To Whom It May Concern:

The Texas Classroom Teachers Association, representing 50,000 classroom teachers and instructional personnel in Texas, appreciates this opportunity to comment on Chairman Miller’s discussion draft of Titles II – IX of the NCLB Act reauthorization. Due to the length of our comments, we have bolded our specific recommendations. We look forward to the continuation of the discussion about the reauthorization of this very important piece of federal legislation.

Teacher Quality

The issue of teacher quality has been the source of much national focus and discussion recently. Since the time the No Child Left Behind Act initially coined the term “highly qualified” teachers, the discussion of teacher quality has intensified, with some influential groups advocating for a change in the term to include the concept of teacher effectiveness as measured by student performance (see Commission on No Child Left Behind). Given the difficulty of measuring teacher effectiveness, we are not surprised that some want to rush to tout a value-added system as the answer to the difficult task of fairly and accurately isolating teacher effects on student performance. However, we're aware of only a couple of researchers who indicate that a value-added measure can be developed (namely William Sanders and Eric Hanushek) and we do not believe that their research has been validated through publication in a peer-reviewed journal. Additionally, given that the most recent studies on the state of value-added systems have found the research regarding the use of statistical models to evaluate teacher effectiveness to be insufficient to support the use of these models for high-stakes decisions, we strongly oppose attempts to use value-added to judge teachers (see attached research). Accordingly, although we are pleased to see that the draft does not appear to change the definition of “highly qualified” to include the notion of teacher effectiveness as measured by student performance, we are extremely dismayed to see that, instead, the draft is replete with grant programs encouraging performance pay for teachers. Additionally, encouraging the use of performance pay adds yet another high-stakes consequence to standardized testing, which runs counter to other provisions in the draft which seek to lessen the influence of testing, such as the use of multiple measures for AYP. For these reasons, we are strongly opposed to these provisions.

Regarding the performance pay grant programs provided in the draft, we note that these programs (Premium Pay, Career Ladders for Teachers, Transition to Teaching, Teacher and Principal Quality State Grants) mix the issues of inequities of teacher quality and performance pay for teachers. Although we join many others in welcoming the use of federal dollars to address inequities in teacher quality via policies focused on reducing teacher turnover and bonuses for teaching in a low-performing school, smaller class sizes, intensive professional development, and paying educators more for teaching in shortage subjects such as math, science, and special education, we object to the insertion of performance pay for teachers into the mix. As we stated earlier, we have a fundamental concern that the premise upon which these performance pay programs are based, that teacher impact on student performance can be fairly and accurately isolated and measured is an unproven theory which has yet to be scientifically validated. Yet, we see this improper assumption incorporated throughout the draft.

For example, we note that the Premium Pay program in Section 2111 of the discussion draft requires that in providing higher salaries to exemplary, highly qualified teachers, school districts must identify exemplary teachers based on, in addition to other measures, the growth of the teachers’ students on any tests required by the state and value-added achievement gains if such teacher is in a state that uses a value-added longitudinal data system. Given the lack of substantial research supporting the use of value-added models to determine teacher effectiveness, the fact that many states don’t have data systems in place to tie students to specific teachers, and that an inordinate amount of time and money would have to be spent in order to engage in the process of determining the value to student performance added by specific teachers, we encourage the focus of this legislation to be more on doing things to ensure that certified and experienced teachers teach at high-need schools and stay there, in the same way the Part B Teacher and Principal Quality state grants are premised upon the recognition of the value of having properly certified and experienced teachers at high-need schools

We also point out that the definition of value-added student achievement gains is weak. It includes nothing about the fact that any such system must be reliable and consistent with the principles of sound statistical analysis, that the criteria for validity and reliability of these systems should be that they are based on research that has been independently peer reviewed and based on empirical evidence that adheres to the basic principles of sound statistical analysis, or that the system is capable of fairly and accurately adjusting for factors beyond the control of an educational institution or educator, including student demographics and community characteristics. These are all the same criteria used by many respected research institutions in deciding whether any given research is valid and reliable (see Using Research and Reason in Education, What is Scientifically Based Research, A Guide For Teachers).

Our point on all of this is probably best illustrated by a provision contained in the Teacher Residency program. In that program, we note that the draft contains a provision that the selection of mentors shall be based, among other things, on “appropriate and fair analysis of gains in student learning, which shall include, when feasible, valid and reliable objective measures of the influence of teachers on the rate of student academic progress.” The inclusion of the word “feasible” in this language is very important because it gets at the heart of our overall concern about the draft’s reliance on the theory that teacher effects on student performance can be fairly and accurately isolated. This is the one place in the draft that we can see some semblance of recognition that determining the influence of teachers on the rate of student academic progress may or may not be feasible. This language is closer to the reality of the current state of research regarding value-added measures. Before any legislation is enacted which assumes that teacher effects on students can be fairly and accurately measured, the assumption should be validated via scientifically valid research. In the same way that the draft requires other activities to be supported by the “Scientifically Valid Research” that is developed in accordance with the accepted “Principals of Scientific Research”, all of which is defined quite extensively in Title IX – General Provisions, we ask that the drafters be consistent with this premise and apply it to the concept of performance pay. If the federal government is unable to offer conclusive evidence in support of the theory of value-added and is unable to offer scientifically validated value-added models for states to use, it is putting the cart before the horse to ask states to go ahead and evaluate and pay teachers based on value-added systems of measurement.

If a study is performed in order to validate the theory, it should be performed by one or more organizations with well-established peer-review processes to study the feasibility, reliability, and validity of using measures of student growth, including value-added measures, as a basis for evaluating and compensating educators. Results from the study should be based upon empirical evidence and published in scientific journals using independent peer review, and validity for this purpose must be established before a student growth measure could be used as a basis for educator compensation or evaluation. Any student assessment instruments used as a basis for educator compensation or evaluation should be certified by the entity that develops the instrument as being validated and reliable for that purpose and independently verified by an impartial psychometrician as being valid for that purpose. These are the same criteria used by many respected research institutions in deciding whether any given research is valid and reliable (see Using Research and Reason in Education, What is Scientifically Based Research, A Guide For Teachers).

We note that the concept of validity for the purpose it is being used is present in the draft, in the definition of “formative assessment” contained in Title IX – General Provisions. That definition states that, among other things, formative assessments are used for purposes for which they are valuable and reliable, consistent with relevant professional standards. This is the same concept we are promoting with regard to any kind of student assessment used to measure teacher performance.

We include here, for informational purposes, the draft’s definition of Principles of Scientific Research, which we support:

PRINCIPLES OF SCIENTIFIC RESEARCH: research that—

(A) applies rigorous, systematic, and objective methodology to obtain reliable and valid knowledge relevant to education activities and programs;

(B) presents findings and makes claims that are appropriate to and supported by methods that have been employed; and

(i) use of systematic, empirical methods that draw on observation or experiment;

(ii) use of data analyses that are adequate to support the general findings;

(iii) reliance on measurements or observational methods that provide reliable and generalizable findings;

(iv) strong claims of causal relationships only in research designs that eliminate plausible competing explanation for observed results, which may include but shall not be limited to random assignment experiments;

(v) presentation of studies and methods in sufficient detail and clarity to allow for replication or at a minimum, to offer the opportunity to build systematically on the findings of the research;

(vi) acceptance by a peer-reviewed journal or critique by a panel of independent experts through a comparably rigorous, objective, and scientific review; and

(vii) consistency of findings across multiple studies or sites to support the generality of results and conclusions.

SCIENTIFICALLY VALID RESEARCH: includes applied research, basic research, and field-initiated research in which the rationale, design, and interpretation are soundly developed in accordance with accepted principles of scientific research.

Highly Qualified

We are also greatly concerned that the draft appears to eliminate a popular option for experienced teachers to demonstrate competency under the “highly qualified” requirements, a high objective uniform state standard of evaluation (HOUSSE).

The current NCLB Act allows states to define HOUSSE and doesn’t provide any standards that HOUSSE must meet. Accordingly, HOUSSE has been the target of some criticism since some states are thought to have set a low standard for HOUSSE. Texas defines HOUSSE as follows: experienced elementary teachers must show that they have 24 points worth of any combination of years of teaching experience at the elementary level (maximum of 12 points), college coursework in English/Language Arts, Math, Science, and/or Social Studies* (1 college hour=1 point) and professional development that meets the standards for Continuing Professional Education (CPE) credit established by Texas State Board for Educator Certification rules (15 CPE clock hours=1 point) AND each of the subjects (English/Language Arts, Math, Science, and Social Studies*) is represented in the 24 points, whether through experience, college coursework or professional development.

HOUSSE for experienced secondary teachers is 24 points (at least six of which represent the subject to be taught) worth of any combination of years of teaching experience in the subject to be taught or in a closely related field (maximum of 12 points), college coursework in the subject to be taught or in a closely related field (1 college hour=1 point), and professional development in the subject to be taught or in a closely related field that meets the standards for CPE credit established by SBEC rules {15 CPE clock hours=1 point }.

We believe the Texas HOUSSE standard is rigorous as confirmed by the National Council on Teacher Quality, which ranked Texas in the top eight states in terms of having a strong HOUSSE standard.

Moreover, HOUSSE has served as a crucial avenue for experienced teachers to demonstrate competency in situations in which they are assigned out-of-field. In Texas, the out-of- field assignment rate has remained at about 20% for the last five years, a statistic that is reflective of the pressing teacher shortage we are experiencing. Due to employment laws in Texas, Texas teachers have little or no control over their teaching assignments; in fact, most Texas teacher contracts contain language specifying that teachers can be assigned as necessary. Eliminating the HOUSSE option for an experienced teacher who is assigned to something for which he/she is not certified, something over which the teacher has little or no control, seems extreme, given the fact that the only other option for these teachers to demonstrate competency would be to pass the relevant certification test or have 24 college semester hours at the secondary level. Certification tests are costly and can be logistically difficult to take; college courses are expensive and take a semester to complete. Both of these options take time and money, something that teachers in this situation will not have when they are typically notified of their assignment at the beginning of the school year, or in some cases, during the school year. Allowing these teachers to be able to demonstrate competency via HOUSSE would enable these teachers to count the benefit of their teaching experience, college hours, and professional development in the subject taught to demonstrate competency. Without this avenue, despite the goal of the NCLB to have highly qualified teachers in every core academic subject, eliminating HOUSSE for these teachers would potentially have the perverse effect of eliminating a job for a certified teacher.

Additionally, because the NCLB requires special education teachers to be highly qualified in every subject taught, contrary to the historical certification of special education teachers as generalists, special education teachers are suffering a significant hardship in now having to have 24 college hours in each subject taught or pass a certification exam in each subject taught. HOUSSE has been an extremely helpful option to these teachers who might have significant college hours (but not a major), experience teaching, or professional development in the subject taught, but do not hold a specialist certificate for the subject. Given that the nation is already suffering from a shortage of special education teachers and the fact that NCLB requirements impose an extra hardship on special education teachers who have traditionally been treated as generalists, we would urge keeping HOUSSE as an option for experienced special education teachers.

If the concern is that some states have set too low a standard with HOUSSE, we would encourage using the reauthorization of the NCLB as an opportunity to incorporate some standards for HOUSSE into the Act. But throwing the baby out is an extreme solution to a problem that may be limited to a few states and can easily be solved by incorporating HOUSSE standards into the Act.

National Board Certification

We also question the inclusion of the National Board for Professional Teaching Standards certificate as a basis for identifying exemplary teachers and paying them more money given the lackluster conclusion of recent studies regarding the correlation between National Board certification and student achievement. (For example, see Premium Pay, Ladders for Teachers) ; We are generally leery of language promoting one program over another, and it appears to us that National Board certification is consistently promoted throughout the draft. National Board certification appears even in seemingly unrelated provisions, such as the requirement for John Glenn Academies to disseminate information on the process of becoming National Board Certified. We note that later in the draft, under National Activities of Demonstrated Effectiveness, there is more generic language referring to nationally recognized teacher certification or credentialing organizations, which would be our preference.

Collective Bargaining vs. Right to Work

We applaud attempts via the Premium Pay program to address the issue of delayed hiring practices by school districts in subsection (g) of the Section. However, this issue is one example of several in the draft in which the attempt to address employment situations present in collective bargaining states might be totally inapplicable or irrelevant in non-collective bargaining states such as Texas. Accordingly, as a general comment, we would urge that consideration be given to the fact that requiring the same thing of all states is unreasonable, given the inapplicability of some of these provisions to non-collective bargaining states.

Additionally, regarding subsection (g) specifically, we also note that this is an insertion of the federal government into the traditionally local arena of hiring and employment compensation.

These issues make it doubtful that the issue can be addressed with a broad brush. If the issue is that collective bargaining contracts interfere with a district’s ability to make timely hires, then the solution should be narrowly tailored to collectively bargained situations. For example, we note that California recently passed legislation to address collective bargaining situations by requiring that a teacher can never be transferred to a low-performing school if the principal of that school refuses to accept the transfer. In addition, the California legislation requires that any seniority-based voluntary-transfer processes be completed for all schools by April 15, thereby freeing principals to consider all teacher candidates equally after this date—and to hire the best one for the job (SB 1655). These are more narrowly tailored solutions to issues presented by collective bargaining agreements. The provisions contained in subsection (g) of the Premium Pay program are entirely too broad, including provisions requiring retiring teachers to notify school districts of their impending retirements no later than March 15 of every year, requiring teacher transfer periods to occur in April, and not requiring schools to hire transferring teachers from other schools without selection and consent. For example, the March 15 notice of retirement deadline is not only an arbitrary date, but will result in teachers in some states having to give notice much earlier in the school year than others, as the school year may end later in some states than others. It is also unreasonable request to require that much advance notice from teachers. If early notice is the goal, then we would suggest something akin to Texas law, that teachers must give notice of intent not to return to the district at least 45 days prior to the first instructional day of the following school year.

Another example of the inapplicability of a provision contained in the draft to Texas and other non-collective bargaining states, is the provision in the Premium Pay section that makes grants available only if the school district has in place or proposes a plan, in collaboration with the local teacher organization, to develop a peer review system of sorts. Once again, we note the heavy influence of union-dominated scenarios with the reference to “the local teacher organization.” This provision would be inapplicable in most school districts in Texas, which have multiple teacher organizations. Rather, we would suggest that the language require significant involvement of local teachers and local teacher organizations in developing the plan, along with evidence of their involvement, such as meeting minutes etc.

Career Ladders for Teachers

Regarding the Career Ladders for Teacher Program in Section 2112, we again object to performance pay for teachers based on student test scores (growth in test scores or value-added for the reasons cited earlier. We support the provision requiring that at least 75% of the schools’ teachers must vote to adopt the program before the program can be established.

With regard to the qualifications of mentor teachers, we ask that the teacher be recommended by the principal OR other current master/mentor teachers so that politics or personal differences don’t play a role in a qualified teacher’s ability to be assigned as a mentor. We note that many of the “qualifications” of a mentor contained in the draft are subjectively determined by someone. Although it’s unclear who that will be, we assume that it will be the principal or other master/mentor teachers. Again, if either/or the principal or master teachers make these determinations, we are more comfortable with the subjectivity of the qualifications, with one exception. One of the provisions requires that a mentor “perform well as a mentor in established induction and peer review and mentoring programs.” We’re unsure what the goal is that this language is seeking to address, but the words “perform well” are too vague to be meaningful. We also note that the provisions don’t require a new mentor to complete a mentor training program, which we believe would be a useful addition.

Teacher Residency Program Grants

Regarding Section 2113, Teacher Residency Program Grants, we note that it appears that much of this language was taken from HR 1642, the Senate version of the Reauthorization of the Higher Education Act. However, there are some important differences that we highlight: HR 1642 envisions a teaching residency as a program for participants to engage in rigorous graduate-level coursework to earn a master’s degree while undertaking a guided teaching apprenticeship. The resident shall work alongside a trained and experienced mentor teacher, who, among other things, may have full relief from teaching duties as a result of such additional responsibilities. HR 1642 also provides for support for residents, once the teaching residents are hired as teachers of record, through an induction program, professional development, and networking opportunities to support the residents through not less than the residents’ first 2 years of teaching.

These are all worthy elements that are missing from Chairman Miller’s draft. Chairman Miller’s draft states that a mid-career professional or recent college graduate shall become enrolled simultaneously in education or teaching in a postsecondary institution that has an agreement with the school district. The meaning of this language in unclear. Is the intent that the person be enrolled in a post-baccalaureate program or master’s degree program? This needs to be clarified. Also, could the person be pursuing an initial bachelor’s degree? We ask that the language be clarified so that eligible persons are only those with at least a bachelor’s degree.

We support the language in the draft that states that the resident shall work alongside a teacher of record, who shall also serve as the resident’s mentor. We understand, from the use of the term “teacher of record”, that the intent of this program is not to have the resident serve as the teacher of record, but rather, teach alongside the teacher of record/mentor. If this is not the case, we would have serious concerns about the resident serving as teacher of record.

Regarding the mentor teacher, the draft requires the mentor to serve not only as teacher of record, but also to take on numerous other duties. Since extensive research has established that one of the key components to a successful mentoring program is release time for the mentor teacher from teaching duties, we ask that the draft include a requirement that the mentor teacher be released from some teaching duties. We appreciate the fact that release time for mentor teachers is a required component for induction programs under Part B of the draft – Teacher and Principal Quality State Grants.

Finally, H.R. 1642 requires that once the resident is hired as teacher of record, the school district support the resident for at least the first two years of teaching. Again, research has established that the most successful mentoring/induction programs last for at least two years; accordingly we ask that the language in the draft be changed from one to two years, similar to the requirement for mentoring/induction programs under Part B – Teacher and Principal Quality State Grants.

Study on Portable Performance-Based Teacher Assessment

Regarding Section 2121/Study on developing a portable performance-based teacher assessment, we note that the draft requires the Secretary to do two things: study the correlation between teacher certification and licensure and other measures of teacher effectiveness as well as to assess whether current teacher certification pedagogy and content tests reflect the latest research and the content the teacher is licensed to teach. Although we are clear on the goal of the Secretary’s second duty, we don’t understand the goal of the first duty. Is the goal to determine conclusively whether teacher certification correlates with student learning gains? If so, the draft needs to contain much more direction to the Secretary regarding who will perform the study, given the politicization of this issue by researchers. We would suggest that the draft contain language that the Secretary contract with one or more organizations with well-established peer-review processes to perform the research. Additionally, if there is an issue with teacher preparation, we believe that the proper approach is to improve teacher preparation.

Improving Professional Development Opportunities

Regarding Section 2122, Improving Professional Development Opportunities, we strongly support this section, especially language providing for grants for support to mentors working with new teachers, training in effective instructionalservices and classroom management strategies formainstream teachers serving students with disabilities and students with limited English proficiency,online professional development resources, enabling teachers to engage in studygroups and other collaborative activities and collegialinteractions regarding instruction,paying for release time and substituteteachers in order to enable teachers to participate inthe activities of the teacher center,assisting teachers in becoming highly qualified and paraprofessionals in becoming teachers, and assisting paraprofessionals in meeting NCLB requirements. These are all important areas of need that have not been sufficiently recognized and funded in the past.

However, we note that once again, the draft contains language assuming a collective bargaining structure in that it requires the representatives of the Teacher Center Policy Board to be selected through the teacher organization, or if there is no teacher organization, by the teachers directly. We are more interested in teacher involvement than preserving a union organizational structure that may not be relevant in all situations and ask that the language be changed to “through teacher organizations”. Finally, we ask that the language that the board may include paraprofessionals be mandatory instead of permissive, as paraprofessionals provide an important perspective in this area.

Part B – Teacher and Principal Quality State Grants

We appreciate that the draft includes language that requires state and local needs assessments be developed with the input of teachers. However, we have found in our experience, that this language is of little use if there’s not also a corresponding requirement of compliance and evidence of teacher involvement, such as meeting minutes etc. Accordingly we ask that such language be included.

We are highly supportive of the language in the draft requiring the state needs assessment to include an account of the number of first year teachers, the number of teachers with provisional or emergency teaching certification, the average teacher turnover rate and the number of core academic subjects taught by highly qualified teachers. We have always believed that this is the type of information that gives a truer picture of the quality of a school than some other measures that have been more frequently used. However, we would suggest that the language for the state needs assessment as well as the local needs assessment require percentages as well as number, and that the number and percentage of out of field teachers in all subjects be a required component of both needs assessments. Additionally, we ask that consideration be given to including class sizes.

We are dismayed to see language in this Part that the grants can be used for developing or assisting school districts in developing performance pay programs, carrying out programs that establish, expand, or improve alternative routes for state certification of teachers and principals, and reforming tenure systems. The inclusion of these provisions, none of which are supported by strong validated research and all of which have consistently been the subject of much controversy, seems gratuitous and we strongly object to them. We note that the notion of performance pay also makes an appearance in the Transition to Teaching program in the draft. Again, we question the prominence this unproven concept assumes in this draft and ask that this language be deleted.

While we understand the need to produce more high quality teachers, we are skeptical of provisions that favor one type of certification route, such as alternative certification, especially given the research highlighting concerns about the quality of teachers being produced by alternative certification programs and their low retention rates in the profession. Accordingly, we would recommend that the language be changed so that ALL routes of teacher certification be expanded etc, so that funds could be used to expand access to traditional educator preparation programs as well.

We strongly support the Teacher Induction programs portion of this Part. The provisions for this program are extremely well-written and contain all the research-supported components of successful induction programs, including the requirement for at least 90 minutes per week of common meeting time for the new teacher to discuss student work with veteran teachers, the required ratios of not more than 12 new teachers per full-time mentor, and reduced workload for beginning teachers. These provisions will greatly assist in stemming the tide of attrition of new teachers who have traditionally been thrown into teaching with a full classload using a sink or swim approach.

We also support provisions in the high-quality professional development portion of this Part, which allow for grants to be used for recruiting and retaining highly qualified teachers, training in effective instructionalservices and classroom management strategies formainstream teachers serving students with disabilities and students with limited English proficiency, professional development to improve teacher and principal knowledge of effective instructional strategies, including improvement of student behavior in the classroomthrough methods employing positive reinforcement, appropriate training in classroom management, support to mentors working with new teachers,enabling teachers to engage in studygroups and other collaborative activities and collegialinteractions regarding instruction,paying for release time and substituteteachers in order to enable teachers to participate inthe activities of the teacher center, online professional development resources, financial incentives forteachers to teach in core academic subjects inhigh-need schools in cases in which there existsa shortage of highly-qualified teachers within aschool or local educational agency, hires teachers to reduce class size to18 or fewer students in kindergarten throughthird grade in high-need local educational agencies. All of these are needed and worthy pursuits, especially the student discipline training.

However, we are dismayed to see once again, the inclusion of language about using the grants to reform tenure systems and this language should be deleted.

Regarding the provisions of the sections Improving Principal Quality in Urban and Rural schools and Partnership Grants for Principals as School Leaders, as a general comment, we appreciate the attention the draft gives to improving principal quality, particularly in the areas of instructional leadership and support of teachers. This focus comports with extensive research citing the importance leadership has in successful schools.

Part C - Partnerships for Math and Science Teacher Quality Improvement

Regarding Section 2302 Grants for Partnerships for Math and Science Teacher Quality Improvement, we are pleased to see language reflecting the recognition that quality professional development requires follow-up training. Numerous studies have shown that follow up is an essential component of quality professional development, and the one that is most likely not to be offered.

Part F – Achievement Through Technology and Innovation

Although we are well aware of the need for teachers to be technologically literate, we have found that, at least Texas’ response to past iterations of this requirement, have been unreasonable in the demands made upon teachers to be assessed on and accountable for mastery of technology application proficiencies, without first making mastery of these proficiencies contingent upon access to technology, quality professional development, and time to implement the new strategies into classrooms. Accordingly, we are wary of the language in this Part that requires states to ensure that every teacher is technologically literate, without accompanying language that prohibits states and school districts from assessing and holding teachers accountable for mastery of technology proficiencies until access to technology, quality professional development, and time to implement new strategies has been established.

We have heard numerous complaints from our members that they are required by the state or their school district to receive technology training, when they have no access to technology in their classrooms, or the timing of the training makes it useless, or the training is irrelevant to their teaching. Accordingly, we greatly appreciate the language in the draft requiring that grant funds be used for, among other things, on-going, sustainable, timely and contextual professional development. We also appreciate language stating that grant funds can be used for technology specialists/coaches to work directly with the teacher. We note that the draft provides that grant funds must be used for increasing student access to technology. We ask that language providing for increased access of teachers to technology also be included.

Title IV – 21st Century Schools

We appreciate provisions contained in the draft for Full Service Community Schools that promote a more holistic approach to education in the recognition that schools don’t operate in a vacuum and that other entities play an important role in ensuring student success.

Title V—Promoting Successful Education Reform and Innovative Programs

Part D Fund for the Improvement of Education

Although we support the draft’s provisions regarding grants for increasing the effectiveness of substitute teaching, we oppose language that requires training in effectively integrating substitute teachers in school operations such as permanent substitutes. In Texas, the use of permanent substitutes is illegal, recognizing that students shouldn’t be taught for any length of time by someone who is not certified and qualified to teach them. Texas prohibits any person from serving as a teacher for more than 30 consecutive instructional days without being on an emergency permit or seeking teacher certification.

If the term “permanent substitute” contemplates someone who is permanently available to substitute rather than someone who effectively serves as the teacher of record, then the draft should clarify the term.

Once again, we appreciate the opportunity to comment on this important legislation.

Holly Eaton

Director of Professional Development and Advocacy

Texas Classroom Teachers Association

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