stakeholders as Partners, not Obstacles.  

It has been suggested that, in taking such a position, EPPs are “protecting our own turf.” That is  highly insulting and disingenuous as it implies that EPPs have an ulterior motive at play here.  EPPs in NC have been preparing the best teachers in our state for decades and EPP faculties are  committed, caring individuals who have dedicated their careers to training teachers because we  are deeply concerned about teaching as a profession. Most EPP faculty have been teachers or  administrators at some point – we’ve been in the trenches; we know the rigors of the  profession. We consider ourselves partners with our P-12 colleagues in educating North  Carolina’s children. We may not be the ones with ulterior motives here. One could easily ask  who profits by allowing microcredential vendors to market their products to alternative entry  teachers? Who benefits by allowing less-prepared teachers in classrooms? Certainly not the  children of North Carolina, nor their families, nor our communities. Rather than denigrate  educational partners across the P-20 landscape, we ask leadership to engage all partners  thoughtfully and authentically in this work, so we may learn from one another’s expertise. If we  partner well, North Carolina’s students and their families will be the true winners. 

In closing, we would like to add that we acknowledge we have not yet seen the final version of  the proposal that will be presented to PEPSC, and we hope that some of our suggestions and  comments are considered moving forward. It is not our intention to derail this project, but  rather, to create a model that can work and has the support of all stakeholder groups. If the  intention of the proposal is to incentivize EPP completion as the first, best path for teacher  preparation, then that proposal should clearly and forcefully reflect that. NCACTE and its  members wholeheartedly support a model that can reduce barriers for becoming teachers,  produce high-quality teachers for all children, and compensate teachers for the hard work they  do. We look forward to continuing these evolving conversations.  

The North Carolina Association of Colleges for Teacher Education


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Clarence Choe